This case study explains how a UK food manufacturing and processing organisation achieved full UV light safety compliance for their UV disinfection tunnels.
The project included:
- UV risk management training for the safety team
- Personal UV exposure measurement
- Legally required UV hazard awareness training
- Review of existing engineering and administrative controls
- Documented compliance under the Control of Artificial Optical Radiation at Work Regulations 2010
The engagement began following attendance at one of our free UV safety webinars and resulted in a complete UV Safety and Compliance Package tailored to their specific process.
The client’s situation
The organisation operates UV disinfection tunnels used to transfer packaging and bulk ingredients from low-risk to high-care production areas.
The objective of the system is to reduce microbiological contamination on non-food contact surfaces, including bacteria such as:
- Listeria
- E. coli
- Salmonella
A newly appointed Health and Safety lead had recently inherited responsibility for the site. Very little documented information existed regarding:
- UV equipment specifications
- Exposure risk assessment
- Safe working times and distances
- Inspection and maintenance records
- UV hazard awareness training
Although the UV system was operational, there was uncertainty around compliance with UK artificial optical radiation legislation and whether worker exposure had ever been formally assessed.
Why UV disinfection systems require formal risk assessment
UV disinfection technology is increasingly used in food manufacturing because it is effective, residue-free and easy to integrate into production lines.
However, UV radiation – particularly UV-C – can present significant occupational health risks, including:
- Acute eye injury (photokeratitis)
- Skin erythema (burn-like reactions)
- Cumulative long-term skin damage
- Increased risk of skin cancer with repeated exposure
Under the Control of Artificial Optical Radiation at Work Regulations 2010, employers must:
- Assess artificial optical radiation exposure
- Implement engineering and administrative controls
- Compare exposure levels against statutory Exposure Limit Values (ELVs)
- Provide specific information and training to employees
- Maintain documented evidence of compliance
Many organisations install UV systems without fully understanding these ongoing duties.
Initial engagement: Free UV Safety Webinar
The Health and Safety lead attended one of our free UV safety webinars to better understand:
- UV radiation risks
- Legal responsibilities under AOR 2010
- Exposure limit requirements
- Common compliance gaps
Prior to the webinar, we held a short consultation call to understand their UV tunnel configuration and working practices. This allowed relevant examples to be incorporated into the session.
During the webinar, real-world case examples from similar food manufacturing environments were discussed. This reassured the organisation that their situation was not unusual and that practical compliance support was available.
UV risk assessment for UV disinfection tunnels
Following the webinar, the organisation commissioned a full UV Safety and Compliance Package.
The first stage was a formal artificial optical radiation risk assessment specific to their UV tunnel system.
Site visit and existing controls review
An on-site assessment was conducted to:
- Observe the UV disinfection process in operation
- Review guarding and interlocks
- Assess access points during loading and unloading
- Identify potential reflection risks
- Evaluate maintenance arrangements
Personal UV exposure measurement
Measured personal exposure levels were taken and compared directly against statutory Exposure Limit Values defined under AOR 2010.
This provided objective evidence of:
- Actual worker exposure
- Risk severity
- Required control improvements
Key findings
The assessment identified:
- Damage to certain protective controls designed to eliminate personnel exposure
- Insufficient warning signage around the UV tunnel area
- Inconsistent use of hand protection during loading and unloading
Although no injuries had occurred, the short maximum exposure time associated with the UV-C wavelength in use meant that employees were operating with reduced safety margin.
Corrective action was recommended immediately.
UV risk management training for the health and safety team
To strengthen internal competence, structured UV risk management training was delivered to the Health and Safety team.
This included:
- Introduction to UV radiation and industrial applications
- Differences between UV-A, UV-B and UV-C
- Equipment selection considerations
- Process monitoring for performance consistency
- Short and long term health effects
- Legal exposure limits
- Required hierarchy of control measures
- Employer duties under AOR 2010
This improved in-house understanding and enabled more confident management of the UV system.
UV hazard awareness training (a legal requirement)
Under AOR 2010, employees exposed to artificial optical radiation must receive specific information and training relevant to their equipment and working practices.
Using the exposure data gathered on-site, bespoke UV hazard awareness training was developed, covering:
- Equipment-specific risks
- Safe working distances and times
- Control measures in place
- PPE requirements
- Reporting procedures
Training was delivered either directly to employees or via the internal safety team for continued in-house delivery.
Common UV compliance gaps in food manufacturing
Across hundreds of UV assessments conducted annually, common compliance issues include:
- No documented UV risk assessment
- No measured exposure data
- Damaged guarding or bypassed interlocks
- Generic rather than equipment-specific training
- No comparison against exposure limit values
- Lack of audit-ready documentation
This case study demonstrates how these gaps can be identified and resolved systematically.
The outcome
Following implementation:
- Damaged protective controls were repaired
- Additional signage was installed
- Mandatory hand protection procedures were formalised
- Exposure levels were verified against statutory limits
- Comprehensive compliance documentation was produced
- Employees received legally compliant training
The organisation now has:
- Verified UV exposure data
- Documented compliance under AOR 2010
- Improved worker awareness
- Audit-ready evidence for regulatory inspection
Most importantly, workers now understand both the benefits and risks of the UV equipment they operate alongside.
Why UV compliance is process-specific
Every UV installation is different. Risk levels depend on:
- UV wavelength and intensity
- Equipment design
- Shielding and guarding effectiveness
- Working position
- Duration of exposure
- Maintenance condition
No generic template assessment is sufficient. Each system requires process-specific evaluation.
With over 20 years specialising in UV light technology and safety compliance, we conduct hundreds of UV risk assessments each year across manufacturing, healthcare and industrial environments throughout the UK and Ireland.
Frequently asked questions about UV light safety
Is UV hazard awareness training legally required?
Yes. Under the Control of Artificial Optical Radiation at Work Regulations 2010, employees exposed to UV radiation must receive specific information and training relating to equipment, exposure levels and control measures. Many organisations lack the internal knowledge and data to produce and conduct effective training.
Do UV disinfection tunnels require a formal risk assessment?
Yes. Any equipment emitting artificial optical radiation requires assessment and comparison against statutory Exposure Limit Values.
Can short UV exposure cause harm?
Yes. UV-C exposure can cause acute eye and skin injury within very short durations depending on intensity and proximity.
What documentation should be available for audit?
Organisations should retain:
- UV risk assessment records
- Exposure measurement data
- Control verification records
- Training documentation
- Maintenance inspection logs
Start with a Free UV Safety Webinar
For organisations operating UV light equipment, a structured introduction to UV safety is often the best starting point.
A free UV safety webinar helps:
- Clarify legal duties
- Identify potential compliance gaps
- Improve internal awareness
- Determine whether formal assessment is required
UV technology provides significant hygiene and operational benefits in food manufacturing, but safety and regulatory compliance must be addressed alongside performance.