Health & safety policy

The college accepts its duty to protect the health, safety and welfare of its staff, students, patients, visitors and anyone else affected by its activities. It will provide safe premises, safe systems of work, competent supervision, adequate training and the equipment needed to work safely, and it expects everyone to co-operate in making that work.

This policy covers teaching on campus and online, the teaching clinic, the herb dispensary, short courses and CPD workshops, public events, external venues used by the college, placements arranged for students, and travel undertaken for college activities. Where the college does not control a venue — an external clinic or a partner organisation’s premises — it satisfies itself that the host’s arrangements are adequate before students or patients are placed there.

Risk management here is meant to be proportionate. The college does not treat paperwork as the point of safety: what matters is that hazards are known, that controls are actually followed in the room, and that anyone can stop a session if they believe it is unsafe. No student will be penalised for refusing to carry out a procedure they believe to be unsafe, and no member of staff will be penalised for raising a safety concern.

The college maintains a register of written risk assessments, held by the health and safety officer and reviewed at least every [XX months], and sooner whenever an activity, a person or a venue changes. Assessments are written by someone competent in the activity, and are read by the people who carry it out — a risk assessment nobody has read has not done its job.

The college bases its first aid provision on a written needs assessment covering each site, the number of people present and the activities taking place. At present the college has [NUMBER] qualified first aiders and [NUMBER] appointed persons. A trained first aider is present whenever the teaching clinic is running, and at all practical sessions and public events.

• First aid kits are held at [LOCATIONS — RECEPTION, CLINIC, DISPENSARY, TEACHING ROOM] and their contents are checked monthly.
• An automated external defibrillator is [LOCATION / NOT CURRENTLY PROVIDED — CONFIRM].
• First aid posters and the names of current first aiders are displayed in the clinic and at reception.
• Emergency contact details for each student on a clinical programme are held in their record, and next-of-kin details are requested for off-site activity.

In an emergency, the priority is the person: call 999 first, then give first aid within your competence, then tell the health and safety officer. Nobody is expected to act beyond their training.

Every accident, near miss, clinical adverse event and dangerous occurrence is recorded, however minor it seems. Near misses are the most useful information the college gets: they show where a control nearly failed, before someone is harmed.

• Internal reporting: the accident book and incident form are held at [LOCATION]. Report the same day to the supervisor or the health and safety officer ([NAME]).
• Clinical adverse events: reported immediately to the supervising practitioner and then to the Clinical Director, and reviewed at [COMMITTEE NAME].
• RIDDOR: deaths and specified injuries are reportable to the Health and Safety Executive without delay; injuries causing more than seven days off work are reportable within 15 days. Reporting is done by [ROLE].
• Insurers: incidents that may lead to a claim are notified to the college’s insurers through [ROLE].
• Learning: every investigated incident produces a written action, with an owner and a date. Actions are tracked to completion by the health and safety officer.

A fire risk assessment is held for each premises the college occupies, and is reviewed annually or whenever the layout or use changes. Escape routes are kept clear and are checked weekly, fire doors are not wedged, and extinguishers and alarms are serviced by a competent contractor. Fire drills are held at least [FREQUENCY — e.g. twice a year] and are recorded, with the assembly point at [ASSEMBLY POINT].

Fire marshals are appointed for each session and are identified [HOW — e.g. by a lanyard]. Personal emergency evacuation plans are prepared for anyone who would need assistance to leave the building, including patients with limited mobility; a patient who cannot self-evacuate is not left alone in a treatment room. Smoking and vaping are prohibited throughout college premises.

Portable electrical equipment is visually checked before use and PAT tested at intervals of [INTERVAL]. Fixed wiring is inspected every [INTERVAL]. The dispensary’s heating and decoction equipment is never left running unattended, and combustible materials are stored away from heat sources.

The college uses single-use, sterile, licensed acupuncture needles, with guide tubes where appropriate. Needles are never reused, re-sheathed by hand, or carried loose. Sharps containers are UN-approved, are located [LOCATIONS], are never filled beyond the marked line, and are collected for incineration by [LICENSED WASTE CONTRACTOR] under a duty-of-care record.

Students may needle only within a supervised session, having completed the relevant training and assessment, and only within the scope agreed by the supervisor. Treatment requires informed consent recorded in the notes. Needling is not carried out on a patient who has not been assessed by the supervisor, and the supervisor remains responsible for the patient throughout.

If a sharps injury occurs

Needling technique, point selection and contraindications are taught and assessed as part of each clinical programme. Safety is an assessed component, not optional reading — see the programme pages for where it sits in the curriculum.

Standard precautions apply to every patient, every time. Hands are washed or sanitised before and after contact; couches, pillows and bolsters are cleaned between patients with [SPECIFIED DISINFECTANT]; linen is single-use or laundered at [TEMPERATURE]; and a fresh pair of gloves is used where contact with body fluids is possible.

• Blood and body fluid spill kits are held at [LOCATIONS], with a written procedure for clinical and non-clinical spills.
• Clinical waste is segregated from domestic waste and stored securely before collection.
• Staff and students must not attend the clinic when they have an infectious illness, and must declare relevant skin, blood-borne or gastrointestinal conditions to the Clinical Director in confidence.
• Sharps containers, surfaces and reusable equipment are audited monthly by [ROLE], and the audit is reported to [COMMITTEE NAME].
• Moxibustion is used with local extraction or adequate ventilation, and patients are asked about respiratory sensitivity before it is offered.

Herbs are handled in the dispensary and preparation room, where the main hazards are airborne dust, allergens, sharp and heated equipment, and the substances used for cleaning and disinfection. COSHH assessments are held for every substance hazardous to health used in the building — including [LIST — e.g. alcohol wipes, disinfectants, essential oils, moxa] — and for the process of grinding, sieving and decanting herbs.

• Grinding and sieving take place in a ventilated area with [EXTRACTION / RESPIRATORY PROTECTION — CONFIRM], and surfaces are cleaned after use.
• Anyone handling herbs who develops respiratory or skin symptoms reports them to the health and safety officer; the college then reassesses the control, not the person.
• Herbs are stored dry, pest-free and off the floor, with stock rotation, batch traceability and a documented recall procedure for any substance found to be contaminated or misidentified.
• Supplied herbs are screened for [TESTS — e.g. heavy metals, pesticides, microbial contamination, sulphur dioxide] and for pharmaceutical adulteration by [TESTING ARRANGEMENT].
• Dispensing follows a second-check system: the dispenser and a second person verify the prescription, the substances, the quantities and the labelling before the patient receives it.
• Heat sources — decoction machines, hot water, moxa — are never left unattended, and a suitable fire extinguisher is provided for the risk.

Because the clinic teaches while it treats, the following controls apply on top of everything above. They are not negotiable, and a student who cannot follow them does not treat patients.

• No treatment begins before the supervising practitioner has assessed the patient and agreed the treatment plan.
• Informed consent is obtained for assessment, for treatment, for student involvement and for any recording of data, and is recorded in the notes.
• Every patient is screened for contraindications and for medication and supplement use — including herbs — before treatment.
• Emergency procedures are displayed in each treatment room, with the emergency contact number, the location of the first aid kit and the protocol for calling an ambulance.
• An anaphylaxis and emergency drug kit is held at [LOCATION] and checked monthly — [CONFIRM SCOPE OF EMERGENCY KIT AND WHO MAY ADMINISTER].
• A supervisor is present in the clinic at all times when students are treating, and there is a maximum of [NUMBER] students per supervisor.
• A patient who faints or reacts adversely is managed by the supervisor, treated as an adverse event, recorded and reviewed — not quietly managed and forgotten.
• Aftercare advice is given verbally and in writing, including when to seek urgent medical help and who to contact if symptoms worsen.
• Lone working by students is not permitted in the clinic or dispensary under any circumstances.

Health and safety induction is mandatory for staff, tutors, volunteers and students before practical work begins, and covers fire procedures, first aid arrangements, sharps and spill procedures, incident reporting and the identity of the health and safety officer. Additional training is provided in needling safety, infection prevention, manual handling and COSHH as the role requires, and is refreshed every [XX years].

The health and safety officer reports to [COMMITTEE NAME] each term with accident and near-miss statistics, the status of outstanding actions, training compliance and the outcome of audits. This policy and the risk assessment register are reviewed annually, or sooner after any serious incident. The next review is due by [DATE].