Our approach
Bubble Fresh (Bubblefresh Limited, company number 12691029) is committed to protecting the health and safety of our employees, clients, and anyone affected by our work. Risk assessment is central to how we operate safely. We carry out suitable and sufficient risk assessments as required by Regulation 3 of the Management of Health and Safety at Work Regulations 1999 and our general duties under Sections 2 and 3 of the Health and Safety at Work etc. Act 1974. Given the unpredictable nature of the environments we work in, including heavily cluttered properties, homes affected by self-neglect, and properties requiring biohazard cleaning, thorough risk assessment is essential.
Scope
This policy applies to all Bubble Fresh employees, including the Director, team leaders, and cleaning operatives. It covers every job we carry out, whether for a private client or a council partner. It also applies to any premises we visit for site assessments or consultations. This policy should be read alongside our Health and Safety Policy, Lone Working Policy, Infection Control Policy, COSHH Policy, Safeguarding Policy, Incident Reporting Policy, and Code of Conduct.
Responsibilities
The Director, Lance James, has overall responsibility for making sure risk assessments are carried out properly across the business. This includes approving generic risk assessments, reviewing the risk assessment process, and providing the resources needed to manage risks effectively. Team leaders are responsible for completing site-specific risk assessments, briefing the team before each job, carrying out dynamic risk assessments during work, and recording all findings. All employees are responsible for following the control measures set out in risk assessments, reporting new hazards or changes in conditions to the team leader, and stopping work if they believe there is a serious risk to anyone's safety.
When we carry out assessments
We carry out a risk assessment before every job. Where possible, this includes a pre-visit assessment based on information from the client or referring council. We ask about the condition of the property, known hazards, the presence of pets, any access difficulties, and any factors that may affect the safety of our team or the client. We conduct an on-site assessment on arrival before any work begins. We carry out dynamic risk assessments (live checks of changing conditions) throughout the job if conditions change or new hazards come to light. For repeat visits to the same client, we review the previous risk assessment and update it to reflect any changes in the client's circumstances or the condition of the property.
What we assess
Our risk assessments cover a wide range of hazards. These include structural hazards such as unstable piles of items, damaged floors, and compromised stairs. We assess biological hazards including bodily fluids, animal waste, mould, and pest infestations. We consider chemical hazards from cleaning products or unknown substances found on site, and fire hazards such as blocked exits, electrical faults, and accumulated combustible materials. In pre-1999 properties, we pause work and seek specialist advice if we identify suspected asbestos-containing materials. We also assess sharps and needle hazards, manual handling requirements, slips trips and falls, working at height, confined spaces, noise and vibration from equipment, and temperature extremes. We check access and egress routes, including emergency escape, and consider lone working risks and client-specific factors (see the section below on client-specific risks). Where a property is subject to a Housing Health and Safety Rating System (HHSRS) assessment by the local authority, we take any findings into account in our own risk assessment.
Hierarchy of controls
When our risk assessment identifies a hazard, we follow the hierarchy of controls set out in the Management of Health and Safety at Work Regulations 1999 and in Health and Safety Executive (HSE) guidance. We apply controls in this order of priority: first, we eliminate the hazard where possible (for example, removing a trip hazard before starting work); second, we substitute a less dangerous option (for example, using a safer cleaning product); third, we put engineering controls in place (for example, ventilating a room before entering); fourth, we use administrative controls (for example, adjusting work methods, limiting time in a hazardous area, or working in pairs); and fifth, we provide personal protective equipment (PPE) as a last line of defence. We never rely on PPE alone where a higher-level control is reasonably practicable. We record the level of control applied for each hazard in the risk assessment template.
Client-specific risks
Many of the people we work with are vulnerable adults who may be experiencing difficult circumstances. Our risk assessments always consider the emotional and psychological wellbeing of the client, including potential distress at seeing their home being cleared or cleaned. We assess the risk of challenging behaviour, including verbal aggression or unpredictable actions, and plan our approach accordingly. We consider any communication barriers, such as language differences, hearing difficulties, or cognitive impairment, and adapt our approach so that the client understands what is happening. We consider the presence of pets and any risks they may pose to our team, including dogs, cats, or other animals that may be distressed or protective. We ask the client or referrer to arrange for pets to be secured or removed from the working area where possible. Where a client has known mental health conditions, substance misuse issues, or safeguarding concerns, we record these in the risk assessment and brief the team before the job begins. If children are present in the property during work, we assess any additional risks and take steps to keep them safe, including restricting access to the working area. We never leave a vulnerable client alone in an area that is unsafe. We treat all client-specific information with sensitivity and in confidence, in line with our Privacy Policy, Safeguarding Policy, and Code of Conduct.
Other people on site
Our risk assessments consider anyone else who may be present at the property during our work, including family members, carers, social workers, council officers, or other professionals. We brief anyone on site about any relevant hazards and any areas they should not enter. Where other professionals are carrying out their own work at the same time, we coordinate with them to make sure our activities do not create additional risks for each other.
Dynamic risk assessment
All team members are trained to continuously assess the environment throughout a job. We encourage a 'stop and think' approach: if something does not feel right, pause and check. If a new hazard is identified, such as structural instability that was not apparent on arrival, the discovery of sharps or hazardous materials, or a change in the client's behaviour or emotional state, work is paused, the area is made safe where possible, and the team leader is consulted before proceeding. Any team member can raise a concern at any time, and all concerns are taken seriously. Dynamic risk assessments are recorded and added to the job file.
Right to refuse or stop work
Any employee has the authority and the duty to stop work immediately if they believe there is a serious and imminent risk to the health or safety of any person, without needing prior approval from a manager. This right is protected under Section 44 of the Employment Rights Act 1996 and Regulation 8 of the Management of Health and Safety at Work Regulations 1999. No employee will face disciplinary action or any other penalty for stopping work on genuine safety grounds. In addition, Bubble Fresh reserves the right to refuse or withdraw from a job at any stage if the risk assessment shows that the work cannot be carried out safely with the resources, equipment, or team available. If we refuse or withdraw from a job referred by a council partner, we will explain our reasons clearly and in writing, and will work with the council to find an alternative solution where possible.
Communicating findings to the team
Before work begins on any job, the team leader briefs all team members on the key findings of the risk assessment, including identified hazards, control measures in place, any client-specific factors, and emergency procedures for that site. For complex or high-risk jobs, team members sign a briefing record to confirm they have understood the risks and the controls. If conditions change during the job and the risk assessment is updated, the team leader communicates the changes to all team members immediately. We use plain, clear language in all briefings so that every team member understands the risks and the steps they need to take.
Sharing assessments with council partners
Where we carry out work on behalf of a council partner, we share relevant risk assessment information with the referring council. This helps both parties to manage risks effectively and supports the council in meeting its own health and safety duties. We also accept and take into account any risk information that the council provides about the client or the property. We share risk assessments in a timely way, normally before work begins or as soon as reasonably practicable afterwards. We only share information that is relevant to the job and the safety of those involved. Any personal data included in risk assessments is shared in accordance with our Privacy Policy and our Data Processing Agreements with each council partner.
Training
All employees receive training in risk assessment as part of their induction, covering hazard identification, the hierarchy of controls, how to carry out dynamic risk assessments, and how to record their findings. Training includes scenario-based exercises relevant to the types of properties and situations our team encounters. Team leaders receive additional training in completing and reviewing formal risk assessments. We assess competence after training through observed practice or supervisor sign-off. We refresh risk assessment training annually and whenever there is a significant change to our procedures. Training records are maintained in line with our Training and Development Policy.
Documentation
We document and keep all risk assessments. We record pre-visit assessments alongside the job booking. The team leader records on-site assessments. We note any significant findings or changes during the job. All risk assessments use a standardised Bubble Fresh risk assessment template, which includes a hazard identification checklist, a severity and likelihood scoring matrix, and a record of control measures applied. We store risk assessment records securely, with access limited to authorised personnel, in line with our Information Security Policy. Risk assessment records are kept for a minimum of 6 years in line with the Limitation Act 1980 (to align with our service record retention and the limitation period for potential claims). Management and council partners can review these records on request.
Changes to this policy
We may update this policy from time to time. Any changes will be posted on this page with an updated date. Where we make material changes that affect how we carry out risk assessments or the responsibilities of our team, we will notify all employees directly and brief them on the changes before they take effect. We will also inform our council partners of any material changes that may affect the services we provide to them.
Review
The Director, Lance James, reviews risk assessment procedures annually, following any significant incident or near miss, and whenever there is a relevant change in legislation or Health and Safety Executive guidance. We also review our generic risk assessments at least annually to make sure they remain current. We monitor the effectiveness of our risk assessments through incident reporting, near-miss analysis, and feedback from team members. Where an incident investigation identifies a gap in our risk assessment process, we update our procedures and retrain staff as needed. Last reviewed: February 2026. Next review due: February 2027.
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