- Independent doctor
175 Fore Street Edmonton London
We took urgent enforcement action and imposed conditions on the registration of My Health Medical Clinic Ltd on 1 October 2024 for failing to meet the regulations related to safe care and treatment and safe and effective staffing at 175 Fore Street Edmonton London. We have imposed the following condition: The registered provider must suspend the provision of dental services.
Report from 7 November 2024 assessment
Contents
On this page
- Overview
- Learning culture
- Safe systems, pathways and transitions
- Safeguarding
- Involving people to manage risks
- Safe environments
- Safe and effective staffing
- Infection prevention and control
- Medicines optimisation
Safe
We found this practice was not providing safe care in accordance with the relevant regulations. During our assessment of this key question, we found concerns relating to the safety of the premises and equipment, including medical emergency equipment, safe and effective staffing, infection prevention and control standards, the management of people's medicines and safeguarding. In addition, we found there was a lack of a learning culture at the practice. These concerns resulted in breaches of Regulations 12 (Safe care and treatment), 17 (Good governance), 18 (Staffing) and 19 (Fit and proper persons employed of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. You can find more details of our concerns in the evidence category findings below.
Find out what we look at when we assess this area in our information about our new Single assessment framework.
Learning culture
The judgement for Learning culture is based on the latest evidence we assessed for the Safe key question.
Safe systems, pathways and transitions
The judgement for Safe systems, pathways and transitions is based on the latest evidence we assessed for the Safe key question.
Safeguarding
The judgement for Safeguarding is based on the latest evidence we assessed for the Safe key question.
Involving people to manage risks
The judgement for Involving people to manage risks is based on the latest evidence we assessed for the Safe key question.
Safe environments
Not all staff knew how to respond to a medical emergency. Staff had not completed training in emergency resuscitation and basic life support every year. Staff we spoke with could not explain the process. The responsible persons lacked sufficient understanding of the requirements in relation to premises and equipment maintenance and servicing. The practice did not ensure the facilities were maintained in accordance with regulations. We did not see evidence of an electrical installation condition report. In addition, the provider could not demonstrate that they had systems in place to ensure portable appliances were safe to use. There were no servicing records for the air conditioning system or the gas boiler. The provider told us that the practice had an arrangement with a local pharmacy to deliver prescription only medication. These were then directly dispensed to patients. The practice did not keep a log of the medication prescribed and there were no systems to review and audit if antimicrobial prescribing was in line with the current guidance.
Not all emergency equipment and medicines were available and checked in accordance with national guidance. Resuscitation (UK) Council guidance recommends at least weekly checks of all equipment and checking should be the subject of local audit.’ Glucagon (the emergency medicine used to treat severe low blood sugar) was stored in the fridge, but there were no systems in place to ensure it was stored at the correct temperature according to the manufacturer`s instructions. The provider could not demonstrate that all fire safety equipment had received appropriate servicing in line with relevant regulation. Servicing of the fire alarm had last been completed on 26 September 2022 and the emergency lighting system had not been serviced annually. A fire risk assessment had been carried out by an external company on 8 October 2022. Actions from this fire risk assessment included that fire awareness training must be completed by each staff member and fire alarms tested weekly; emergency lighting and fire extinguishers tested monthly. The risk assessment said that records of this testing must be entered in the logbook. The provider could not demonstrate that recommendations made in the fire risk assessment had been actioned or records were maintained consistently. In addition, the fire risk assessment had not been reviewed regularly by a competent person. However, fire exits were clear and well signposted. The premises were visibly clean and free from clutter. We saw satisfactory records of servicing and validation of the sterilisation equipment in line with manufacturer’s instructions.
The practice did not have effective systems in place for the safe use of radiography equipment. A radiation protection advisor and radiation protection supervisor had not been appointed. There was no risk assessment for the use of radiation equipment and the practice did not have local rules to identify and describe the controlled areas. The provider could not demonstrate that a critical examination and acceptance test or the 3-yearly performance check of the intra-oral x-ray unit had been carried out. Recommendations identified in the yearly electro-mechanical test of the intra-oral unit dated 24 July 2024 had not been actioned. The practice had not carried out risk assessments to minimise the risk that could be caused from substances that are hazardous to health. In addition, staff did not have access to the safety data sheets of hazardous materials used within the service. The provider could not demonstrate that they had completed a risk assessment to assess the risks associated with the use of sharps. We did not see that a safer sharps system has been implemented in line with Health and Safety (Sharps instruments in healthcare) Regulation 2013. There were no systems in place to ensure recalls and rapid response reports relevant to the service issued by the Medicines and Healthcare products Regulatory Agency were reviewed. Staff were not aware of the recent recalls and alerts relevant to primary dental practices.
Safe and effective staffing
Staff we spoke with did not have the skills, knowledge and experience to carry out their roles. There were no records to show that the staff member, who completed the decontamination of dental instruments on the day of inspection and generally helped out with decontamination on other days, had received any training in the dental field. We were not assured that they had the sufficient qualifications, competence, skills and experience to carry out duties relating to the decontamination of dental instruments safely. There were no records to show that staff discussed their training needs during annual appraisals or 1 to 1 meetings. The responsible person did not demonstrate a sufficient understanding of protecting vulnerable adults and children from abuse, although the Safeguarding policy and procedure stated that raising concerns with the relevant authority was their responsibility.
The practice recruitment process did not reflect the relevant legislation. We could not see evidence of checks for proof of identity, full employment history, Disclosure and Barring Service checks, documentary evidence of qualifications relevant to that person’s duties or evidence of registration with the General Dental Council for the associate dentist, the dental therapist, dental hygienist and the qualified dental nurse. There were no records to show that staff had received a structured induction programme. We did not see evidence of any training for any members of the dental team. This included evidence of training in safeguarding vulnerable adults and children, medical emergencies, infection control, fire safety, radiography, and interacting with people with a learning disability or autism. The supervision and monitoring of staff working in the service was not effective in that the provider did not identify the gaps in staff`s knowledge in the areas of the management of medical emergencies and infection prevention and control. There were no systems in place to monitor staff training to ensure appropriate action can be taken quickly when training requirements are not met. We were not assured that the practice employed a sufficient number of suitably qualified staff to provide chairside support and undertake infection control duties. We noted that the practice was open 4-5 days a week, however they only had one dental nurse who worked on Saturday. There were no records of performance reviews or appraisals to ensure learning and development needs were identified. There were no systems in place to ensure staff were supervised until they demonstrated an acceptable level of competence.
Infection prevention and control
We observed the decontamination of used dental instruments, which did not align with national guidance. There were no dedicated handwash sinks in the surgery or decontamination room. Staff did not perform handwashing before performing the decontamination process and soap was not available. Staff did not wear the appropriate Personal Protective Equipment, including visor, heavy duty gloves and mask for the decontamination process. Staff performing decontamination of dirty instruments were not always bare below the elbow. A detergent specifically designed for the decontamination of dirty instruments was not used. Instruments were not fully immersed and were scrubbed under running water. A thermometer was not used to ensure water used for manual cleaning was under 45C. Staff did not use an illuminated magnifier to inspect instruments. We observed some sterilised instruments had rust and cement residue. There were no systems in place to monitor the use of long-handled brushes and heavy-duty gloves. We observed cross contamination of surfaces multiple times during the decontamination process. For example, the clinical waste bin was opened by hand and scrubbed instruments were set down in the clean zone before sterilisation. In addition, we saw that the ‘clean’ transportation box was kept in the designated ‘dirty’ sink. Overall, we were not assured that the practice had effective and service specific infection control arrangements in place to control and reduce the risk of infections. We were not assured the practice had systems in place to ensure clinical waste, containing material contaminated with bodily fluids and contaminated sharps, were collected by a designated clinical waste company. We were shown a clinical waste contract relating to waste transfers between 10 January 2022 and 30 September 2023. A current contract and waste collection consignment notes were not made available for review. In addition, clinical waste was not stored securely.
Staff used a vacuum autoclave to sterilise instruments, however the instruments were not wrapped before sterilization. There were no records to show that weekly and daily testing on the autoclave were being completed in line with manufacturer's instructions or current guidance. We saw 2 entries in the logbook; one from 25 May 2024 and one from 29 July 2024. We saw that some endodontic files, which should be single use, were sterilised after use and not disposed of. Systems to monitor the storage time of sterilised instruments were not effective. We saw some unwrapped instruments in the drawers within the treatment room. The provider could not demonstrate that unwrapped items kept in the clinical area had been reprocessed at the end of the day or at the beginning of the next working day. The infection prevention and decontamination policy was not tailored to the service and there was no written manual cleaning process staff could refer to. We were not assured that staff caring out the decontamination process had the sufficient qualifications, competence, skills and experience to carry out duties relating to the decontamination of dental instruments safely. We were not shown evidence that staff carrying out the decontamination process had received training relevant to decontamination of dental instruments. Staff failed to demonstrate sufficient knowledge of the management of Dental Unit Water Lines (DUWLs). DUWLs were not flushed and disinfected in line with current guidance. A disinfectant specifically designed to use on DUWLs was not available. A Legionella risk assessment had not been carried out to identify the risk associated with bacteria developing in the water lines and a written waterline management scheme was not available for review.
Medicines optimisation
The judgement for Medicines optimisation is based on the latest evidence we assessed for the Safe key question.