Preparations for HSA inspections
by Jane Renehan
Jane Renehan explores how dental practices can prepare for inspections by the Health and Safety Authority.
The question – Dear Jane…
The Health and Safety Authority (HSA) recently inspected a colleague’s dental practice. What does a practice need to do to prepare for HSA inspections? For example, what documentation may the HSA inspector look for?
Answer
The Safety Health and Welfare at Work Act (2005) and subsequent regulations confer the Health and Safety Authority (HSA) with the legal framework by which the authority is responsible for the protection of workers and consumers.
Dental practices are included in the 2.5 million workers in Ireland for which the HSA has responsibility. The HSA monitors compliance with legislation at the workplace and can take enforcement action (up to and including prosecutions).
In recent months, there has been an increase in the number of unannounced HSA inspections. Inspectors assess compliance with safety, health and welfare at work obligations. However, the latest inspections have placed an emphasis on the HSA’s Biological Agents Code of Practice (updated 2020).
Biological agents
Biological agents are defined as a microorganism such as bacteria, fungi, virus, parasite etc, which may be able to provoke an infection, allergy or toxicity.
| Group one | Unlikely to cause human disease to employees |
| Group two | Can cause human disease and might be a hazard to employees, although it is unlikely to spread to the community and in respect of which, there is usually effective prophylaxis or treatment available |
| Group three | Can cause severe human disease and presents a serious hazard to employees, which may present a risk of spreading to the community, although there is usually effective prophylaxis or treatment available |
| Group four | Causes severe human disease and is a serious hazard to employees and which may present a high risk of spreading to the community, and in respect of which there is usually no effective prophylaxis or treatment available |
See Table 1 for biological agents’ classification into four groups according to their level of risk of infection. Dental practices’ biological agents fall into risk groups one, two and three.
Inspectors focus on the employers’ measures to prevent or reduce the risk of exposure, in addition to the existing controls to protect staff.
Practices usually have four weeks to provide a written response outlining their corrective actions and compliance plan in response to the inspector’s report. Failure to comply with a request or instruction from an inspector may result in further enforcement action, including prosecution.
Common failings
Next, let’s outline some common failings, from inspectors’ reports, where practices have fallen short of the minimum legal standards.
Annual safety statement
Firstly, it is the legal duty of dental practice owners to conduct an annual risk assessment.
Based on the outcome of the risk assessment, a safety statement is drawn up or updated. This document should be reviewed annually, or where circumstances alter significantly before then.
The inspector will review the safety statement to ensure it is practice-specific and reflects in full the hazards and associated controls particular to that practice.
The inspector will seek to establish that the annual safety statement review is signed and dated by a responsible person (usually practice owner) and brought to the attention of all staff.
Inspectors have found significant breaches of the legislation with respect to the absence or inadequate quality of risk assessment and safety statements.
Standard operating procedures
Secondly, inspectors have requested access to the practice-specific standard operating procedures (SOPs) relating to the autoclaving of dental instruments.
These SOPs are assessed to ensure that they include the use of appropriate PPE, along with procedures for the segregation and separation of clean and contaminated equipment.
Hand hygiene
Thirdly, inspectors look at the patient treatment rooms, as these must contain a sink that is exclusively designated for hand hygiene, with hot and cold running water, soap and a dedicated means of drying hands.
A recent inspector’s report obliged a practice to install an additional hand hygiene sink in a surgery.
Legionnaires’ control plan
Fourthly, each practice is legally obliged to have a site-specific legionnaires’ control plan based on the HPSC’s national guidelines (2009).
This control plan must be done by a competent person and should include, but not be limited to, SOPs and record keeping for cleaning, flushing, disinfection and maintenance of dental unit waterlines. These SOPs should include information on dealing with periods when the equipment is temporarily not in use, such as long weekends and holidays.
HPSC guidelines require dental practices to undertake a risk assessment on legionella prevention and control at least annually. In addition, periodic (six-monthly) testing of the efficacy of dental unit waterline cleaning, using validated procedures, is a requirement.
Note the practice’s legionnaires’ control plan should also include an assessment of the premises’ plumbing outlets and management of blind ends (dead legs) where water cannot flow in the pipe system.
Inspectors have reported a high number of practices that are non-compliant with their legionella prevention and control legal obligations.
Autoclave examination report
Fifthly, inspectors have requested access to the report of examination for each autoclave. This document, which has strict legal requirements, is sometimes referred to as the pressure vessel inspection (PVI). It should not be confused with a service or validation certificate.
Practice owners should be aware that autoclaves require three types of test certificates:
- Servicing
- Validation
- Pressure vessel testing.
A competent person must conduct the report of examination every 14 months or, on occasion, 26 months (testing frequency will depend on the type of autoclave).
Be prepared
Finally, when an HSA inspector issues their report, the range of topics covered is not exhaustive. Inspections tend to be thematic, usually focusing on specific elements of the overall management of health and safety in the workplace.
Practice owners need to remain aware that the health, safety and welfare at work legislation is wide-ranging, covering the four healthcare occupational hazard categories:
- Physical
- Chemical
- Biological agents
- Psychosocial.
In summary, recent HSA inspections have examined practices’ risk assessment and safety statement, SOPs for instrument decontamination, hand hygiene facilities, legionella control plan and a pressure vessel test report for each autoclave. This list is not exhaustive, but it gives an indication of the range and depth of topics inspected.
Is your practice HSA inspector ready? If in doubt, speak with a competent person or compliance professional.
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