Health surveillance, medical surveillance and safety critical medicals during the Coronavirus (Covid-19) pandemic

Updated guidance for occupational health providers and appointed doctors during the Coronavirus pandemic.

HSENI updated guidance on 8 September 2020 setting out a proportionate and flexible approach to enable health surveillance, medical surveillance and safety critical medicals to continue during the pandemic. This advice (issued on 13 January 2021) will act as a further update to that guidance.

It continues to balance the need to protect the health, safety and welfare of workers and current constraints presented by the coronavirus pandemic

For all health surveillance an adequate assessment of the worker should continue to be carried out (including specialist referral where required), with the provision of appropriate advice to the worker and employer.

This guidance sets out options for conducting health surveillance remotely. Face to face assessments can be undertaken, if considered necessary, subject to a suitable and sufficient risk assessment

Where local or national restrictions are implemented due to coronavirus, occupational health providers should discuss the delivery of health surveillance with an affected employer to establish an appropriate course of action.

The guidance will be reviewed as appropriate.

Health surveillance using questionnaires

Where health surveillance is performed using questionnaires, they can be administered remotely. For questionnaires requiring follow up, this can be by telephone, video or face to face. Face to face assessments can be undertaken, subject to a suitable and sufficient risk assessment, putting in place appropriate controls, taking into account public health advice on coronavirus.

Respiratory health surveillance

Providing a current respiratory health questionnaire does not raise any concerns (for initial and review medicals), and previous lung function tests were normal (for review medicals) occupational health providers can defer spirometry for up to 12 months (including any previous deferral periods) and face to face assessment is not necessary.

Spirometry should be performed only when necessary, where it changes the assessment (such as a safety critical medical) or where management of a worker (such as where there is a clinical concern or known lung function abnormality). Where spirometry is considered necessary in these types of circumstances, the potential for aerosols containing coronavirus should be taken into account. It should be subject to suitable and sufficient risk assessment and appropriate controls put in place, including the provision of suitable personal protective equipment (PPE) etc. The reasons for performing spirometry should be documented.

Control of Substances Hazardous to Health Regulations (Northern Ireland) 2003 (COSHH)

For health surveillance under COSHH regulation 11 and medical surveillance under Schedule 6, occupational health professionals, occupational health technicians, responsible persons and appointed doctors can perform assessments using this updated guidance.  

Control of Asbestos Regulations (Northern Ireland) 2012 (CAR)

For medical surveillance under CAR, appointed doctors can perform assessments remotely, following this updated guidance. Where no problems are identified, they can issue a certificate for up to 12 months (including any deferral periods already allowed by preceding guidance). Where a face to face assessment is considered necessary, it should be subject to a suitable and sufficient risk assessment, putting in place appropriate controls, taking into account public health advice on coronavirus.

Doctors can follow the same approach for assessing workers who are carrying out non-licensed work with asbestos.

Ionising Radiations Regulations (Northern Ireland) 2017 (IRR)

For medical surveillance of classified persons, appointed doctors can carry out remote assessments. For a remote assessment requiring follow up, this can be done by telephone, video or, if considered necessary, face to face. Face to face assessments can be undertaken, subject to a suitable and sufficient risk assessment, putting in place appropriate controls, taking into account public health advice on coronavirus.

Control of Lead at Work Regulations (Northern Ireland) 2003 (CLAW)

For medical surveillance under CLAW, appointed doctors can obtain blood lead levels and perform assessments in accordance with The Control of Lead at Work, Approved Code of Practice & Guidance (L132). Face to face contacts (blood taking) can be undertaken, subject to a suitable and sufficient risk assessment, putting in place appropriate controls, taking into account public health advice on coronavirus.

Control of Noise at Work Regulations (Northern Ireland) 2006

Occupational health professionals and audiologists can defer audiometry for up to 12 months (including any deferral periods already allowed by preceding guidance). If audiometry is likely to change the assessment or the management of the worker, it can be performed subject to a suitable and sufficient risk assessment, putting in place appropriate controls, taking into account public health advice on coronavirus.

Control of Vibration at Work Regulations (Northern Ireland) 2005

Health surveillance for hand arm vibration syndrome (HAVS) can continue using initial and screening questionnaires remotely. If a remote assessment requires face to face follow up, it should be subject to a suitable and sufficient risk assessment, putting in place appropriate controls, taking into account public health advice on coronavirus.

Safety critical medicals

Safety critical medicals can be carried subject to a suitable and sufficient risk assessment, putting in place appropriate controls, taking into account public health advice on coronavirus.