Health surveillance is an essential process within laboratories, particularly when hazardous substances are used on a regular basis. In this feature article, Mike Sopp outlines the benefits of a rigorous health surveillance programme, the requirements it must meet under COSHH, and what steps to take following health surveillance.
Many laboratories are likely to undertake activities that involve the use of substances that may be hazardous to health.
A robust health surveillance programme in a laboratory environment can play a significant part in the overall control and monitoring of the risks associated with harmful substances.
However, there can be many factors to take into account for those tasked with managing a health surveillance programme in a laboratory. Owing to the fast-changing nature of hazard assessments and safety guidelines, it is essential to ensure that any programme follows current best practice to ensure that it is effective and meets legislative requirements.
Purpose and factors
In essence, health surveillance is about putting procedures in place in the laboratory to detect early signs of work-related ill health among employees exposed to certain health risks, and then acting on the results when required to do so to prevent serious health issues from occurring. It provides a means of checking whether or not control measures are working effectively while also monitoring the accuracy of risk assessments.
Health surveillance clearly has a significant role to play in any laboratory’s management of risk of exposure. Yet, there can be certain factors that have the potential to negate any health surveillance programme if not properly managed, including:
the diverse and continually changing range of activities undertaken, with employees encountering numerous potentially hazardous substances that may need differing surveillance requirements
short-term activities which require the updating and reviewing of risk assessments, as activities are changing or evolving rapidly
the “one-off” nature of some activities, which may have only limited information or guidance on the potential hazards involved
the utilisation of temporary employees on a short-term basis preventing sufficient data collection to determine if risk control measures are effective
the potential for some employees to fall through the surveillance programme (eg cleaning or maintenance workers).
To overcome such factors and to ensure legislative and best practice requirements are met, laboratory managers need to ensure systems for health surveillance management are flexible, adaptive and firmly implemented.
Health surveillance needs
According to the Health and Safety Executive (HSE), good health surveillance involves a cyclical process, the first steps being:
completion of a risk assessment and introduction of risk controls
determination of the need for health surveillance
consideration of the type of health surveillance required.
The completion of a suitable and sufficient risk assessment involves systematically looking at the work activities undertaken in the laboratory to see which hazardous substances may be present, identifying the significant risks, and determining the requisite precautions needed to eliminate or control these risks.
Having completed the risk assessment and identified all reasonable precautions, a decision will need to be made as to whether health surveillance is required. Regulation 11 of COSHH states that health surveillance will be deemed appropriate when:
an employee is exposed to a substance specified in schedule 6 of COSHH
there is an identifiable disease/adverse health effect and evidence of a link with workplace exposure
it is likely the disease/health effect may occur
there are valid techniques for detecting early signs of the disease/health effect
these techniques do not pose a risk to employees.
COSHH gives examples of when this may apply, including; where there have been previous cases of work-related ill health in the workplace; where there is reliance on personal protective equipment or; where there is evidence of ill health in jobs within the industry.
A good example of this latter point would be in respect of the control of “laboratory animal allergy”, an allergic hypersensitivity response which may develop as a result of exposure to animal allergens. According to the HSE guidance “health surveillance is appropriate for all employees who are likely to be exposed to animal allergens”.
It is worth noting that the requirement for health surveillance only applies to employees under COSHH, and that there is no legal requirement for health surveillance for non-employees, though laboratories may wish to extend provision to others who may be present.
Having determined the need for health surveillance, decisions will have to be made as to what this will entail. This can include:
the review of exposure monitoring data
the review of risk assessments
visual checks undertaken by a responsible person
enquiries about symptoms, inspection, or examination by a suitably qualified person
medical surveillance under the supervision of an appointed doctor.
To ensure the most appropriate health surveillance is undertaken, the laboratory manager should be seeking best practice advice and guidance such as that provided for laboratory animal allergy.
Having determined the need and type of health surveillance, the laboratory will then need to design and implement a programme for it to be undertaken. A key factor in this process is to determine who will be undertaking the health surveillance.
This will be very much dependent upon the type of surveillance required. In general terms, the more complex the surveillance type, the greater the level of medical knowledge that will be required.
Whatever the level, those carrying out health surveillance should know what procedure to use, how to interpret data and how to act on results. In other words, they will need to be competent.
Many laboratories will seek the service of professional occupational health providers. In doing so, the HSE stress the need for laboratories to clearly set out to potential providers what level of service is required. A useful checklist of matters to consider when purchasing health surveillance provision from a third-party can be found on the HSE website.
Having planned and implemented a health surveillance programme, the laboratory will need to:
ensure a process is in place to receive the necessary data
take action to protect those found to have health issues
take action on results where workplace problems are found
keep appropriate health surveillance records.
For larger laboratories, it may be beneficial to review surveillance outcomes as groups to assist in identifying whether or not the control measures adopted are in fact working.
Where health surveillance of an individual does indicate a specific issue, the laboratory manager should immediately consider a number of actions, not least checking the health of employees performing similar work activities and reviewing the risk assessment. Decisions will have to be made as to what action to take, including:
action taken to reassess the workplace controls and implement any necessary changes
arrangements for any further specialist assessment of health
arrangements to transfer the employee(s) to alternative employment within the workplace.
Finally, for each employee under health surveillance, the laboratory is required to keep an up-to-date “health record” containing the personal details of the individual and the results of any health surveillance procedures.
A health record should not include any confidential clinical information as it needs to be accessible by the employer to help inform local risk assessments, and to enable appropriate controls to be put in place.
Health records are required to be kept in an accessible format so that individual employees may have access to their record on request. Legally, records must be kept for 40 years from the time of the last health surveillance.
Health and Safety Executive: www.hse.gov.uk
GN EH76: Control of laboratory animal allergy
Faculty of Occupational Medicine: www.fom.ac.uk