Managing skin health at work
Work-related and occupational skin diseases are a well-known risk for employers. Some are relatively common, for example, contact dermatitis, which usually presents as an itchy rash caused by a contact with a substance, triggering an allergic reaction.
However, there are many more conditions that employers must be aware of too, including contact urticaria, acne, infective or mechanical skin disease, skin cancer and folliculitis, for example.
The conditions are usually classified by their source, with “occupational skin disease” capturing problems caused directly by work and “work-related skin diseases” reflecting any skin problem caused, or made worse, by work or the work environment.
According to statistics from the Health & Safety Executive (HSE) and the Labour Force Survey (LFS), there were, on average, 16,000 people a year (between 2019 and 2022) who had skin problems they regarded as being caused, or made worse, by work.
The LFS data shows that the prevalence of work-related skin problems, whilst variable, has remained relatively constant over the last ten years.
The risks to employers are not just related to the stipulations of the Health & Safet at Work Act 1974 and Control of Substances Hazardous to Health Regulations 2002 (as amended) (COSHH). There may be legal costs, productivity, employment and reputational costs associated with falling foul of the law.
The HSE can enter any UK business premises at any time to check for compliance with health and safety laws. In September 2023, the HSE issued 70 improvement notices to UK businesses, triggered by COSHH standards not being met. Generally, compliance with the law is much better value than remedial steps following HSE enforcement.
The size of the problem
Although some 16,000 cases of work-related (or potentially work-related) skin problems have been self-reported each year in recent years, the number of problems proven to be caused by work is much lower.
An estimated 876 new cases of work-related contact dermatitis were diagnosed by dermatologists in 2019, which is the current best estimate of the prevalence of the problem. However, the risks and costs associated with just one case can be large for any single employer, so prevention (usually based on the principles of ‘avoid, protect, check’) is key.
You only need to put “skin at work compensation” into Google to get a sense of the number of ‘ambulance chasing’ law firms, with no win-no fee services, that could be a real problem for employers.
Whilst work-related skin problems can be quite common, they do occur far more frequently in some higher-risk job roles. Beauticians, cooks, florists, dental practitioners, printing, construction workers and metal workers frequently show up in monitoring statistics as higher-risk roles.
Coming into contact with chemicals, for example, cleaning agents, having wet hands for long periods or even exposure to the sun can easily cause problems. HSE statistics also show that about 53% of cases of contact dermatitis were allergic in nature and 60% were caused by other irritants (with a small proportion of cases having both allergic and irritant elements).
The most common conditions
Identifying skin diseases as work-related usually involves considering when the disease first appeared, if it gets better when away from work, and if there’s a likely cause in the work environment.
Contact dermatitis is skin inflammation caused by contact with chemicals or physical agents. There are two main types:
- Irritant contact dermatitis (ICD), which results from skin damage by irritants, but doesn’t involve allergies.
- Allergic contact dermatitis (ACD), which occurs in people with allergies to specific agents. It may take time to show up after exposure, but tends to occur upon re-exposure.
Contact urticaria (also called ‘hives’) is a temporary skin reaction that happens quickly after exposure and usually goes away after exposure stops. Other non-allergic skin issues include folliculitis (inflammation of hair follicles), acne, and skin diseases from exposure to bacteria, fungi, or viruses.
Mechanical skin disease can also result from physical damage due to certain occupations, such as repetitive tasks. Skin neoplasia (abnormal tissue growth) can occur from exposure to various chemical and non-chemical cancer-causing agents in the workplace.
What should I do about it?
The good news is that although these problems are common they are preventable. There are simple, cost-effective steps employers and workers can take to avoid skin problems at work, and to manage them if they do happen, using the approach advocated by the HSE; the Avoid, Protect and Check approach.
Avoiding direct contact between unprotected hands and substances, products and ‘wet work’ is the key first step. For example, where practical, an employer should consider:
- Eliminating use of the substance/product/wet work if possible
- Substituting the product or substance for an alternative if possible
- Following a comprehensive risk assessment, introduce controls (e.g. tools or equipment) to maintain a distance between skin and substances/products/wet work.
Protect the skin wherever possible. However, avoiding contact may not always be possible so:
- Provide suitable PPE, such as gloves. Glove selection can be complex, so it is worth checking on the HSE website for advice or seeking independent specialist advice.
- Do all you can to ensure workers wash their hands before eating and drinking, also before wearing gloves.
- Ensure you do all you can to encourage workers to wash any contamination from their skin quickly.
- Provide appropriate means for drying the skin and ensure workers are encourage to wash and dry their skin appropriately.
- Use commercial pre-work creams and encourage skin protection by moisturising as often as possible, definitely at the end of each day, which helps the skin to repair itself.
Either self-checking or with a colleague or a professional (like an occupational health advisor) check hands or other exposed areas regularly for the first signs of itchy, dry or red skin:
- Regularly checking the skin aims to spot the early signs of dermatitis, or other skin problems
- The sooner a problem is identified, the easier it is usually is to fix
- Regular checks can also show if good controls are being maintained, or provide an early indicator that controls are not working as they should
Understanding the risks
The first step towards preventing or controlling the exposure of skin to a source of potential irritation is to conduct an effective risk assessment.
As with any risk assessment, you must consider whether it is reasonably practicable to prevent the problem (the skin exposure). Sadly only the Courts can decide what is or what is not reasonable, although following the freely available advice (and templates) from the HSE is likely to be a good standard to start with.
If prevention is not reasonably practicable, the risk assessment should work out how to ensure adequate control of the skin exposure. The HSE says that COSHH Regulations are ‘goal setting’ and recognise that risk cannot always be eliminated. The aim is therefore to reduce the risk of the exposure.
Assessing skin exposure risk
When assessing the risk of skin exposure, you should consider the following:
- Chemical hazards: understanding the properties of the chemicals involved
- Health effects: knowing how these chemicals can affect health (specialist independent advice may be helpful)
- Exposure details: considering how, where, how often and for how long people are exposed to the chemicals
- Chemical quantity: assessing the amounts used, produced or present, including any by-products, waste, or released chemicals
- Type of work: recognising the nature of the work (emergency, maintenance, routine) and the work location (e.g. fixed or temporary).
- Control measures: evaluating the effectiveness of existing safety measures and controls identified during your risk assessment
- Monitoring data: include data from tests and monitoring, such as surface and skin contamination, and biological monitoring
- Health surveillance: consider professional surveillance and health-related data when the risks indicate it is prudent to do so
Recording a risk assessment
If your workplace has five or more employees, you must keep a record of:
- The risk assessment findings
- The steps to prevent or control risks, including administrative measures required by regulations
Reviewing your risk assessment
The employer should review the risk assessment when:
- The assessment is deemed invalid for any reason
- The nature of the work changes
- New information indicates that the assessment is no longer valid
Effective control of skin exposure to chemicals
When it’s not practically possible to completely prevent skin exposure to chemicals, employers must consider and apply the “principles of good control practice” for the specific work circumstances.
To ensure adequate control of skin exposure, the following steps are essential:
- Process design and operation: setting up processes and activities in a way that minimises the release of harmful substances
- Consider all exposure routes: thinking about how exposure can occur through the skin, ingestion and inhalation when developing control measures
- Proportional measures: implementing control measures that are proportionate to the health risks
- Effective controls: choosing the most effective and user-friendly control options, also considering ergonomics
- PPE: providing suitable PPE when other control measures may be insufficient
- Regular review: continuously checking and review the effectiveness of all control measures.
- Employee education: constantly informing and training employees about the hazards, risks and how to use control measures
- Overall risk management: ensuring that the control measures introduced do not increase overall health and safety risks
Monitoring dermal exposure
Before conducting dermal exposure monitoring, it’s essential to have a clear purpose and a plan for assessing the results’ significance. Dermal exposure monitoring serves to:
- Demonstrate the effectiveness of engineering and procedural controls in managing exposure
- Identify areas where controls are insufficient and require improvement, or confirm that additional measures are unnecessary
- Assess changes in employee exposure due to process or procedural changes
- The decision to perform dermal exposure monitoring should be based on factors like the COSHH assessment, the potential for serious health effects (like skin sensitisation or cancer) in case of control failure and the availability of suitable procedures.
As part of your risk assessment, you’ll also need to decide whether health surveillance is required. Health surveillance is designed for the protection of individuals, to identify any indications of disease, or adverse changes related to exposure, at the earliest opportunity. This is so that steps can be taken to treat the condition or to advise about future management. Similarly as reviewing exposure risks, it will also highlight if any controls are not working as intended.
However, the HSE are very clear that because skin tests which may be predictive, so looking towards future health, cannot be fully reliable, or because of ongoing exposure to toxins, dermatological health surveillance cannot be regarded as reducing the need for exposure controls or effect post-exposure decontamination.
COSHH Regulation 12 stipulates that whoever is carrying out skin assessment, evaluation, monitoring and health surveillance, or advising on the control of risks arising from exposure, should have adequate knowledge.
Many employers choose to delegate the work to, for example, occupational health practitioners, although it is possible that the work can be delegated to an employee, as long as they have suitable training to gain the relevant knowledge.
When is health surveillance necessary?
Health surveillance is needed when employees are exposed to potential harm from hazardous substances, such as skin irritants, even after implementing control measures.
The conditions for health surveillance to be required are:
- A substance is known to be linked to a specific disease or health issue
- There’s a reasonable chance of the disease or issue occurring in the workplace
- Valid methods exist for detecting signs of the disease or issue, without causing harm
Health surveillance might be appropriate in these types of situations:
- When employees are exposed to substances causing skin sensitisation (allergic contact dermatitis)
- When employees are exposed to substances causing urticaria
- In cases of past work-related skin diseases, like dermatitis or urticaria in the workforce
- Instead of relying solely on PPE as a control measure, which might not be totally effective
- In jobs with evidence of skin disease within the industry, like frequent contact with water commonly causing dermatitis in hairdressers and healthcare workers
- When employees are exposed to hexavalent chromium compounds causing skin issues, like chrome ulcers in platers
These are not exhaustive and there can be other instances where health surveillance is necessary. Your own risk assessment and potentially seeking independent specialist advice should inform your decision.
Health surveillance for occupational contact dermatitis
Health surveillance can be structured into tiers, to help understand the most effective approaches.
Higher-level health surveillance
This is usually appropriate when there’s clear evidence of a hazard and significant exposure. It involves:
- Assessing an employees’ skin condition before they start a job or piece of work
- Regular visual skin inspections by a designated person, with the frequency of inspection based on the risks identified
- Informing and advising employees about potential exposures and symptoms to watch for
- Educating employees on how and to whom they should report any symptoms between inspections
Lower-level health surveillance
This is for occasional or potential exposure when control is sufficient. It can include:
- An annual questionnaire administered by a trained person
- Informing employees about potential exposures and symptoms to watch for
- Educating employees on reporting symptoms
Who should conduct health surveillance?
A ‘responsible person’ within the organisation, trained to carry out health surveillance, should oversee the process. This is often delegated to an occupational health professional. This person should:
- Assess new employees’ skin condition
- Periodically check employees’ skin for early signs of disease
- Maintain records securely
- Report results to the employer for control measures and risk assessment review
- Advise the employer when expert help is needed, if skin problems are detected
The ‘responsible person’ can be an employee with the right training and should have knowledge of workplace substances, potential diseases, early signs of diseases, exposure methods, controls, and what to do in case of problems.
If skin problems are identified, the ‘responsible person’ should recommend consulting an appropriate health professional.
Engaging with an occupational health professional can help guide employers through whether surveillance or other controls may be appropriate, as well as carrying out surveillance activities. The Society of Occupational Medicine has a free ‘find a provider’ directory which lists just about every occupational health business in the UK. If consultancy support is required, the same website has a free ‘find a professional’ directory which may be helpful too.
The Commercial Occupational Health Providers’ Association also has a free ‘find a provider’ service, which may also be helpful too. Businesses should look out for an “SEQOHS” accreditation, as it means the provider has met independently assessed standards of provision (it’s a bit like ISO accreditation for occupational health).
If activities are to be conducted ‘in house’ consideration should be given to recent guidance from the Office of the Information Commissioner (see this article for more information) which places significant emphasis on the storage and maintenance of health records, which are a legal requirement for many businesses.