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{{org_field_name}}
Registration Number: {{org_field_registration_no}}
Safe Use of Emollients and Fire Risk Management Policy
1. Purpose
This policy sets out the arrangements used by {{org_field_name}} to ensure that emollients are used, stored and managed safely and that the associated risk of fire is identified, assessed and reduced as far as reasonably practicable.
Emollients themselves are not necessarily flammable when applied to the skin. However, all types of emollient, including paraffin-containing and paraffin-free products, can transfer from the skin onto clothing, bedding, dressings, towels, upholstery and other fabrics. Repeated contamination can cause residue to build up within the fabric. Contaminated fabric can ignite more easily and may burn more rapidly and intensely when exposed to an ignition source, creating a risk of serious or fatal burns.
The fire risk must therefore be considered for every person who uses an emollient and must not be limited to products containing paraffin or to products carrying a specific flammability warning.
{{org_field_name}} will assess and manage emollient-related risks as part of the person’s individual care planning and risk assessment arrangements and as part of the premises fire risk assessment.
This policy supports compliance with:
- the Health and Social Care Act 2008;
- Regulation 12 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Safe Care and Treatment;
- Regulation 15 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Premises and Equipment;
- Regulation 17 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Good Governance;
- Regulation 18 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Staffing;
- the Regulatory Reform (Fire Safety) Order 2005; and
- current Medicines and Healthcare products Regulatory Agency (MHRA) and Care Quality Commission (CQC) guidance concerning the fire risk associated with emollient products.
The organisation will ensure that people using the service, their representatives where appropriate, staff and other relevant persons are provided with information about emollient-related fire risks and the precautions required to reduce those risks.
2. Scope
This policy applies to:
- All staff members including carers, nurses, and ancillary workers.
- People we support who require emollient creams for skin conditions.
- Visitors and family members involved in personal care.
- Fire safety officers and emergency responders within our care home premises.
3. Related Policies
This policy is closely linked with:
- CH11 – Safe Care and Treatment Policy
- CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy
- CH16 – Health and Safety at Work Policy
- CH17 – Infection Prevention and Control Policy
- CH18 – Risk Management and Assessment Policy
- CH20 – Fire Safety and Evacuation Procedures Policy
- CH21 – Medication Management and Administration Policy
- CH22 – Handling and Disposal of Hazardous Substances Policy
4. Safe Use of Emollients
4.1 Selection, Supply and Use of Emollients
Emollients must be used in accordance with the person’s assessed needs, prescription or dispensing label where applicable, manufacturer’s instructions and care plan.
Where staff support a person to use a non-prescribed emollient, the product must be identified and the person’s care plan and risk assessment must reflect its use where this is relevant to their care or safety.
Staff must not assume that a paraffin-free or water-based emollient presents no fire risk. The fire-safety precautions contained within this policy apply to all emollients because residues from both paraffin-containing and paraffin-free products may contaminate clothing, bedding, dressings, towels, upholstered furniture and other fabrics.
Staff must check the product label, packaging and patient information supplied with the product and follow any specific safety warnings.
4.2 Application and Personal Care
Emollients must be applied in accordance with the prescription, dispensing instructions, manufacturer’s directions and the person’s care plan. Staff must not alter the amount or frequency of application solely for the purpose of reducing fire risk unless this has been agreed with an appropriate healthcare professional.
Staff must practise appropriate hand hygiene following application and must take reasonable steps to prevent unnecessary transfer of emollient residue onto towels, furniture and other fabrics.
People using emollients, and their representatives where appropriate, must be informed that clothing, bedding, dressings and other fabrics contaminated with emollient residue can ignite more easily and burn more rapidly and intensely.
People using emollients must be advised:
- not to smoke while wearing clothing, dressings or other fabrics that may be contaminated with emollient residue;
- not to use candles or other naked flames;
- to keep contaminated clothing, bedding and other fabrics away from open fires, heaters and other potential ignition or high-temperature heat sources; and
- to tell staff about any smoking, cooking, heating or other activity that could increase their individual fire risk.
Where a person chooses to smoke or undertake another activity involving an ignition source, this must not be managed solely by giving verbal advice. An individual, person-centred risk assessment must identify appropriate control measures that respect the person’s rights while reducing the risk as far as reasonably practicable.
4.3 Clothing, Bedding and Other Fabrics
Clothing, bedding, towels, dressings, throws and other washable fabrics that may become contaminated with emollient residue must be changed and washed frequently in accordance with the person’s assessed risk and the manufacturer’s or fabric care instructions.
Items must be washed at the highest temperature permitted by the item’s care instructions. Staff must not assume that washing, including washing at high temperatures, completely removes emollient residue or eliminates the associated fire risk.
Where emollient residue may transfer onto upholstered furniture, mattresses, cushions or other items that cannot readily be washed, appropriate washable and replaceable coverings must be considered as part of the person’s individual risk assessment.
Contaminated fabrics must continue to be treated as presenting an increased fire risk even after washing.
4.4 Individual Emollient Fire Risk Assessment and Care Planning
An individual emollient fire risk assessment must be completed where a person uses an emollient and there is a foreseeable risk arising from transfer of the product onto clothing, bedding, dressings, towels, furniture or other fabrics.
The assessment must be proportionate to the individual circumstances and must consider, where relevant:
- the type of emollient used and the frequency and extent of application;
- whether the product is applied over large areas of the body;
- whether dressings, bandages, clothing or bedding are likely to become contaminated;
- smoking or access to cigarettes, lighters, matches or smoking materials;
- candles, open fires, gas appliances, cookers and other naked flames;
- portable heaters, electric bar heaters, halogen heaters or other heat sources;
- the person’s mobility and ability to move away from danger;
- cognitive impairment, learning disability or other factors affecting understanding of the risk;
- sensory impairment;
- the person’s ability to summon assistance;
- oxygen therapy or other equipment that may increase fire risk;
- the person’s usual seating and sleeping arrangements;
- the frequency with which clothing, bedding and other fabrics are changed and laundered;
- contamination of upholstered furniture or other items that cannot readily be washed; and
- any previous fire incident, near miss or unsafe practice.
The identified risks, control measures and relevant instructions for staff must be clearly recorded in the person’s care plan and risk assessment.
Where an individual’s emollient use materially affects their ability to evacuate safely or increases their exposure to fire, the information must also be reflected, where relevant, in their Personal Emergency Evacuation Plan or other individual evacuation arrangements.
The assessment must be reviewed whenever there is a relevant change in the person’s circumstances, treatment, emollient use, smoking behaviour, environment, mobility, cognition or fire risk, following an incident or near miss, or where there is reason to believe that the existing assessment is no longer suitable or sufficient.
4.5 Staff Training
Staff whose duties may involve supporting people who use emollients must receive appropriate information, instruction and training before carrying out those duties independently.
Training must include:
- the fire risk associated with all emollients, including paraffin-free products;
- how emollient residue transfers to fabrics and can accumulate over time;
- recognition of common ignition and heat sources;
- correct application and handling in accordance with the person’s care plan;
- precautions relating to clothing, bedding, dressings, towels, furniture and other fabrics;
- the importance and limitations of laundering contaminated fabrics;
- individual fire-risk assessment and care planning;
- action to take where a person smokes or is exposed to other ignition sources;
- emergency procedures; and
- reporting of incidents, near misses and changes in risk.
Training must be refreshed periodically and whenever changes in guidance, identified risk, staff competence or service arrangements indicate that refresher training is required.
The Registered Manager must maintain sufficient records to demonstrate that relevant staff have received the required training and are competent to follow this policy.
5. Fire Risk Management and Prevention
5.1 Fire Safety Measures
Emollient-related fire risks must be incorporated into the home’s overall fire-safety arrangements and fire risk assessment.
The service must identify potential ignition and heat sources and ensure that appropriate measures are in place to reduce the risk of contaminated fabrics coming into contact with them.
People using emollients, staff and relevant visitors or representatives must be given appropriate information about the risk and the precautions required.
Smoking, candles, naked flames, open fires, heaters and other ignition or heat sources must be considered within individual and premises fire risk assessments where relevant.
Where a person who uses emollients smokes, an individual risk assessment and appropriate control measures must be in place. The person’s smoking arrangements must be consistent with the home’s fire-safety arrangements and must reduce the risk associated with contaminated clothing and other fabrics as far as reasonably practicable.
Any warning signs used by the service must be based on assessed need and must not replace individual risk assessment, care planning, staff communication or other necessary control measures.
5.2 Fabrics, Furnishings and Fire-Safety Equipment
Fire-resistant or fire-retardant bedding, clothing, furniture coverings or other specialist materials must not be relied upon as the sole control for emollient-related fire risk.
Where specialist bedding, clothing, furniture coverings or other equipment is identified as necessary by the fire risk assessment or individual risk assessment, it must be suitable for its intended purpose, maintained appropriately and used in accordance with the manufacturer’s instructions.
Clothing, bedding, dressings, towels, upholstery and other fabrics contaminated with emollient residue must continue to be regarded as presenting an increased fire risk.
Fire detection, alarm and fire-fighting equipment must be appropriate to the risks identified in the premises fire risk assessment, correctly located, maintained and available for use in accordance with the home’s fire-safety arrangements.
Staff must not select or use a particular type of fire extinguisher solely because an emollient is involved. Any attempt to use fire-fighting equipment must be consistent with staff training, the premises fire procedure and the specific type of fire involved.
5.3 Emergency Procedures
If a fire or suspected fire involving a person who uses emollients or emollient-contaminated fabrics occurs, staff must:
- raise the alarm immediately in accordance with the home’s fire procedure;
- summon the Fire and Rescue Service in accordance with the home’s emergency arrangements;
- implement the home’s evacuation or fire strategy without delay;
- move people away from immediate danger where this can be done safely and in accordance with their evacuation arrangements;
- follow the person’s Personal Emergency Evacuation Plan or other individual evacuation arrangements where applicable;
- not place themselves or others at unnecessary risk by attempting to fight the fire;
- use fire-fighting equipment only where they have been trained and it is safe and appropriate to do so;
- obtain urgent medical assistance for anyone who has sustained burns, smoke inhalation or other injury; and
- preserve relevant information and evidence following the incident where this can be done safely.
An emollient-related fire, suspected fire or near miss must be reported promptly to the Registered Manager or person in charge and managed under the organisation’s incident reporting and fire-safety procedures.
Following any incident or near miss, the person’s individual risk assessment, care plan, evacuation arrangements and the premises fire risk assessment must be reviewed where relevant.
6. Monitoring, Compliance and Review
6.1 Fire Risk Assessments and Individual Risk Management
The premises must have a suitable and sufficient fire risk assessment completed and maintained in accordance with the Regulatory Reform (Fire Safety) Order 2005.
The premises fire risk assessment must be reviewed regularly and must be reviewed where there is reason to suspect that it is no longer valid or where there has been a significant change in matters to which it relates. Relevant findings and required control measures must be recorded and acted upon.
Emollient use and associated fire hazards must be included within the premises fire risk assessment where relevant.
Individual emollient fire risk assessments must be maintained for people whose emollient use creates a foreseeable fire risk and must be reflected within their care plan and evacuation arrangements where applicable.
Individual assessments must be reviewed when circumstances change, including changes to:
- the emollient or frequency of use;
- the area of the body to which the emollient is applied;
- smoking behaviour;
- access to ignition or heat sources;
- mobility;
- cognition;
- sensory ability;
- oxygen use;
- room or sleeping arrangements;
- laundering arrangements; or
- any other factor that could materially change the fire risk.
An individual assessment must also be reviewed following an emollient-related fire, near miss or other evidence that existing control measures may not be effective.
Fire drills and emergency exercises must be undertaken at appropriate intervals in accordance with the premises fire risk assessment and fire-safety arrangements. The effectiveness of arrangements for people who require assistance to evacuate must be considered when evaluating drills.
6.2 Incident Reporting, Investigation and External Notifications
Any emollient-related fire, suspected fire, significant unsafe occurrence or near miss must be reported without delay to the person in charge and the Registered Manager.
The Registered Manager must ensure that the incident is appropriately investigated and that relevant records are retained.
The investigation must consider:
- the source of ignition or heat;
- the person’s emollient use;
- clothing, bedding, dressings, towels, furnishings or other contaminated materials involved;
- whether existing risk assessments were adequate;
- whether care plans and evacuation arrangements were followed;
- whether staff had received appropriate training;
- whether any equipment, environmental or procedural failure contributed to the incident;
- whether any other people may be exposed to the same risk; and
- what immediate and longer-term corrective action is required.
Following an incident or near miss, relevant risk assessments, care plans, fire procedures and control measures must be reviewed and amended where necessary.
The Registered Manager must consider whether the incident meets the criteria for notification to the Care Quality Commission under the Care Quality Commission (Registration) Regulations 2009.
Where a statutory notification is required, it must be made to CQC without delay and using the current CQC notification process.
This includes, where applicable, incidents involving:
- a notifiable serious injury to a person using the service;
- police involvement;
- damage to the premises that affects, or is likely to affect, the safe provision of care;
- failure or malfunction of fire alarms or other safety devices for the period specified by the Regulations; or
- another event that prevents, or threatens to prevent, the service from being carried on safely.
Where the circumstances constitute a notifiable safety incident under Regulation 20 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, the statutory duty of candour must also be followed.
Any other statutory reporting requirements arising from the circumstances of the incident must also be considered.
The office must be informed and the Registered Manager contacted at {{org_field_phone_no}}.
If the concern arises outside normal office hours, the designated out-of-hours contact must be used: {{out_of_hours}}.
6.3 Staff and Management Responsibilities
The Responsible Person for fire-safety purposes must ensure that the duties applicable to the premises under the Regulatory Reform (Fire Safety) Order 2005 are met and that the fire risk assessment takes account of relevant emollient-related risks.
The Fire Safety Lead, {{org_field_the_fire_safety_lead_name}}, must support implementation and monitoring of the fire-safety controls described in this policy within the limits of their role and competence.
The Registered Manager, {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}, is responsible for ensuring that:
- individual emollient-related fire risks are appropriately assessed and incorporated into care planning;
- staff receive appropriate information, instruction and training;
- relevant fire-risk control measures are implemented;
- incidents and near misses are reviewed and acted upon;
- required CQC and other statutory notifications are made;
- relevant records are maintained; and
- this policy is implemented and monitored effectively.
Care staff must:
- follow each person’s care plan and risk assessment;
- apply emollients in accordance with authorised instructions;
- follow the fire precautions identified for the person;
- record administration or application where this is required by the person’s medicines or care records;
- report any change that may increase fire risk;
- report contamination of fabrics or furnishings where additional action may be required; and
- report incidents, near misses or failures to follow agreed fire-safety arrangements promptly.
7. Policy Review
This policy will be formally reviewed at least annually and sooner where necessary.
An earlier review must take place where:
- relevant legislation, statutory guidance, CQC requirements or nationally recognised safety guidance changes;
- the Medicines and Healthcare products Regulatory Agency issues new or revised safety information relating to emollients;
- CQC or the Fire and Rescue Service identifies a relevant concern or required improvement;
- the premises fire risk assessment identifies a change that affects this policy;
- an emollient-related fire, near miss or other significant incident occurs;
- monitoring, audit or investigation identifies that existing arrangements are ineffective; or
- there is a material change to the service, premises, equipment or people supported that affects emollient-related fire risk.
The Registered Manager must ensure that revised requirements are communicated to relevant staff and that any resulting changes to training, care plans, risk assessments, emergency arrangements or working practices are implemented.
This policy must be read and implemented alongside the organisation’s fire-safety, medicines-management, risk-assessment, care-planning, incident-reporting and emergency procedures.
Compliance with this policy contributes to meeting the requirements of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, particularly Regulation 12 – Safe Care and Treatment, Regulation 15 – Premises and Equipment, Regulation 17 – Good Governance and Regulation 18 – Staffing, together with applicable duties under the Regulatory Reform (Fire Safety) Order 2005 and the Care Quality Commission (Registration) Regulations 2009.
Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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