Health surveillance of at-risk employees can help problems be identified and addressed early. And it need not be taxing. Beverly Coleman summarises the process in seven manageable steps.
Safety often trumps health. Much attention is given to the safety risks that have an immediate effect on workers such as falls from height and rightfully so but ill-health risks, the ones that develop silently over months and years can be missed. Hundreds of thousands of workers are made ill through their work each year, yet occupational ill health is preventable and with prevention comes healthy and productive employees as well as reduced likelihood of litigation. Health surveillance is a way to ensure that not only are legal duties fulfilled, but employees’ health is kept on the radar.
What is health surveillance?
Health surveillance is a programme of ongoing checks conducted on employees who are exposed to occupational health risks, such as:
noise and vibration
substances hazardous to health including solvents, dusts, fumes and biological agents
asbestos, lead or work in compressed air
It is a statutory requirement under the Management of Health and Safety at Work Regulations 1999, Control of Substances Hazardous to Health Regulations 2002, Control of Lead at Work Regulations 2002, Control of Asbestos at Work Regulations 2012 and the Ionising Radiation Regulations 1999. There are several industries where health surveillance is a requirement such as construction, mining, agriculture, beauty, printing and motor vehicle repair.
Health surveillance is a key component in running health and safety effectively. It provides the opportunity to identify ill-health effects at an early stage, establish a baseline and enables organisations to implement preventive measures to help avoid or reduce the likelihood of harm to workers. Additionally, it brings to light areas where further controls may be needed, provides data that can be used to evaluate health risks and raises the opportunity for employers to deliver targeted training and instruction to workers.
Implementing a health surveillance programme
Step One: Risk assessment
A risk assessment must first be undertaken to identify what the workplace hazards are, who is at risk and what controls need to be taken.
Step Two: Decide whether health surveillance is needed
Once the risks to employees have been analysed, a decision can be made on whether health surveillance is required. The Health and Safety Executive’s Decision-making map can assist here; the map is in two sections — type of exposure and type of health surveillance. For example, if workers are at risk of exposure to asbestos containing materials the specific legal requirements can be found in the relevant regulations.
Step Three: Decide on the type of health surveillance required
There are different forms of health surveillance dependent on the risk to workers, such as self-assessments and skin surveillance for those who come into regular contact with substances like latex, cement and soaps. There is audiometry for those exposed at or above the Upper Exposure Action Value (UEAV) and those exposed above the Lower Exposure Action Value (LEAV) with a sensitivity, family history of hearing problems, existing hearing damage or previous work history at high noise levels. Guidance accompanying the regulations will recommend types of health surveillance.
Step Four: Setting up a health surveillance programme
Central to the programme is those who are at risk — the employees — so it is crucial that they and their representatives are involved in the set-up of the programme from the very beginning. Legally, employers are required to consult employees and their representatives on health surveillance. Additionally, involvement leads to employee co-operation, enhanced understanding of the process and why health surveillance is important. It will provide an opportunity to inform employees of their legal duties, which are that they must attend their appointments and what action will be taken by the employer should they refuse. Working together will highlight potential issues that may not have been considered by management. Think about how the assessments will be carried out during the working day especially how those who may work remotely, those who change shift patterns and those who are absent due to sick leave or holidays will be assessed and where assessments will take place.
Knowing the type of assessment that is required will assist in deciding how the programme should be delivered. Where there is a risk of hand-arm vibration the programme can be set in specific tiers, for example:
tier 1 — initial questionnaire for at risk operatives to complete (establishes a baseline)
tier 2 — if no issues are identified an annual questionnaire is to be completed by the operative on the anniversary of completion of the initial questionnaire
tier 3 — where issues are identified the operative will be assessed by an Occupational Health (OH) Practitioner
tier 4 — if appropriate OH Practitioner will refer operative to OH doctor for formal diagnosis
tier 5 — OH doctor may require further tests to confirm diagnosis.
At this point in the process, it is also important to appoint employees who will lead on the delivery of the programme. Any appointed employee should receive suitable training to fulfil their responsibilities, which should be clearly documented.
Give consideration at the planning stage to the possible outcomes; health surveillance may identify conditions that will require an employee’s roles to be revised or changed all together. And where certain occupational diseases are diagnosed such as occupational dermatitis they will need to be reported under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).
Step five: Find a competent health surveillance practitioner
A trained practitioner is required for some health surveillance assessments such as hand-arm vibration syndrome. Some OH providers have specialist practitioners with experience in the different types of health surveillance. Where this is not the case specialist services can be tendered for, or recommendations sought from similar organisations. It is important to certify that the chosen provider is competent to carry out the assessments required. Agree how the information should be submitted to the organisation, the timescales and what further support they can provide such as analysis of data and advice on further preventive controls.
Where there is no requirement for statutory medical surveillance a medical professional is not needed. Part of an in-house programme can include trained managers and supervisors carrying out visual inspections, looking for any early signs of conditions, and questionnaires can be circulated to employees where they can highlight any changes. A qualified doctor or nurse should still be available to gain further advice if a health issue is identified.
Step six: Roll out the programme
Implement the health surveillance programme to employees who have been identified as at risk through the risk assessment exercise. Ensure that those managing the programme regularly review how it is progressing by ensuring employees are kept in the loop and assessments are being carried out to a good standard. Other OH programmes and initiatives can and should continue to run alongside the health surveillance programme.
Step seven: Assessment outcome review and necessary action
Once the questionnaires and assessments have been submitted they must be reviewed as soon as possible, to establish whether conditions have been diagnosed and if so what further action is to be taken. The results of assessments can be used to train and inform employees of the potential ill-health effects as well as used as a baseline so that they can be referred to at the next assessment. Record keeping is crucial; health surveillance records must be kept for as long as an employee is under the programme. However, for those exposed to risks from asbestos, lead, ionising radiation, etc records should be kept for much longer, up to 40 years due to the latency period of certain diseases.