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Freddie  
#1 Posted : 11 October 2021 14:55:29(UTC)
Rank: New forum user
Freddie

Hi all

I have a staff member who is saying that their GP has diagnosed occupational dermatitis following use of a cleaning chemical at work

I understand occupational dermatitis should be reported under RIDDOR, but do I have to have official confirmation from the GP before doing so?

Any help much appreciated!

Thank you, Freddie

A Kurdziel  
#2 Posted : 11 October 2021 15:07:03(UTC)
Rank: Super forum user
A Kurdziel

This says when occupational dermatitis needs to be reported - https://www.hse.gov.uk/riddor/occupational-diseases.htm

 

At the bottom of the page it says “A reportable disease must be diagnosed by a doctor. Diagnosis includes identifying any new symptoms, or any significant worsening of existing symptoms. For employees, they need to provide the diagnosis in writing to their employer. Doctors are encouraged to use standard wording when describing reportable diseases on written statements they make out for their patients.”

Edited by user 11 October 2021 15:11:03(UTC)  | Reason: thought of something extra

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Freddie on 12/10/2021(UTC)
HSSnail  
#3 Posted : 11 October 2021 15:13:16(UTC)
Rank: Super forum user
HSSnail

Within the "interpritation" section  of the regs it states

diagnosis” means a registered medical practitioner’s identification (in writing, where it pertains to an employee) of—

(a) new symptoms; or
(b) symptoms which have significantly worsened;
So like the Guidance A refers you to.
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Freddie on 12/10/2021(UTC)
Evans38004  
#4 Posted : 11 October 2021 15:22:01(UTC)
Rank: Forum user
Evans38004

I had a smiliar issue over a decade ago, tour external office cleaners visited several sites / companies during a normal week, as well as solitary private cleaning of premises - we were the only one who insisted that they wear suitable skin protection. 

We asked the affected person to be skin-tested to see which product was causing the skin condition, turned out to be the most common cleaning product that used and she admitted to be using at home / at other locations without protection. Based on our Occ Health practitioner advice, we did NOT report the case. 

The individual did put a claim in against our comapny, which the insurance company (frustratingly) decided to pay out a small amount of compensation to avoid legal costs of court action - "you can't prove that the person was adequately supervised constantly" 

 

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Freddie on 12/10/2021(UTC)
peter gotch  
#5 Posted : 11 October 2021 15:24:13(UTC)
Rank: Super forum user
peter gotch

Hi Freddie

Quite a lot of ifs, whats and maybes in your question!

RIDDOR Reg 8 deals with occupational diseases.

Occupational diseases

8. Where, in relation to a person at work, the responsible person receives a diagnosis of……

……(c) occupational dermatitis, where the person’s work involves significant or regular exposure to a known skin sensitizer or irritant;

“Diagnosis” is a defined term in RIDDOR Regulation 1

“diagnosis” means a registered medical practitioner’s identification (in writing, where it pertains to an employee) of— (a) new symptoms; or (b) symptoms which have significantly worsened;

So, yes, something in writing + also you need to consider whether the dermatitis results from “significant or regular exposure to a known skin sensitizer of irritant”.

So, first does the diagnosis clearly link the dermatitis to occupational exposure; next is that cleaning fluid a known skin sensitiser or irritant - the Safety Data Sheet for the material should tell you this, assuming that you have the SDS and that it is compliant.

Then you have to consider whether the exposure has been "significant or regular" - depending on the job might be obvious, might not. Ultimately one that could only be determined by the Courts.

The enforcing authority can't take action if you report something that turns out to be not reportable. Can take action if you don't and it is reportable.

Sorry - can't give you a more authoritative answer!

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Freddie on 12/10/2021(UTC)
stevedm  
#6 Posted : 12 October 2021 07:57:37(UTC)
Rank: Super forum user
stevedm

firstly the GP isn't always qualified in Occupational Health - but is legally required to report it under riddor independantly of the site... IF and it is a big if he has actually done that you should reveive a copy...if what I suspect has happened is that he questionsed and the PT said I get it from work, doesn't always equal a diagnosis..

steps to take - either requested formal diagrnosis letter from PT or refer to OH for full assessment and confirmed diagnosis...you can report now but until you have a confirmed disganosis in your hand or at the very least a letter from his GP I would hold off..

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Freddie on 12/10/2021(UTC)
HSSnail  
#7 Posted : 12 October 2021 08:13:59(UTC)
Rank: Super forum user
HSSnail

Dont forget the commenest cause of occupatinal dermatitis (according to HSE) is that highly dangerouse chemical H20 - good luck getting a data sheet for that one. It could be caused simply by wet work in general

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webstar on 15/10/2021(UTC)
Kate  
#8 Posted : 12 October 2021 09:35:42(UTC)
Rank: Super forum user
Kate

There should be no difficulty in getting a safety data sheet for dihydrogen monoxide.  I received one from a chemicals supplier from whom I had purchased it in a purified form.  An important thing to note with it, documented in the first aid section, is that if you get it on your skin or in your eyes, you should wash it off with water.

thanks 2 users thanked Kate for this useful post.
HSSnail on 12/10/2021(UTC), CptBeaky on 12/10/2021(UTC)
stevedm  
#9 Posted : 12 October 2021 11:17:39(UTC)
Rank: Super forum user
stevedm

you know that Dihydrogen monoxide is water...don't you..

chris.packham  
#10 Posted : 12 October 2021 11:56:00(UTC)
Rank: Super forum user
chris.packham

I have lost count of the number of times I have been asked to help with a skin condition suspected of being occupational in origin. Of course, if there is a diagnosis in writing by a registered medical practitioner it has to be reported under RIDDOR. 

However, in many of the cases I investigated it was possible to show that the skin condition was not, or only partly, due to occupational exposures. 

You can break contact dermatitis into three main types - irritant, allergic and systemic. Ignoring systemic for the moment, with allergic contact dermatitis the appropriate test (patch test) will be needed to confirm the causative substance. This may not be mentioned on a safety data sheet. There are over 4,900 recognised skin sensitisers, many of which will not have been assigned H317 and thus will not appear on the safety data sheet. If the substance in the diagnosis if present in the workplace is there actual exposure? Daft question? No, i have seen situations where it was assumed that the diagnosis stated occupational contact dermatitis where an investigation failed to identify exposure. In one case the dermatitis, diagnosed as occupational allergy to formaldehyde turned out to be a non-occupational exposure due to metabolism of aspartame as a sweetener in fizzy drinks into formaldehyde!

Much more common is chronic irritant contact dermatitis. This is almost never to a single chemical but to an accumulation of skin damage from repeated exposures over time due to repeated exposures to many different irritants, at home as well as at work. Since we have no way of measuring the effect of each exposure simply stating that the diagnosis was to chemicl X is seldom realistic. If a GP believes that the dermatitis is irritant how will they decide if the exposure to one specific chemical in the workplace was the exclusive cause?

And of course, we can have a combination of allergic and irritant and systemic contact dermatitis. Systemic dermatitis is an allergic skin reaction caused by inhalation or ingestion of a sensitiser to which the person has become sensitised. 

Conclusion: This is just a superficial description of some of the complexities that can trap the unwary. There are over 100 constitutional diseases that can minic contact dermatitis. We had a case where a diagnosis of occupational urticaria (not dermatitis in this case, but indicates some of the complexity) to latex. Lady was sensitised to latex protein but not allergic. She could handle rubber with no problem if she thought it was plastic but would react to plastic if she thought it was rubber. (real diagnosis was undifferentiated idiopathic somatoform urticaria!)

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Freddie on 12/10/2021(UTC)
HSSnail  
#11 Posted : 12 October 2021 11:56:57(UTC)
Rank: Super forum user
HSSnail

Originally Posted by: Kate Go to Quoted Post

There should be no difficulty in getting a safety data sheet for dihydrogen monoxide.  I received one from a chemicals supplier from whom I had purchased it in a purified form.  An important thing to note with it, documented in the first aid section, is that if you get it on your skin or in your eyes, you should wash it off with water.

OK Kate you have me. Are you being ironic or did you get a data sheet? And if so did they not the posibility of contact dermatitis. As we Now water is an 8 letter word (HijklmnO)

Kate  
#12 Posted : 12 October 2021 13:00:59(UTC)
Rank: Super forum user
Kate

Yes, I have genuinely seen safety data sheets for deionised water and for distilled water.

Yes, one of them really did say that exposure should be treated by washing with water.

No, they did not mention dermatitis.

CptBeaky  
#13 Posted : 12 October 2021 13:16:44(UTC)
Rank: Super forum user
CptBeaky

To be fair, our alcohol hand sanitiser suggests wearing gloves when using the product......

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Kate on 12/10/2021(UTC)
chris.packham  
#14 Posted : 12 October 2021 16:16:11(UTC)
Rank: Super forum user
chris.packham

I have a safety data sheet for a product called a 'non solvent cleaner'. The active constituent is a diester solvent!

I have a file of safety data sheets. The label reads 'Works of Fiction'.

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Kate on 12/10/2021(UTC)
chris.packham  
#15 Posted : 12 October 2021 16:19:57(UTC)
Rank: Super forum user
chris.packham

'An irritant is defined as any agent, physical or chemical, capable of producing cell damage. Everything can be an irritant if applied for sufficient time and in sufficient concentration. Water, being the most abundant element of the skin, is usually regarded as banal and gentle. However, the irritancy of water is beyond doubt.'

From  Dermatotoxicology, second edition, Zhai H, Maibach HI, CRC Press

Holliday42333  
#16 Posted : 13 October 2021 08:00:13(UTC)
Rank: Super forum user
Holliday42333

Originally Posted by: CptBeaky Go to Quoted Post

To be fair, our alcohol hand sanitiser suggests wearing gloves when using the product......

All liquid hand soaps say that on the SDS too!  Oh and 'Avoid contact with skin'

Going back to SDSs for water; a chemicals company selling lab reagent (pure) water used to provide, in the early '90's an MSDS that clearly stated 'fatal by ingestion'.  This is technically true but unhelpful in context.  It got amended when Allan St John Holt referenced it in one of the editions of his, unofficial, NEBOSH Cert study guides.

(only the long of tooth will remember the name of Allan St John Holt and the fact he was aslo a regular contributor to these forums, both publically and via PM)

Edited by user 13 October 2021 08:13:05(UTC)  | Reason: Spelling etc in the absence of a spellchecker

thanks 3 users thanked Holliday42333 for this useful post.
HSSnail on 13/10/2021(UTC), Kate on 13/10/2021(UTC), peter gotch on 13/10/2021(UTC)
HSSnail  
#17 Posted : 13 October 2021 08:50:04(UTC)
Rank: Super forum user
HSSnail

(only the long of tooth will remember the name of Allan St John Holt and the fact he was aslo a regular contributor to these forums, both publically and via PM)

I remember Allan - but would not describe myself as long in tooth more gummy not many teath left! All this goes to show the problems faced by us mear mortal pratictioners when trying to deal with COSHH in particular.

peter gotch  
#18 Posted : 13 October 2021 10:39:50(UTC)
Rank: Super forum user
peter gotch

Does remind us that these Forums were around long before their revamp in 2009.

....and that OSH professionals and others have been trying to help people with their questions here for a very long time.

stevedm  
#19 Posted : 14 October 2021 07:47:10(UTC)
Rank: Super forum user
stevedm

all of this is good debate, but the key issue is that you need a formal diagnosis before anything else...and the GP might not be the person best placed to give it...refer to OHP and get formal diagnosis...

chris.packham  
#20 Posted : 14 October 2021 10:39:38(UTC)
Rank: Super forum user
chris.packham

Agreed, if no other specialised help available referral to an OHP is the best route. Much skin disease is caused by more than one exposure to more than one chemical. So where there is a reasonable assessment that there may have been an occupational exposure as a causative factor it is necessary that any diagnosis should include this in the diagnosis. A GP is, in my experience, seldom in the position to do this. Almost always it will involve someone with the appropriate knowledge about skin and its interaction with the immediate environment visiting the workplace to identify any potential and relevant sources of exposure. If it is decided that a clinical diagnosis is required then the dermatologist will need the appropriate briefing. Otherwise there is a real possibility of what I call a 'clinically accurate, occupationally irrelevant' diagnosis. Of course, any investigation and diagnosis must also include any relevant non-occupational exposures and personal conditions, e.g. atopy, that may be relevant. 

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