Health & Safety Executive/Local Authorities Enforcement Liaison Committee (HELA)

To: Health and Safety and Food Hygiene Enforcing Authorities

For the attention of: Local Authority Health and Safety and Food Hygiene Enforcement Managers, Health and Safety and Food Hygiene Regulators and others

This circular provides advice to Health and Safety and Food Hygiene Regulators (for clarity and convenience referred to as Inspectors) who are involved in visits to catering establishments where a significant amount of direct food handling/preparation is undertaken.

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Inspection intervention 2007/8: Preventing work-related contact dermatitis in the catering industry

Aim

1. The aim of the dermatitis in catering project is to raise awareness of the issue within the catering sector and begin a behavioural change to effect a reduction in the number of cases of dermatitis. This work forms part of the Skin Disease Project within the Disease Reduction Programme (DRP) which is part of the FIT3 programme. The target for the Skin Disease Project as a whole is to prevent around 840 cases of work‑related contact dermatitis by 2007/2008. This represents a reduction of about 10% of the incidence rate in 2004/05.

2. We are working in partnership with the Food Standards Agency (FSA) to ensure that our proposals for this project and the controls being promoted do not conflict. We are also exploring where we can be more ‘joined-up’ to ensure consistency of messages.

Background

3. Work-related contact dermatitis (referred to as dermatitis hereafter) is a skin disease caused by work. It is often called eczema and develops when the skin’s barrier layer is damaged. This may lead to redness, itching, swelling, blistering, flaking and cracking. The most susceptible parts of the body are the hands, followed by forearms and face. It can be very painful and severe enough to keep people off work or force them to change jobs. An additional issue arises in sectors such as catering, where good personal hygiene practices must be followed – those suffering from dermatitis may be tempted to avoid hand‑washing because it is painful and can aggravate their condition.

4. Dermatitis is one of the main causes of ill health in the hotel and catering sector. The incident rate for the hotel and catering sector (the average number of new cases per year) is twice the all industry average (12.8 per 100 000 workers, compared to an all-industry average of 6.5 per 100 000 workers). This figure represents only the most serious cases which are referred onto specialists. The true figure is likely to be significantly higher, as many people will simply ‘live’ with dermatitis or leave the profession¹. In fact, almost all workers involved in ‘wet working’² jobs develop some degree of dermatitis³.

5. HSE statistics indicate that those most at risk of developing dermatitis within the catering sector are chefs and cooks and kitchen and catering assistants.

6. The main causes of dermatitis within these groups are:

• Chefs & cooks – contact with foods & flour (57% of cases), wet work i.e. washing-up (31%), contact with soaps and cleaners (30%).
• Kitchen & catering assistants – wet work (47%), foods & flour (37%), soaps and cleaners (27%).

7. Dermatitis can easily be prevented and should not be seen as ‘one of those things’ or ‘part of the job’. The controls required to prevent dermatitis are simple and entirely compatible with good food safety practice.

Action required

8. Inspectors are asked to raise awareness of dermatitis during inspections and where appropriate through alternative interventions such as ‘awareness days’, sometimes referred to as SHADs.

9. Interventions should be focussed on those businesses/establishments where a significant amount of direct food handling/preparation is undertaken e.g. restaurants, hotels, care homes, hospitals and canteens.

Inspections

10. Catering premises may be visited more often for food safety inspections rather than for health and safety inspections. To capitalise on these visits, inspectors are asked to incorporate dermatitis as an issue during food safety visits, but this does not preclude it from being covered during health and safety inspections. Choose whichever best suits your local needs.

11. The simplest way to incorporate dermatitis into the food safety inspection is to address it during your general discussions about food safety requirements. Preventing dermatitis is simple and often the control measures suggested will address both dermatitis and food safety issues; for example, promoting the use of tools rather than direct handling of food; using dishwashers rather than washing by hand. Appendix 1 contains guidance on how to incorporate dermatitis in this way and provides information which can be added to your Food Safety Inspection Aide Memoir/Visit record sheet. The LACORS Inspection Aide Memoir under EC 852 has also been amended to reflect this compatibility.

12. Integrating dermatitis within the existing food safety inspection is likely to have a greater impact on the outcomes sought, because it demonstrates that what business’s are already doing (or being encouraged to do) for food safety, also protects their workers from the main causes of dermatitis. Drawing this linkage also demonstrates that health and safety is not an added burden but in fact complimentary to their business.

13. Where dermatitis is covered as part of a health and safety inspection, you may wish to combine it with other projects targeting the catering sector such as slips and trips (kitchens) and respiratory disease (asthma/flour dust). The information in Appendix 1 can also be used to form an aide memoir for a health and safety visit on dermatitis.

Enforcement

14. This is an awareness-raising project so enforcement activity is not being sought, but of course, you may come across situations where compliance is so low or find actual cases of dermatitis that you have to consider the HSC Enforcement Policy Statement.

15. If you wish to progress the matter, or require specialist support, some of HSE's Occupational Health Inspector (OHI) resource has been secured for joint visits. OHI's are Inspectors who specialise in Occupational Health and support LA and HSE Inspectors at visits when they consider specialist knowledge is required. Access to this support is obtained through the existing arrangements you have locally, typically the ELO (Enforcement Liaison Officer) or Partnership Team. A joint visit with an OHI is also a very good way for them to learn about the LA enforced sector and for you to learn more about the inspection and control of skin hazards, health surveillance, and investigation of cases of dermatitis. They are also able to explain to the business operator/employer how to manage skin disease, including setting-up or modifying the existing arrangements.

16. If you are considering enforcement action it is strongly recommended that you arrange a joint visit with an OHI or as a minimum discuss your proposed action with them. This will be essential where the premise is enforced by HSE under the Health and Safety (Enforcing Authority) Regulations 1998 but you have incorporated dermatitis into a food safety inspection, as you will have no powers of enforcement for health and safety. (OC 124/11 provides further details on these regulations.) Alternatively contact your local Enforcement Liaison Officer.

Alternative interventions

17. You may wish to raise awareness of this issue in ways other than inspection of individual premises, through awareness days for instance. Dermatitis alone may not be sufficient to get ‘take up’ of events, so you may wish to consider combining dermatitis with other initiatives aimed at the catering industry. This could focus on other FIT3 health and safety initiatives such as slips and trips, or other topics outside occupational health and safety but which target the same audience, for instance events around the smoking ban or food safety, if that fits with your local priorities.

Activity dates

18. Interventions are to be carried out throughout the financial year 2007/8. Supporting material for the project will be available from May 2007 (see Paragraph 22 for more information).

Reporting activity and impact of the Fit3 Programme (LA enforcement officers)

19. When planning and implementing work within the Fit3 programme it is essential to feedback details of activities and outcomes. This is to allow monitoring of progress towards the DRP objectives and where necessary to refocus work activities and to consider the adequacy of current support. Feedback also provides invaluable information for the Health and Safety Commission/HSE & LA Enforcement Liaison Committee/Local Authority Unit when responding to Ministers and the Local Better Regulation Office (LBRO) on the achievements of the LA/HSE partnership in delivering the DRP and the Fit3 programme in general.

20. Please use one or more of the following ways to record your activities and achievements both quantitatively and qualitatively:

• provide feedback 'in year' to Partnership Teams (for visits carried out as part of Food Hygiene inspections, these may come via your Local Food Liaison Group)
• complete the topic inspection report forms on the HELA Training Co-ord website
• upload information onto the Extranet e.g. as an example of good practice
• contribute to research based evaluation work (if requested), sponsored by certain key Fit3 projects/programmes ( e.g. Better Backs Campaign)
• apply for HELA annual awards
• complete the LAE1 form for 07/08

Training

21. The DRP ran a series of training events for local authorities during the early part of 2006. These included a session on work related dermatitis. Not all inspectors, and certainly not dedicated Food Safety inspectors, will have attended these events. As this project is about awareness raising a detailed knowledge of the topic is not necessary (and support where detailed knowledge is required i.e. enforcement is available from HSE OHIs) but there may be a need to provide some basic information/training. A training PowerPoint presentation with speaker’s notes is available which should be sufficient to meet any training needs you have. This presentation can be downloaded from the extranet or requested via your Partnership Team. This is designed to be delivered by someone within your own team. If you feel that you do not have the knowledge/experience within your own team to run this training please approach your local Partnership Team or contact the Catering Team (see paragraph 31).

Supporting material and other interventions

22. To support and reinforce the work that you do during the inspection, there will be two leaflets available for you to leave at the workplace. The first is the generic dermatitis leaflet ‘Preventing Dermatitis at Work’ INDG233 (rev1) and the second is a new, basic catering specific flyer. See paragraph 32 for details on how to order sufficient stocks of these items. Also see paragraph 27 for sources of further information.

23. There is also a standard PowerPoint presentation with speakers notes which can be used during alternative interventions (i.e. awareness days). The presentation covers what dermatitis is, what causes it and how to prevent it. The presentation is available to download from the extranet or you can contact the catering team. The team will also try to support these events as far as possible; so if you need a presenter/speaker please do not hesitate to contact us.

24. The project team is also working on a number of other interventions. The most significant of these is stakeholder engagement. We have established a network of external stakeholders who will raise awareness of the issue to their own audiences. The stakeholders include key Trade Associations (e.g. Institute of Hospitality (previously HCIMA)), Trade Unions (UNISON, TGWU) and other relevant bodies e.g. CIEH as well as those employing significant numbers within the sector (e.g. Compass Group, National Association of Care Caterers).

Communication campaign pilot

25. Direct inspections are generally one of the most effective ways of bringing about behavioural change but the catering sector is large and diverse and, this year in particular with the smoking ban and food labelling, is subject to a number of regulatory changes and initiatives. This all suggests direct interventions alone will not secure the level of change needed. The dermatitis team consists of LA and HSE representatives, and as stated above, the team is engaging with industry stakeholders to understand how best to influence and bring about the changes required. However, there are still a lot of questions about which interventions will work best. The project is therefore going to pilot a range of intervention techniques in September in the Midlands region. The pilot will be evaluated and the findings fed into next years work. Details of the pilot as it develops will be available via the Partnership Teams. Also look out for ‘DC News’ the dermatitis in catering project (quarterly) newsletter which provides a general update on the project⁴.

26. The project team will also use other communication routes such as articles in trade publications, attendance at conferences and events and of course the web. The ‘skin at work’ section of the HSE website is currently being updated and this will include industry specific pages.

Further advice

27. Further information on dermatitis and its causes is given in the Topic Inspection Pack for Work-Related Contact Dermatitis [595KB]. Additional information can also be found on the Extranet and the HSE website hse.gov.uk/skin (this includes 5 free to download posters on dermatitis).

28. E-coshh essentials has a number of relevant information sheets – the main ones are: SR1, SR2, SR4, SR7, SR9, SR24, SR25, SR26 and SR27 with SR0 and G403 (dermatitis health surveillance).

29. Free HSE publications - ‘Preventing contact dermatitis at work’ INDG233 [76KB] (rev1) and ‘COSHH: A Brief Guide to the Regulations’ INDG136 [185KB] (rev3)

30. The priced HSE publication ‘A recipe for Safety’ also includes information on dermatitis. The chapter on occupational health can be downloaded from the HSE website at www.hse.gov.uk/food/occhealth.pdf [123KB]

Contacts

31. The Dermatitis in Catering project team is made up of LA and HSE representatives. You can contact the team at: catering@hse.gsi.gov.uk

Ordering collateral

32. The leaflets (see paragraph 22) to support this project will be available from May 2007. Orders should be placed directly with HSE Books, quoting reference MISC762 (this is the specific number to ensure that you get both leaflets in the one order). Orders should be placed by one of the following methods:

• fax: 01787 313995
• in writing to HSE Books: PO Box 1999, Sudbury, Suffolk CO10 2WA or
• by email: hsebooks@prolog.uk.com.

33. You must provide the name of your local authority, the number you require (based on 1 of each leaflet per visit) the name of the individual who is to receive the order, the full delivery address including postcode, a contact telephone number and an email address. Initial orders will be limited to 200 per local authority.

34. If the leaflets are required for a specific event rather than for distribution during inspection, it is important to tell HSE Books of the date of the event so they can meet time critical orders. If advance orders are not placed you must allow a minimum of 5 working days for orders to be processed and delivered.

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Appendix 1 – Incorporating Dermatitis into Food Safety Inspections

The catering team recognises that the level of experience and knowledge on dermatitis amongst inspectors will vary. The amount of time available to discuss dermatitis during an inspection will also vary. Inspectors should raise the issue of dermatitis during inspections at a level they feel comfortable with.

The simplest way to incorporate this topic into food safety inspections may be to make some small amendments to the Food Inspection checklist/Aide memoir that you may use locally and incorporate dermatitis into the food safety inspection itself rather than ‘tagging’ it on at the end of the inspections as a stand alone topic.

The principle message is that preventing dermatitis does not have to be difficult or expensive. Just follow three simple steps:

• Avoid contact
• Protect the skin
• Check for early signs of dermatitis

APC is based on the Control of Substances Hazardous to Health Regulations 2002 (as amended) (COSHH). Under COSHH, employers must seek to prevent exposure ( A void). Where preventing exposure is not reasonably practicable, then employers must adequately control exposure ( Protect, this encompasses the whole of the new emphasis in Regulation 7 to apply the eight principals of ‘good control practice’ ⁵). Employers must carryout appropriate health surveillance where their assessment has shown this is necessary or where COSHH sets specific requirements ⁶ ( Check).

Many of the APC controls promoted are consistent with the best practice controls promoted for food safety, as demonstrated in the table below.

Of course, any controls implemented will be based on an assessment of the risk for the individual workplace, its activities and those employees liable to be exposed.

Examples of good food safety methods	APC Risk based controls
Dishwashers wash things at a high temperature. This is great for killing bacteria.	Avoid Using a dishwasher rather than washing by hand
Avoid handling food as much as possible. Hands can easily spread harmful bacteria onto food	Avoid Using automated processes where practicable e.g. mixing / kneading by machine rather than by hand, automatic potato peelers Using tools for handling food rather than hands e.g. tongs, scoops
Remove jewellery (except wedding bands) for work. Jewellery can collect and spread harmful bacteria or fall in food.	Protect Remove jewellery (except wedding bands) for work. Jewellery can trap water and cleaning products next to the skin and cause dermatitis.

Below are the suggested ‘checks’ (in bold) to add to your local food safety inspection checklist. The text in italics is for your information only so that the checks are put into context with APC. If you have room on your checklist, you could always record additional comments.

Procedures

Personal hygiene

• Skin care regimes in place: Yes [  ] No [  ] some [  ]
  
  Protect. For dermatitis, this should include removing of jewellery, thorough drying of hands after washing and moisturising regularly.

Sickness arrangements

• Skin checks carried out: Yes [  ] No [  ]
  
  Check. Regular skin checks by a ‘responsible person’ ⁷ can spot the early signs of dermatitis and prevent more serious dermatitis developing. Steps can then be taken to treat the dermatitis.

Training

• Instruction given on dermatitis and skin care regimes: Yes [  ] No [  ]
  
  Protect. Employees should receive suitable information, instruction and training on dermatitis: its causes and effects, prevention, controls and skin care

Premises and equipment

Wash hand basins in food rooms

• Soft paper towels: Yes [  ] No [  ]
  
  Protect. This is a ‘best practice’ control. Soft paper towels are less abrasive on the skin.

• Skin creams: Yes [  ] No [  ]
  
  Protect. Moisturising as regularly as possible throughout the day will restore the skins protective oils. (Use appropriate creams that will not contaminate food e.g. hypoallergenic, fragrance free and nut oil free)

Sanitary accommodation

• Soft paper towels: Yes [  ] No [  ]
  
  Protect. This is a ‘best practice’ control. Soft paper towels are less abrasive on the skin.

• Skin creams: Yes [  ] No [  ]
  
  Protect. Moisturising as regularly as possible throughout the day will restore the skins protective oils. (Use appropriate creams that will not contaminate food e.g. hypoallergenic, fragrance free and nut oil free)

Footnotes

1. A recent review of RIDDOR showed a less than 5% compliance rate with Regulation 5 (disease reporting, which includes dermatitis).
2. Wet work is the term generally used to describe prolonged or frequent contact with water – e.g. water/chemical mixtures or wet food (tasks such as washing up, washing food, general cleaning, frequent hand‑washing). Where frequent contact with water/chemical mixtures or wet food represents a risk of causing dermatitis it will fall under the COSHH requirements. A rule of thumb for wet work is a total contact of more than 2 hours per day or more than 20 hand washes per day
3. JSC English (2004). Current concepts of irritant contact dermatitis. Occup Environ Med. 61:722-276
4. Do you want to join the DC News mailing list? Contact the team on the catering e-mail address. It is also available on the extranet at https://extranet.hse.gov.uk/C1/Skin%20Disease/default.aspx (login required)
5. See www.hse.gov.uk/coshh/index.htm for more detail
6. COSHH Regulation 11
7. A "responsible person" is someone appointed by the employer and is competent to carry out assessments for early signs of dermatitis or changes to the skin and is charged with reporting to the employer the findings of the procedure. This person may be a supervisor, foreman, first-aider, safety representative or the employer. The appointment of such a person forms part of a completed HEALTH SURVEILLANCE procedure/protocol, which ideally should be written down, for consistency and so that people can refer to it.

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