Thursday 17 March 2011

Managerial Section F: COSHH Regs & H&S

Domain: Knowledge of Health and Safety
MF. Knowledge of COSHH regulations and other H&S policies

Recommended for assessment by Deanery:
Copy of Practice Health and Safety Policy
A signed reflective commentary demonstrating understanding of the policy.
A copy of practice COSHH statements
Signed reflective commentary demonstrating understanding of the COSHH requirements.

Included for assessment:
A. Signed Reflective Commentary demonstrating an understanding of the practice Health and Safety policy and the principles and legislation that the policy is based upon.
B. Copy of Practice Health and Safety Policy 
C. Signed reflective commentary demonstrating understanding of the COSHH regulations and their implications for a dental practice.
D. Copy of several practice COSHH Statements (all 25 available on request including safety data sheets)




A. Signed Reflective Commentary demonstrating an understanding of the practice Health and Safety policy and the principles and legislation that the policy is based upon.
Health and Safety

Risk management assessments in the general dental practice environment.

The following reflective commentary aims to look at the responsibilities of a dentist in providing a healthy, safe environment for staff and patients. I will look specifically at some of the legislation surrounding health and safety law.

The legislation found withing the Health and Safety Act 1974- seeks to protect all those at work and failire to comply with the requirements can lead to prosecution by the Health and Safety executive. The professional care of patients/clinical judgement is not covered by the Act.

Basic requirements are that the dentist:

  • Provides and maintains safe equipment, appliances and systems of work.
  • Ensures that dangerous substances are handled and stored correctly and safely
  • Maintains the place of work.
  • Provides a working environment that is safe, without risks to health and adequate facilites for employees welfare at work.
  • Provides necessary instruction and training and supervision to ensure health and safety.

Health and Safety Policy

Practices with five or more employees must be brought to the attention of all employees (including self-employed associates) Inlcuded within the evidence is a copy of the health and safety policy and statement of the company (evidence 5/6). It is a significant document at approximately 30 pages plus it includes:

1. The statement of intent- a declaration of employers commitment to provide a safe working environment.
2. Details of responsibilities throughout the workplaces
  1. Details of dafe systems of work/safe working practices.


Hazards and Risks

A hazard can be defined as anything that can or has the potential to cause harm (i.e. chemicals, electricity etc)
A risk can be defined as the chance of harm actually occurring.

The obligation to undertake risk assessment is a legal requirement. The Health and Safety at Work Act 1974 requires that employers ensure the health and safety of all those who may be affected by work activities. Other regulations that require a risk assessment to be carried out include the:

  • Control of Substances Hazardous to Health Regulations 2002
  • Ionising Radiations Regulations 1999
  • the Manual Handling Operations Regulations 1992
  • Fire Reform Order 2006.


A risk assessment had not been carried out that I could find. It is highly likely that this information is kept at a regional level.
I talked to the practice manager about this. I did however use the BDA example1 of a risk assessment and adapted it to the practice as an initial framework to build upon.



Risk Assessment

A provisional risk assessment of the practice was carried out on (associate dentist) and the following are the significant findings. A review of the risk assessment is due on 30 January 2009

Significant hazards
Those at risk
Existing controls or action
required

Autoclave
Risk of explosion, scalds and burns
Dental nurse

• staff receive full instruction immediate area) and training in the safe use of autoclaves
• manufacturers' instructions and operating procedures are kept nearby the autoclave
• malfunctions or faults are reported to the practice manager for remedial action
• autoclaves are serviced regularly and inspected for safety purposes in accordance with the Written Scheme of Examination.
Biological agents
Risk of infection from -
• Bacteria/micro-organisms
• Blood/saliva

Dentist, dental nurse, hygienist, patient
Biological agents are covered by COSHH - see separate assessment
• universal precautions and current infection control guidelines are followed - see practice infectioncontrol policy
• relevant staff are immunised against hepatitis B and their responses checked
• regular training in infection control procedures is provided
• see also Sharps
For action: Regular training and updates in infection control guidelines for all staff.
Display screen equipment
Receptionist / practice manager
• individual workstation assessments undertaken for regular users – see separate assessments
• equipment and seating can be adjusted to individual needs
• eye test is provided if requested by employee
• window blind is provided to control glare on screen [if glare is a problem]
• training in software used is provided
• Information on DSE health and safety has been provided (HSE leaflet).
Electrical
• electric shock or burns
• fire from damaged equipment
All staff
• staff advised to visually check plugs, Risk of - cables or equipment for signs of overheating or damage and report these to the practice manager for remedial action.
• visual inspection of all portable appliances is carried out annually/six monthly by the practice owner [or other competent member of staff] and findings recorded
• all electrical equipment is inspected and tested by a qualified electrician at regular intervals (every three years suggested)
For action: Training for staff to include simple visual checks of electrical equipment.
Eye injury
Risk of –
• flying debris and splatter from rotary instruments
splashing during the cleaning of instruments.
Dentist, dental nurse, hygienist, patient
• use of protective eyewear during clinical procedures for both staff and patients and when cleaning instruments and equipment prior to sterilisation
• use of high speed aspiration for procedures involving rotary instruments
• use of rubber dam whenever possible to restrict the operative field
• immunisation against hepatitis B for all clinical health care workers and response to the vaccine checked
Eye injury from light curing unit
Risk of damage to the eye from blue (and white) light
Dentist, dental nurse, patient
• avoid prolonged or direct viewing
• use of suitable protective eyewear or light shield (red, orange or yellow)
Fire
All staff, patients and visitors.
• fire alarm system (if fitted) checked and tested annually by service engineer
• self-contained smoke alarms are cleaned and batteries changed annually
• staff trained in the evacuation procedure
• fire fighting equipment is checked and tested annually by service engineer
• fire exits and fire-fighting equipment are clearly marked
• access to exits and extinguishers is kept clear at all times
• fire drills are held twice yearly (but for practical reasons do not have to be during patient time)
• procedures to be followed in the event of a fire are displayed [where].
For action: Practice manager to make regular inspections to ensure that fire precautions are followed and housekeeping standards are maintained.
Hazardous substances
Risk of skin, eye and respiratory tract irritation, asthma, allergy and poisoning
Dentist, dental nurse, hygienist, cleaner, patient, visitors andcontractors

• Hazardous substances are covered by COSHH - see separate assessment
• staff made aware of the risks from the hazardous substances they work with and the precautions needed to avoid or control these risks
• substances assessed include acids, adhesives, blood and saliva, disinfectants, strong detergents and other cleaning agents, latex gloves,mercury, nitrous oxide, solvents and radiographic chemicals.
Manual handling
Risk of injury to back or other part of the body
All staff involved in lifting and/or a awkward or repetitive handling (for example, stock deliveries, assisting elderly and disabled
• training and information provided
including good handling techniques and how to recognise harmful manual handling
• information on manual handling techniques is available (HSE leaflet) and kept [where]
For action: Annual review of manual handling techniques to be undertaken (practice meeting).
Radiation - ionising
Risk of accidental over- exposure from x-ray equipment
Patient, dentist, dental nurse.
• Radiation Protection Adviser appointed - see separate risk assessment
• Radiation Protection Supervisor is on the premises at all times
• those involved in the taking and processing of radiographs have received the appropriate training and possess the relevant knowledge
• x-ray equipment is regularly checked and maintained in accordance with the manufacturer's, suppliers and RPA's advice
• arrangements for dealing with accidental or unintended doses are contained in the Local Rules.
• x-ray equipment can be switched off in the event of malfunction without entering the controlled zone
• current guidelines on radiology standards are followed closely – see Guidance notes on the safe use of x-ray equipment (NRPB/DH, June 2001) and BDA Advice Sheet Radiation in dentistry (A11).

Sharps
Risk of infection from used needles, instruments and spicules of teeth or bone
Dentists, dental nurses, patients, hygienists, waste contractors

• thick household type gloves provided for handling and cleaning used instruments prior to sterilisation
• needles are only re-sheathed using a device
• all staff trained in the safe use and disposal of sharps - see practice policy on disposal of clinical waste
• sharps are discarded into an approved container
• all staff are immunised against hepatitis B and their response to the vaccine checked.
• sharps injuries are reported immediately and dealt with as appropriate - see practice policy on inoculation injuries
• If required, medical advice will be sought as soon as possible.
For action: Regular updates on the procedures to be followed in the event of an inoculation injury (practice
meeting).
Slips, trips and falls
Risk of injury
Staff, patients and visitors.
Good quality flooring, which is well maintained
All staff trained to maintain good housekeeping standards
Spills cleared up immediately
Walk areas kept unobstructed.
Risk of exposure to infectious hazardous waste
Staff and waste contractors.
Waste segregated and disposed of or in appropriate containers – see practice policy on disposal of healthcare waste
Waste collected for disposal by authorised waste disposal company records of disposal maintained.



Legislation in General Dental Practice
The following section deals with what health and safety legislation requires of my practice. In each section the relevant legislation is listed in bold with a paragraph below giving a synopsis of the relevant obligations. At the end of section I summarise the degree of compliance with the legislation.



1. Infection control
Health and Safety at Work Act (1974).
Management of Health and Safety at Work Regulations (1992)
Control of Substances Hazardous to Health (COSHH) Regulations 2002
The Health Act (2006)
Dentists have a duty to take appropriate precautions to protect patients and other members of the dental team from the risk of cross infection. Failure to employ adequate methods of infection control would almost certainly render a dentist liable to a charge of serious professional misconduct. The importance of minimising the risk of infection and the control of hazardous practices is clearly laid out in the Health and Safety at Work Act (1974). This act is the primary legislation on health and safety I the workplace, placing legal obligations on both employer and employee. Additional obligations are defined in the Management of Health and Safety at Work Regulations (1992) and Control of Substances Hazardous to Health (COSHH) Regulations 2002The Health Act (2006) specifically provides a legal framework for the prevention and control of infections in acute and primary care.




2. Radiography
Ionising Radiation (Medical Exposures) Regulations 2000
Ionising Radiation Regulations (IRR 1999)

See KS4.3 for legislation relevant to Radiography




3. Waste disposal
Environmental Act 1990
Environmental Protection (Duty of Care) Regulations 1991.
Special Waste Regulations 1996

Under the Environmental Act 1990, dentists as producers of non-domestic waste are required to sort and store the waste securely and in an appropriate manner. Part of this legislation involves maintaining records and having the relevant documentation. An example of this is the ‘waste transfer note’ (KS2 evidence 3)

Environmental Protection (Duty of Care) Regulations 1991. “Clinical waste is waste that is contaminated with blood, saliva and other body fluids and may prove hazardous to any person coming into contact with it. Clinical waste sacks must be no more than three-quarters full, have the air gently squeezed out to avoid bursting when handled, be labelled and tied at the neck, not knotted. Sharps waste (needles and scalpel blades) must be sealed in UN type approved puncture proof containers (to BS7320), which must be labelled before disposal. Sharps’ containers should be disposed of when no more than two-thirds full. Clinical waste should be disposed of by high temperature incineration, or other disposal facility licensed to handle it.” (REF A3 advice)

Special Waste Regulations 1996- Prescribed medicines and waste classified as irritant, harmful, toxic, carcinogenic or corrosive are regarded as special waste. Local anaesthetic solution is a prescribed medicine so partially discharged cartridges must be disposed of as special waste. Disposal of special waste is subject to additional controls. Radiographic developer and fixer are classified as special waste.


Reflection: within the practice we have a contract with XYZ hygiene that collect the clinical waste on a regular basis and dispose of it by high temperature incineration. The clinical waste is stored in a safe area. We have a special combined ‘sharps and special waste’ container which is collected and emptied by XYZ Hygiene also. A waste transfer note is kept in the practice records. I evaluated the storage of the clinical waste and found the bags we knotted and not tied this was brought up at a practice meeting.



4. Complaints procedure
Reflection: A copy of the practice complaints procedure can be found at Evidence3 .The complaints procedure is in keeping of what it recommended for good practice.1


5 Pressure vessel regulations

Provision and Use of Work Equipment Regulations 1998.
The Pressure Systems Safety Regulations 2000

All those who use autoclaves within the practice should be thoroughly trained in their use. All autoclaves and air-receivers with a capacity of more than 250 Bar-litres must comply with the Regulations. Before an autoclave or air-receiver is used, a ‘competent’ person should draw up a written scheme of examination detailing the periodic examination of the vessel. The written scheme must be regularly reviewed. Records must be kept to show that the periodic examinations have been carried out in line with the written scheme. The maximum intervals for inspection are 14 months for autoclaves and 26 months for air receivers. Examination for safety reasons is not equivalent to servicing and performance testing, which should be carried out in accordance with the manufacturer’s instruction. Where the Regulations do not apply, for example small capacity air receivers, regular maintenance is still essential.”

Reflection: Reviewing the requirements of the regulations it became apparent that the practice is currently performing poorly in complying with the regulations. There is no written scheme to be reviewed and there is no logbook for each autoclave. Although there is a record on the vacuum autoclave of the last service and next one due- it is insufficient and does not comply with the regulations. I spoke to the practice manager about these issues and advised that they should be addressed.


6. Transportation of clinical materials

Carriage of dangerous goods and use of transportable pressure equipment regulation 2004 (amendment 2005)
International carriage of dangerous goods by road (ADR 2007)

Dentists using Royal Mail to send patients’ specimens to pathology laboratories for diagnostic opinion or tests must comply with the UN 602 packaging requirements. The
602 packaging requirements ensure that strict performance tests (including drop and puncture tests) have been met. The outer shipping package must bear the UN packaging specification marking. Only first class letter post, special delivery or data post services must be used. The parcel post must not be used. Every pathological specimen must be enclosed in a primary container that is watertight and leak proof. The primary container must be wrapped in sufficient absorbent material to absorb all fluid in case of breakage and then placed in a second durable watertight, leak proof container. Several wrapped primary containers may be placed in one secondary container provided sufficient additional absorbent material is used to cushion the primary containers. Finally, the secondary container should be placed in an outer shipping package that protects it and its contents from physical damage and water whilst in transit. The shipping package must be conspicuously labelled ‘PACKED IN COMPLIANCE WITH THE POST OFFICE INLAND LETTER POST SCHEME’. The sender must also sign and date the package in the space provided. Information concerning the sample (data forms, letters and descriptive information) should be taped to the outside of the
secondary container. A dentist sending a pathological specimen through the post without complying with the above requirements may be liable to prosecution.

Reflection: The practice does not have a policy or written protocol on how to send a specimen through the post as none of the dentists take biopsies. The practice does have a policy on disinfection of lab work (KS2 evidence12). Even though this is the case it would be wise to put in place a policy should there be the need for a soft tissue biopsy to be taken.




7 Electricity at work

Electricity at Work Regulations 1989

All appliances must be correctly wired and fused and should be installed by contractors registered with an appropriate organisation, for example, the National Inspection Council for Electrical Installing Contracting. Whilst the Regulations do not specify the need for examination and testing, the requirements for suitability, integrity and safety of electrical equipment imply a need for some form of inspection and testing. It is not mandatory to maintain records of inspection and testing but they would help provide evidence that all reasonable steps had been taken to comply with the requirements of the legislation. Electrical equipment must be in good working order at all times.

Reflection: There is a formal annual electrical inspection and each electronic item has a sticker applied to the mains cable detailing the last inspection and when the next is due.





8 Fire precautions

The Fire Precautions (Workplace) Regulations 1997

The Fire Precautions (Workplace) Regulations 1997 require you to assess what fire precautions are needed by carrying out a fire risk assessment as part of your general risk assessment. The Regulations specify the following requirements for emergency routes and exits:
  • They must be kept free of obstruction at all times and allow employees (and patients) to evacuate the premises quickly and safely
  • Where possible they should lead directly to a place of safety they should be appropriately and clearly indicated
  • Emergency lighting should be provided where necessary
  • Emergency doors must open in the direction of the escape and in an easy and immediate action
  • Sliding and revolving doors should not be used as emergency exits.

Reflection: The practice clearly displays fire-exit signs and has a written protocol for where all staff should meet in the event of a fire. Fire extinguishers are available and easily accessible on all floors. The practice also has an inbuilt sprinkler system. As part of the induction training each person is given an introduction and shown the fire exits.
My previous employer kept a Fire Drill statement4. This detailed the evacuation procedure for the clinic.


9. First aid regulations
First-aid and medical Emergencies
The Health and Safety (First-Aid) Regulations 1981

All workplaces must have adequate first-aid provisions, the extent of which depends upon the hazards present and the number of people employed (including associates and self-employed hygienists).Access to first-aid facilities must be available for all employees during working hours, even when shifts are worked. The Health and Safety (First-Aid) Regulations 1981 require you to assess the first-aid requirements of the practice taking the following factors into account:
  • the hazards and risks associated with the work – your practice risk assessment will help
  • the number of people at the practice and where they work
  • previous accidents (recorded in the accident book)
  • access to emergency facilities and services
  • arrangements for covering planned and unplanned absences
  • patients – although there is no legal requirement to provide first-aid treatment and facilities to non-employees.

Qualified personnel: Dental practices with fewer than 50 workers are required to have an appointed person on the premises at all times the practice is open. The basic ‘emergency first-aid’ course for appointed persons is recommended and should include emergency actions, cardiopulmonary resuscitation (CPR), control of bleeding, treatment of wounds and treatment of the unconscious patient.
First aid box: all dental practices must have at least one first-aid box clearly marked with a white cross on green background. First-aid boxes should contain sufficient quantities of suitable first-aid materials and nothing else.

Reflection: The practice currently has a first aid box in addition to the emergency kit. But the practice does not have an appointed person. I enquired with the practice manager who reported that this had been brought up at several meetings but no action had been taken despite the regulations. I decided that I would raise the issue and any other relevant issues with the regional clinical manager.


10 Use of computers

Display screen equipment (DSE)
Health and Safety (Display Screen Equipment) Regulations 1992

The use of computers within the practice is becoming increasingly common. Where employees habitually use DSE for a significant part of their normal work, you will have certain obligations (Health and Safety (Display Screen Equipment) Regulations 1992). Where DSE use is more or less continuous on most days, the worker will be deemed to be a user. Work involving DSE use should be planned to incorporate breaks or changes of activity. Short frequent breaks are better than longer, less frequent ones and ideally the individual should have some discretion over when they are taken. The workstation must meet minimum requirements. For example, the screen should normally have adjustable brightness and contrast controls, to allow individuals to find a comfortable level for their eyes, helping to avoid the problems of tired eyes and eyestrain.  Health and safety training should be provided to make sure employees can use all aspects of their workstation equipment safely and know how to make the best use of it to avoid health problems, for example by adjusting the chair, using a wrist pad and foot rest.

Users’ can ask the employer to provide eye and eyesight tests. If spectacles are required specifically for working at the DSE, the employer must provide them but not spectacles that are required for any other purpose. The results of the eye and eyesight test can only be disclosed to the employing dentist with the consent of the employee (Access to Medical Reports Act 1988).

Reflection: The most intensive users of the DSE in the dental setting is the Reception team and the practice manager. For the dental nurses and dentists it is less important as using the computer is not as frequent or continuous. There is no formal training programme in place currently for using a DSE though there seems to be an awareness of what constitutes good practice in the use of one. Again this issue was raised with practice manager.


11 Accidents at work

Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR)

Employers are required to notify the HSE of major accidents (including death) and dangerous occurrences (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR). Reports to the HSE (Incident Control Centre) can be made by telephone, fax or email without delay to allow any necessary investigation to begin promptly. The employing dentist must also confirm the details in writing within 10 days on Form F2508.Accidents causing more than three days’ absence from work must also be reported by sending a completed accident report form (F2508) to the Health and Safety Executive within 10 days of the accident – no immediate notification by telephone is required. Reports must be submitted using the proper form and there are penalties for failing to notify. Adverse incidents involving medical devices should also be reported to the Medicines and Healthcare Products Regulatory Agency (formally the Medical Devices Agency). The appropriate reporting forms are available from the BDA.

The practice has a RIDDOR compliant accident book that details the legislation described above and declares when an accident is reportable under the legislation. There has not yet been occasion to notify the HSE of a major incident.

My previous practice in Milton Keynes had the following documentation relevant to compliance with much of the legislation described above. This has been included in addition to the statement from my current practice.

Health and Safety Policy Statement 5- The document expresses the desire for the clinic to comply with providing the environment safe. It also details who is responsible within the company for implementation and accountability of safety procedures.
This document goes hand-in hand with the Health and Safety Policy 6. This policy is covers specific issues such as who the Safety Officer is within the clinic and although is not in sufficient detail- gives an overview of the general aims and the aspects of legislation that is being complied with.

Associated Evidence including

B. Copy of Practice Health and Safety Policy 

1. Legislation and Good Practice Guidelines. BDA advice sheet A5. 2007

2. Health and Safety in dental practice. BDA advice sheet A3. 2007

3. Practice complaint procedure. The Practice Manual.

4. Fire drill statement. 

5. Health and safety policy statement.

6. Health and Safety policy.







C. Signed reflective commentary demonstrating understanding of the COSHH regulations and their implications for a dental practice.
D. Copy of several practice COSHH Statements (all 25 available on request including safety data sheets)

Control of Substances Hazardous to Health Regulations

Much of the information contained in the following reflective commentary is derived from the BDA advice sheets A3- Health and Safety and A5- Risk assessment in Dentistry. When examining the existing risk assessments in the practice- it was possible to find information relating to the optical department in the Health and Safety file but was not specific to cover dentistry. I contacted the regional manager who within a few days I received a CD with 324 data sheets for various materials. Included was a folder of data listing of 25 risk assessments of hazardous materials. Each is classified into three categories of risk:

Level 3- Low risk
Level 2- Moderate risk
Level 1- Significant risk

The higher the risk the more detailed the information required. I have included an example of each of the forms (Evidence 1-3). I have included examples of some of the most recent assessments as Evidence 4.
Whilst the information is comprehensive and complies with the recommendations, this data should be readily available and staff should be more aware of the sheets and their implications- otherwise the data just becomes just a paper exercise.

Risk assessment – hazardous substances

The legislation in Control of Substances Hazardous to Health Regulations is designed to protect workers against illness and injury or potential death caused by exposure to hazardous substances. The COSHH Regulations require practices to eliminate or reduce exposure to known hazardous substances in a practical way.
e.g. changing the process or activity to remove the need for the hazardous substance or prevent it from being generated, replace the substance with a safer alternative or use it in a safer form.

When carrying out a COSHH assessment, the clinic will need to:
• identify the hazardous substances in the practice
• decide who might harmed and how
• assess the risks associated with their use
• carry out any necessary health surveillance
• prevent or control the risk
• ensure staff are aware of the risks and trained to handle hazardous substances carefully
• make a record of your assessment and update it regularly

BDA advice sheet A3 discusses important information about exposure limits. Although there are few substances within dentistry where this is concerned it is important to be aware: There are two types of occupational exposure limits for hazardous substances; occupational exposure standards (OESs) and maximum exposure limits (MELs). MELs are set for substances for which no safe level of exposure can be identified or for substances for which safe levels may exist but difficult to achieve in practice. Exposure to these substances has or is liable to have serious health implications of workers – for example, may cause cancer or occupational asthma. Where the material safety data sheet provided by the manufacturer refers to an OES or MEL, dentists are those levels in order to ensure a safe working environment for their employees. Few substances used in dentistry are assigned a MEL.

Manufacturers of hazardous substances are required to display an orange and black warning symbol on the label and packaging of any substance that is classified as hazardous:



Harmful, toxic, corrosive & irritant.
In addition, the manufacturers and suppliers of hazardous substances must provide material safety data sheets, which contain more detailed information on the hazards presented and the required first-aid measures.


Examples of materials that should be contained within the COSHH assessment.
Directly from BDA advice sheet A5
• latex gloves (risk of allergy)
• mercury (toxic by inhalation)
• nitrous oxide (can affect central nervous system at high concentrations)
• solvents (various ill-health effects)
• radiographic chemicals (irritating to eyes and skin and possibly respiratory system)
Most restorative and impression materials and mouth rinses pose negligible risk so will
not need to be included in your COSHH assessment. When you assess the risks, you
should consider:
• how often it is used? Daily, weekly, monthly, quarterly or annually
• how much of the substance is used? Small amounts (grams or millilitres) or medium
amounts (kilograms or litres)
• how could people be exposed to it? Inhalation, direct contact, skin absorption, or
swallowing, for example

Actions required

If a substance does not present a risk or the risk is trivial then nothing more needs to be done. If there are significant risks associated, then it is necessary to decide how to reduce the risk.

Record and review the assessment. The COSHH assessment should be recorded and kept with any relevant material safety data sheets.

Ensure that precautions are followed and controls are maintained. Staff must receive suitable information and training on the precautions for handling and using hazardous substances and supervised where necessary. T

Monitoring exposure If the assessment shows that there could be a serious risk to health from a substance harmful to health then a method of monitoring the exposure should be necessary.

Ensure staff are properly informed, trained and supervised: Staff who work with hazardous substances should be provided with the following information (from BDA advice sheet A3)

• the nature of the substances they work with or are exposed to and the associated
risks

• the precautions they should take and the control measures in place

• the importance of using any personal protective clothing or equipment provided

• the results of any exposure monitoring and health surveillance

• emergency procedures (in the event of exposure or a spillage, for example).
Flammable substances are not necessarily hazardous to health (they may simply be
flammable) but they are obviously a risk to safety. You need to ensure that these
substances present minimum risk:

• store and use flammable substances in a well ventilated area so that any vapours
given off from a spill or leak will be dispersed rapidly

• avoid sources of ignition in areas where flammable substances are stored or handled.
Ignition sources include sparks from electrical equipment, cutting tools, hot surfaces,
open flames from heating equipment and cigarettes

• sunlight is a heat source - a glass window may intensify heat during the summer to a
considerably high temperature, which has been known to cause aerosol cans to
explode (including deodorant and hairspray cans)

• flammable substances should be stored in suitable containers away from general
work and storage areas, especially if being stored in large quantities.


Conclusion

No-one likes meaningless paper based exercises and COSHH could be just that if not used correctly. In addition to being a legal requirement, assessments are also a useful training tool and should be an essential part of an new employee induction and staff meetings. Risk assessments should be reviewed and updated as necessary.
Evidence 1- Low Risk hazard form

Evidence 2- Moderate Risk hazard form

Evidence 3- High Risk hazard form

Evidence 4- Risk Assessment sheets.

Evidence 1

COSHH Risk Assessment




Level 1 – Significant Risk






Name of substance







What is it used for?







Hazardous Ingredients







How often is it used?







Who uses it?







How much is used







Nature of risk







How do you store it?







How do you dispose of it?







First aid measures for eyes







First aid measures for skin







First aid measures for ingestion & inhalation







Control measures & PPE







Ventilation needed







Fire fighting measures







Additional Information






Evidence 2

COSHH Risk Assessment




Level 2 – Moderate Risk






Name of substance







What is it used for?







Hazardous Ingredients







How often is it used?







Who uses it?







How much is used







Nature of risk







How do you store it?







How do you dispose of it?







First aid measures for eyes







First aid measures for skin







First aid measures for ingestion & inhalation







Control measures & PPE







Ventilation needed







Fire fighting measures







Additional Information






Evidence 3

COSHH Risk Assessment




Level 1 – Significant Risk






Name of substance







What is it used for?







Hazardous Ingredients







How often is it used?







Who uses it?







How much is used







Nature of risk







How do you store it?







How do you dispose of it?







First aid measures for eyes







First aid measures for skin







First aid measures for ingestion & inhalation







Control measures & PPE







Ventilation needed







Fire fighting measures







Additional Information






Evidence 4

COSHH Risk Assessment


Level 2 – Moderate Risk




Name of substance
LATEX GLOVES




What is it used for?
Clinical Procedures, Decontamination Procedures




How often is it used?
Every day




How much is used
Changed for each patient contact




Nature of risk
  • Immediate hypersensitivity reactions from latex, and delayed hypersensitivity reactions from residual chemicals.
  • Irritant (non-specific) contact dermatitis- skin damage from chemical irritants in gloves or handwashes. Worsened by physical irritations (glove powder or frequent washing/drying) and inadequate drying
  • Delayed (Type IV) – T-lymphocyte mediated, due to chemical residues in gloves or handwashes
  • Immediate (Type 1) – IgE response, often due to latex proteins. Occurs quickly, localized redness and itching (urticaria) and swelling (oedema). Severe reactions could cause anaphylaxis




How do you store it?
In original packaging. Avoid extremes of heat and keep out of direct sun




First aid measures for eyes
Irrigate thoroughly with water. Seek medical attention if mucous membranes affected




First aid measures for skin
Remove gloves immediately and wash affected part with saline water. If there is no relief, seek medical attention. If a reaction to this product is experienced its use should be discontinued immediately and medical attention sought. Once such a reaction is experienced do not continue wearing a latex glove until a latex protein allergic reaction has been ruled out.




Control measures & PPE
  • Non-latex gloves should be used as preference (Nitrile or Vinyl) to reduce latex proteins in the environment
  • If latex gloves used, these should be powder-free gloves with low extractable protein levels (<50μg/g), low in residual chemicals and powder-free
  • Hands should be washed after removing latex gloves. Barrier creams should not be used in conjunction with latex gloves as they may increase the penetration of the allergens




Fire fighting measures
Extinguishing media suitable to cause of fire and surroundings
No fire or explosion hazards are associated with these products. They will melt at elevated temperatures.




Additional Information
Data sheets for several product lines available







Level 2 – Moderate Risk




Name of substance
UNOGUARD




What is it used for?
Impression disinfection




Hazardous Ingredients
Potassium peroxomonosulphate
Sulphuric acid monododecyl ester
Isodecanpolyethylenegylcol




How often is it used?
Daily




Who uses it?
Nurse, Dentist, Therapist, Hygienist




How much is used
2 litres of solution, replaced daily or when visibly soiled




Nature of risk
Irritating to shin and eyes




How do you store it?
Keep tightly closed in original container, avoid dust formation




How do you dispose of it?
Wipe up solution with absorbent towel and dispose of in general waster
Collect powder spillage and dispose of in clinical waste
Dispose of empty container in general waste




First aid measures for eyes
Flush immediately with plenty of water, seek medical advice




First aid measures for skin
Wash off immediately with plenty of water




First aid measures for ingestion & inhalation
Rinse mouth immediately with plenty of water. Seek medical advice. DO NOT induce vomiting




Control measures & PPE
Impermeable gloves, safety goggles




Ventilation needed
Background ventilation




Fire fighting measures
Foam, powder, water or CO2 suitable




Additional Information
Data sheet available








Level 1 – Significant Risk






Name of substance
PORCELAIN ETCH






What is it used for?
Acid etching solution for ceramics






Hazardous Ingredients
Hydrofluoric acid






How often is it used?
Infrequently






Who uses it?
Dentist, nurse






How much is used
>1ml






Nature of risk
Corrosive, Very Toxic






How do you store it?
Keep tightly closed in a cool place
Will attack glass and most ceramics. May attack some metals. Handle with PPE in well ventilated area






How do you dispose of it?
Rigid sealed plastic container (sharps bin)






First aid measures for eyes
Remove contact lenses before flushing. With eyelids held open, flush immediately with lukewarm water for at least 15 minutes. DO NOT use an eye ointment. Apply 1-2 drops of Calcium Glyconate. If a physician is not immediately available, apply one or two drops of 0.5% Pontocaine Hydrochloride solution.






First aid measures for skin
Flush skin with large amounts of water and remove contaminated clothing, watches, etc. Seek medical attention for all burns, regardless of how minor they may seem






First aid measures for ingestion & inhalation
DO NOT INDUCE VOMITING -SEEK MEDICAL ADVICE IMMEDIATELY Rinse mouth thoroughly and give large amounts of milk or water if person is conscious. After ingestion of fluorides, give milk or Calcium Gluconate orally.
Transport to hospital if there is any suspicion of ingestion






Control measures & PPE
Always wear protective eye wear. Wear suitable protective clothing and gloves






Ventilation needed
Use only in a well ventilated area






Fire fighting measures
General: Evacuate all personnel; use protective equipment for fire-fighting. Use self-contained breathing apparatus when the product is involved in fire.






Additional Information
Data sheet available







Level 2 – Moderate Risk




Name of substance
Etching Gel / Acid Etch




What is it used for?
Etching enamel and dentine




Hazardous Ingredients
Phosphoric acid




How often is it used?
Daily




Who uses it?
Dentist, Hygienist, Therapist, Nurse




How much is used
>1ml




Nature of risk
Corrosive




How do you store it?
Store in a tightly closed container at room temperature. Avoid strong bases and metals, moist air or water




How do you dispose of it?
Used medication containers for incineration




First aid measures for eyes
Immediately flush with plenty of water. After initial flushing, remove any contact lenses and continue flushing for at least 15 minutes. Have eyes examined and tested by medical personnel




First aid measures for skin
Wash with soap and water. Get medical attention if irritation develops or persists




First aid measures for ingestion & inhalation
If swallowed, do NOT induce vomiting. Give victim a glass of water or milk. Call medical assistance immediately. Never give anything by mouth to an unconscious person




Control measures & PPE
Eye protection, suitable protective clothing, gloves




Ventilation needed
Use in a well ventilated area




Fire fighting measures
General: Evacuate all personnel; use protective equipment for fire-fighting. Use self-contained breathing apparatus when the product is involved in fire




Additional Information
Several data sheets available listed under ‘Etching Gel’






Level 1 – Significant Risk




Name of substance
LEGIONELLA & WATER-BORNE ORGANISMS




Hazardous Ingredients
Organisms present in Dental Unit Water Lines (DUWL) and in hot and cold water systems




Who uses it?
All team members, patients, visitors, contractors




Nature of risk
Biohazard




Water supply, storage and distribution must comply with Approved Code of Practice L8
  • Written Scheme
  • Risk Assessment
  • Operational Plan (schematics, operational instructions, emergency procedures)
  • Training




DUWL
The water lines on Castellini equipment present a risk of micro-organism contamination and transmission. All units must be maintained according to the guidance in the Surface & Equipment Decontamination Policy. The system must be drained and cleaned daily, all water bottles must be left empty and inverted to dry overnight. Disinfection of water lines using Perasafe must be carried out at the start of each day.
NOTE: Perasafe has a COSHH Group 2 risk assessment. See the relevent Risk Assessment sheet and associated COSHH Data Sheet before using this product

Hot


Cold Water Supply
  • The practice supply should conform to Water Supply (Water Fittings) Regulations 1999 and other relevant legislation
  • Water temperature should equilibrate below 200after 2 minutes of draw-off
  • Any tap or outlet used infrequently should be flushed through once a week




Hot Water Supply
  • Water temperature should equilibrate to at least 500C after 1 minute of draw-off
  • Any tap or outlet used infrequently should be flushed through once a week




Contingency Procedures
  • The practice should carry sufficient supplies of fresh distilled or RO water to enable instrument decontamination to continue for the remainder of the day in the event of power failure
  • Power failure resulting in hot water temperatures falling below 500C will require the system to be shut down
  • Loss of mains supply will create hygiene issues for patients and staff WC’s/washroom and will result in shutting the practice until supply is regained





Level 2 – Moderate Risk


Name of substance
MERCURY, ENCAPSULATED


What is it used for?
Amalgam restoration


How often is it used?
Daily


How much is used
Capsules


Nature of risk
Toxic by inhalation.
Danger of cumulative effects


How do you store it?
Original packaging, stored in a dry place at room temperature


First aid measures for eyes
Protective eyewear


First aid measures for skin
Gloves


First aid measures for ingestion & inhalation



Control measures & PPE
Protective gloves and eyewear worn
Mercury spillage kit available
Check the amalgamator from time to time to ensure capsules have not leaked during the mixing process.
Used amalgam capsules are a source of mercury vapour and as such should be stored as mercury / amalgam waste and collected for disposal by a licensed company.


Ventilation needed
Adequately ventilated clinical rooms to ensure airborne concentrations are within the occupational exposure limit


Fire fighting measures
Breathing apparatus, protective clothing – toxic fumes


Additional Information
Data sheets available for several amalgam manufacturers
Spillage should be controlled and collected using Mercury Spillage kit:
  • Collect globules of mercury together with brush supplied
  • Remove as much as possible using syringe supplies
  • Place in waste container supplied
  • Sprinkle sulphur powder on remaining spillage, bush into scoop supplied, place in waste container
  • Decontaminate area using equal parts CaOH/Sulphur mixed with tepid water and applied with a mop to effected surfaces
See Mercury Spillage Kit data sheet and instructions held inCOSHH_Data Sheets on the intranet