Responsibility for health and safety
The persons with overall responsibility for health and safety at hygeia are:
Neil Phillips – Practice Director – has overall responsibility for health & safety.
Joanne Giddy – Clinical Director – responsible for clinical health & safety matters (ie anything relating to the treatment of patients in the surgeries).
Any questions or concerns about health and safety should be directed to Joanne Giddy or Neil Phillips.
Neil Phillips has responsibility for reporting in accordance with RIDDOR (the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013). These rules require us to report certain matters to the Health and Safety Executive. These include death and serious injuries to people at work or members of the public and includes any injury that keeps a person off work for over 7 days. There is also a list of occupational diseases that must be reported; such as occupational dermatitis, occupational asthma or carpal tunnel syndrome. “Dangerous occurrences” include things like explosions, collapse of a building and so on. Detailed guidance is available on the Health and Safety Executive website.
While overall responsibility for health and safety rests with Joanne Giddy and Neil Phillips, all personnel have a responsibility to act in a safe manner. Everyone must have regard to their own safety and the safety of those around them. A resume of these responsibilities (and other matters relating to health and safety law) is on display in the staff room.
This general risk assessment is conducted and reviewed/updated by Neil Phillips. This is done at least annually and more often when significant changes occur either in the workplace or working practices.
Hazard: Discomfort caused by inadequate welfare provision: NOT A SIGNIFICANT HAZARD.
Risk: In view of facilities provided and practice history: LOW RISK.
Hazard: Food poisoning caused by spoiled food and drink as a result of inappropriate storage : MODERATE HAZARD.
Risk: In view of precautions taken: LOW RISK.
Breaks: Team members take adequate breaks in accordance with the working time directive.
Rest facilities: There is a designated staff room and a picnic bench and other seating outside for summer use.
Drinking water: There is a supply of tap and bottled water in the staff room.
Other drinks: There are facilities to make hot drinks in the staff room and the practice provides tea, coffee, milk, fruit squash, hot chocolate and other beverages.
Food: There is a supply of snack food in the staff room – the practice provides fruit, cheese, crackers and other foods.
Food and drink storage temperature control: Food and drink that are temperature-sensitive and require storage in a cool environment in order to maintain their shelf-life are stored in a fridge in the staff room (eg milk, cheese). This fridge is fitted with a calibrated high-low thermometer. The temperature readings are checked and recorded every day that the practice is open. Any anomalous readings are investigated and appropriate action taken – which may include re-setting the thermostatic control, repairing or replacing the fridge itself and quarantining or disposing of stock where necessary. The thermometer is re-calibrated annually.
Toilets: There are separate male and female toilet facilities.
Hand washing: There are hand washing facilities with soap and disposable hand towels in the staff room, toilets and surgeries. In the surgeries there is also an alcohol based hand wash.
Temperature: The building is fitted with climate control systems that heat the practice in winter and cool it in summer, producing a comfortable working environment at all times. The filters are cleaned and the units are serviced and maintained by engineers every 6 months to ensure efficient operation (refer to Testing, Maintenance, Audit & Compliance Schedule in the Reception Document Database). Wall thermometers are placed in all areas to verify that air temperatures are acceptable in accordance with the Workplace (Health Safety and Welfare) Regulations 1992. Additional portable electric heaters are available in the winter if team members request them.
Problems and issues: There have been no problems or issues in relation to general welfare arrangements since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible exposure to ionising radiation: SIGNIFICANT HAZARD.
Risk: In view of precautions, testing and monitoring: LOW RISK. Refer to separate local rules and radiography risk assessment for full details.
Problems and issues: There have been no problems or issues in relation to radiation since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible exposure to Legionella bacteria: SIGNIFICANT HAZARD.
Risk: In view of precautions, testing and monitoring: LOW RISK. Refer to separate written scheme for full details. Legionella risk assessment is performed every 2 years plus in certain other circumstances, such as alterations to the water system – refer to Testing, Maintenance, Audit & Compliance Schedule plus original assessment documentation in the Reception Document Database.
Problems and issues: There have been no problems or issues in relation to Legionella since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible exposure to toxic free mercury and release of same into the environment – SIGNIFICANT HAZARD.
Risk: Use of mercury in placement of amalgam fillings now discontinued but amalgam waste still produced during removal of existing restorations – in view of precautions taken: LOW RISK
Discontinuance of use: Several European countries have already banned the commercial use of mercury, including the placement of amalgam fillings. The EU has set out detailed plans for the phasing out of mercury use by 2030. The new UN treaty on mercury use has set out plans for a gradual phasing out of mercury in all industries, but does not yet impose a total ban on its use in dental amalgam (though a partial ban, including on its use in pregnant and breastfeeding women and in children, is already in force in the UK). The reason for this concern over the use of mercury in dentistry is the potential environmental damage caused by free mercury when it is released from amalgam fillings post-mortem during cremation NOT concern for the safety of amalgam as a dental restorative material per se. Nonetheless, in anticipation of an eventual complete ban we discontinued the use of dental amalgam (and, therefore, mercury) at hygeia in November 2010. Procedures for dealing with waste amalgam will remain in place since waste amalgam will still be generated during removal of pre-existing amalgam restorations. However, free mercury spillage is no longer possible, so the spillage kit has been removed. Also, urine analysis has been discontinued: during many years of monitoring we have not recorded any significant levels of mercury in urine samples supplied by clinical staff, and now that the placement of new amalgam fillings has ceased the risk of exposure has further reduced, so routine urine analysis has also been stopped.
Spillages: Defunct with effect from November 2010. A special mercury spillage kit is kept in surgery 1. Dr Giddy and Mr Phillips are familiar with it and its use. Surfaces where any spillages may occur in the surgeries are impermeable and smooth – in particular the amalgamator machine sits in a foil-lined tray to assist in the detection and removal of any spillages. We have minimised the risk of spillages by switching from a traditional mercury/amalgam mixing system (which involves handling free liquid mercury) to an encapsulated amalgam system. The amalgamator machine is checked every 6 months for signs of internal and external mercury contamination (refer to Testing/Maintenance/Audit Schedule in Hygeia Document Database).
Ventilation: Defunct in relation to mercury, but still relevant for general health/infection control reasons. Both surgeries were fitted with an automatic ventilation system in 2000. This operates whenever the lights are switched on. The system complies with BDA recommendations on ventilation. The system is tested annually weekly to ensure that it is working correctly (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database).
Monitoring: Defunct with effect from November 2010. All clinical staff are monitored for evidence of excessive occupational exposure to mercury. Urine samples are sent to the UK Mercury Screening Service once a year. A level of <10µmols Hg/mol Creatinine is acceptable (refer to Testing/Maintenance/Audit Schedule in Hygeia Document Database).
Training: All new clinical staff receive training in handling dental amalgam and correct disposal of associated amalgam waste (refer also to the practice waste disposal policy for further information).
Problems and issues: There have been no problems or issues in relation to mercury since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Sharps, inoculation injuries and immunisation
Hazard: Possible transmission of disease from an infectious patient to others: SIGNIFICANT HAZARD.
Risk: In view of precautions and testing: LOW RISK.
Disposal of contaminated sharps: All sharps are placed into special sharps boxes immediately after use. New wall-mounted sharps containers have now been introduced in both surgeries. These have been placed even closer to the point of use, allowing the operator who uses the sharp to dispose of it themselves without the need for it to be handled by a second person (eg the dentist need not rely on their nurse to remove and dispose of the sharp). Used sharps containers (these are never filled to more than two-thirds full) are stored in the lockable clinical waste bins until they are collected for safe disposal. Refer to the Waste Disposal and Infection Control policies for full details.
Procedure for inoculation injuries: Refer to the practice Infection Control policy for full details. The inoculation injury procedure is also displayed in the surgeries adjacent to the sharps disposal point.
Personal Protective Equipment: The practice routinely uses examination gloves, heavy duty gloves, face masks and safety glasses to help prevent inoculation injuries. Clinical staff are also issued with special surgery footwear that has hard toe-caps to prevent injury to the feet caused by dropping sharps. Refer to the practice Infection Control policy for full details.
Computer Controlled Local Anaesthetic Delivery System (“The Wand”) The Wand was introduced at the practice in November 2017. It is not a “safer sharp” system. Nonetheless, we take the view that NOT to use The Wand would compromise patient care because it denies patients the benefits of The Wand’s profound and reliable anaesthesia while also avoiding unwanted collateral soft tissue numbness. It’s use is therefore justified pursuant to regulation 5(1)(b) of the Health and Safety (Sharp Instruments in Healthcare) Regulations 2013: “The 2013 Regulations”.
In order to reduce risks associated with the use of a non “safer sharp” system, we have implemented a safer system of working by placing sharps bins into wall mounts immediately adjacent to where the sharps are produced so that the operator (ie the dentist) who uses the sharps (in particular, The Wand handpieces with their integral needle) can dispose of them immediately themselves rather than leaving them for another team member (ie the nurse) to clear away, eliminating multiple handling of sharps and, therefore, greatly reducing the risk of a sharps injury. We have also introduced additional information on sharps disposal adjacent to the point of use in each surgery and now operate a system of repeat training in sharps handling.
The Wand’s handpieces are re-sheathed after use. This is usually prohibited under regulation 5(1)(c) of the 2013 Regulations. However, this is essential when using The Wand in order to eliminate the risk of sharps injury posed by leaving an unsecured/unsheathed Wand handpiece on a surgery work surface. The cap of the handpiece is securely held in the base of The Wand machine itself and so becomes a safe holder for the entire handpiece and the connected tubing after use and pending disposal. Were the handpiece and its tubing not so secured and re-sheathed, they would pose a risk to persons in the vicinity. Also, holding the handpiece securely and safely allows the tubing to be detached from the machine and for the operator to safely handle the handpiece when disposing of it. Re-sheathing is a single-handed process that minimises risk to the operator.
Disposable safety syringe system: Where The Wand is not the preferred anaesthetic delivery system, the practice uses a disposable safety syringe system called “Safety Plus” (rather than a disposable needle system) to help prevent needlestick injuries. Indeed, since the introduction of the Safety Plus system in 2000 there have been no reported needlestick injuries. Refer to the practice Infection Control policy for full details.
Safety scalpel system: With effect from 27th January 2016, the practice has introduced a new “Safety Scalpel” for use in surgical work. These scalpels have a sliding, lockable safety cover that allows the user to safely cover the blade before disposal of the scalpel, eliminating the need for re-sheathing and reducing the risk of inoculation injury during disposal. There have been no recorded incidents involving scalpel injuries but we have decided to adopt these since they are now considered best practice.
Immunisation: All clinical staff are required to be immunised against Hepatitis B and Tuberculosis. Refer to the practice Infection Control policy for full details.
Problems and issues: There were a number of needlestick incidents after November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice and implemented an accident reporting system. None involved a high risk patient and no staff were infected as a result. Nonetheless, the Safety Plus disposable syringe system was introduced in 2000 and there have been no reported needlestick injuries since. Introduction of The Wand and our new safer system of working has not caused any additional sharps injuries to occur. Since this risk assessment was last reviewed there have been no recorded sharps injuries.
Decontamination, disinfection, sterilisation and hand hygiene
Hazard: Possible transmission of disease from an infectious patient to others: SIGNIFICANT HAZARD.
Risk: In view of precautions and testing: LOW RISK.
Equipment & procedures: The practice operates a comprehensive Infection Control policy (qv) and decontamination/sterilisation equipment is tested, validated and maintained in accordance with the manufacturer’s recommendations and HTM01-05 (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database).
Hand hygiene: New clinical staff are trained in proper hand hygiene and hand washing as part of their induction process. In 2014, we started giving repeat training in hand hygiene to clinical staff on a biannual basis. Notices setting out correct hand-washing procedures are displayed at the hand wash basins in each surgery. Soap is available at all wash basins. Alcohol based hand wash is used in the surgeries. The surgeries were fitted with “no-touch” soap and alcohol gel dispensers in January 2015. Re-usable towels are NEVER used at the practice – only paper towels are available. Refer to the practice Infection Control policy.
Problems and issues: There have been no problems or issues with decontamination, disinfection, sterilisation or hand hygiene since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible injury, poisoning, infection, etc from hazardous substances: SIGNIFICANT HAZARD.
Risk: In view of precautions: LOW RISK.
COSHH assessment procedure: It is the responsibility of the Practice Director to assess all potentially hazardous substances at the practice. This is done by examining the practice premises, the list of substances used and relevant Safety Data Sheets; feedback from team members (in particular at team meetings and from the Clinical Director – Joanne Giddy); consideration of policies, procedures and working practices; consideration of the Health and Safety Executive’s guidance on COSHH and risk assessment generally; and consideration of the advice published by the British Dental Association on risk assessment and COSHH. When complete, the results of the COSHH assessment and any updates/reviews are discussed at a team meeting and published on the practice website.
Other risk assessments: Various other risk assessments are also relevant to the Control of Substances Hazardous to Health (COSHH) Regulations 2002. For example, mercury is dealt with above in its own section. The practice Waste Disposal Policy and Infection Control Policy contain detailed instructions on safe disposal and handling of various substances. The storage of hazardous substances is also dealt with in the section titled “Storage of drugs and dental supplies”, below.
Substances potentially hazardous to health in our workplace: There are a number of substances in our workplace that may pose a hazard to health. These include:
- Bodily fluids – in particular saliva and blood – released in the course of providing dental examinations and treatment to patients; and which may contain bacteria, viruses, etc that could cause infections in others. These may be in a liquid form on contaminated instruments, gloves, tissue or cotton products, etc; they may also be thrown from the patient during treatment (known as “dental spatter”), posing a risk of inoculation to team members via the eyes, nose, mouth or open wounds; they may also be contained in aerosols produced during treatment that may be inhaled.
- Chemicals and materials used in the provision of dental treatment – for example, hypochlorite used to irrigate canals during root canal treatment. The mechanisms of exposure are the same.
- Chemicals used in infection control – such as detergents and disinfectants. Again, skin contact, splashes and inhalation are the main routes for exposure.
- Compressed gases – such as butane used for our Bunsen burner or oxygen kept as part of the emergency resuscitation equipment. These are mainly a risk as they pose an explosion hazard and this is primarily a storage issue (see below).
Persons at risk: Patients and team members alike are at risk of harm from the transmission of infection and also possible skin irritation, burns, eye injuries or poisoning from hazardous chemicals when not correctly handled.
Safety Data Sheets (SDS): A full inventory is kept of substances in use at the practice (refer to Surgery Consumables Stock List in the hygeia document database). A collection of SDS relevant to these substances is also maintained and is available to all team members working with these potentially hazardous substances (refer to reception computer desktop – COSHH folder). These sheets have been considered by Neil Phillips in the course of conducting each COSHH assessment.
Personal Protective Equipment: Only clinical staff are required to use or handle hazardous substances in the course of their duties and they already use gloves, masks and eye protection for infection control purposes which also provide protection from hazardous chemicals. They also use heavy-duty gloves and plastic aprons during decontamination procedures while handling cleaning and disinfection chemicals. These items of PPE also provide protection against infection from bodily fluids.
Ventilation: Refer to section on “Mercury”, above.
Monitoring: Refer to section on “Mercury”, above.
Dental Unit Water Lines (DUWLs): In order to reduce the risk of accumulated bacteria and viruses (in particular, Legionella) contaminating the micro-bore tubing inside DUWLs and forming potentially harmful biofilms inside the equipment, the practice uses a bottled water system and water used in the dental units is treated with the Alpron system (refer to the Infection Control Policy).
Discontinuance of use: A number of materials are no longer used at our practice in order to reduce risks to patients and staff. These include powdered examination gloves, latex gloves, latex rubber dam, latex polishers (ie those used by the hygienist for tooth polishing), x-ray developer, x-ray fixing solution, lead foils from x-ray film packets and mercury. At present, there are no other potentially hazardous substances that we use in the course of our work that we can discontinue (as at August 2018).
Substitution: In the past, a number of potentially hazardous substances have been substituted in order to reduce risk. One example is mercury. Prior to complete discontinuance of its use in 2010, the practice moved from the use of amalgamators (which mix liquid mercury with a powder to produce mercury amalgam) to encapsulated amalgam (which affords a completely contained/isolated mixing process) in order to reduce the risk of exposure and spillage. At present, there are no further substitutions we are aware of that we could make in order to reduce risks (as at August 2018).
Training: All new clinical staff receive training in COSHH procedures as part of their induction training and repeat training regarding COSHH is also given to existing team members.
Storage: See “Storage of Drugs and Dental Supplies”, below.
Consultation with team members: COSHH is discussed with team members at monthly team meetings. This provides an opportunity for Neil Phillips and Joanne Giddy to inform the team about changes that may affect their work and COSHH practices; the team is also asked for feedback about any matters relevant to COSHH.
Outcome of latest assessment: The conclusion of the most recent assessment (19.8.2018; previously 30.8.2017, 4.8.2016, 4.5.2015, 17.5.2014, 20.3.2013, etc) is that the existing precautions, training, equipment, monitoring, etc are adequate to ensure that exposure to potentially hazardous substances is as low as is reasonably practicable.
In particular, any substances that can be removed from use have been and those that remain are essential for the provision of safe and effective dental care. Where substitutions are possible, they have been made. Potentially hazardous substances are safely stored, including compressed gases. Mechanical ventilation is in use in both surgeries and in the staff room and systems are tested weekly. Careful hand hygiene practice is a good control measure – there are dedicated hand hygiene stations in each treatment room, these are used routinely in infection control processes and personnel undergo induction training and bi-annual training in hand hygiene. Regular cleaning of the surgeries (as part of our infection control processes) and of the entire practice environment serve as a control measure against possible infection. Storage facilities are adequate – all potentially hazardous supplies are stored safely. Eye-wash and an eye-bath are available in the staff room, together with a fully stocked first aid kit, including dressings. Appropriate fire extinguishers are available in the work areas. A spillage procedure is set out in the Infection Control Policy (qv) and appropriate chemicals are available to deal with spillages. Face masks, eye protection, vinyl gloves, heavy-duty gloves and plastic aprons are in routine use and provide ample protection from the materials we use in our workplace aswell as the potential transmission of infection.
The most potentially hazardous chemical we use is mercury and staff are monitored to ensure they are not exposed to unacceptable levels; also, mercury handling has been changed to make it safer (ie switch to encapsulated system) and mercury amalgam use will cease from 2010. We ceased using mercury in 2010, which had previously been potentially the most hazardous chemical in use.
Problems and issues: There have been no problems or issues in relation to COSHH since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible electrocution caused by faulty electrical devices and installations: SIGNIFICANT HAZARD.
Risk: In view of precautions and testing: LOW RISK.
Portable appliances: Are tested every other year to ensure they are safe for use (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database). This had previously been annual.
Electric wiring: Is tested every five years to ensure that it is still safe for use (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database).
System design: The electrical system was checked and partially replaced/redesigned in 1999 to improve safety. All circuits are now protected by MCBs and all external lighting and power sockets are protected by RCDs. Circuits have all been properly identified and re-labeled.
Problems and issues: There have been no problems or issues in relation to electricity since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible injury caused by outbreak of fire: SIGNIFICANT HAZARD.
Risk: In view of precautions and testing: LOW RISK.
Competent Person: The Practice Director, Neil Phillips, is the Competent Person for the purposes of fire risk assessment and safety.
Risk Assessment: The Competent Person is responsible for reviewing and updating this Fire Safety Risk Assessment on a yearly basis as part of the annual general risk assessment process.
Dangerous & Flammable Substances: The practice keeps compressed oxygen for medical emergency purposes. This is stored inside a cupboard. All staff are instructed in its proper safe use. The cylinders are checked by a team member every day to ensure they are safely stowed and not damaged or leaking (and subject to a monthly double-check). They are also serviced or replaced by a trained engineer on an annual basis. We also keep a small “domestic-size” propane cylinder (the size of an aerosol can) to fuel the Bunsen burner/heat gun used for heating wax in the surgeries. This is also stored inside a cupboard. These substances are essential for the proper and safe operation of the practice so cannot be taken out of use. Team members are instructed to ensure that fire fighters are informed of the presence of these hazards in the event that they attend the premises. Bins are emptied every day to avoid a build-up of flammable material inside the building.
Smoking: Smoking is prohibited in the building and everywhere else on our site.
Electricity: All portable electrical equipment undergoes annual testing and the wiring system in the building is tested every 5 years (see section on “Electricity” above).
Pressure Vessels: We have two autoclaves (pressurised steam sterilisers) and an air compressor with a pressurised storage tank. These present an explosion risk in the event of a fire but are essential for the operation of the practice and cannot be removed. Team members are instructed to ensure that fire fighters are informed of the presence of these hazards in the event that they attend the premises.
Alarm system: The building is fitted with a fire and intruder alarm system. There are smoke detectors in each surgery, the reception/waiting area, the office and the staff room. The alarm system is connected to a monitoring service that summons the fire brigade in the event of a fire even if no one at the practice manages to call for assistance. The fire station is less than three minutes from here by road. The system is tested by a trained engineer every 6 months to ensure it is operating correctly and the smoke detectors are also cleaned every 6 months (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database).
Fire fighting equipment: Fire extinguishers are available in both surgeries and in the staff room (all three are Carbon Dioxide in view of likely electrical/chemical involvement in any fire) and also in the reception/waiting area and the office (both Foam for furnishings, carpets, etc). NB: The extinguisher in the office was added on 27th January 2016 on the advice of the engineer who visited to service the extinguishers and in order to comply with BS5306; the wall signs adjacent to each extinguisher were also replaced with luminous signs that are visible in the dark. The extinguishers are checked monthly to ensure they are correctly mounted and labelled and that they have not been damaged, discharged or tampered with. They are also tested annually by a trained engineer (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database).
Signage & exits: There is only one exit door. One exit in reception is sufficient since all other rooms open into reception. The entire building is on a single level with no upper floors, stairways, steps, lifts, corridors, etc. There is a fire exit sign in reception (which is luminous so that it can be seen in the dark) and a fire safety notice in the staff room which summarises the correct procedures to follow in the event of a fire and identifies the assembly point. The assembly point is clearly signed in the car park.
Fire Doors: In view of the nature of the building (ie it is very small, on a single floor and has all rooms opening into reception where the only exit is situated) there is no need for fire doors to be fitted. Fire doors are, in fact, fitted on each of the surgeries (treatment rooms) because they are made of a dense material that reduces sound transmission. These are fitted with door closers to control their closing speed because they are heavy. They are not in situ because fire doors were deemed necessary for fire safety purposes.
Vulnerable Persons: The most likely example of a vulnerable person in the context of the practice (with the risk of fire in mind) is a person with reduced mobility or a wheelchair user. Because the building is so small and on a single level with ramp access, no special arrangements are necessary. In the event of a fire, team members would simply assist such vulnerable persons to leave the premises in the same manner that they assist them when arriving at or leaving the building on any other occasion.
Evacuation Responsibilities: In the event of a fire evacuation, the person on duty at reception has responsibility for ensuring that everyone in the building is alerted to the fire, that the fire brigade has been called (not simply relying on the alarm system to summon them) and that a roll-call is carried out at the assembly point to ensure that no-one has been left behind. This is because the person on duty at reception is best placed to know who is in the building at any given time and also has immediate access to the telephone. The person at reception is also responsible for ensuring that the practice cat is removed from the premises in the event of a fire.
Training: All new staff receive training in evacuation procedures, use of fire fighting equipment and operation of alarm systems. There is an ongoing annual training programme which includes fire practices.
Problems and issues: There have been no problems or issues in relation to fire since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Violence and Aggression
Hazard: Possible injury by violent or aggressive patients: NOT A SIGNIFICANT HAZARD.
Risk: In view of history of practice: LOW RISK.
Precautions: Although there has never been a problem with this, the reception desk is fitted with a personal attack button linked to the intruder alarm system that can be used to summon help in an emergency. Lone working is infrequent. When it occurs the lone worker is instructed to lock the entrance door and not to allow anyone into the building unless they know who they are. Refer also to the practice’s policy on violence and aggression.
Training: All new staff receive training in operation of the alarm system and personal attack button. Reception staff are instructed that if they are threatened and money is demanded, they are to hand over the money and not attempt to tackle a criminal themselves.
Problems and issues: There have been no problems or issues in relation to violent or aggressive patients or intruders since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Prosecution of the Practice owners for failing to prevent the payment of bribes or use of inducements by employees to gain financial or other advantage for/on behalf of the Practice: SIGNIFICANT HAZARD.
Risk: In view of the nature of our business: LOW RISK.
Legislation: Under the Bribery Act 2010 organisations may be held responsible for allowing persons (eg their officers and employees) to use bribes on their behalf. A statutory defence is available to such charges provided that the organisation has carried out a risk assessment and implemented appropriate policies and procedures to minimise the risk of bribery on its behalf.
Nature of our business: The nature of an organisation’s business and the industry sector that they operate in can make bribery more likely. Dentistry and healthcare are not, to our knowledge, industries recognised as high-risk for bribery purposes. It is, in fact, very difficult to imagine any set of circumstances where anyone in our organisation could ever use bribery as a means to procure some financial or other benefit for us.
Geographical risk: We do not trade overseas, nor with overseas interests, and so are not exposed to high-risk environments for bribery purposes.
Employee risk: All financial transactions are controlled and monitored closely by the Practice Director. Bank accounts, for example, are checked every day for unusual activity and no-one else has access to cheque books, payment cards or online/telephone banking facilities. We do not hold other assets or high-value goods that could be offered as a bribe. It is, therefore, impossible to imagine any team member having access to the means to commit a bribery. Even if they somehow did manage to access Practice resources for this purpose it would be detected immediately. In any event, we are unable to imagine a reason why they might attempt to bribe someone. Finally, all incoming text communications arriving at the practice either on paper (eg by post) or electonic media (eg email, SMS) are opened and read by the Practice Director regardless of who they are addressed to or whose attention they are marked for (refer to Data Protection Privacy Notice). This means that it is impossible for anyone to communicate with a third party by “official channels” without this being discovered by the Practice owners.
Anti-bribery measures: In view of the outcome of this risk assessment, no additional policies or procedures need to be implemented.
Problems and issues: There have been no problems or issues in relation to bribery since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Tripping and Slipping
Hazard: Possible injury from falls as a result of slips or trips: SIGNIFICANT HAZARD.
Risk: In view of precautions: LOW RISK.
Internal flooring: Clinical areas and washrooms are fitted with Altro Walkway non-slip floor coverings. Other indoor areas are fitted with heavy duty commercial contract carpeting specially designed for healthcare settings. There are no stairs, steps, sills or slopes inside the building.
Staff are instructed not to walk on wet floors after they have mopped them – and, therefore, to leave mopping the surgery floors until the very last job before they leave each day – refer to infection control checklist 2. The clinical team are no longer responsible for mopping surgery floors and so this is no longer a concern for them, this task being handled out-of-hours by the environmental cleaning contractors.
Furniture: Furniture in the building is arranged so as to provide easy access without obstructions in order to minimise the possibility of trips and falls and also to help people with visual impairments and wheelchair users to navigate safely.
Outside areas: The practice car park is flat and free from pot holes and obstructions. There is a concrete ramp leading to the front door. Pathways and approaches are broad, free from obstructions and benefit from flush (lowered) kerbs. The practice keeps a small stock of salt to treat the surface of the access ramp in icy weather.
External lighting: There are 21 external lights at the practice. They illuminate the exterior for both safety and security purposes. The system is controlled by a timer and light sensor so that the exterior and approaches are lit between 7.00am and 9.00pm (whenever it is dark at those times). The system will even switch the lights on during daylight hours if it suddenly becomes darker, eg where there is a storm. The system is also connected to motion detectors that turn the external lights on if someone approaches the building during the night between 9.00pm and 7.00am. These things assist with safe access and egress, particularly during the winter months and for people with visual impairments.
Footwear: Clinical staff are issued with special protective footwear that has a non-slip sole. This is to give added slip resistance if floors are wet.
Problems and issues: There has been only one incident in relation to slipping or tripping since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice. This incident (in January 1999) involved someone slipping on a wet surgery floor after they had mopped it. There was no significant injury. Since then the flooring in the surgeries has been replaced with Altro Walkway (which offers high slip-resistance even when wet). Staff were, at the time of this incident, already under standing instructions not to walk on wet floors (and therefore to leave this task until the very last of the day) – and had already been issued with non-slip footwear (see above). There have been no further incidents and the clinical team are no longer required to wet mop the surgery floors at the end of the day – this task is now done by our environmental cleaning contractors.
Hazard: Possible injury and/or infection from contaminated waste: SIGNIFICANT HAZARD.
Risk: In view of precautions: LOW RISK.
Waste disposal policy: The practice has a comprehensive waste disposal policy that deals with correct handling and disposal of all the different types of waste we produce. Refer to the policy document for full information.
Training: All new clinical staff receive training in waste disposal procedures as part of their induction training.
Problems and issues: There have been no problems or issues in relation to waste disposal since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible injury or harm to cleaning staff caused by chemicals or equipment: SLIGHT HAZARD.
Risk: In view of precautions: LOW RISK.
Cleaning contractor responsible for own risk assessment: In February 2015 we engaged a new environmental cleaning company. They agreed to risk-assess their own operations here.
Training: Our cleaning contractor is responsible for training all their operatives in safe cleaning procedures.
PPE: Our cleaning contractor is responsible for ensuring that all their operatives use hand and eye protection where appropriate.
COSHH: Our cleaning contractor is responsible for selecting and supplying appropriate and safe chemicals for use by its operatives.
Equipment: Our cleaning contractor is responsible for selecting and supplying appropriate and safe equipment for use by its operatives.
Problems and issues: There have been no problems or issues in relation to cleaning personnel since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible injury from defective or incorrectly operated equipment: SIGNIFICANT HAZARD.
Risk: In view of precautions, testing and monitoring: LOW RISK.
New equipment: It is the responsibility of the Practice Director, Neil Phillips, to ensure that all new equipment purchased is suitable for its intended use, bears appropriate CE (or equivalent) marks, is functioning correctly and is decontaminated or sterilised (as appropriate) prior to first use. Records of new equipment purchases (in the form of invoices and other purchase documentation) are maintained as part of the routine financial records. A library of operators’ guides and maintenance manuals are kept in the office.
Testing, Maintenance, Audit & Compliance Schedule: The practice operates a comprehensive testing and maintenance regime. Autoclaves are serviced, tested, validated and have an annual pressure vessel inspection.
The compressor undergoes a pressure vessel inspection on a biennial basis. (This provision is now defunct since the new oil-free compressor has a much smaller tank and does not require such certification under the pressure vessels regulations.) Ultrasonic baths are tested and validated on a weekly, monthly and quarterly basis. Electrical appliances and wiring are tested at biennial and 5-yearly intervals respectively (see above). Fire extinguishers are checked every month and tested annually by an engineer (see above). X-ray equipment is tested every 3 years, undergoes routine servicing every year and safety checks every 6 months (refer to the local rules and radiation risk assessment). The alarm system also undergoes testing every 6 months (see above). The water system is checked on weekly, monthly, biannual, annual and biennial basis (refer to practice Written Scheme on the Prevention of Legionella). Amalgam mixers are checked for mercury contamination.
Monitoring: For example, the temperature of water at all outlets is tested on a monthly basis to ensure that Legionella risk is appropriately managed; the Reverse Osmosis (RO) system is tested monthly with a Total Dissolved Solids (TDS) meter and the filters & membranes are replaced when appropriate; etc. For example, in addition to testing the x-ray equipment every 3 years, clinical staff are issued with personal dosemeters that are tested every 3 months. In addition to checking the amalgam mixing machines and other safety measures, clinical staff have their mercury levels monitored.
Training: All new clinical staff receive training in the use of all necessary equipment as part of their induction training.
Problems and issues: There had been no problems or issues in relation to defective or incorrectly operated work equipment between November 1998 (when Joanne Giddy and Neil Phillips took on responsibility for the practice) and December 2012. In December 2012, a workman injured his hand when a sweeping brush broke while he was using it to sweep the car park. This appears to have happened because the metal handle of the broom had rusted and weakened. The broom has been replaced with a new wooden one. The other tools in use outdoors have been checked and are satisfactory. We now ensure that persons working outdoors at the practice wear heavy-duty gloves.
First aid and medical emergencies
Hazard #1: Possible worsening of injury by inadequate first aid facilities: SLIGHT HAZARD.
Hazard #2: Possible harm to patient suffering medical emergency or collapse during treatment: SIGNIFICANT HAZARD.
Hazard #3: Potential vulnerability of emergency drugs and equipment to tampering/unauthorised use: SIGNIFICANT HAZARD.
Risk #1: According to our own accident records, injuries are rare and have always been minor – eg small cuts, abrasions, etc. Significant precautions are also taken to avoid injury (eg our Risk and COSHH assessments, PPE, training, etc.) so the risk is assessed as: LOW TO MEDIUM RISK.
Risk #2: Patient medical emergencies are extremely rare in dental practice. Significant precautions are also taken so these problems are assessed as: LOW RISK.
Risk #3: In view of the inaccessibility of the emergency drugs and equipment to unauthorised persons and the daily, weekly and monthly checks we carry out, the risk is assessed as: LOW RISK.
Medical risk assessment/medical history taking: All patients are required to complete medical history questionnaires and these are verified verbally by the dentist or hygienist. These allow us to identify patients at particular risk so that we can take measures to reduce the chance of a problem arising.
Emergency drug kit: There is a fully stocked emergency drug kit kept in surgery 1. The contents are checked and, if necessary, replaced every day by the surgery staff and also weekly by non-surgery staff (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database). In accordance with GDC/Resuscitation Council guidance the kit contains GTN spray, a Salbutamol inhaler, adrenaline injections, aspirin, Glucagon injection (stored in the drug fridge to extend shelf-life), glucose and Midazolam; the kit also has a Laerdal pocket mask with oxygen port, a spacer for use with inhalers, a set of oropharyngeal airways in sizes 0, 1, 2, 3 and 4, disposable vinyl gloves and aprons, safety glasses and surgical tape.
AED and other resuscitation equipment: We also keep a Res-Q-Vac/Yankauer portable suction unit, an automated blood glucose measurement device, a pulse oximiter to measure heart rate and oxygen saturation, adult and child resuscitation bags (BVMs) with resuscitation masks in sizes 0, 1, 2, 3 and 4 plus a Defibtech Automated External Defibrillator with adult and paediatric pads, safe-cut scissors and disposable razors. These are checked every day to ensure that batteries are charged, electronics are functioning, etc (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database).
Emergency oxygen: There is a BOC Medical “Lifeline O2 Pro” emergency oxygen kit (including oxygen face mask, tubing, Hudson non re-breather mask, etc) together with a spare cylinder in surgery 1. Pressure gauges and oxygen flow are checked every day (we also monitor for possible leaks) and double-checked by the Practice Director every month, plus the cylinders are tested or replaced and the contents of the kit are checked and, if necessary, replaced every 12 months by a visiting BOC engineer (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database). The cylinders are type CD with a nominal capacity of 460 litres each and an adjustable flow rate of up to 15 litres per minute – sufficient to maintain a patient for over 90 minutes.
Vulnerability of emergency drugs and equipment: It is virtually impossible for a visitor to tamper with the drugs or equipment. We are a very small practice and know all our patients personally, so an unknown person would be immediately obvious. The drugs and equipment are safely stowed in a cupboard in surgery 1 behind the dentist’s work station. In order to tamper with this, a person would have to get past reception unnoticed, into the surgery and into the cupboard behind the dentist and her nurse, open the kit, tamper with the items, put the kit back again and leave undetected. One item – the glucagon – is stored in a drug fridge in the plant room. Again, it would be extremely difficult for someone to enter, pass through reception into the plant room without being seen, tamper with the drug (which they could not know would be there), put it back and leave again unnoticed. Even if such tampering or unauthorised use were to occur, we carry out checks of the emergency drugs and equipment on a daily, weekly and monthly basis, so this would be detected quickly and the affected drugs replaced: refer to Testing, Maintenance, Audit and Compliance records kept at reception.
Training: Clinical staff receive annual training in CPR, first aid procedures and defibrillator use.
First aid kit: There is a fully stocked first aid kit kept in the staff room. The contents are checked and, if necessary, replaced every month (refer to Testing, Maintenance, Audit & Compliance Schedule in Reception Document Database).
First-Aiders/Appointed Persons: There is no requirement for a small dental practice such as ours to have trained first-aiders in addition to the medical emergency training we undergo every year: refer to guidance from Dental Protection in 2009 (copy saved on the Office desktop and in the “Equipment Testing and Maintenance – Correspondence” folder of the hygeia document database). We are required to have an appointed person or persons for the purposes of first aid: these are Joanne Giddy and, in her absence, Neil Phillips. They are the people team members must contact immediately if someone is injured or falls ill. It is their responsibility to manage any incidents, to include calling an ambulance if required. It is also their responsibility to ensure that the first aid kit is properly stocked (see previous paragraph).
Practice location: The practice is located only a 3 minute drive from the nearest ambulance station meaning that professional assistance is quickly available.
Accident reporting: An accident report book is kept at reception. The Practice Director is responsible for compliance with RIDDOR and CQC reporting requirements.
Problems and issues: There have been no problems or issues in relation to first aid or medical emergencies since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible injury from sprains and strains when handling heavy or awkward items: SLIGHT HAZARD.
Risk: In view of precautions: LOW RISK.
Manual handling policy: The practice operates a simple manual handling policy. Staff are instructed not to move any large, heavy or awkward item at all unless they ABSOLUTELY HAVE TO. They are instructed that they must seek help from the Practice Director or Clinical Director if they are in any doubt about their ability to move an item safely. When deliveries are received the delivery person must always be asked to place the items in a convenient area so that large, heavy boxes can be unpacked without the need to move them again. Staff are not permitted to lift patients into or out of wheelchairs (though they are allowed to give assistance to patients and carers when requested, provided always that it is safe to do so). A small movable step is provided to help staff reach items stored at a high level and we try always to ensure that items are stored within easy reach. In reality this rarely poses a problem since ceilings in the building are low and there are few places where anything might be stored at high level.
Training: All new staff receive training in basic manual handling procedures as part of their induction training. They are given a demonstration in safe lifting – ie bending the knees rather than the back.
Problems and issues: There has been only one issue in relation to manual handling since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice. In 2004, Dr Giddy experienced mild back pain for several weeks after lifting a patient out of their wheelchair. We no longer do this and there have been no further problems.
Display Screen Equipment & workstations
Hazard: Possible injury from eye strain or muscular problems/RSI from poor posture: SLIGHT HAZARD.
Risk: In view of precautions, monitoring and practice history: LOW RISK.
Affected staff: The only staff affected by DSE safety issues are those whose work requires the use of DSE for continuous periods of an hour or more on most working days: Health and Safety (Display Screen Equipment) Regulations 1992. This means that the receptionist and the Practice Director are affected by these provisions. Dentists, hygeinists and nurses may also be affected if they routinely spend an hour a day or more on study, clinical record keeping or audit tasks: this means that Jo Giddy is also affected by the regulations (NB Jo was added to the list with effect from August 2018, though she had been working with DSE for periods of over an hour for some time before this).
Equipment selection: The practice has installed very large, high resolution flat screen LCD monitors that make it easy to read the text; also they do not flicker and have a very high refresh rate that helps reduce eye strain. Keyboards are provided with wrist supports and are inclinable to enhance comfort and reduce the risk of RSI. All areas where DSE is used has been fitted with CAT2 lighting to help reduce eye strain.
Workstation assessment: The Practice Director is responsible for workstation design and assessment. Indeed, he actually built the workstations at reception and in the office. Assessment is carried out annually in accordance with guidance published by the Health and Safety Executive and includes consideration of the comfort of the hands, wrists and forearms, seating position, legroom, size of work space, size of any screen, lighting and glare, etc. At the time of writing (August 2018) all workstations have been assessed as adequate.
Monitoring: All affected staff are reminded to arrange eye tests (cost reimbursed by the practice) at intervals determined by the optician. The normal intervals are either annual or biennial depending on the individual.
Problems and issues: There have been no problems or issues in relation to workstations and Display Screen Equipment since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Storage of drugs and dental supplies
Hazard: Possible injury or poisoning caused by unauthorised persons accessing medical supplies: SIGNIFICANT HAZARD.
Risk: In view of precautions and practice history: LOW RISK.
Hazard: Possible harm caused by medical supplies that have not been stored at an appropriate temperature and which have therefore degraded and become less effective/ineffective: MODERATE HAZARD.
Risk: In view of precautions and practice history: LOW RISK.
Storage: Almost all stocks of dental medicaments, anaesthetics and other dental consumables are stored in locked metal cabinets inside surgery 1. The locks on the cabinets prevents unauthorised access. A few dental medicaments/consumables are stored in a drug fridge in the staff room. This is not locked, but the items are not in a place where they can be seen by the public and are virtually impossible to access without being seen (see below – access). The Emergency Drug Kit, oxygen cylinders and AED are stored in a low-level cupboard immediately behind the dentist’s seat in surgery 1. This is not locked, but the items are out of view and are virtually impossible to access without being seen (see below – access). NHS prescription pads were kept in a locked cabinet but we no longer use pre-printed prescription pads so this is no longer an issue. We do not dispense prescription drugs and so there are no security issues associated with these.
Access: Dental supplies are almost all stored inside the surgery itself. The surgery is never left unattended. Even if the clinical staff were to leave the room there is always someone at reception with a clear view of anyone entering or leaving the surgery. It is therefore practically impossible for an unauthorised person to gain access. A few items are stored in the drug fridge in the staff room. There is always someone at reception when the practice is open with a clear view of anyone entering or leaving the staff room. It is therefore practically impossible for an unauthorised person to gain access.
Storage temperature control: Dental supplies that are temperature-sensitive and require storage in a cool environment in order to maintain their shelf-life are stored in the drug fridge in the staff room. This fridge is fitted with a calibrated high-low thermometer. The temperature readings are checked and recorded every day that the practice is open. Any anomalous readings are investigated and appropriate action taken – which may include re-setting the thermostatic control, repairing or replacing the fridge itself and quarantining or disposing of stock where necessary. The thermometer is re-calibrated annually.
Problems and issues: There have been no problems or issues in relation to storage of dental supplies since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Hazard: Possible injury from vibrating work equipment (in particular rotary dental handpieces): SLIGHT HAZARD.
Risk: In view of precautions and practice history: LOW RISK.
Overview: Occupational exposure to vibrating tools is regulated by the Control of Vibration at Work Regulations (2005). Employers have a duty to protect workers from injury caused by vibration. Weighted-vibration magnitudes for dental tools are so low that it would be impossible to breach the Exposure Action Value laid down in the Regulations. Nonetheless, a risk assessment is required and steps must be taken to minimise any exposure and, therefore, risk of injury: see BDJ vol 199 no 9 pp 575-577 “The European vibration directive – how will it affect the dental profession?” by N.J. Mansfield.
Equipment selection: The practice purchases only high-quality dental handpieces and motors from reputable manufacturers: W&H and Bien Air. These manufacturers are themselves required by law (under the European Medical Devices Directive 1993/44/EC) to reduce risks to users by designing and manufacturing safe equipment.
Testing, Maintenance, Audit & Compliance Schedule: The practice operates a comprehensive testing and maintenance regime. Any handpieces whose performance begins to decline are sent to W&H for service and repair, optimising their performance and minimising the vibration produced.
Exposure reduction: The person most at risk from vibration injury from rotary instruments is Jo Giddy. She works three and a half days a week, so her exposure to vibration risk is reduced compared with a practitioner working five days per week. It is not at present possible in practice to eliminate the use of vibrating instruments entirely, though we keep under review developments in laser technologies suitable for hard-tissue use which may one day supplant traditional rotary devices for some procedures.
Problems and issues: There have been no problems or issues in relation to vibration injuries since November 1998 when Joanne Giddy and Neil Phillips took on responsibility for the practice.
Web version 28: 19.8.2018
Previous web versions: 29.7.2006, 10.8.2006, 15.12.2006, 8.3.2007, 28.2.2008, 30.10.2008, 31.1.2011; 25.1.2012; 18.2.2012; 19.12.2012; 23.2.2013; 9.3.2013; 20.3.2013; 23.5.2013; 20.2.2014; 17.5.2014 (reviewed 20.6.2014); 25.6.2014; 18.7.2014; 21.2.2015; 26.2.2015; 4.5.2015 (reviewed 5.6.2015); 19.2.2016; 4.8.2016; 4.2.2017; 30.8.2017; 19.4.2018