This guidance provides information to support HSE and LA Inspectors with enforcement activities in relation to the prevention of occupational contact dermatitis. It also enables inspectors to raise awareness of the standards duty-holders need to meet to comply with the law.
Occupational contact dermatitis (dermatitis is sometimes known as eczema) accounts for a significant proportion of work-related ill health. Skin disease is the second commonest occupational disease in the European Union (BOHRF 2010). Contact dermatitis accounts for 70-90% of all occupational skin disease. Up to half of workers with occupational contact dermatitis experience adverse effects on quality of life, daily function and relationships at home. Occupational contact dermatitis is common and the impact can be severe. However, a key message is that, in general, the preventative measures required are simple, low-cost and easy to implement.
Inspectors should ensure that duty-holders have an effective management system in place that can identify causes of occupational contact dermatitis, assess the risks and, if exposure cannot be prevented, then adequately controlled.
Whilst dermatitis can occur in just about any workplace, inspectors should note the following high risk industries:
Inspectors should ask to see the company’s COSHH risk assessment (if the company employs more than five people) and ensure that skin hazards have been identified for substances either used (check labels and safety data sheets) or generated in the workplace (check industry guidance). The risk assessment should take account of dermal exposure pathways such as immersion, splashes, deposition or contact with contaminated surfaces.
Inspectors should note that prolonged or frequent contact with water (often termed ‘wet work’), particularly in combination with soaps and detergents, can cause dermatitis (e.g. a long time spent washing up or frequent hand washing). As a guide, more than two hours a day or twenty to forty hand washes is likely to put an employee at risk.
Adequate control of dermal risks may not be achieved by a single working practice. A combination of control measures is typically appropriate, following the simple APC - Avoid, Protect, Check approach:
Avoid contact with materials that cause dermatitis. Employers should, where reasonably practicable;
Protecting the skin is particularly important if the steps above aren’t practical or aren’t enough to totally avoid contact. Employers should protect workers’ skin by:
If there is still a risk to skin health after the implementation of all reasonably practicable precautions, employers should put a health surveillance programme in place to check for possible harm.
With regards to health surveillance for dermatitis;
Guidance on the employer's legal duties is provided on the Health surveillance web pages. More specific guidance on health surveillance for dermatitis can be found in Health surveillance for occupational contact dermatitis – G403. Where appropriate, Inspectors should ask to see the company’s health surveillance records.
The range of issues and controls are outlined on the Skin at Work web pages. The area for health and safety and medical professionals contains more technical information. Within this area is a page for inspectors. This page aims to provide easy access to information useful to both HSE and LA inspectors undertaking inspections.
For inspectors, the Enforcement Management Model (EMM) (see Appendix 1 for examples) should be used to determine the appropriate action to take when they have formed their opinion that there is non-compliance.
This guidance is focused on the following two skin conditions caused by exposure to substances in the course of work:
HSE has no proactive inspections in relation to dermatitis. Inspectors should address any matters of evident concern (MEC) which come to their attention. In addition during inspection visits, inspectors should proactively consider if there are hazards which have the potential to cause multiple cases of dermatitis (Matter of Potential Major Concern or MPMC).
Recording & Reporting
There are no special reporting arrangements for inspectors.
FOD Occupational Health Inspectors.
FOD Specialist Inspectors - Occupational Hygiene.