Once basic health and safety procedures are in place in the dispensary , practices must look at compliance with the second tier of legal requirements.
Risk management is at the top of this list. There are five steps to this process: defining what is a hazard and what is a risk; identifying hazards; evaluating risks and deciding on precautions; recording findings; and implementation and assessment.
Hazards and risks
A hazard is defined as something that exposes one to risk; a risk is something that might give a degree of danger or chance of injury.
When starting to write the policy, set the scene, noting that the risk assessment carried out for the practice as a whole is very different to that prepared for the dispensary.
The areas that need special attention are those requiring a standard operating procedure (SOP), so the paperwork should be simple to replicate.
Briefly, the main areas for concern are: taking in prescription requests; processing repeat prescriptions; assembling and labelling prescriptions; transferring dispensed items to the patient; ordering and unpacking stock; personally administered items; and error procedures.
Equipment in the dispensary, including electrical items of any sort, plus seating, steps or stools, should also be included in any risk assessment. As with an SOP, someone must be responsible for this policy and dates set for its review.
The Control of Substances Hazardous to Health (COSHH) regulations require all employers to identify hazardous substances at work; assess the risks; minimise the risks; inform all employees of hazards; and train all employees on risks and precautions.
Assessments may be written or verbal. However, it is always preferable to have a hard copy and it is important that dispensing staff know where to access the information.
For this reason, it is wise for dispensary assessments to be carried out by senior dispensing staff, although practice managers may wish to have an input.
Having identified a hazardous substance, ask yourself it is really needed and, if necessary, dispose of it safely, recording the event. If the item is needed it should be used and stored correctly.
Cleaning substances, particularly bleach, need to be included in this category if they are kept in the dispensary, even though they may also be included in a COSHH assessment for the whole practice.
It is probably more efficient to use and store cleaning substances away from the dispensary so there is no need to include them in the dispensary assessment.
The prevention of infection in the dispensary is closely linked to any COSHH assessment as the hazardous substances included in the policy are likely to be the ones that pose a risk of infection.
Biological samples, ingredients of mixtures, caustics, cytotoxics, needles and ampoules should all be treated with care.
Disposal of clinical waste may not be solely a dispensing function, so practice and dispensary policies should dovetail. To minimise any risk to dispensing staff, protective clothing such as disposable gloves, aprons and masks should always be available and the staff instructed to use them when dealing with any hazardous substance.
Since procedures for disposal of sharps and ampoules should already be included in the SOP portfolio, it is essential that all dispensing staff are up to date with these instructions and sign when the SOPs are reviewed.
If the event of an incident
If an incident does occur, a full report should be produced and should tell the reader: what happened; how and why it happened; and what action was taken.
A copy of this report should remain in the dispensary for reference and the SOP should be updated to ensure that a repeat of the incident will not occur.
A policy statement for all these issues must be included in new contracts of employment, for example: 'the practice believes in taking all reasonable steps to ensure the health, safety and welfare of employees and others affected by surgery activities'.
Once these assessments have taken place and the documentation has been seen by all relevant staff, a yearly update will be all that is required.
- Annette Arthur is a consultant for dispensing practices.
- Control of Substances Hazardous to Health http://www.hse.gov.uk/coshh/