Once a risk assessment has been completed, the methods chosen to adequately control the identified risks should, as far as possible, follow the hierarchical approach set out in the Management of Health and Safety at Work Regulations 1999 and COSHH, namely:
- eliminating risk;
- controlling risk at source or by safer design;
- using physical engineering controls and safeguards supported by;
- safe systems of work;
- the use of personal protective equipment; and
For general guidance on risk control and management, including example risk assessments, see: Risk management.
Consider if the hazardous procedure can be replaced completely and the associated risk eliminated.
Safe systems of work
Minimising the risks through suitable systems of work
Systems of work are usually implemented by standard operating procedures or local codes of practice. Because they rely on individuals adhering to them, usually they are only used to supplement other control measures. Examples of such systems relating to infection prevention and control are:
- Laboratory rules - eg prohibiting eating, drinking and smoking and the application of cosmetics in working areas where there is a risk of contamination.
- Sharps policy - avoiding the use of, or exposure to, sharps, such as needles, glass, etc.
- Waste disposal policy - where sharps are unavoidable, safe disposal procedures such as the use of sharps bins made available at point of use, and forbidding the re-sheathing of needles.
- Decontamination and disinfection procedures - effective decontamination of reusable equipment (eg tattooing instruments, dental drills).
A summary of requirements designed to protect health care workers in England from BBV exposure is provided in The Health Act 2006: Code of practice for the prevention and control of healthcare associated infections, (known as The Hygiene Code). Although the Act is enforceable in England alone, the associated Code of Practice contains information that is relevant for anyone providing occupational health support for healthcare workers, and for prevention and management of occupational exposure to BBV. Additional guidance for the Scottish healthcare sector is available from the Scottish Infection Manual.
Failure to observe 'The Hygiene Code' in England may either result in an Improvement Notice being issued to the NHS body by the Healthcare Commission, or in it being reported for significant failings and placed on 'special measures'.
Medical Devices Regulations 2002 (as amended)
Needles and many other medical sharps are covered by The Medical Devices Regulations 2002 and regulated within the UK by The Medicines and Healthcare Products Regulatory Agency (MHRA). As such, they should be designed and manufactured in such a way that, when used under the conditions and for the purposes intended, they will not compromise the clinical condition or the safety of patients, or the safety and health of users, or where applicable, other persons, provided that any risks which may be associated with their use constitute acceptable risks when weighed against the benefits to the patient and are compatible with a high level of health and safety. Enforcement actions relating to these regulations may differ slightly depending on where in the UK they are applied.
In particular, with regard to needles , other medical sharps and blood-borne viruses, the essential requirements state that devices must be designed in such a way as to eliminate, or reduce as far as possible, the risk of infection to the patient, user and third parties. The design must also allow easy handling and, where necessary, minimise contamination of the device by the patient or vice versa during use. It may be appropriate to consider the use of newer technology such as retractable needles, where the health and safety benefits may justify any additional cost.
A summary of the MHRA's regulatory responsibilities can be found on the MHRA web site at: Medical device appeals.
Controlling the risks at source or by safer design
- Collective protective measures should take preference over personal protective equipment;
Use of personal protective equipment
Designing in risk control measures
- Use a microbiological safety cabinet for any laboratory work that could create infectious aerosols;
- Use interlocks on diagnostic equipment used to analyse blood or other body fluids;
- Use safer needle devices and/or blunt ended scissors to prevent and control inoculation injuries;
- Use appropriate equipment for the job, PUWER regulations require that the equipment you provide for use at work is:
- Suitable and safe for its intended use;
- Used only by people who have received adequate information, instruction and training;
- Accompanied by suitable safety measures, eg, protective devices, markings and warnings; and
- Designed and manufactured in compliance with any essential requirements set down in certain Community Directives regarding the safety of products