Health and medical surveillance

Health and medical surveillance

 

Introduction

The health of employees is vital to ensure that businesses can continue to operate without time lost due to absences.

An important part of occupational health is how work and the work environment can impact on workers’ health.

No employees should become ill because of the work they do. Therefore, as an employer, you must make sure workers’ health is not impacted by their job.

What is health surveillance?

Health surveillance is a scheme of repeated health checks which are used to identify ill health caused or made worse by work. 

Health and safety law requires health surveillance to be provided by employers when workers remain exposed to health risks even after you have put controls in place. This is because control measures may not always be reliable, despite appropriate checking, training, and maintenance.

Specific health risks which require health surveillance to be provided include:

  • vibration 
  • noise
  • substances hazardous to health

Where a risk assessment identifies a need, employers should have an ongoing health surveillance scheme. For example, where:

  • an identifiable disease or health effect may be linked to workplace exposure
  • the particular work conditions make it likely that the disease or health effect may occur
  • there are valid low-risk techniques for detecting signs of the disease or effect

A health surveillance scheme should have input from a competent occupational professional. Further information on occupational health service provision can be found at:

Vibration

Employers must provide health surveillance for all employees who, despite action taken to control the risk, are likely to be regularly exposed to hand-arm vibration above the exposure action value (EAV), or who are at risk for any other reason.

Health surveillance for hand-arm vibration exposure may involve asking workers a short set of questions to identify any early signs or symptoms of exposure effects (See examples of Hand-Arm Vibration Syndrome (HAVS) health surveillance questionnaires in the ‘Resources’ section below).

Which jobs are most likely to create a risk?

  • construction and civil work
  • engineering
  • forestry
  • foundries
  • motor vehicle manufacture and repair
  • maintenance of parks, gardens, verges, grounds etc
  • shipbuilding and ship repair
  • utilities (for example gas, water, telecommunications)

Which tools are most likely to create a risk?

  • chainsaws
  • grinders (all types and sizes, for example angle, die, straight, vertical etc)
  • hand-fed equipment, for example pedestal linishers, grinders, mops
  • impact drills
  • scaling hammers including needle scalers
  • pedestrian controlled equipment including mowers, floor saws, floor polishers
  • powered hammers for chipping, demolition, road breaking etc
  • sanders and polishers
  • hand-held saws for concrete, metal, ground clearance etc
  • poorly maintained equipment

When an employee is diagnosed with HAVS, it is important that employers and health professionals take the necessary steps to ensure that the condition is not made any worse by work. This also applies even if the disease is connected to earlier employment or by activity outside the workplace.

Noise

Employers must provide health surveillance (hearing checks) for all employees who are likely to be regularly exposed to noise which is above an upper exposure action value, or who are at risk for any other reason.

The Health and Safety Executive (HSE (GB)) publication L108 Controlling noise at work - Guidance on Regulations provides detail of circumstances where health surveillance for noise exposure should be provided. A key indicator is where workers may be exposed to regular and frequent daily noise exposure, or peak sound pressure levels at or above an upper Exposure Action Value (EAV), i.e.:

  • daily or weekly exposure of 85 dB(A)
  • peak sound pressure of 137 dB(C)

Health surveillance should also be provided for workers where the working environment is not generally noisy but there are occasional periods where workers are exposed well above the upper EAV and the worker is heavily reliant on personal hearing protection.

Also, workers who are vulnerable to hearing loss from noise exposure should be provided with suitable health surveillance, for example, those with pre-existing hearing loss, those having treatment with certain medication, or those who have been exposed to certain chemicals, which can increase the risk of further damage to hearing in combination with noise.

Further guidance is provided under Regulation 4 and 9 of HSE (GB) publication:

When an individual is suffering from noise induced hearing loss (NIHL) it is crucial that employers and occupational health professionals take steps to preserve the remaining hearing ability and that appropriate adjustments and hearing protection are provided.

Employers may be concerned that NIHL is not due to exposure at work as they believe that workers are exposed to high levels of noise outside of the workplace. It is crucial that employers arrange for employees to have a baseline hearing check when they join an organisation and employers reduce noise exposure where they can. It is also important to then ensure that hearing protection is both provided and worn properly.

The Society of Occupational Medicine have published the following guidance around diagnosing occupational NIHL:

Substances hazardous to health

Every year many employees become ill from exposure to harmful substances whilst at work. The ill health effects of exposure to such substances can take many years to appear and often employees and employers do not recognise the risks or the connection between ill health later in life to exposure at work.

Many materials or substances used or created at work could harm workers’ health. These substances can include dusts, vapours, gases or fumes that are breathed in, or liquids, gels or powders that can come into contact with workers eyes or skin. There could also be harmful micro-organisms present that can cause infection, an allergic reaction, and may be toxic.

Harmful substances can be present in anything from paints and cleaners to flour dust, solder fume, blood or waste. Ill health caused by these substances used at work are preventable. Many substances within the workplace can harm workers’ health but, if used properly, they shouldn’t.

Employers have a duty to eliminate or reduce the risk from harmful substances and processes but as part of their management system there should also be a suitable system of health or medical surveillance. This is because control measures may not always be reliable, despite appropriate checking, training, and maintenance.

When is health surveillance required for substances hazardous to health?

Health surveillance is required under the Control of Substances Hazardous to Health Regulations (Northern Ireland) 2003 (COSHH NI) when:

  • there is a disease associated with the substance in use
  • it is possible to detect the disease or adverse change and reduce the harm
  • workplace conditions make it likely that the disease will appear

There are a wide variety of substances and processes where providing health surveillance would be necessary. Common examples include:

  • respiratory sensitisers/asthmagens (for example isocyanates, flour dust)
  • cancers (for example Mboca, silica, rubber, fume, tar)
  • dermatitis (sensitising for example cement or contact mineral oils)

Health surveillance may be as simple as skin / hand examination but in other cases it may require the input of an occupational physician (doctor or nurse). If a GP offers this service, the employer needs to be sure the GP is competent regarding occupational medicine.

The clinical outcomes are personal, and the service provider must interpret the results for each person.

The service provider must supply general information to the employer to keep up to date health records and may anonymise/group data to highlight trends.

Involving employees and their representatives

Health surveillance can fail where employees have not been told what its purpose is, how it will be carried out and what it means for them as individuals. 

Employees might suspect that programmes are introduced, not to protect them, but as a threat to their jobs. Overcome this by involving employees, and, where appropriate, their representatives, early on.

Where trade unions are recognised, consult safety representatives in good time about the development of any health surveillance programme, covering the following issues:

  • the aim of the programme and how it fits with your health and safety policy
  • other means you use to protect employees, and whether it is required by law
  • how employees can raise health and safety issues
  • the benefit to the individual in taking part, especially that it is not in their long-term health interests to conceal symptoms
  • what is involved, including any referral procedures
  • what information will be given to the employer, how this will be conveyed
  • what will happen with the results, including employment consequences
  • confidentiality
  • how the programme will be monitored and evaluated

Employers’ checklist for providing health surveillance

  • is there a health risk hazard in the workplace?
  • is there any occupational health input in the workplace? (for example, a competent person in the organisation, or a doctor, or nurse?)
  • what needs to be controlled and who needs to control it? 
  • implement the necessary action
  • monitor to make sure actions are working

Medical surveillance

What is medical suveillance?

As prescribed in specific regulations, employers must undertake medical surveillance where there could be worker exposure to certain high hazard substances or agents.

Medical surveillance is a program aimed at detecting and monitoring health conditions in individuals exposed to specific hazards in the workplace. These include:

  • asbestos
  • compressed air 
  • ionising radiation
  • lead
  • some substances hazardous to health

A doctor appointed by HSENI is required to conduct the medical surveillance (not health surveillance), except for some lower risk non-licensed asbestos work.

Please refer to HSENI’s appointed doctors page for further information.

Why should I provide medical surveillance?

Workers should not suffer ill health due to work and, as such, medical surveillance provides an early warning to employers. 

Medical surveillance can assist employers in making changes to process to prevent further harm, or to ensure that existing controls are working, for example PPE/RPE not correctly worn or fitted, or local exhaust ventilation (LEV) systems not positioned correctly or properly maintained. 

Medical surveillance for exposure to asbestos

The Control of Asbestos Regulations (Northern Ireland) 2012 requires that anyone who carries out licensable work with asbestos must have been medically examined in the past two years by a doctor individually appointed by HSENI for that purpose (an ‘appointed doctor’).

Employees who carry out any Non-Notifiable Licensed Work (NNLW) must also have a medical examination on or before 30 April 2015. 

From 1 May 2015, anyone carrying out NNLW should have been medically examined under the Regulations in the past three years.

Further guidance is available at paragraphs 499 to 528 of the following HSE (GB) publication:

Medical surveillance for work in compressed air

The Work in Compressed Air Regulations (Northern Ireland) 2004 requires the appointment of a Contract Medical Adviser to provide occupational health advice on all aspects of the work in compressed air.

Adequate medical surveillance, carried out by an appointed doctor or employment medical adviser, must be provided to all employees who work in compressed air. Where an employee is to be assigned to work in compressed air, the medical surveillance is required to be provided before they start the work. Medical surveillance will include examinations at intervals recommended by the appointed doctor or employment medical adviser but will not extend further than 12 months.

Regardless of medical surveillance, employers must ensure that employees do not work in compressed air if they have any medical conditions that would put them at risk. Likewise, employees must inform their employer of any applicable medical conditions they may have.

The Regulations also require for all those working in compressed air to also be fit for construction site and tunnel work. Specifically, they should be fit enough to get themselves quickly to an area of safety in case of an emergency, such as fire or collapse.

Further guidance for appointed doctors is available within the following HSE (GB) publication:

Medical surveillance for exposure to ionising radiation

Under The Ionising Radiations Regulations (Northern Ireland) 2017, employers of anyone exposed to ionising radiation, because of work activities, must decide when such an employee needs to be designated as a classified person. In deciding whether a person must be classified, the employer should take account of the potential for exposure to ionising radiation (including the possibility of accidents etc which are likely to occur) as a result of the work the individual is required to undertake. 

An employer should designate as a classified person any employee who works with any source of ionising radiation capable of giving a dose rate where it is reasonably foreseeable an employee could receive an effective dose greater than 20 mSv, or an equivalent dose in excess of a dose limit within several minutes.

Before that person is classified, employers must make sure that the employee has been certified as fit for the intended type of work within the previous 12 months. This may require a medical examination. Employers will then need to decide with the relevant doctor for continuing medical surveillance.

Employers must also arrange for adequate medical surveillance for any employee who has received an overexposure, whether that employee has been designated as a classified person or not.

Further guidance is available at paragraph 526 of the following HSE (GB) publication:

Medical surveillance for exposure to lead

Where employee exposure to lead is significant, the employer must make sure that the employee is under medical surveillance by a relevant doctor. 
The Control of Lead at Work Regulations (Northern Ireland) 2003 defines “significant” exposure to lead as meaning exposure in the following circumstances:

  • where any employee is or is liable to be exposed to a concentration of lead in the atmosphere exceeding half the occupational exposure limit for lead
  • where there is a substantial risk of any employee ingesting lead
  • where there is a risk of contact between the skin and lead alkyls or other substances containing lead which can be absorbed through the skin

Employees who do not have ‘significant exposure’ may still require to be under medical surveillance if a doctor certifies that it is necessary, for example if poor work practices or hygiene are observed.

Further guidance is available at paragraphs 262 – 321 within the following HSE (GB) publication:

Medical surveillance for exposure to substances hazardous to health

As outlined within Regulation 11 of the Control of Substances Hazardous to Health Regulations (Northern Ireland) 2003, if an employee is exposed to a substance and is engaged in a process specified in Schedule 6 of the Regulations, any appropriate health surveillance provided must also include medical surveillance under the supervision of a relevant doctor at intervals of not more than 12 months or at such shorter intervals as the relevant doctor may require.

Further guidance is available at paragraphs 233 - 254 within the following HSE (GB) publication:

Resources

Key Legislation