This section outlines the legal context for, and the methods of carrying out, risk assessments.
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 occurring 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.
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.
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.
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 sensitizers, 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.
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: firstname.lastname@example.org or telephoning + 44 (0) 870 850 5131.
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.
The HSE health surveillance pages include a range of guidance for employers. 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.
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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