How can I ensure my practice meets health and safety standards?

The law that applies

Health and safety law applies to your practice whether you employ ten people or work alone. The Health and Safety at Work etc. Act 1974 sets the general duty to protect employees and anyone else affected by your work, which includes patients and visitors. Under the Management of Health and Safety at Work Regulations 1999, the minimum is to identify hazards, decide how likely and serious the harm could be, and remove or control the risk.

The HSE sets out the basics every business needs:

• a health and safety policy, written down once you have five or more employees
• a risk assessment, with significant findings recorded once you have five or more employees
• a competent person to help you, who can be you
• information, training and consultation for your staff
• suitable welfare facilities, such as toilets, washing facilities and drinking water
• first aid arrangements
• a way of reporting certain incidents under RIDDOR
• the health and safety law poster or leaflet if you employ anyone. See the health and safety poster.

Once you employ anyone, you also need employers' liability insurance with at least £5 million of cover. See essential insurance.

Start with a risk assessment

Walk round the premises and think through a typical clinic day, from the patient arriving to the waste being collected. For each hazard, note who could be harmed, what you already do and what else you need to do. HSE's five steps are to identify hazards, assess the risks, control them, record your findings and review the controls.

Include people who are more vulnerable, such as pregnant staff, young workers and disabled staff or patients. If you work in shared or rented premises, agree in writing who is responsible for the building, fire systems, water and communal areas.

The hazards that matter in general practice

Area	What you need
Sharps and bloodborne viruses	A sharps risk assessment, safer sharps where reasonably practicable, sharps bins at the point of use and a written needlestick procedure
Hazardous substances	A COSHH assessment for cleaning products, disinfectants, liquid nitrogen if used, and biological agents. See COSHH for private GPs.
Infection prevention and control	An IPC policy, a named lead, handwashing facilities, cleaning schedules and an audit programme
Clinical waste	Correct segregation, a licensed contractor and records. See dealing with medical waste.
Fire	A written fire risk assessment by the responsible person, and safe storage of oxygen cylinders
Water	A legionella risk assessment. The CQC notes that in many cases it will show the risk is low and already controlled.
Electrical and medical equipment	Maintenance, testing and calibration in line with the manufacturer's instructions. See equipment for private GPs.
Medical emergencies	Resuscitation equipment, emergency medicines and trained staff. See the emergency drugs cabinet.
Lone working and violence	A plan for evening clinics, home visits and working alone, including how to call for help
Display screen equipment	Workstation assessments for staff who use a computer for much of the day

People and training

Name a lead for each area. In a small practice one person often covers several, but the CQC expects a clear lead for infection control and a named resuscitation lead. Give new starters an induction that covers fire procedures, sharps, spills, waste, first aid and how to report incidents.

Staff who have contact with patients need the right immunisations for their role. See immunisations for your staff. Keep a training log so you can show who has done what and when refreshers are due.

Reporting incidents

RIDDOR requires employers, the self-employed and those in control of premises to report specified incidents to the HSE. For a GP practice, the one to know is sharps: a needlestick from a sharp known to be contaminated with a bloodborne virus is reportable as a dangerous occurrence, and seroconversion after a sharps injury is reportable as a disease. A needlestick from a source that is negative or cannot be traced is not reportable unless the injury itself meets another RIDDOR threshold, such as more than seven days off work.

Keep your own log of all incidents and near misses as well. An accident book is a legal requirement once you have 10 or more employees, and it is good practice before then. Incidents that affect patients also belong in your significant event process. See clinical governance.

What the CQC looks at

In England, CQC regulation 15 requires premises and equipment to be clean, secure, suitable, properly used, properly maintained and appropriately located. It expects regular health and safety risk assessments of the premises and equipment, acted on without delay. Regulation 12 covers safe care and treatment, including equipment and medical emergencies. The CQC must refuse registration if you cannot show you will meet these regulations, so have your risk assessments ready before you apply.

Useful evidence includes your risk assessments, fire risk assessment, legionella assessment, COSHH file, equipment log with service and calibration dates, cleaning schedules, IPC audits, training records and incident log. Many practices keep policies and training records in a compliance system such as QCS or GP TeamNet, or in a well-organised shared drive.

Keeping it going

• Set a yearly review date for every assessment, and review sooner after an incident or a change such as new premises or a new service.
• Use a simple monthly checklist for things that drift: sharps bins, first aid kit, emergency medicines and equipment, fridge logs and fire exits.
• Discuss health and safety at team meetings, and act on what staff tell you.

Scotland, Wales and Northern Ireland

The same health and safety law applies across Great Britain and is enforced by the HSE and local councils. Northern Ireland has its own equivalent legislation, enforced by HSENI. Fire safety law is different in Scotland and Northern Ireland. The service regulator is Healthcare Improvement Scotland, Healthcare Inspectorate Wales or RQIA instead of the CQC, and each has its own standards for premises.