What our customers can expect

The Care Worker Agency will take effective measures to control substances that are hazardous to health in order to reduce the risk of harm to employees and customers.

Explanation of terms used in this policy

Hazard: Potential source of harm or ill health to a person(s).

Risk: The likelihood that a person(s) may be harmed or suffers adverse health effects if exposed to the hazard.

Control measures: Safety precautions to reduce the risks.

Policy statement

Aims

The aims of this policy and procedure are to:

• Set out a systematic framework for identifying and controlling risks from hazardous substances;
• Provide guidance on how to apply the framework so as to reduce risks to employees and customers;
• Promote continuous improvement in the way that risks are managed;
• Make sure that directors and employees meet their statutory obligations so that people are protected.

Legal requirements

Using chemicals or other hazardous substances can put people’s health at risk, causing diseases such as asthma, dermatitis or cancer. In the workplace, managers and employees have a duty of care to make sure that any hazardous substances are used, stored and disposed of safely. 

The Control of Substances Hazardous to Health Regulations 2002 (amended) (COSHH) for England, Scotland and Wales; and The Control of Substances Hazardous to Health Regulations (Northern Ireland) 2002 require employers to:

• Identify any substances in the workplace that are hazardous to health;
• Assess the risks and decide how to prevent harm to health;
• Determine what hazards can be eliminated and introduce control measures to reduce  any remaining risks to health including first aid;
• Provide information, instruction and training for employees on COSHH;
• Record COSHH assessments
• Monitor that safety precautions are being used and that these are effective. Make improvements where necessary;
• Make sure that chemicals are stored and disposed of safely to avoid the risk of fire, explosion and environmental damage.

The Care Worker Agency COSHH procedure is in line with HSE guidance in the UK and Northern Ireland on working with substances that are hazardous to health.  Employees are expected to apply this procedure at all times. Failure to do so may result in disciplinary action.

Scope

This policy and procedure applies to all employees of Imagine Homecare including office based staff and care staff working in customers’ homes.  

Key principles

• Many substances can harm health; however, ill health caused by hazardous substances is preventable. These procedures will not merely be a paper exercise.  Managers will use the information gathered from COSHH assessments to actively promote the safety of employees and customers.
• Managers will eliminate the use of hazardous chemicals wherever practicable. Where this can’t be achieved, all reasonable steps will be taken to find chemicals or processes that are less hazardous.
• Managers will make sure that risk assessments and control measures are in place for any hazardous substances used at work (the office and the customer’s home). These will be recorded and their effectiveness monitored.
• Managers will obtain data sheets for any hazardous substances used in the office premises. Managers will use these to assess the risks and to determine appropriate control measures.
• The Care Worker Agency supervisors or care managers will carry out a COSHH risk assessment as part of the initial care planning process with customers and when care plans are reviewed (refer to Customer Support Plan Guidance). These will be in writing and will include details of safety precautions that care workers must take.
• Supervisors or care managers will review and update assessments if new types of chemicals are purchased by the customer or if the care plan changes so that new hazardous substances are introduced e.g. support involving bodily fluids.
• Managers will make all employees aware of these procedures and will provide appropriate instruction and training. They will monitor whether safety precautions are being used and whether these are effective.
• Managers will listen to any concerns or feedback from care workers and use this information to improve safety measures.
• Care workers will comply with this procedure and will familiarise themselves with the COSHH assessments for each of their customers.  
• Care workers will report any concerns relating to hazardous substances in their workplaces or when new products are introduced. This does not include normal domestic products that customers purchase from supermarkets, providing these have clear instruction labels. Care workers will also report any illness or injury sustained as part of their duties.  
• This policy and procedure will be reviewed following any changes to the legislation or within a period of not more than two years.

Quality monitoring

The application of the COSHH policy and procedure will be monitored by:

• Routine reviews of customers’ care and support plans;
• Supervision and appraisal of employees;
• Investigations into incidents occurring as the result of exposure to hazardous substances.

Information gathered from quality monitoring will be used to improve safety measures where necessary.

Procedure

To keep customers and staff safe, managers will complete the COSHH risk assessment included at appendix 2 prior to using any chemicals. Guidance on how to do this is provided below.

Step 1

Identify any substances in the workplace that are hazardous to health

A substance hazardous to health is a substance or preparation (mixture) with the potential to cause harm if they:

• Are inhaled or swallowed;
• Come into contact with or are absorbed through the skin;
• Come into contact with the eyes (caustic fluid splashes can damage eyesight permanently).

Hazardous substances contain organisms that are toxic or are irritants.  Examples include; bleach, washing-up liquids, dishwasher detergents and rinse-aids, drain-cleaning products, oven cleaners, disinfectants, toilet cleaners, sanitisers, descalers, polish; other products that give off fumes such as ozone from photocopiers; dusts and vapors; or bacteria and other microorganisms found  in bodily fluids  (blood, soiled linen, urine and vomit).  

Some products you may use may be classed as ‘dangerous for supply’. If so, they will have a hazard symbol on the label e.g. bleach. By law, suppliers must provide you with a safety data sheet for these products. Part 15 of the sheet will tell you what the dangers are and parts 4-8 will tell you about storage, handling and what to do in the event of an emergency. Hazards and risks are not only limited to these products. Other products in the list above may also be hazardous, even though they are not ‘dangerous for supply’.

Generally shampoos and normal body soaps are not classed as hazardous substances; however, this will depend upon the level of exposure and whether the people who are exposed to them have any special conditions that would make them more sensitive. Within the risk assessment under step 2, it is important to ask employees and customers whether they have any known allergies or any other medical condition that may be affected by particular products e.g. dermatitis, asthma, latex allergy etc (this is also included as part of the recruitment procedure).

Procedures that only apply to the office environment

In the office the care manager/supervisor will walk around the workplace and consult employees to identify products or processes that may expose them to hazardous substances e.g. photocopier toner and developer fluids.

Procedures that only apply to the customer’s home

As part of the assessment for each activity specific care and support plan, the care manager/supervisor will consider the tasks that the care worker will carry out and identify any hazardous substances that they will be exposed to and the extent of the exposure.  The products can be generic e.g. bleach, glass cleaners, bodily fluids rather than a list of individual types or brands (see example at appendix 2). Care workers will inform the care manager/supervisor if their customer purchases new types of products that may be hazardous.

Step 2

Assess the risks to health

The care manager/supervisor will evaluate the risks to the health of employees and customers. They will consider:

1. How each substance may be harmful;
2. Who may be harmed and whether any of these people could be harmed more than others e.g. pregnant women, individuals with asthma, dermatitis or  suppressed immune systems;
3. The likelihood that the hazardous substance will affect someone’s health. Is there a possibility of substances being ingested, inhaled, absorbed through the skin or swallowed? How often is exposure likely to occur and for how long?
4. What effects could the substance have?
5. Whether the arrangements for storage, movement or disposal present any additional risks, for example moving soiled linen.

Procedures that only apply to the office environment

All chemicals used on office premises will be risk assessed. Managers will obtain copies of the Material Safety Data Sheets (MSDS). MSDS for branded products are available from the product's manufacturer. Supermarkets hold safety data sheets for all their own brand cleaning products. Managers can obtain copies by going to their websites.

If a new chemical is required for office use, then the MSDS will be obtained from the supplier before the chemical is purchased. Managers will use the MSDS and product labels to determine the risks.  Any chemical that has to be mixed with another will be assessed to ensure that no adverse reaction could occur. The MSDS will provide information on incompatible chemicals. The importance of this procedure cannot be overstated as even some everyday cleaning chemicals can cause a serious reaction (even an explosion) if they are mixed.

Procedures that only apply to the customer’s home

It is not necessary to obtain MSDS for everyday domestic products bought from the customers’ local supermarkets. The product label will specify the risks, instructions for use and what to do in the event of accidental contact. Use this product information when completing the COSHH assessment at appendix 1.

Never mix different types of cleaning products. There may be adverse chemical reactions when substances are mixed, for example cleaning products containing bleach mixed with acidic toilet cleaners or limescale removers will give off harmful gases, bleach and lemon juice can give off chlorine etc.

Step 3

Decide what precautions are necessary to reduce the risks and prevent harm

Managers will consider:

1. Can the employee avoid using the hazardous substance?
2. Can the substance be substituted with one that has a lesser risk e.g. swapping an irritant cleaning product for something milder?
3.  Can the employee use a safer form to prevent exposure e.g. using a solid rather than liquid form of the product to avoid splashes?
4. What control measures are necessary to reduce residual risks e.g. using personal protective clothing such as disposable gloves, only using in well ventilated areas?
5. What first aid is required in the event of contact?

Managers will always seek to eliminate the risk by using an alternative product.  Where this is not possible, rigorous, effective controls will be implemented. These will be included in the COSHH assessment (template at appendix 2).

Office based staff and care workers must adhere to these control measures. They will also:

1. Wear gloves and aprons when handling hazardous substances;
2. Not mix cleaning products;
3. Not use products that they do not recognize, products without clear product information labels or that have not been risk assessed;
4. Never decant cleaning products to other containers;
5. Store products securely with the caps firmly closed;
6. Follow the instructions in the COSHH assessment or product label about how to use; where to use and what to do in the event of contact.

A list of care workers’ responsibilities and a summary of manager responsibilities is included at appendix 1.

Step 4

Record the assessment

Managers will record the COSHH assessment using the template at appendix 2. This will include:

1. The name of chemical or substance;
2. Sufficient information to show why decisions about risks and precautions have been made;
3. Instructions for use, storage and disposal;
4. What to do in the event of first aid being required;
5. Any other relevant and/or important information.

Step 5

Provide information, instruction and training for employees  

Employees need to be aware of and understand the risks associated with substances which may be hazardous to health. Managers will provide care workers with a copy of the ‘Procedures for Care Workers’ at appendix 1. A copy of the full procedures will be available on the intranet.

Managers will also provide information, instruction and training to all staff as part of their induction on the safe use and handling of chemicals, specifically;

• The names of substances to which they are liable to be exposed;
• The risks to health created by exposure;
• Significant findings of any risk assessment;
• The precautions employees must take to protect themselves and customers.

Further training will be given when required, e.g. on the introduction of new chemicals or new operating procedures. All training will be delivered in a practical form to ensure that the hazards and control measures are clearly understood.

Step 6

Monitor that safety precautions are being used and are effective and make improvements where necessary

Employees are also expected to bring any concerns about the operation of these procedures, or the handling of hazardous substances, to their line manager or supervisor. These concerns will be dealt with promptly. If further action is required, the employee raising the concern will be kept fully informed.

The COSHH assessment will be reviewed as part of the routine review of care plans six monthly or if new products are introduced or if any concerns arise.

Step 7

Make sure that chemicals are stored and disposed of safely

Make sure that products are always kept in original containers and are never decanted. The original containers will contain instructions for use, how they can cause harm and what to do in the event of contact.

Procedures that only apply to the office environment

The Care Worker Agency will provide proper storage facilities based on the properties of the chemicals used. The correct storage information will be obtained from the MSDS. Managers will be responsible for the regular review of all storage arrangements.  

Managers will ensure that all chemicals are disposed of in accordance with the guidance given on the MSDS. Staff must not decant substances from the original container to another.

Procedures that only apply to the customer’s home

Imagine Homecare staff provide support to customers in their own homes; therefore it is the customers’ choice about where they store potentially harmful substances. If the risk assessment indicates concerns about the storage arrangements, the care manager or supervisor will discuss this with the customer. Managers will agree with customers what control measures are necessary.  Providing customers have capacity, they have a right to take risks, however, The Care Worker Agency has a statutory duty to protect the safety of its employees. If control measures cannot be agreed then the care worker will not use the hazardous product(s).

.Related policies (This list is not exhaustive and may be subject to change)

• Customer Support Plan Guidance
• Recruitment Procedures
• Training and Development
• Health and Safety
• Incident and Accident Reporting
• Infection Control
• Infectious Disease.

Appendix 1

PROCEDURE FOR CARE WORKERS

What our customers can expect

The Care Worker Agency will take effective measures to control substances that are hazardous to health to reduce the risk of harm to employees and customers.

Explanation of terms used in this procedure

Hazard: Potential source of harm or adverse health effect on a person or persons.

Risk: The likelihood that a person(s) may be harmed or suffers adverse health effects if exposed to the hazard.

Control measures: Safety precautions to reduce the risks.

What the law says

Using chemicals or other hazardous substances can put people’s health at risk, causing diseases such as asthma, dermatitis or cancer. In the workplace, managers and employees have a duty of care to make sure that any hazardous substances are used, stored and disposed of safely. This is a legal requirement.  Harm caused by hazardous substances is preventable. These procedures are not merely a paper exercise; they are an important part of keeping you and your customers safe.

What is a hazardous substance?

A substance hazardous to health is a substance or preparation (mixture) with the potential to cause harm if they:

• Are inhaled or swallowed;
• Come into contact with or are absorbed through the skin;
• Come into contact with the eyes (caustic fluid splashes can damage eyesight permanently).

Hazardous substances contain organisms that are toxic or are irritants.  Examples include; bleach, washing-up liquids, dishwasher detergents and rinse-aids, drain-cleaning products, oven cleaners, disinfectants, toilet cleaners, sanitisers, descalers, polish; other products that give off fumes such as ozone from photocopiers; dusts and vapors; or bacteria and other microorganisms found  in bodily fluids  (blood, soiled linen, urine and vomit).  

Some products you may use may be classed as ‘dangerous for supply’. If so, they will have a hazard symbol on the label e.g. bleach. By law, suppliers must provide you with a safety data sheet for these products. Part 15 of the sheet will tell you what the dangers are and parts 4-8 will tell you about storage, handling and what to do in the event of an emergency. Hazards and risks are not only limited to these products. Other products in the list above may also be hazardous, even though they are not ‘dangerous for supply’.

Generally shampoos and normal body soaps are not classed as hazardous substances; however, this will depend upon the level of exposure and whether the people who are exposed to them have any special conditions that would make them more sensitive. Within the risk assessment under step 2, it is important to ask employees and customers whether they have any known allergies or any other medical condition that may be affected by particular products e.g. dermatitis, asthma, latex allergy etc (this is also included as part of the recruitment procedure).

About this procedure

Imagine Homecare COSHH procedure is in line with HSE guidance on working with substances that are hazardous to health.  Employees are expected to apply this procedure at all times. Failure to do so may to result in disciplinary action.

Summary of managers’ responsibilities

Managers will:

• Carry out COSHH assessments for each of your customers. A copy of the assessment will be placed with the activity specific care plans in the client folders in the customers’ homes. The assessments will:

• Identify any substances in the workplace that are hazardous to health;
• Assess the risks to you and your customers and decide how to prevent harm to health;
• Decide what hazards can be eliminated and introduce precautions to reduce any remaining risks to health.

• Provide information, instruction and training for employees on COSHH.
• Monitor that safety precautions are being used and that these are effective. Make improvements where necessary.
• Use information gathered from COSHH assessments to actively promote the safety of employees and customers.
• Listen to any concerns or feedback from care workers and use this information to improve safety measures. Keep care workers informed of any action that they may take.
• Review and update assessments if new types of chemicals are purchased by the customer or the care plan changes so that new hazardous substances are introduced e.g. support involving bodily fluids.

Care workers responsibilities

You must:

• Comply with this procedure and read the COSHH assessments for each of your customers.
• Let your line manager know if you have any specific conditions that may be adversely affected by cleaning products e.g. asthma, dermatitis.

• Not use any substances which may present a risk of harm to staff and the customer unless absolutely necessary, always look for less hazardous alternatives.

• As far as possible use normal household detergents for cleaning such as washing-up liquid (this removes grease oil and dirt).

• Not bring any hazardous substances to customers’ homes other than those which you are authorized to purchase on their behalf.

• Always read product labels carefully and follow the instructions about how to use a cleaning product; where to use it and what to do in the event of contact.

• Do not use products that you do not recognize, products without clear product information labels or types of products that have not been included in the COSHH assessment.

• Never mix different types of cleaning products. There may be adverse chemical reactions when substances are mixed, for example cleaning products containing bleach mixed with acidic toilet cleaners or limescale removers will give off harmful gases, bleach and lemon juice can give off chlorine etc.

• Keep chemicals away from your skin. Always use Personal Protective Equipment (gloves and aprons) during your work and especially when using any cleaning substances or dealing with bodily fluids. Remove and dispose of gloves and aprons carefully to avoid contamination with skin or clothing. Wash any splashes immediately following instructions on product label.

• Make up only as much solution as you will need for immediate use and replace caps firmly on containers immediately.

• Store chemicals safely in a cool, dry, dark place, capable of keeping in spills. Store immediately after use and do not leave substances lying about in customers’ homes.

• Avoid storing more than you need.

• Never decant substances from the original container to another.

• Bring any concerns to your line manager or supervisor or if the customer purchasers new types of products that have not been included in the COSHH assessment. Also report any illness or injury as a result of exposure to a hazardous substance as soon as you are aware of this.

Ask your line manager if you would like to see a copy of the full COSHH policy and procedure.

COSHH RISK ASSESSMENT                                                         APPENDIX 1