HEALTH & SAFETY  HAZARDOUS SUBSTANCES


Manager Practice


M


EDICAL and dental practices are often regarded as safe places where health considerations are of para-


mount importance. But most practice manag- ers would agree that the work performed by clinical, administrative and support staff presents a number of potential risks to the health of both employees and the public. This article looks at the risks associated with the storage and use of hazardous sub- stances on practice premises and, in par- ticular, considers practices’ duties under the Control of Substances Hazardous to Health Regulations (COSHH) 2005. In general terms, the risks are much the same for medical and dental premises, although there are likely to be more hazardous substances stored at GP surgeries. One of the more significant risks in prac-


tices relates to cleaning operations which often take place outside normal opening hours. Depending on the size of the premises, practices may use a single cleaner or a team of workers who will make use of a variety of cleaning agents. Due to the requirement to maintain a high


standard of cleanliness in premises, some of the substances used by cleaning staff will be more powerful – and potentially more danger- ous – than those found in the typical home. Some of the most powerful cleaning agents, such as sulphuric acid and bleach products, are highly acidic or alkaline and can inflict serious injury if accidentally spilled on skin or splashed in eyes. It is important to bear in mind that,


whether the cleaner is self-employed or sup- plied by an agency, the practice will share the legal responsibility for any injury resulting from a spillage. In the event of such an injury, the practice can only demonstrate legal compliance by proving that a suitable COSHH risk assessment had been carried out, that the risk of injury from the cleaning fluid had been identified, and that suitable and sufficient control measures had been taken to ensure the cleaner’s safety. This can be done through


various means including ensuring you have followed the steps explained in the ‘hierarchy of control’ (Elimination, Substitution, Control the risk at source, Education and Training, and Personal Protective Equipment) as well as providing training in the use of the substance. The same principles apply to every hazard- ous substance routinely stored and used at the practice’s premises. A second key COSHH consideration is drug supplies stored on practice premises. The practice should maintain a comprehensive inventory of all drugs, and staff should be required to maintain permanent records of the arrival of drugs at the practice as well as when and to whom they are issued. This requirement applies even more rigidly to controlled drugs and stems indirectly from the Harold Shipman case which centred on the alleged murder of more than 200 patients by Dr Shipman. Shipman ran a single-handed practice and routinely obtained supplies of diamorphine which he then used to deliver fatal doses to elderly patients. Full guidance on the receipt, storage and


issuing of controlled drugs is available from a variety of NHS sources, while the Misuse of Drugs Act and the Misuse of Drugs Regula- tions clearly set out the legal requirements. Guidance is also given on the recommended security arrangements for controlled drugs kept on practice premises. Another relevant COSHH consideration


centres on the procedures required for the taking, receipt, storage and despatch of blood, urine and stool samples. Patients will rarely turn up at the surgery with their own blood samples, but GPs and nursing staff will take blood samples on a daily basis. In addition to the obvious dangers associated with the use of sharps, it needs to be borne in mind that blood is a major infection hazard and COSHH obliges the practice to have assessed the hazards associated with taking blood samples, identified who is at risk, put suitable control measures in place and provided appropriate training to those involved. These steps need


to be recorded in writing and reviewed at least once a year. Similar considerations apply to urine and


stool samples and to vomit. Patients may supply urine samples while at the surgery, bring stool samples in for analysis and will sometimes vomit unexpectedly while on the premises. COSHH requires practices to have gone


through the same process as that described above for blood. Each set of risks is subtly different so different hazards and control measures will apply. Finally, it is worth noting that COSHH also


applies to the range of so-called superbugs, including MRSA and C. difficile. While many outbreaks of infection take place in hospital, these infections can easily be acquired in the community, and this means that practices should have appropriate risk assessments and control measures in place in respect of these. Although compensation claims stemming from superbug infection are relatively rare, no medical or dental practice wants to find itself on the receiving end of a claim based on a negligent failure to take the required control steps. 


Ian McKinnon is head of Health and Safety Services at Law At Work


Law At Work provides employment law and health and safety services to MDDUS members. For more information and contact details please visit www.lawatwork.co.uk


06


SUMMER 2012  ISSUE 6


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