Health Surveillance | Wessex Health and Safety

Health Surveillance

1. Overview

An important part of occupational health is how work and the work environment can impact on workers’ health. As an employer, you must make sure workers’ health is not impacted by their work.

Health surveillance is a scheme of repeated health checks which are used to identify ill health caused by work. Health and safety law requires health surveillance when your workers remain exposed to health risks after you have put controls in place. Health risks which require health surveillance include noisevibration and substances hazardous to health.

Health surveillance schemes should usually be set up with input from a competent occupational health professional.

The law requires that health surveillance includes medical surveillance for certain hazards such as asbestoslead, and ionising radiation.

Where medical surveillance is required, you must use a competent occupational health doctor appointed by HSE, called an appointed doctor. The one exception is for some lower risk asbestos work.

Health surveillance is not the same as health monitoring, health promotion or health screening. It:

  • should only be used for workers who need it
  • provides feedback about actions you may need to take to prevent further harm and protect workers
  • allows workers to raise concerns about how work affects their health
  • provides the opportunity to reinforce workers’ training and education

2. Manage the risk

Your risk assessment will help you decide if you need health surveillance. You should:

  • look around your workplace and decide what may harm your worker’s health
  • decide if you are taking reasonable steps to reduce risk and prevent harm
  • think about reasonably practicable improvements you can make or controls you can put in place to reduce risk

Your findings from health surveillance must contribute to your risk assessment and implementation of effective controls. Health surveillance can detect ill health effects early and show whether you need to review and revise your risk assessment and control measures. Control measures may not always be reliable, despite checking and maintenance.

Other issues that can indicate whether health surveillance might be appropriate include:

  • previous cases of work-related ill health in your workplace
  • reliance on personal protective equipment as an exposure control measure – experience shows its use isn’t always managed properly
  • evidence of ill health in jobs in your industry
  • information from insurance claims, manufacturer’s data and industry guidance

3. Consult workers about health surveillance

You must consult your workers and their representatives. Health surveillance only works with their co-operation. Consultation can help increase worker’s commitment to health surveillance and compliance with control measures.

Ask workers what they think the health hazards are in your workplace. They can:

  • help you identify workplace risks
  • make sure your controls are practical

Make sure workers understand:

  • the systems you have put in place to control identified risks and your health surveillance scheme
  • why health surveillance is important and what it is for
  • what will happen if ill health is identified
  • they can attend health surveillance appointments during work time, and you as the employer must pay for the surveillance
  • their own duties in law (for example they must attend appointments)
  • what action you may take if they refuse to attend appointments

4. Understand your business needs

Health surveillance

As an employer, you should have an ongoing health surveillance scheme if:

  • an identifiable disease or health effect may be linked to the exposure at work
  • it is likely that the disease or health effect may occur under the particular conditions of the work
  • there are valid techniques for detecting signs of the disease or effect
  • the technique is low risk to workers

Valid techniques are those that are precise enough to detect something wrong that could be caused by exposure to a health risk; and which are safe and practicable to conduct.

Health surveillance is a legal requirement in specific circumstances when there is still some residual risk to worker’s health despite the control measures you may have put in place, and they are likely to be exposed to:

Health surveillance is used to identify occupational diseases, such as:

Medical surveillance

As defined in certain regulations, you must use medical surveillance where there could be exposure to certain high hazard substances or agents. A doctor appointed by HSE must do the medical surveillance, except for some lower risk asbestos work.

This includes work with:

5. Setting up a health surveillance scheme

As an employer, you should put an ongoing health surveillance scheme in place where your risk assessment shows it is necessary. When setting this up, you should:

  • consider all the health hazards for which health surveillance may be required
  • know which workers could be exposed to each health hazard and ensure they receive the appropriate range of health surveillance

You may also need to:

  • take advice from an occupational health professional
  • identify who will lead and manage your health surveillance scheme
  • agree roles, responsibilities and communication arrangements
  • consider the practical details of performing health surveillance, for example shift workers and remote workers

6. Act on the results of health surveillance

When your health surveillance is concluded, you must get feedback from the occupational health professional who carried it out. Until you have received this feedback your health surveillance is not complete.

Feedback should include advice on fitness for task with the relevant exposure(s) and when further health surveillance is required for each worker undergoing health surveillance. You should enter this information into the individual health records that you must keep.

You must act on the results to protect workers where health surveillance shows they have work-related ill health. If further investigation is required, this should be done in a timely manner in discussion with the occupational health professional.

For example, if an occupational health professional advises you that a worker is not fit for a task, consider assigning the worker to alternative work where there is either restricted or no risk from further exposure.

You must also review your risk assessment and control measures to prevent other workers developing work-related ill health.

Where possible, review your feedback from health surveillance for groups of similarly exposed workers, or those involved in similar tasks. This can help provide a clearer view of how effective your controls are for each source of health risk. When doing this, groups of workers should be big enough to protect individual worker’s anonymity and prevent disclosure of confidential medical information.

7. Record keeping

There are different records employers must maintain as a result of undertaking health surveillance; health records and medical records. It is important to understand the difference.

Health records

A health record is a legal record of the outcome of health surveillance. Employers must keep them for all workers under health surveillance. They must be kept for at least the period specified in the relevant regulations, for example 40 years under the Control of Substances Hazardous to Health Regulations (COSHH). Where regulations do not specify how long they should be kept for, the health record should be kept at least while you employ the worker.

Health records must contain information about the worker’s details, where they work, the hazards they have been exposed to and their fitness to continue to be exposed to those hazards. They should not contain confidential medical information unless you have the worker’s written consent.

It is good practice to offer workers a copy of their health record when they leave your employment or if you cease trading.

Medical records

Medical records must be kept in medical confidence by the occupational health professional responsible for the health surveillance scheme. They may include confidential clinical notes, test results and more general information about workers’ health.

You can only access medical records with the written consent of the worker.

If you change your occupational health provider, you should ensure that medical records (paper and electronic) are transferred to your new provider.

8. Health monitoring, biological monitoring and biological effect monitoring

Health monitoring

Monitoring the health of workers where the effects from an activity or exposure at work are suspected of causing ill health effects, but the association has yet to be fully established.  This would follow the same principles as health surveillance but is not a legal requirement. Where relevant refer to industry guidance. You should consult with your occupational health professional for advice on the approach to implement in your workplace.

Biological monitoring and biological effect monitoring

Biological monitoring (PDFis the measurement of a chemical or its breakdown products in a biological sample (usually urine or blood) to indicate how much chemical has entered the body by all routes of exposure. For example, measurement of lead in blood of workers exposed to lead dust.

Biological effect monitoring is the measurement of biological effects resulting from absorption of chemicals. For example, measurement of protein in urine of workers exposed to cadmium to check their kidney function.

Biological monitoring and biological effect monitoring can play a role in exposure assessment and health surveillance, helping you evaluate your control measures and manage risks to workers’ health. In setting up a biological monitoring programme, you should seek advice from an occupational health professional, and you may need to involve an occupational health physician.

 

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