A guide to cross infection control

infection control Feb 05, 2021
A guide to infection control

In June 2020 Jennifer Young Training launched the free Control of Cross Infection in the Post COVID-19 World course to support therapists in returning to work in the wake of the pandemic.

The course has also been designed to help supersede the amount of fake and unfounded information about infection and how to assess risk around it, giving practitioners the tools to make their own, informed decisions in order to protect themselves and their clients through carefully considered protocols and processes.

In this paper, we give a top line overview of cross infection control in the context of supporting spa businesses and therapists with information on:

  • Defining risk
  • Understanding infection
  • Considering processes that are already in place
  • Legal requirements
  • Risk assessments

This is covered in greater depth in the complete Control of Cross Infection in the Post COVID-19 World course - linked at the end of this paper.


“I’m delighted to introduce Jennifer Young. I first met Jennifer virtually through the Control of Cross Infection course. I believe it’s the most comprehensive course to help therapists manage this area.” - Ron Myers, The Consulting Room

“I was very anxious about going back to work. It was a minefield with all the conflicting information from different bodies. As soon as I logged into Jennifer’s course it was so easy to follow and so supportive in helping us all to go forward and carry on.” - Toni Hopkins, therapist

Jennifer Young’s background has revolved around infection control. It began when she was working for the Health and Safety Executive (HSE), the enforcing authority and independent regulator for work-related health, safety and illness, as one of their inspectors.

By developing her expertise in that field, it allowed Jennifer to advise the courts if required. For example, if someone was to say that they went to a spa, caught Covid-19 and now had a debilitating condition, a case would eventually be brought. In that scenario, the court would ask an impartial expert to advise. Jennifer would have been that person in that job.

Today, Jennifer helps spas and therapists to welcome those who have cancer. They are an immunocompromised group, so control of cross infection has always been a top area of importance for her and her team.

Key points:

  • If you are being given advice on how to manage cross infection and risk, it should come from a level as high as the HSE.
  • When being given advice, you should ask where it has come from.
  • No one should be giving you hard and fast rules as situations change and are circumstance dependent. You need to have the skills to decide your own rules.


What is infection?

  • The invasion and growth of germs in the body. The germs may be bacteria, viruses, yeast, fungi or other microorganisms.
  • Infections can begin anywhere in the body and may spread all through it.
  • Symptoms can be fever and other health problems depending on the infection.


What is infection control?

It refers to policies and procedures used to minimise the risk of spreading infections, especially in hospitals and human or animal healthcare facilities.

- The Medical Dictionary

How do we define risk?

It is incredibly difficult to define risk succinctly and many of those working closely to the field of risk are not able to pinpoint it. However, experts define it as:

Likelihood x severity (consequence)

In context, on our recent webinar on this topic, an attendee rightly described it as the following, which encapsulates not just risk, but also the risk assessment process. She said:

“It is the probability and likelihood of some risk occurring whether very likely or very remotely, the steps you’ve taken to prevent that incident happening and how you can best protect yourself and your client both in the clinic and on their way into the clinic.”

Existing experience that you have and can draw upon

Most therapists are already doing a lot by way of risk assessment and infection control as a result of their standard Level 3 training. Where they have been failed by the spa industry, is that we do these things as a matter of process but are never told why we’re doing them.

For example, when doing a facial you will have been told remove make up from the eyes before the mouth. This is because the eyes are much more prone to infection.

Other examples of things you will be doing as standard include, but are not limited to:

  • Washing your hands regularly
  • Changing the bedding and washing linens between clients
  • Changing the towels between clients

You will also have procedures in place to protect yourself and your client if they come into the clinic with a cold or a cold sore, for example.

If you can manage that infection risk, you can manage other infection risks. What is not being made clear, is that risk is a changing landscape, and even within Covid itself, that landscape continues to change as different variants emerge.

Are the challenges of Covid-19 as bad as we think?

As an industry we’re not in a good place at the moment, there are high risks that need to be properly considered for the safety of all. However, but we have also been unfairly discriminated against over the last 12 months.

In July 2020, when hairdressers and barbers were allowed back to work, therapists were not. In part, that may have been because there’s a narrative in the industry that says we’re not regulated, but we are. Without going into a detailed definition on regulation, we have the same level of regulation as any other UK industry. As a result, we are actually much better prepared to handle risk than many of us think we are.

Key points:

  • The control of infection is understandably vital
  • There are already many practices in place for controlling infection in a therapy environment
  • It’s important for you to understand why you take certain actions in order to understand their impact


You are required to complete risk assessments in order to help control infection. This is a result of the Control of Substances Hazardous to Health Regulations (COSHH) - or the law that requires employers to control substances that are hazardous to health. This has been around for decades and you will have heard it commonly referred to as a risk assessment, and it will help you control the risk of cross infection.

Key points:

  • The risk assessment process requires you to have an understanding of likelihood, hazard and risk in order to be able to do it.
  • You may be required to take technical and scientific information into account when carrying out an assessment. This is one of the reasons risk assessments around Covid-19 have been so challenging, because the latest government guidelines have changed so regularly and so rapidly.
  • The assessment is your responsibility, not that of the brands giving you information. However, it could be the responsibility of your employer.
  • The assessment must be regularly updated in light of new information and/or changing circumstances. Our advice is to put a three-month review date into your planning as standard practice, unless something comes in to prompt a change beforehand.


When it comes to making decisions about the safety and wellbeing of our clients and ourselves, we need to understand risk and have a clear way of assessing it - in short, a risk assessment.

We do this by looking at the risk factor and combining that with each hazard.

  • A hazard is something with the potential to cause harm
  • Risk is the likelihood x severity (consequence)

In order to rate severity, you have to know what you’re rating it for. You’re rating it for hazards. So, decision making begins by drawing up a list of hazards and we recommend that you do this is a team and that when you’re doing it, it’s in the mindset of expecting the worst. When you’ve identified those things that have the potential to cause harm, you look at the likelihood of that happening and how severe that harm could be.

The risk assessment process

The HSE’s recommended steps to risk assessment are:

  • Identify the hazards
  • Identify the possible consequences
  • Estimate the likelihood of the possible consequences
  • Estimate the risk
  • Evaluate the risk
  • Record the findings

In our graphic for the risk assessment process, the feedback loop is especially important. This will help to fill any gaps that you may be missing that could supersede those you have identified. For example, consider a different context regarding the two-metre rule for social distancing. If you’re walking along the pavement and step out into the road to keep two metres from another pedestrian, but you step into oncoming traffic, you may be exchanging a low-level risk for a much higher one. Use your feedback loop so that you don’t get hit by the proverbial truck.

Enforcing authorities are obsessed with definitions, and for good reason - it gives you something to hang your risk assessment on.

The two important areas of definition in your risk assessment are:

A hazard's likelihood of occurrence or how likely that harm is to be realised:

  • Rare - occurs rarely
  • Unlikely - unexpected but might occur
  • Moderate - expected to occur occasionally
  • Likely - expected to often occur
  • Almost certain - expected to occur very often

The potential severity of the consequence:

  1. Insignificant - damage negligible (paper cut)
  2. Minor - basic first aid needed
  3. Moderate - treatment required
  4. Major - hospitalisation
  5. Catastrophic - loss of life

The graph that we have created is not included in the HSE guidelines but helps to provide a road map for your next steps once you have your numbers. If you find that the severity of a consequence is at 4 or 5, it doesn’t necessarily mean that a treatment can’t be delivered, but it does mean you need to look at introducing control measures to bring the risk right down.

When you look at Covid-19, there’s increasingly good data about vulnerability, making the consequences more and more well informed. That helps us to manipulate likelihood and consequence in our assessments, however it does raise some controversial questions, which can cause other issues.

For example, we know that certain groups of people are at higher risk than others. The most effective way of removing the risk is to refuse to treat them. This has been the historic situation with cancer patients. However, that raises the issue of discrimination, is counter to most therapist’s motivation to care, and it has moral consequences and sometimes legal implications as well as real consequences. There is no one way to handle this, but if you have the tools to keep coming back to those two key factors that you need to manipulate, then you will be able to make an informed decision on a case by case basis.

Your risk assessment

When creating your own risk assessment, you need to break it down into:

  • Specific steps
  • Their associated hazards
  • What you’re going to do about them
  • Who’s responsible for those actions

It’s not just about seeing the treatment as a whole, but each stage of a client’s journey. When you’re a therapist faced with a global pandemic and you don’t realise you already have a lot of risk assessment processes in place, it’s overwhelming. There are things you will have to do before you reopen your practice and there are things you will need to do when you reopen and in an ongoing capacity but breaking it down into these steps will help to manage the processes.

The example risk assessment form is from July 2020 and you should check government guidance regularly for updates.

Hierarchy of control

When you have recognised that there’s something that needs controlling, there’s a hierarchy of things to consider and you are legally required to address some things before others. The most effective measures are at the top and the less effective are at the bottom.

  • The most effective way of handling a hazard is to remove it entirely - don’t use the product or don’t treat the client. However, as mentioned before, this can raise other issues and isn’t always a satisfactory approach.
  • The next thing you can do is isolate the exposure. That’s why you see perspex screens in shops for example.
  • Once you have implemented a control, you need to assess its efficacy to justify your action or, sometimes, inaction.
  • Complete information on understanding the hierarchy of control is available in the full Control of Cross Infection in the Post COVID-19 World course.

Implementing your risk assessment

  • Who - do you need a risk assessment team? We strongly advocate the use of teams in doing a risk assessment.
  • Define - be very clear about what needs to be assessed and how you’re going to assess it. For example, the process might be different for facials as opposed to dealing with laundry.
  • Observe - do this with each of the processes if you can, or talk them through if not. For example, with spa treatments at Jennifer Young Training we always send a step-by-step treatment layout so you can make assessments for each stage.
  • Include - If you’re an employer you should involve employees. If you’re in the happy position of having a good relationship with your clients, include them in the process as well for a gold standard approach.

Key points:

  • Remember that the HSE is not the enforcing body for therapists, it is a central organisation. Your local authority Environmental Health officers are your go-to for information, and you may find that information differs from one region to the next.
  • We are often asked about the use disclaimers when it comes to risk. These do not help you if a problem should occur. You can ask for a client to provide informed consent, which requires them to have an understanding of the process for it to be valid. This may include having a signed note from their doctor.


Risk is not a static thing and the important thing is to have the methodical tools for assessing each situation for each individual. Armed with that information, there’s no need to panic. The important things to remember are:

  • To do a methodical and thorough risk assessment
  • Stay informed about updates to government guidelines and other factors that could affect your process
  • Regularly revisit your processes to make sure they’re up to date

“The Control of Cross Infection in the Post COVID-19 World helped me in so many ways, not just improving my confidence and that of my client base, but also in negotiating the minefield of health and safety, environmental health. To say that you’ve done a qualification means that people sit and listen and take you seriously.” - Marianne, therapist

If you would like to take our FREE, accredited qualification in cross infection control, please follow the link below.


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