Preventive action and early identification
This section outlines the legal context
for, and the methods of carrying out, risk assessments.
Legal background
More relevant
legislation
Preventive action
Identifying the cause of the
problem
Skin protection management
programme
Risk assessment
tools
Control measures
Monitoring exposure
Health
surveillance
Educating and training
employees
Reporting mechanisms
Legal background
All workplaces are covered by the Health and Safety at
Work etc Act 1974. This sets out the general duties that
employers have towards employees and members of the public, and the
duties that employees have to themselves and each other. The
employer should, so far as is reasonably practicable, protect the
health, safety and welfare of employees while at work.
The
Management of Health and Safety at Work Regulations 1999 (as
amended) gives more detail about the requirements under the
Health and Safety at Work Act 1974. These regulations place duties
on the employer to assess risks and, where necessary, to take
action to safeguard health and safety, including health
surveillance if appropriate.
Legal requirements when dealing with dangerous substances are
set out in The
Control of Substances Hazardous to Health (COSHH) Regulations 2002,
as amended 2004. The first requirement is to prevent exposure
(both inhalation and skin) to substances hazardous to health.
Employers must:
- carry out a risk assessment (regulation 6)
- make sure that exposure to hazardous substances is adequately
controlled (regulation 7)
- put in place appropriate control measures which are properly
maintained (regulations 8 and 9)
- monitor exposure in the workplace (regulation 10)
- carry out health surveillance (regulation 11)
- provide information, instruction and training to employees
exposed to hazardous substances (regulation 12).
Guidance on how these can be achieved is in the accompanying
Approved Code of Practice, which is available as a priced
publication from the HSE.
A brief guide to the
regulations by the HSE gives a good introduction to
COSHH.
The new European Union (EU) chemicals regulation, REACH
(Registration, Evaluation, Authorisation and restriction of
Chemicals) was brought into force on 1st June 2007 by the European
Commission (EC). Under REACH, chemical manufacturers and importers
are responsible for the identification and management of the risks
associated with their substances. A major element of REACH is
the requirement for manufacturers and importers of substances
(either on their own, in preparations or articles) in annual
volumes of ≥ 1 tonne to register them with the European Chemicals
Agency (ECHA), with un-registered substances becoming illegal to
manufacture, supply and use. Some substances are exempt from
these regulations, which mainly include; waste, radioactive
materials, substances under customs supervision. non-isolated
intermediates, substances being transported and some naturally
occuring low-hazard substances. Registration is phased over a
number of years based on the manufactured/imported quantities and
toxicity of the substances. Further information on complying with
REACH is available from the ECHA and HSE websites.
A key aspect of REACH is the requirement for manufacturers and
importers of substances to communicate down the supply chain how
their substances or preparations can be used safely, through
provision of a Safety Data Sheet (SDS). SDS, previously
covered under the Chemicals (Hazard Information and Packaging for
Supply) Regulations (CHIP), will continue to contain information on
the hazards of the substance or preparation and the recommended
risk management measures.
The
Chemicals (Hazard Information and Packaging for Supply) Regulations
2009 (CHIP4) require the suppliers of dangerous chemical to
identify the hazards of the chemical and communicate them to their
customers. The regulations also require the chemicals to be
packaged safely.
More relevant legislation
The
Workplace (Health, Safety and Welfare) Regulations
1992
These aim to make sure that workplaces meet the
health, safety and welfare of each member of the workforce, which
may include people with disabilities.
The
Personal Protective Equipment at Work Regulations
1992
Personal protective equipment means all equipment
(including clothing that protects against bad weather) which is
intended to be worn or held by a person at work, and which protects
against one or more risks to health or safety, and any addition or
accessory designed to meet that objective.
Equality Act
2010
The Act gives rights to people who have or have had a disability
which makes it difficult for them to carry out day-to-day
activities. The disability could be physical, sensory or mental. It
must also be substantial and have a long term effect, ie it must
last or be expected to last for at least 12 months.
You can get more information on these pieces of legislation on
the websites of the Office
of Public Sector Information and HSE.
Preventive action
The HSE’s webpage Skin at work gives lots
of information on occupational skin diseases, with links to
leaflets including
Preventing dermatitis at
work, a step-by-step action plan on
preventing work-related dermatitis and Strategies
for prevention: occupational contact dermatitis.
Identifying the cause of the problem
It’s important to correctly identify the cause of a particular
skin condition. For example, an outbreak of dermatitis among
employees in a plant that uses metalworking fluids may be due to
wet work or to an allergen in part of the process. Assuming that
one of these is the cause of the problem, without carrying out an
investigation, might have no impact on the incidence of the
condition.
It’s also important to consider the scale of the problem. For
example, one case of dermatitis in a workplace does not necessarily
indicate a serious problem.
Not all skin problems are due to occupational factors, and
employers need to consider whether an employee’s condition has been
made worse by work. For example, an employee’s genetic
predisposition towards dermatitis or pre-existing dermatitis could
be exacerbated by wet work. Employers also need to consider whether
the condition could make work difficult for the employee.
Skin protection management programme
To prevent or minimise skin problems in the workplace, it’s a
good idea to have a skin protection management programme. The
programme should cover:
- risk assessment
- control measures
- monitoring of exposure
- health surveillance
- education and training
The HSE has a metalworking
fluids questionnaire that employers can use to design a
management programme covering risk assessment, preventing or
controlling inhalation and skin exposure, and carrying out health
surveillance.
Aspects of a skin protection management programme are discussed
below.
Risk assessment tools
Under the COSHH Regulations, when employees work with chemicals,
employers must carry out a risk assessment. An HSE leaflet outlines
the five steps to risk
assessment:
- identify the hazards
- decide who might be harmed and how
- evaluate the risks and decide on precautions
- record your findings and implement them
- review your assessment and update if necessary
The HSE’s COSHH essentials website
provides advice on controlling the use of chemicals and was
developed to help firms comply with the COSHH Regulations. The user
is asked for information about the process, tasks and use of
chemicals before being offered advice.
The European Agency for Safety and Health at Work report on
Skin diseases and dermal exposure: policy and practice overview
includes advice on diagnosis, measurement and risk assessment of
skin diseases and dermal exposure.
Control measures
If possible, the substance causing the problem should be
substituted by a safer one. For example, if it’s practicable to
replace glue containing a contact allergen with an alternative
which has no skin sensitisers, then this would be an effective way
of reducing the risk of hand dermatitis. However, this may not
always be possible, and re-designing the work process to avoid
handling the substance or to avoid splashes or immersion should be
considered. For example, using a tool such as a spatula to apply
glue, instead of the hands, will provide a safe working distance
between the chemical and the user’s skin.
To meet the COSHH Regulations you need good controls and good
practice. Effective control measures for airborne contaminants,
such as local exhaust ventilation and enclosures, may also help to
reduce exposure arising from deposition of chemicals on the skin,
particularly where airborne contamination can arise, such as mixing
and applying epoxy resins, welding and soldering, and working with
glass fibres.
Finally, as a last resort, personal protection should be used.
The most important form of personal protection is probably
impervious gloves. If used properly, they’re effective against most
irritants. It’s important to consider how long the gloves are worn
each day, as wearing them for long periods of time can result in
sweaty hands, which can contribute to skin problems. Improper use
of gloves could result in irritants and allergens becoming trapped
inside the gloves. Finally, certain types of glove, for example,
those made from latex, can themselves cause skin problems.
In Selecting protective
gloves for work with chemicals, the HSE lists four requirements
that must be met for protective gloves to be suitable:
- they must be appropriate for the risks and conditions they are
used in
- they must take into account the ergonomic requirements and
state of health of the person wearing them
- they must fit the wearer correctly
- they must prevent or control the risk involved without
increasing the overall risk
This leaflet also provides guidance on selecting the most
suitable glove material to protect workers from exposure to
chemicals.
Other forms of skin care include skin creams and skin
cleansers.
A regular use of moisturising creams keeps the skin hydrated and
supple, preventing dermatitis. Emollient creams can be used
during and after work to maintain the moisture of the skin.
However, ‘barrier creams’ do not provide full protection barrier as
chemicals will always work their way trough to the skin.
Furthermore, long term use may increase the skin’s susceptibility
to disease.
Skin cleansers remove contaminants from the skin – the most
effective but least powerful cleanser should be used. Immediately
rinsing the skin with water or washing with mild soap is often
enough to remove irritants and allergens.
Monitoring exposure
When there’s a risk of developing dermatitis, it’s important to
assess the likelihood and level of dermal exposure. In the case of
wet work, an assessment of exposure can be made by looking at the
frequency and duration of wet hands.
Guidance produced by the German Federal Ministry for Economics
and Labour recommends that workers should not have their hands wet
for more than 2 hours or more than 20 times each day, and that
impervious gloves should not be worn for more than 4 hours each
day.
Although this guidance applies to water only, the same principles
can be applied to other liquids. However, because most liquids are
more harmful than water, the frequency and duration of contact with
the hands should be reduced.
The Institute of Occupational
Medicine (IOM) has developed a simple
prototype wet-work sampler that detects wetness on the hands.
Although the IOM retains copyright on this sampler, it will
co-operate with any scientist who wants to use the method. Further
information about the sampler can be obtained by emailing: info@iom-world.org or telephoning +
44 (0) 870 850 5131.
For more in-depth advice on the measurement of the risks of
dermal exposure, contact the British Occupational
Hygiene Society.
Health surveillance
Under the COSHH Regulations, employers must carry out health
surveillance of employees who are, or who are likely to be, exposed
to substances that are hazardous to health. Health surveillance
helps employers detect the signs of skin disease at an early stage
and to reduce exposure to the substances if there’s a problem. It
also allows the employer to determine the extent of the problem, ie
whether it’s confined to one employee who had an existing skin
problem or more widespread. Here, carrying out an annual
questionnaire may be useful. For occupations where there are known
risks to employees’ skin, pre-employment screening might be
appropriate.
An introduction on Understanding health
surveillance at work offers brief guidance for employers, which
is further expanded on in a priced publication by the HSE on
Health surveillance at work.
As part of COSHH essentials, the HSE has a guidance document on
health surveillance
for occupational dermatitis. Another HSE guidance document, on
medical aspects of
occupational skin disease, provides advice on health
surveillance for health professionals. The TUC’s workSMART site
provides information on health
surveillance for employees.
Educating and training employees
Under the COSHH Regulations, employers have a duty to provide
employees who may be exposed to a hazardous substance with
education, instruction and training on the possible risks to
health, and the precautions they should take. This should cover
specific signs and symptoms to be aware of. Employees should be
taught how to examine their skin and be advised to report any
problems.
Reporting mechanisms
Identifying skin problems early is important. Employers need to
make employees aware of the risk factors, what symptoms to look
for, and how to report them should they arise.
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