Chemicals Manufacturer Fined £3.8M After Worker Loses Leg in Caustic Soda Incident

Industrial Chemicals Limited received a £3.8 million fine at Southwark Crown Court on April 21 after pleading guilty to health and safety violations that left one worker with a below-knee amputation and another requiring skin grafts, according to Printweek.

The penalty marks the second multimillion-pound fine for the paper-making chemicals manufacturer in just over a year, with the company previously fined £2.5 million in April 2025 for uncontrolled acid releases at its facilities.

Two Sites, Two Injuries

The December 2019 incident at ICL's West Thurrock facility left Michael Bartholomew, then 59 and working as a chemical loader, with life-altering injuries after he stepped into a puddle suspected to contain caustic soda. The safety boots provided to Bartholomew were in poor condition and failed to protect against the hazardous chemical, according to the Health and Safety Executive investigation.

Bartholomew sustained severe burns that required amputation of his leg below the knee. He has not returned to work since the incident. In his victim personal statement, Bartholomew described losing his independence and ability to engage in activities with his grandchildren, including fishing trips and backyard football.

A second incident occurred in August 2022 at ICL's Titan Works site in Grays, which has since closed. An employee manually decanting caustic soda at 50 percent concentration noticed drips from a hose had fallen onto his foot, causing burns that later required skin grafts. The worker has since returned to employment.

Systemic Failures Across Multiple Sites

The HSE investigation uncovered widespread safety failures at the West Thurrock location. Inspectors documented multiple leaks of hazardous substances from pipework, valves, hoses and vessels throughout the site. Work systems did not account for spillages, controls for clearing spills were inadequate, and the ground around the boiler house was unmade, allowing puddles to accumulate.

The facility lacked sufficient designated or enforced walkways to safely direct workers across the site, the investigation found.

At the Grays facility, investigators found no risk assessment or documented safe system of work for the caustic soda decanting task. HSE determined the process could have been fully automated using an existing automatic intermediate bulk container dosing plant with fixed pipework and remote controls, eliminating manual handling of the corrosive chemical entirely.

Following the 2022 incident, ICL stopped using 25-liter containers and began receiving IBCs already mixed to the required concentration, removing the hazard completely.

The company pleaded guilty to two charges of breaching Regulation 7(1) of the Control of Substances Hazardous to Health Regulations 2002. In addition to the £3.8 million fine, ICL was ordered to pay costs of £124,748.

Pattern of Violations

"This was a company operating with significant volumes of a highly corrosive material but had manifestly failed to put proper measures in place to protect their workers and prevent exposure," HSE Inspector Julia Gebauer said. "The consequence was two separate incidents at two separate sites – one of which resulted in life-altering injuries – that pointed to a pattern of avoidable risks that Industrial Chemicals Ltd could and should have prevented."

The prosecution represents the second major enforcement action against ICL within 13 months. The April 2025 fine of £2.5 million followed two uncontrolled releases of acid—one involving hydrochloric acid and the other sulphuric acid—at company facilities.

ICL reported sales of nearly £169 million in its most recent accounts for 2024. The company manufactures chemicals used in paper production and operates facilities in the Thames Estuary area.

The pattern of repeat violations at facilities handling hazardous materials mirrors broader concerns about corporate safety policies that fail to translate into actual worker protections, particularly at sites where automation could eliminate exposure risks entirely.

Policy Implications

The £3.8 million penalty demonstrates escalating financial consequences for companies that fail to implement basic hazard controls, particularly when those failures result in permanent disabilities. The fine represents roughly 2.2 percent of ICL's annual sales, a scale intended to send a deterrent message across industries handling corrosive materials.

The case highlights enforcement priorities around substances regulated under COSHH. The HSE investigation's finding that automation could have eliminated the manual decanting task entirely raises questions about whether regulators should mandate automation where technically feasible for high-hazard processes. ICL's decision to automate only after an injury occurred, despite having the equipment available, suggests voluntary safety improvements remain inadequate without regulatory pressure.

For workers in chemical manufacturing and related industries, the repeat violations at ICL underscore the importance of reporting inadequate protective equipment and work systems before injuries occur. Bartholomew's case demonstrates that even provided safety equipment can fail when not properly maintained or suited to the specific hazard, a gap that workers themselves are often best positioned to identify before exposure occurs.