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What is workplace health surveillance?
All employers in the UK have a duty of care to those who work for them and much of this is bound in law. Duties include making sure employees are not exposed to hazardous substances or circumstances, that they are equipped to undertake their duties safely and that their health is protected while they are at work.
The risk assessment is your starting point.
The legislation is clear; employers are responsible for making suitable and sufficient risk assessment of all health and safety hazards of which their employees could be exposed to while they are at work (Management of Health and Safety at Work Regulations 1999: reg.3)
When the risk assessment identifies that a hazardous substance or task cannot be eliminated and some risk remains you will need to take further steps. To prevent the risk of injury or exposure causing an occupationally induced disease, personal protective equipment (PPE) is often the next line of defence.
PPE acts as a barrier to exposure but it must not be considered to provide complete protection. The only method that will ensure employees are not exposed to the hazard is by medically monitoring and assessing each individual through robust health surveillance programs that are appropriate to the needs of the risk assessment.
Health surveillance therefore, is designed to monitor the effectiveness of the PPE controls that are already in place.
Is health surveillance a legal requirement?
Health surveillance may be required by law for employees who are exposed to:
- Noise or vibration
- Ionising radiation
- Asbestos, lead or work in compressed air
- Solvents, fumes, dusts, biological agents and other substances hazardous to health
Workers involved with asbestos, lead, compressed air or ionising radiation require statutory medical surveillance under specific regulations, conducted by an HSE appointed occupational health physician. The nature and frequency of these medicals are specific to the defined hazard.
Other forms of health surveillance such as fit to work assessments for particular jobs are undertaken as good practice.
Health surveillance should be conducted when:
- There is an identifiable adverse health outcome
- The health outcome can be linked to exposure
- There is a likelihood the health outcome will occur
- There exists valid techniques for detecting the indictors of the health outcome
Conducting a health surveillance programme the right way
Pointing out the issues is only part of the solution, of course. You need to put in place the strategies and processes that will ensure you are protecting the health of your workforce. The process begins by formulating a robust health surveillance policy, which has been agreed with your employees.
The policy might include a simple method of health surveillance in which a responsible person can be trained to make routine basic skin surveillance checks.
For more technical methods of health surveillance, it is advisable that occupational health professionals assume responsibility for delivering health surveillance programmes. It is essential that the process is through and conducted by trained clinicians using appropriate equipment that is regularly maintained to ensure the results provided are legally defensible.
Ultimately, if your risk assessment identifies a health risk and that the only protective measure is the provision of PPE, then failure to monitor employee health on a regular basis could ultimately mean that you have failed in your duty of care to protect your workforce. Employers have faced legal action through both the criminal and civil courts for such negligence.
How regularly should health surveillance be conducted?
The frequency of health surveillance monitoring is dependent on exposure levels and is therefore determined by the risk assessment.
Health surveillance should be conducted at the start of employment or after exposure to the hazard – whichever comes first. The initial test will establish a baseline and identify any contributing factors that could increase the individual’s risk of developing any conditions. If future testing identifies any changes in an employee’s health this should be investigated further and more specialist advice should be sought.
We all have the right to work in a place that is safe and healthy. Occupational health can help employers and businesses ensure their compliance with legislation and help to create a safe work environment.