CQC and Carpets
We have been approached by a number of practices asking what the regulations state about flooring in GP practices as this seems to be a hot topic for CQC at the moment. As you might expect there is not a single regulation that states what type of flooring you should have in consulting rooms or clinical rooms, nor what you can do in these types of rooms. Furthermore the guidance is ambiguous and arguably contradicts itself. In order to try and help practices, particularly those with CQC inspections imminent, I will endeavour to give chapter and verse on the actual regulations and then provide my view on what is actually required for CQC.
Starting with the GMS/PMS regulations, these state:
1.—(1) The contractor must ensure that the premises used for the provision of services under the contract are—
(a) suitable for the delivery of those services; and
(b) sufficient to meet the reasonable needs of the contractor’s patients.
This is obviously vague and open to interpretation, since it doesn’t define what is suitable. However, you could take the view that, since it is the contractor who must ensure the premises are suitable, then it is the contractor who defines what is suitable. However, I suspect CQC will have a view on that interpretation so let’s look at the CQC view which can be found in Nigel’s Surgery No. 5 . This states:
Carpets should not be used in treatment and minor surgery rooms. The flooring in clinical areas should be seamless and smooth, slip-resistant, easily cleaned and appropriately wear-resistant. This also applies to all areas where frequent spillage is anticipated. Spillage can occur in all clinical areas, corridors and entrances.
Carpets can be used in areas where the risk of spillage is lower, such as consulting rooms, waiting area, dispensing areas and administrative, storage and meeting rooms.
The first document states that:
“Flooring in clinical areas should be seamless and smooth, slip-resistant, easily cleaned and appropriately wear-resistant” and “Carpets should not be used in clinical areas”. (Emphasis from original document).
Part 2 of the second document states
Carpets should be avoided in clinical areas. Both documents then go on to state: If carpets are to be considered for non-clinical areas (for example interview rooms, counselling suites, consulting rooms), it is essential that a documented local risk assessment is carried out with IPC involvement and a clearly defined pre-planned preventative maintenance and cleaning programme is put in place.
However Part 4 of the second document then introduces the following categories of space:
Clinical Dry, Clinical Wet, Clinical Specialist, Non-clinical Wet, Non-clinical Dry, Heavy Traffic and Specialist Patient Areas.
There are examples of each category and consulting rooms are included in Clinical Dry which specify that “sheet systems” or “seamless finish systems” must be used, inferring that carpets should not be used. The only category which allows “textile flooring” to be used is Non-clinical Dry, the examples of which include Offices and Stores.
This confusion about whether a typical GP consulting room is clinical or non-clinical is further compounded by the fact that the introduction to each document does not state that it applies to GPs.
The law states that the Code must be taken into account by the CQC when it makes decisions about registration against the infection prevention requirements. The regulations also say that providers must have regard to the Code when deciding how they will comply with registration requirements. So, by following the Code, registered providers will be able to show that they meet the requirement set out in the regulations. However, the Code is not mandatory so registered providers do not by law have to comply with the Code. A registered provider may be able to demonstrate that it meets the regulations in a different way (equivalent or better) from that described in this document. The Code aims to exemplify what providers need to do in order to comply with the regulations.
Within the Code, Criterion 2 states that registered providers must “Provide and maintain a clean and appropriate environment in managed premises that facilitates the prevention and control of infections”. It also references the actual Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Regulation 15 which the CQC use as the basis for their inspection regime. This states that:
- All premises and equipment used by the service provider must be—
- suitable for the purpose for which they are being used,
- properly used
- properly maintained, and
- appropriately located for the purpose for which they are being used
2. The registered person must, in relation to such premises and equipment, maintain standards of hygiene appropriate for the purposes for which they are being used.
And since the definitions of clean, properly used and properly maintained take us back to HBN 00-09 and HBN 00-10 then we are in a circular argument, that gives CQC the ability to raise as an issue any practice that has carpet in a room that is used for consultations.
In summary then, in order to not fall foul of CQC on this issue, the most straightforward thing to do is ensure you have “sheet systems or seamless finish systems” (aka vinyl) throughout. However, if you do have textile flooring (aka carpets) then you can potentially reduce the impact from CQC by ensuring a “documented local risk assessment is carried out with IPC involvement and a clearly defined pre-planned preventative maintenance and cleaning programme is put in place”. Unfortunately this doesn’t guarantee that CQC won’t then raise it as an issue in the report and it may be difficult to challenge subsequently.
I hope that allows practices to make informed decisions. Unfortunately the dilemma presented by the NHS in the HBNs and interpreted by CQC might only be solved by SCS*.
*Other flooring suppliers are available.