Posted By Paul Leadbetter Ann The law simply states that suitable and sufficient rest facilities shall be provided at readily accessible places. The ACoP states that, in offices and other reasonably clean workplaces, work seats will be sufficient provided that workers are not subject to excessive disturbance during breaks. For consumption of food, seats in work areas can be counted as eating facilities provided that they are in a sufficiently clean place and there is a suitable surface on which to place food. So - your manager may well be right! Paul