Programme 04 · Control of Substances Hazardous to Health 2002
Skin health surveillance and occupational dermatitis
Occupational contact dermatitis is common, under-reported and frequently dismissed as dry hands until it is bad enough to stop someone working. It is also the cheapest programme to run properly, which makes it the one most worth not skipping.
The cheapest programme to run properly, and the one most often skipped. Caught early, most cases are solved by changing the work.
The duty
What COSHH requires
Where workers are exposed to substances that can damage the skin, and there is a reasonable likelihood of that damage occurring under the conditions of the work, COSHH requires health surveillance. For skin this is straightforward and inexpensive: a baseline check, then regular structured skin checks, with referral when something is found.
Two distinct conditions are in scope. Irritant contact dermatitis is direct damage from repeated contact with water, detergents, solvents or friction, dose-related and usually improvable. Allergic contact dermatitis is an immune sensitisation to a specific agent; once established, tiny exposures can trigger it, and the worker generally cannot go back to that agent.
Who is in scope
Wet work and the common sensitisers
Wet work is the most widespread trigger and the most often overlooked. It is generally treated as significant where hands are wet for roughly two hours or more a shift, where hands are washed very frequently through the shift, or where occlusive gloves are worn for extended periods, because sweat inside a glove damages skin much as water outside it does.
| Agent or activity | Typical settings |
|---|---|
| Wet work and frequent handwashing | Food production, catering, healthcare, cleaning, hairdressing |
| Metalworking fluids | Machining, turning, grinding, CNC |
| Wet cement and chromate | Construction, groundworks, concrete and screeding |
| Epoxy resins and hardeners | Composites, flooring, coatings, wind and marine |
| Solvents, degreasers and thinners | Maintenance, paint shops, print |
| Rubber chemicals and glove accelerators | Any setting with heavy glove use |
| Hairdressing chemicals | Colouring, bleaching, shampooing |
The programme
What skin surveillance involves
- Baseline skin assessmentA short questionnaire and a look at the hands and forearms before or shortly after exposed work starts, recording any pre-existing condition so later changes are interpretable.
- Regular structured checksRoutine checks at intervals set by the risk, which a trained responsible person can carry out for most workers most of the time. The questions are simple and consistent: is the skin dry, red, itchy or cracked, and does it improve away from work.
- Referral on findingsAnything suggestive routes to an occupational health professional for assessment, advice to the worker, and advice to you on controls and on that worker's continued exposure.
- Advice that is actually actionableMost early skin problems are solved by changing the task, the glove, the frequency of contact or the aftercare rather than by removing the worker.
When something is found
Occupational dermatitis is reportable
Occupational dermatitis diagnosed by a doctor is reportable under RIDDOR where the worker's work involves significant exposure to a known skin sensitiser or irritant. As with the other programmes, a confirmed case is evidence about the controls: review the risk assessment for the task, and consider everybody else doing it.
Skin is also the programme where early detection changes the outcome most reliably. Irritant dermatitis caught early usually resolves with changes to the work. Allergic sensitisation, once established, is generally permanent, and the worker cannot return to that agent.
How Polarisk runs it
The programme, without the administration
The duty is mapped
Roles map to skin surveillance on the exposure criteria, so the list of who is owed an assessment is derived rather than remembered. Workers who need none are evidenced as such.
Each worker answers privately
A single-use link, bound to that person at issue and spent on use. Your organisation's own account is refused at the answers.
Protocol triages, a human judges
Responses are scored against the protocol and drafted for review. A registered clinician reads every case and signs under their own name and registration number.
The cycle runs itself
Due dates, reminders and lapse tracking are handled. You are told who has not answered, by name, while there is still time to act.
Evidence is generated
The audit pack comes from the live record: duty map, completion by site, certificate register and the sign-off trail behind each judgment.
Appointed-Doctor streams
Asbestos, lead, ionising radiation and compressed air require an HSE Appointed Doctor. We do not run those, and will say so rather than quote for them.
Questions
Common questions
Is dry, cracked skin really a legal matter?
It can be. Occupational contact dermatitis is a recognised occupational disease, it is reportable under RIDDOR where the criteria are met, and it grounds civil claims. It is also the classic case of a condition normalised into invisibility: workers assume rough hands come with the job and do not report it, which is exactly why the duty is to check rather than to wait for a complaint.
Do our own supervisors have to be clinicians to run skin checks?
No. Routine skin checks can be carried out by a trained responsible person, which is what makes the programme affordable to run at proper frequency. What they must not do is interpret findings or decide about fitness. Anything abnormal routes to an occupational health professional, and Polarisk routes it automatically so it cannot be quietly closed.
How often should skin checks happen?
More often than most other programmes, because skin changes fast and is easy to inspect. The interval is set by the risk: high-exposure wet work or strong sensitisers warrant frequent checks, lower-risk work less often. Baseline first, then a regular cycle, with escalation whenever something is reported between checks.
What is the difference between irritant and allergic dermatitis, and why does it matter?
Irritant contact dermatitis is direct damage from repeated contact and is broadly dose-related, so reducing contact usually improves it. Allergic contact dermatitis is an immune sensitisation to a specific agent: once sensitised, very small exposures can trigger a reaction. The distinction determines whether the answer is better controls or removal from that agent entirely, which is why it needs a clinical assessment rather than a manager's judgment.
Can we combine skin checks with our other surveillance?
Yes, and it is usually the sensible thing to do. Most workers in scope for skin surveillance are in scope for something else too. Polarisk maps each worker to all the programmes their role triggers and runs the cycles together, so one person is not asked to respond four separate times a year for four separate programmes.
Start here
Find out what you owe before an inspector does
Four questions about your workforce and its exposures. You will get an estimate of the assessments owed each year, by programme, and where your current arrangement leaves a gap. No sign-up and no personal data.