Working with oils and greases - Health and Safety implications

It is an inevitable consequence of many aspects of production and maintenance work that workers will come into contact with lubricants, including greases and oils.  Prolonged contact with oils and greases can cause a range of skin problems, such as: rashes (e.g. oil acne), dermatitis and even skin cancer and testicular cancer.  Contact with hot lubricants, during servicing or maintenance, may also cause burns. 

The chemically hazardous nature of oils means that consideration needs to be given to the provisions of the Control of Substances Hazardous to Health Regulations 2002 (COSHH).  Under these regulations, the employer has various duties for preventing exposure to hazardous substances or for controlling such exposure to prevent harm to employees.  The employer must: 

·       assess the health risk arising from the work done and decide what precautions are needed,

·       introduce appropriate measures to prevent or control the risk,

·       ensure that control measures are used and the equipment is properly maintained and procedures observed,

·       where necessary, monitor exposure to hazardous substances and carry out appropriate health surveillance,

·       inform, instruct and train employees as to the risks and of the precautions to be taken,

·       make appropriate arrangements for dealing with accidents, incidents and emergencies. 

Oils can be damaged (or denatured) in normal use and the used oils are usually more hazardous than the clean, new oils. It is generally the used oils that are more strongly associated with skin cancers, etc.

Some of the hazards associated with oils and greases

Skin rashes and dermatitis

‘Oil acne’ may be identified by the presence of blackheads, pimples and pustules on the skin.   The arms are the area most commonly affected (as these are the area most likely to come into contact with oils and greases), but any other part of the body may be effected if it comes into contact with oils or oil soaked clothing.  Oils may also remove the skin’s own naturally protective oils, leaving it dry.  This dry skin is liable to crack and is more susceptible to damage caused by cuts and abrasions.

Skin cancer and testicular cancer

It has been established that contact with certain mineral oils may cause cancer in humans. The carcinogenic potential of oil products is usually, but not always, associated with the presence of polycyclic aromatic hydrocarbons.  Used oils (especially used engine oil) have been shown to have elevated polycyclic aromatic hydrocarbons levels.  Prolonged exposure to certain mineral oils, and especially to used engine oil, can lead to the development of warty swellings or sores on the skin, especially where contact is on the scrotum.  These warty swellings are slow to heal and may be cancerous.  It is recognised that prolonged skin contact with used engine oil can lead to skin cancer and testicular cancer (from putting oily rags into overall pockets).  Consequently, used engine oil is listed as a carcinogenic substance in Schedule 1 of the Control of Substances Hazardous to Health Regulations 2002 (COSHH). 

Slipping hazard

Slips often take place when there is not effective contact between a shoe sole and the floor surface. This can be due to: faults with the floor surface, an inappropriate floor surface, inappropriate footwear or contamination between the shoe sole and the floor surface such as oils, greases and water. All of these factors, either individually or in combination, affect slip resistance.

Burns

In common with all hot substances and surfaces, skin contact with hot oils, or pipe work carrying hot oils, may cause burns.

Some of the methods that can be used to control the hazards from oils and greases

The best control measures are those that avoid contact with oils (such as fully enclosed pumping systems in place of pouring systems for draining and filling operations), while others limit the amount of contact (such as hand washing after exposure). 

Risk Assessment
The use, storage and disposal of oils should be subject to suitable and sufficient risk assessments. The risk assessments should consider all of the processes involved and should specify the measures that will be used to control these hazards and risks. The risk assessmetn process should consider COSHH; Slips, trips and falls; hot oils; burns; fire risk; etc.

Overalls and Aprons

Workers potentially exposed to oils should be provided with a sufficient number of protective overalls.  It is usual for them to have at least three sets of overalls (one set to wear, one set being cleaned and at least one spare set), although some tasks may require more sets of overalls.  Suitable arrangements need to be made for the overalls to be cleaned.  It is recommended that overalls are dry cleaned in order to remove oils and greases.  Ideally, overalls should be supplied without (trouser) pockets, so that oily rags cannot be stuffed into the pockets - reducing the potential for prolonged skin (scrotal) contact.  Lack of pockets also reduces the risk of other injuries from the tools, etc. that may also otherwise be put into them.

The use of (disposable) plastic aprons should be considered for certain operations where there is a risk of oil contamination of the overalls.

Gloves

Appropriate gloves should be worn as a barrier to protect the hands from contact with oils and greases.  In many cases, disposable gloves are used, while in others, more robust longer use nitrile gloves are provided.  The type of gloves provided will be dictated by the level of protection required and the type of work being undertaken.  The thin, disposable gloves reduce skin contact with oil while allowing fine work to continue. The potential helath risks (to some people) from powdered latex gloves should be considered as part of the overall risk assessment. 

Suitable washing facilities

Decent washing facilities are necessary to remove oil from the skin.  These should include both hot and cold running water as well as suitable skin cleansers.  Suitable hand drying facilities should also be provided, such as paper towels.  The use of suitable conditioning creams after washing can help to counter the degreasing effects of the oil on the skin.  Skin must never be cleaned with solvents, etc.  So called “barrier creams” must not be relied on to protect the skin from exposure to oils.  They can, however, be a useful extra protection and can make it easier to wash oils off of the skin after exposure.

Tissue roll in place of rags

It is recommended that, where appropriate, the use of rags for cleaning up is replaced by the use of suitable tissue wipes (usually supplied in a roll form).  Dispensers for these rolls may be wall mounted at suitable locations in the workshop.  This means that clean tissue is readily available for addressing small spills, cleaning tools, etc. and also that there is no temptation to keep rags (potentially oil contaminated) in overall pockets.

Draining and filling of lubrication systems, including those associated with vehicles

The drainage of used oil from lubrication systems offers significant risk of contact with the used oil.  These contact risks exist during the draining process, but also in subsequent handling of the drained oil, such as during transfer to a waste disposal holding vessel such as an oil drum or tank.  The risks may be reduced substantially by the use of a suitable oil collection vessel that later allows the waste oil to be pumped from the collection vessel to the waste oil storage vessel.  The collection vessel should be fitted with a wide funnel (for catching the oil) which should in turn be fitted with mesh to catch sump keys, bolts, oil filters, etc.

Storage arrangements

Oil, including waste oil, should be stored in suitable, robust vessels inside a bunded storage area (with a bund capacity of at least 110% of the size of the largest storage vessel). Waste oils should be disposed of by a licensed collector of such special waste. 

Information, instruction and training 

Employees who are potentially exposed to oils and greases must be made aware of the hazards associated with these materials and of the control measures to be used to protect their health.  Awareness can also be raised with suitable notices and leaflets that are available from the HSE. 

Spillage procedure

As oils and greases cause slippery surfaces and so, consequently, any spillages must be cleaned up immediately, using suitable absorbent granules.  Appropriate steps should be taken to stop leaks, including general maintenance, gasket replacement, etc.

Potential for oil in air-lines

Where compressed air is used to provide breathing air to air-fed masks, etc., care must be taken to ensure that the workers are not exposed to oil mists from the compressed air.  Suitable filters should be fitted and maintained and the quality of the air should be checked regularly.

Health surveillance

As it is recognised that prolonged skin contact with mineral oils can lead to occupational dermatitis and, in some cases skin cancer, the employer should carry out routine skin inspections as a precautionary measure. Employees should be encouraged to report sore, red or itching skin, whilst the responsible person should carry out regular, documented and recorded skin inspections of hands and forearms at monthly intervals. Cases of suspected dermatitis should be referred to a doctor or occupational hygiene nurse for further investigation. The results of health surveillance must be recorded and records must be retained for 40 years.

Summary

 

As well as being excellent lubricants, oils and greases are hazardous substances.  Prolonged exposure may result in skin problems, including skin (and scrotal) cancer.  Avoiding exposure to oils is the best control measure available and is often achieved by the use of suitable barrier techniques, such as gloves, overalls, etc.  Where exposure does occur, good personal hygiene and health surveillance are essential.  Oil spillages causing slippery surfaces must be cleaned up immediately and oils (including waste) must be stored and disposed of appropriately.

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The management of Health and safety of communal areas

In buildings with multiple occupancy, the landlord (or building manager or facilities manager) is responsible for the premises as a whole, but also has special responsibility for the common areas of the premises.  These can be thought of the parts of the premises not demised to (or directly under the control of) individual tenants.  Typically, these may include: car parking areas, external areas (roads, paths, lighting, refuse storage areas, etc), entrance doors, reception areas, corridors, staircases and lifts. In addition, the landlord will usually be responsible for the various plant rooms (boiler room, lift motor room, pump rooms, etc), roof areas, fixed electrical installation, water supply, etc as well as for the safe management of contractors working in these areas. There are also some special areas of safety management that fall under the control of the landlord or facilities manager, such as: fire safety for the common areas, the fixed electrical installation, cooling towers, asbestos, etc.

Asbestos

It is recommended that the landlord has a Managment Survey (previously refered to as a Type 2 survey) or a Refurbishment / demolition survey (previously referred to as a Type 3 asbestos survey) carried out on the premises. The key findings of this assessment must be made available to tenants and to contractors and should include the location and type of any asbestos containing materials.

Where asbestos (or asbestos containing material) is known to be present in a building, there should be some form of asbestos management plan in place. This may involve simply monitoring the condition of the asbestos at regular intervals to ensure that it has not been damaged. At the other extreme, it may involve a planned removal of the asbestos by a competent organisation.

Control of contractors

Control of contractors working on site on behalf of the landlord can be a difficult area to manage. Many landlords (and facilities managers) introduce some form of contractor approval system to ensure that certain minimum standards are met. These systems usually ensure that the contractors have adequate insurance, that they have a health and safety policy and that they have appropriate risk assessments and method statements in place.  They do not ensure that the contractors are carrying out the work in accordance with the risk assessments and method statements. It is recommended that at least some of the works carried out by contractors are observed and monitored by the landlord (or their representative) to ensure that they are working in accordance with their agreed standards.  Higher risk activities should be monitored more often and more closely.  Certain contractor tasks will require a higher level of control, such as the use of a permit to work system.

Contractors will need to be given appropriate information and instruction relating to hazards associated with the premises. These may include the presence and location of asbestos, the location of underground services (such as gas, water and electrical services), etc.

COSHH and chemicals

Copies of safety data sheets and of the COSHH assessments should be available on site for any substances used or stored in the common areas, even if stored and used by contractors. These may include water treatment chemicals, cleaning materials and maintenance sprays and lubricants, etc.

Electricity

In most premises, the tenants will be responsible for their own portable electrical equipment. The fixed electrical installation may be responsibility of the landlord or the tenant, depending on the tenancy contract. In many cases, the fixed electrical installation (in part or in total) will be the responsibility of the landlord. In this case, it is recommended that the landlord arranges for the fixed electrical installation to be tested and inspected by a competent person (such as an NICEIC approved contractor) at regular intervals (usually five yearly inspections for commercial premises and three yearly inspections for industrial premises).

External areas and building façade

The external areas of the premises should be inspected regularly, including checks on the condition of the building façade and all structure attached to the building, such as lights, aerials, CCTV cameras, flagpoles, etc. Similarly, checks should be carried out for all external areas, including car parking areas, roads and footpaths, fencing, lighting, etc. Any defects should be addressed and made safe.

Fire Safety

Fire safety is likely to be a shared responsibility, with the landlord being responsible for the common areas and the tenants being responsible for their demised area. It is recommended that the landlord carries out a fire risk assessment for the common parts of the premises and make suitable arrangements for the provision, maintenance, servicing and testing of:

·         A fire alarm, including automatic fire detection

·         Emergency lighting (in the common parts)

·         Fire fighting equipment (in the common parts)

·         Doors, fire doors and automatic door release systems

·         Emergency evacuation routes

·         (Wet or Dry) risers and sprinkler systems

·         Housekeeping in common areas

Tenant responsibilities

The landlord should make it clear to the tenant what their responsibilities are. While the landlord may, reasonably, be responsible for the provision, servicing and maintenance of collective fire safety measures (such as building wide fire alarm and fire/smoke detection) the tenant is responsible for the safe evacuation of their own workers and visitors from the premises. The tenant may be responsible for the provision of fire fighting equipment in their demised area, etc. The responsibilities need to be considered, identified and ascribed.

Tenants’ fire risk assessments

Tenants are generally responsible for their own fire safety arrangements, although some aspects (such as a building-wide fire alarm) may be shared facilities managed by the Landlord. It is recommended that the landlord request copies of the tenants’ fire safety risk assessments and that copies of these are filed and, if requested, made available to the fire authority during the course of an inspection visit.  A tenant should provide the landlord (and other tenants) with information relating to special fire risks, such as the storage of LPGs, etc.

Gas supply and services

The landlord should ensure that the gas supply and services are safe and are maintained in a safe and serviceable condition.  All gas pipe work should be clearly identified (with suitable labels stating “Gas” or by colour coding the pipe work (yellow ochre). All gas equipment under the control of the landlord should be regularly maintained and serviced (by a Gas Safe registered contractor) and a Landlord’s Gas Safety Certificate should be obtained for all gas equipment.

Lifts and lift motor rooms

Lift motor rooms should be clearly identified and should be kept locked and should only be accessed by competent persons (such as lift engineers). Hydraulic lifts should be bunded to contain any leakages of hydraulic oil and all lift motor equipment must be suitably guarded.

Passenger lifts should be tested and inspected by a competent person at least once every six months although this frequency may be reduced to once in every twelve months for goods lifts that are not used to transport people (i.e. if their use is restricted to goods only), as required under the Lifting Operations Lifting Equipment Regulations 1998 (LOLER).

Suitable arrangements should be made for the servicing and maintenance of lifts and for the rescue of people trapped due to lift failure.

Pressure systems

Any pressurised systems within the premises should be tested and inspected by a competent person at the intervals described in the written scheme of examination for the system.  As with other equipment, the landlord will be responsible for ensuring that it is serviced and maintained in a safe condition.

Roof areas

Access to roof areas should be secured to prevent unauthorised access. Consideration must be given to the protection of workers from falls from height. This will require a risk assessment to determine the appropriate control measures for the premises. Typical collective control measures include having suitable edge protection (such as a balustrade wall or fenced edge protection of at least 1100 mm height). In certain cases it may be appropriate to consider individual or personal protective measures such as anchor points for use with harnesses and lanyards.  

Consideration should be given to the need for roof access. It is common for various pieces of plant and equipment to be located on flat roof sections, especially air conditioning units, water storage tanks, lift motor rooms, etc. In such cases, regular roof access may be required by a range of contractors. If contractors are required to make use of individual protective measures, then the use of such equipment must be made clear to the contractor and the landlord should satisfy themselves that the use of such equipment is covered in the contractors risk assessments and method statements, etc. In cases where the roof area is accessed by tenants’ contractors (such as to service tenants’ air-con units or to fit aerials) then the landlord should ensure that the tenant and the tenant appointed contractor have considered to the safety issues associated with roof access.

Other aspects of roof access safety to be considered include fragile roof sections, glazed sections and skylights, etc.

Staircases, landings and corridors

Staircases should be in good condition, ideally with handrails on both sides of the staircase. The staircases, landings and corridors should be well lit, free from obstructions and slipping and tripping hazards. These areas should be checked regularly to ensure that they remain in good condition.

Water supply and cooling towers, etc

The landlord will usually be responsible for the water supply to the premises, including cold water storage tanks, water heating arrangements and hot water storage. The landlord is also likely to be responsible for ensuring that the risks from poor water hygiene are avoided or controlled. This will usually require a Legionella risk assessment in line with the requirements of the HSC Approved Code of Practice & Guidance (L8) "Legionnaires' disease: The control of legionella bacteria in water systems". Control measures required may include: regular water temperature monitoring, maintenance of cooling towers, provision and maintenance of water dosing chemicals and equipment, dip-slide sampling of cooling tower water, etc. Such work is often contracted out to a water hygiene specialist.

In premises that have cooling towers or evaporative condensers, the landlord will be responsible for ensuring that these have been notified to the local authority (as required under the Notification of Cooling Towers and Evaporative Condensers Regulations 1992). Further to this, the landlord must maintain and service the cooling tower to ensure that the risks from Legionella are controlled properly. This will involve a detailed cooling tower (legionella) risk assessment and regular checking and testing of the water in the tower. Such work is often contracted out to a specialist water hygiene company.

Window and canopy cleaning

Suitable arrangements much be made for the cleaning of the building and its windows and canopies, etc. This may well involve working at height using ladders, scaffolds, cherry pickers, scissor lifts, window cleaning cradles, abseiling systems, etc. Although such work is generally carried out in external areas, consideration needs to be given to the cleaning of high level internal structures, such as atrium glazing, etc. Any access equipment associated with the premises must be tested and inspected by a competent person at appropriate intervals. This includes the testing and inspection of eye-bolt anchor points, access cradles and associated runways, etc.
 
Michael Ellerby
Director
LRB Consulting Limited
www.LRBconsulting.co.uk

Health and Surveillance

Introduction
Every year many thousands of employees suffer or are made ill by the work that they do.  The harm may come from several occupation factors, such as:

• Noise
• Noise induced hearing loss (NIHL)
• Tinnitus
• Vibration
• Hand-Arm Vibration Syndrome
• Exposure to chemicals
• Dermatitis
• Skin sensitization
• Reduced lung capacity
• Occupational asthma
• Respiratory sensitization
• Poisoning (such as by lead)

The HSE estimates that between 1,500 and 3,000 people in Great Britain each year develop some form of occupational asthma.

Many of these illnesses can be identified by the process of health surveillance.  In some cases, they can be identified before too much harm is done.  Health surveillance is about putting in place systematic, regular and appropriate procedures to detect early signs of work-related ill health among employees exposed to certain health risks; and allowing the employer to act on the results.

Health Surveillance and Risk Assessment

Employers must carry out risk assessments.  These assessments must be suitable and sufficient to identify how employers (and also non-employees) can be harmed and how that harm can be avoided or, if this is not reasonably practicable, minimised.  The Management of Health and Safety at Work Regulations 1999 (MHSW) create this duty in all work situations and other sets of Regulations enforce this requirement in certain circumstances.  Schedule 1 of MHSW details a hierarchy that the employer must follow when considering control measures (i.e. measures to avoid or reduce the harm that people may suffer).  Health Surveillance is at the bottom of this hierarchy.  The main reason for this is:

• Health Surveillance does nothing to protect the employee from harm – it merely allows the employee to determine t he amount of harm of the level of exposure to harmful agents (chemicals, noise, vibration, etc.).

When Health Surveillance should be carried out and by whom

Health surveillance should be carried out when all of the following conditions are satisfied:

• The work being carried out (or the environment in which the work is being carried out) is known to damage health in some particular way
• There are valid and safe ways to detect the disease or condition – It is important to understand that health surveillance is only worthwhile in situation where it can reliably show that damage to health is starting to happen or that there is a likelihood of such damage occurring. It is also important to understand that a particular health surveillance technique is only useful if:
• it provides accurate results,
• it is safe, and
• it is practical.
• It is reasonably likely that damage to health may occur under the particular conditions at work?
• Health surveillance is likely to benefit employees

Health surveillance should also be carried out when it is expressly required by legislation, such as where an employee is engaged in one of the processes listed in Schedule 6 of the Control of Substances Hazardous to Health Regulations 2002 (such as: manufacture involving exposure to vinyl chloride monomer (VCM), pitch, carbon disulphide, potassium or sodium dichromate, auramine, Magenta or several other identified substances) and is likely to receive significant exposure to the substance involved.
 

Procedure	By whom	Examples
Self Checks	The employee	Self checks are suitable for those employees exposed to hazards who have been properly trained in how to look for easily recognisable signs and symptoms of disease.  The employee should know who to go to if they find anything that causes them concern.
Basic (visual) checks for signs of disease	Responsible Person	Skin inspections where people work substances that can cause dermatitis, such as: Detergents metalworking fluids (MWF) shampoos
Enquiries about symptoms, inspection and examination	Qualified person	An occupational health: o   Checking for signs of asthma o   Measuring lung function Audiologist: o   Measuring hearing
Clinical examinations	Should be carried out by or be supervised by a doctor.   Interpretation of results may also require a doctor.	In some cases this is a legal duty (for example for employees exposed to lead); in others the nature of the tests will require the expertise of a doctor to interpret the results and advise on their significance. Examination by a doctor is also likely to be necessary where health surveillance by a responsible person or an occupational health nurse has identified possible work-related ill health that requires further investigation, diagnosis and treatment.
Biological monitoring and biological effect monitoring	In general, these should be carried out by or supervised by a doctor.   The samples may be taken by a suitably trained person.	Blood testing for: lead mercury carbon monoxide Urine testing for: cadmium fluoride Urine testing for breakdown products of: isocyanates styrene

 

Responsible Person
Anyone trained to identify straightforward signs and symptoms caused by working with certain substances or processes.  A responsible person must not be expected to diagnose the possible cause of symptoms.  Managers, supervisors or first aiders could carry out these checks. An occupational health doctor or nurse should train these people to recognise signs or symptoms requiring further assessment and to know when and how to refer employees.

Qualified person

A qualified person usually means an occupational health nurse checking, for example, for signs of asthma.  It can also be someone with appropriate technical knowledge, for example an audiologist carrying out hearing tests or someone trained to conduct lung function tests.

Typical health surveillance for those working with substances that may cause dermatitis

Skin health surveillance should be considered in cases were workers:

• Have the following occupations: construction work, health service work, rubber making, printing, paint spraying, agriculture, horticulture, electroplating, cleaning, catering, hairdressing, floristry
• Are (potentially) exposed to any of the following substances: epoxy resins, latex, rubber chemicals, soaps and cleaners, metalworking fluids, cement, wet work, enzymes, corrosive chemicals, irritant chemicals, solvents and other similar organic liquids (such as paint thinners, etc.)
• Are (potentially) exposed to any products that are labelled:
• R43 ‘May cause sensitisation by skin contact’
• R42/43 ‘May cause sensitisation by inhalation and skin contact’.

Typical forms that the skin health surveillance could take include:

• Assessing the skin condition of workers as soon as possible after they start (and preferably within six weeks) a relevant job to provide a baseline.
• Implementing regular testing at appropriate intervals (such as monthly, every few months or annually - as advised by an occupational health practitioner)
• The regular testing could involve a suitable questionnaire and skin inspection (hands, forearms and, if these can be contaminated, lower legs) by a responsible person.

Typical health surveillance for those working with substances that may cause (occupational) asthma

Respiratory health surveillance should be considered in cases were workers:

• Have the following occupations: bakers, food processors, beauty service providers, cleaners, painters, repairers (including electronics), welders and woodworkers (including forestry).
• Are (potentially) exposed to any of the following substances: isocyanates (such as in two-pack spray paints), glutaraldehyde, wood dust (hard wood, soft wood, MDF, plywood, etc), latex (such as from powdered natural rubber latex gloves), flour dust, grain dust, rosin-cored solder fume, laboratory animals or glues and resins
• Are (potentially) exposed to any products labelled:
• R42 ‘May cause sensitisation by inhalation’ (may lead to asthma)
• R42/43 ‘May cause sensitisation by inhalation and skin contact’; or
• Have had a confirmed case of (occupational) asthma.

Typical forms that the respiratory health surveillance could take include:

• Assessing the respiratory health of workers before they start a relevant job to provide a baseline.  This could be achieved by a combination of questionnaire and lung function assessment.
• Implementing regular testing (again a combination of questionnaire and lung function assessment) at appropriate intervals (nominally annually or as advised by the health professional.
• Arranging for the results to be explained to the worker by the health professional.
• Arranging for the health professional to report to the employer on the fitness of the worker to work.
• Interpreting the results of the health surveillance (in conjunction with the health professional) and identify whether there is any requirement to revise the risk assessment, and if so in what way.
• Appointing a responsible person (supported by the health professional) to report any symptoms that occur between tests.
• Setting up a simple system to keep and monitor attendance records to identify any patterns in sickness absence.

Making and keeping Health Surveillance Records
All health surveillance programmes should include the keeping of suitable records, including a health record for each individual. These are important as they provide:

• An historical record of jobs involving exposure to substances or processes that require health surveillance;
• A record of the outcome of previous health surveillance procedures
• A demonstration (to enforcing authorities) that health surveillance has been carried out.
• Useful information that may later provide a defence in the event of prosecution or civil proceedings.

The records should contain, as a minimum, the following information:

• Full name
• Gender
• Date of birth
• Employee’s address
• NI Number
• Date of start of current employment
• Brief employment history (of jobs with exposure to hazardous substances, etc.)
• Conclusions of health surveillance

Health surveillance records should be retained for a minimum period of 40 years (or should be passed to the HSE if the company ceases trading).  As with all personal data being held by a company, there are various data protection issues that must be considered.

Summary

Health surveillance is important as a means of demonstrating that the control measures put in place to protect workers from harm are effective.  Health surveillance is, however, ineffective as a control measure in its own right as it can only measure how much, or how little, harm has been done to an individual – it cannot protect them from that harm.  Health surveillance can be carried out in a number of different ways by different groups of people.  Whenever an organisation is considering the introduction of health surveillance, health professionals should be consulted to help to plan and design the service to be provided.  Health surveillance should be carried out at appropriate, regular intervals and suitable records of should be maintained of all health surveillance.

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