Managing Rubber Fume & Dust Exposure in Northampton Manufacturing Facility

Background

A manufacturing facility based in Northampton, UK commissioned a COSHH assessment to evaluate employee exposure to hazardous substances as part of its compliance programme.

The site operates from an industrial estate and specialises in the production of:

Rubber components for automotive and industrial applications
Plastic injection moulded parts

Operations were split across:

Unit 1: Plastic injection moulding
Unit 2: Rubber injection moulding, compression moulding, and finishing processes

Approximately 80 employees worked across extended production shifts in environments with potential airborne contaminant exposure.

The Challenge

The key objective was to determine whether workplace exposures complied with the Control of Substances Hazardous to Health (COSHH) Regulations 2002 (as amended).

Substances assessed included:

Rubber fume (carcinogenic)
Rubber process dust
Formaldehyde and acrolein
Volatile Organic Compounds (VOCs)

While Workplace Exposure Limits (WELs) provide a legal benchmark, COSHH requires a more stringent approach - especially for carcinogens - mandating exposure reduction to As Low As Reasonably Practicable (ALARP).

Assessment Approach

The occupational hygiene strategy included:

Personal air monitoring using body-worn sampling pumps positioned within the breathing zone
Static monitoring to assess background concentrations
Task-based exposure profiling across production roles
Sampling aligned with HSE MDHS methods and analysed via ISO 17025-accredited laboratories

This ensured the data was both robust and inspection-ready.

Key Findings

1. WEL Compliance Achieved — But Exposure Still Significant

All measured exposures were below Workplace Exposure Limits.

However, COSHH requires further action where:

Substances are carcinogenic
Exposure exceeds 10% of the WEL

2. Significant Exposure in Key Production Areas

The monitoring data showed rubber fume exposure reaching up to 74.2% of the WEL in compression moulding operations.

High-risk areas included:

Compression moulding
Rubber injection moulding
Blasting and finishing

3. LEV System Failures Identified

The site observations highlighted critical issues:

LEV systems overdue for statutory testing
Main system recorded as “FAIL”
Poor capture efficiency at key machines

This represents a direct compliance risk under HSG258 (LEV guidance).

4. Gaps in PPE & Working Practices

No face-fit testing for RPE
Limited or inconsistent use of respiratory protection
Use of compressed air for cleaning, generating airborne dust
Continued dry sweeping, increasing inhalation exposure

5. Health Risks Confirmed

Rubber fume → potential carcinogen
Dust → respiratory disease risk (e.g., COPD)
VOCs → neurological and systemic effects

COSHH Implications

This Northampton-based case highlights a key compliance reality:

Being below WELs does not equal compliance under COSHH.

Key failings included:

Ineffective engineering controls (LEV)
Lack of ALARP-driven exposure reduction
Insufficient RPE programme
Limited health surveillance

Recommended Control Measures

1. Engineering Controls

Redesign LEV ducting to improve airflow and capture
Ensure 14-month statutory LEV testing
Install airflow indicators and maintain logbooks

2. Administrative Controls

Replace dry sweeping with HEPA vacuum or wet cleaning
Eliminate compressed air cleaning practices
Improve task supervision and process control

3. RPE Improvements

Implement face-fit testing programme
Upgrade to FFP3 or powered RPE where required
Enforce consistent use in high-risk areas

4. Health Surveillance

Introduce respiratory and skin health monitoring
Consider biological monitoring for total exposure assessment

5. Training & Awareness

Reinforce COSHH training and hazard awareness
Educate staff on correct use of controls and PPE

The Outcome

Following intervention, the Northampton facility:

Improved exposure control toward ALARP levels
Addressed critical LEV compliance failures
Strengthened readiness for HSE inspection
Reduced long-term occupational health risks

Key Takeaway

This case reinforces a critical point for UK manufacturers:

COSHH compliance is not about staying below limits - it’s about actively reducing risk.

Without proper controls:

Exposure can remain significant
Compliance can still fail
Workers remain at risk

If your site is “within limits”… that doesn’t mean it’s under control.

The real question is - can you prove your exposure is ALARP?