Primary Care Health and Safety

The Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999 set the baseline. The Control of Substances Hazardous to Health Regulations 2002 cover disinfectants, mercury and amalgam, anaesthetic gases, cytotoxics, latex and biological agents. The Health and Safety (Sharp Instruments in Healthcare) Regulations 2013, SI 2013/645, supplement COSHH rather than replace it. The Ionising Radiations Regulations 2017 protect workers and the public and are enforced by HSE. The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, protect patients and are enforced in England by CQC. The Pressure Systems Safety Regulations 2000 require a written scheme of examination for autoclaves and compressed gas systems. The Environmental Protection Act 1990 section 34 duty of care, the Hazardous Waste (England and Wales) Regulations 2005 and the Waste (England and Wales) Regulations 2011 govern healthcare waste. Registration in England runs under the Health and Social Care Act 2008 and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, SI 2014/2936. Controlled drugs sit under the Misuse of Drugs Act 1971, the Misuse of Drugs Regulations 2001 and the Misuse of Drugs (Safe Custody) Regulations 1973.

CQC registration for GP and dental practices

In England a provider carrying on a regulated activity must be registered. The activities that catch primary care are the treatment of disease, disorder or injury, diagnostic and screening procedures, surgical procedures, maternity and midwifery services, family planning, plus transport services, triage and medical advice provided remotely. The fundamental standards that carry the safety weight are regulation 12 on safe care and treatment, regulation 15 on premises and equipment, regulation 17 on good governance and regulation 18 on staffing. Infection prevention and control sits inside regulation 12, informed by the Code of Practice on the prevention and control of infections. We deliberately do not name a current CQC assessment framework or quality statement structure on this page. CQC's assessment approach has been in flux since the 2024 independent reviews and we would rather check the position for your inspection than publish something that reads confident and is out of date.

Decontamination, waste and sharps

HTM 01-05, decontamination in primary care dental practices, remains live. Its publication page shows original publication in March 2013 with a last update in January 2024 and no withdrawal or supersession recorded, which is itself a notable fact given the base date. It is England-only. Scotland, Wales and Northern Ireland use their own guidance. In scope: the instrument decontamination cycle from cleaning through inspection, sterilization and storage, washer-disinfectors and ultrasonic baths, benchtop steam sterilizers with validation and periodic testing, separation of dirty and clean, hand hygiene, personal protective equipment, water quality including dental unit waterlines and single-use item policy.

Healthcare waste follows HTM 07-01, Safe and sustainable management of healthcare waste. We cite it by title rather than by version year, since we could not confirm whether a revision has been issued since 2021. What matters operationally does not turn on the year: correct segregation into the colour-coded streams, the right sharps container lid for medicinally contaminated, non-medicinally contaminated and cytotoxic sharps, waste carrier checks, consignment notes retained for three years and a periodic waste audit. Dental amalgam is separately controlled and requires amalgam separators with specialist disposal.

The Sharp Instruments Regulations 2013 are short and are enforced. Avoid the unnecessary use of sharps. Where sharps cannot be avoided, use safer sharps with a protection mechanism where reasonably practicable. Prevent recapping. Place secure containers and disposal instructions close to the work area. Train people. Have arrangements for prompt response to an injury including post-exposure prophylaxis and hepatitis B immunisation. Record and investigate. Report under RIDDOR 2013 where the criteria are met.

Radiography, pharmacy and veterinary practice

For dental radiography the two regimes run in parallel. Under IRR17 you notify or register with HSE, appoint a Radiation Protection Adviser and a Radiation Protection Supervisor, carry out a prior risk assessment, produce local rules and designate a controlled area, arrange critical examination of newly installed equipment and maintain engineering maintenance and quality assurance. Staff in a typical dental practice are usually not classified persons and dosimetry may not be required. That has to be the documented output of the risk assessment rather than an assumption. Under IRMER 2017 the employer, referrer, practitioner and operator must all be identified in writing, with written procedures, justification of every exposure, optimisation, diagnostic reference levels, clinical audit, equipment quality assurance, training records for each entitled role and notification to CQC of clinically significant accidental or unintended exposures.

For pharmacy the premises standards are the General Pharmaceutical Council's Standards for registered pharmacies, revised in June 2018. Five principles run from governance through staffing, the environment and condition of the premises, safe handling of medicines and medical devices, to equipment and facilities fit for purpose. GPhC is consulting on new standards and rules following new legislation. We describe that as in progress, since we could not verify the outcome or the timetable. Controlled drugs bring the safe custody cabinet, the register with running balances and no alterations, witnessed destruction with denaturing, standard operating procedures and, where required, a Controlled Drugs Accountable Officer under the Controlled Drugs (Supervision of Management and Use) Regulations 2013. The health and safety consequence of holding controlled drugs is robbery and violence risk, which drives the lone worker risk assessments we do for branch and out of hours working.

For veterinary practice the Royal College of Veterinary Surgeons Practice Standards Scheme operates through modules and awards, at Core Standards, General Practice and Veterinary Hospital levels. It is voluntary, it is not statutory and accreditation discharges none of your duties under the 1974 Act. The distinctive hazards are waste anaesthetic gas, radiography and animal handling. On anaesthetic gas we specify active scavenging ducted outside or passive scavenging with charcoal canisters weighed and replaced rather than run to exhaustion, leak testing of the circuit and machine before every list, cuffed tubes and correctly fitting masks in preference to chamber induction, adequate room air change rates and exposure monitoring where the assessment cannot otherwise demonstrate control, with particular attention to pregnant staff. We do not publish exposure limits for the volatile agents on a web page, since the position differs by agent and needs reading against the current edition of EH40. On radiography, the veterinary problem is manual restraint putting hands near the primary beam. The right answer is sedation or general anaesthesia with positioning aids so that nobody holds the animal, with holding permitted only exceptionally and under strict conditions. IRMER does not apply because the patient is an animal. The whole protective burden falls on IRR17. Zoonoses are COSHH biological agents, covering leptospirosis, ringworm, toxoplasmosis, psittacosis, Q fever, campylobacter and salmonella. HSE has no dedicated veterinary practice guidance suite. Its zoonoses and veterinary medicines pages are agriculture-facing. Anyone implying otherwise has not looked.

We work with practice managers, principals and partners. We scope the work so that it lands as a short prioritised list rather than a folder nobody opens.

• Practice health and safety audit covering the full duty set, mapped to the standards your inspector will use rather than to a generic checklist.
• Legionella risk assessment and written scheme covering the building system and the dental unit waterlines, including flushing at the start and end of sessions, waterline disinfection, anti-retraction valves, sampling frequency and action levels.
• Decontamination review against HTM 01-05, covering room layout, workflow, validation and periodic test records for benchtop sterilizers and washer-disinfectors.
• Written scheme of examination and competent person inspection for autoclaves and compressed gas systems under the Pressure Systems Safety Regulations 2000, scoped and arranged by us end to end.
• COSHH assessments for clinical chemicals, anaesthetic agents, cytotoxics and disinfectants, with a scavenging and monitoring strategy where volatile agents are used.
• Radiation arrangements review covering the prior risk assessment, local rules, controlled area, RPA and RPS appointments, critical examination and the IRMER written procedures and entitlement records.
• Sharps policy and safer-device implementation review, with the post-exposure pathway tested rather than assumed.
• Waste segregation and duty of care audit, covering carrier checks, consignment notes and amalgam separation.
• Violence and aggression risk assessment for reception and dispensing areas, plus lone working arrangements for branch sites, home visits and on-call.
• Fire risk assessment for the premises, including BAFE SP205 third-party certified fire risk assessments, independently certificated by SSAIB, where you want external assurance.