Do I need COSHH as a private GP?

What COSHH is

COSHH stands for the Control of Substances Hazardous to Health Regulations 2002. It requires employers to prevent or adequately control exposure to substances that can harm health. The HSE says it covers:

• chemicals and products containing chemicals
• fumes, dusts, vapours, mists and gases, including asphyxiating gases
• biological agents (germs).

It does not cover lead, asbestos or radioactive substances, which have their own regulations. If a product's packaging carries a hazard symbol, treat it as hazardous.

Does it apply to you?

Yes, if you use any hazardous substance at work, which every GP practice does. The HSE's position is simple:

• If you have employees, every part of COSHH applies.
• If you are self-employed with no employees, all parts apply except monitoring and health surveillance.

If you work under practising privileges in someone else's clinic, the clinic will usually hold the COSHH assessments for its products. You still need to follow them and tell the clinic about anything you bring in.

Substances in a typical GP practice

Substance	Main risks	Typical controls
Cleaning products and surface disinfectants	Skin and eye irritation, dermatitis	Use ready-to-use or milder products, gloves, a cleaning schedule and correct storage
Chlorine-releasing products for blood spills	Irritant, and can give off chlorine gas if mixed with acidic products	Spill kits, a written spill procedure, ventilation, never mix products
Blood and body fluids	Bloodborne viruses and other infections	Standard infection control precautions, safer sharps, staff immunisation, needlestick procedure
Disposable gloves	Latex allergy and skin sensitisation	A glove selection policy. HSE says powdered latex gloves should not be used.
Formalin in specimen pots	Irritates the eyes, nose, throat and skin, can cause allergic contact dermatitis, and is classed as a human carcinogen with long-term exposure	Pre-filled sealed pots, spill procedure, storage away from heat
Liquid nitrogen for cryotherapy	Cold burns and, in a poorly ventilated space, asphyxiation	Suitable storage and transport, PPE, a specific risk assessment
Medical oxygen	Fire risk and manual handling	Safe storage and signage, covered in your fire and emergency risk assessments

Latex deserves a mention. HSE advises that employers must be able to show they have assessed which gloves to provide and have a glove policy that takes account of staff or patients with latex allergy.

How to do a COSHH assessment

1. List every product and substance. Walk through clinical rooms, the cleaning cupboard, the kitchen and any storage area. Include what your cleaning contractor brings in.
2. Get the safety data sheets. Suppliers must provide an up-to-date sheet for products classified as dangerous. The sheet describes the hazards, handling, storage and emergency measures, but it is not your risk assessment.
3. Decide who could be exposed and how. Think about breathing it in, skin contact and swallowing, how often it is used and by whom, and include cleaners, contractors and patients.
4. Remove or substitute first. Ask whether you need the product at all, or whether a safer form would do, such as wipes instead of a spray, or a milder cleaner.
5. Control what is left. Store products labelled and upright, away from patients and with incompatible products apart. Plan how spills will be cleared up, and provide PPE where other controls are not enough.
6. Record and tell your staff. If you have five or more employees you must record the significant findings. Whatever your size, staff need to know the risks and precautions, and how to use PPE.
7. Review. Revisit the assessment when you change a product or a process, after an incident, and at least yearly.

HSE publishes example COSHH risk assessments and a brief guide that you can adapt. Many small practices do this themselves. You can also use a compliance service, but the legal duty stays with you.

Biological agents

Exposure to blood and body fluids is the main biological risk in general practice, and COSHH is one of the laws behind staff immunisation. The Green Book says the COSHH risk assessment should indicate which pathogens staff are exposed to, and staff at risk should be offered appropriate immunisation. See immunisations for your staff.

Needlestick and sharps injuries are managed under the same hierarchy of controls, together with the Health and Safety (Sharp Instruments in Healthcare) Regulations 2013. See meeting health and safety standards and dealing with medical waste.

What the CQC will expect

COSHH is health and safety law enforced by the HSE and local councils, but the CQC checks that your premises and equipment are safe under regulation 15, which includes managing hazardous materials in line with current legislation. A tidy COSHH file is easy evidence. Keep:

• a list of hazardous products with their safety data sheets
• your assessments and the date each was reviewed
• your spill procedure and needlestick procedure
• a record of staff training on both.

Scotland, Wales and Northern Ireland

COSHH applies across Great Britain and is enforced by the HSE. Northern Ireland has its own equivalent COSHH regulations, enforced by HSENI. The approach is the same.