Health Surveillance

Introduction
It is a sad fact that eery year, many thousands of employees suffer or are made ill by the work that they do.  The harm may come from a range of 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 1500 and 3000 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 (irreversible) 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

It is well established that 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.

www.Lrbconsulting.co.uk

My week (in Health and Safety)

I do not have a "typical week". For me, most weeks are different from the ones either side of them, although there are some common themes.

This week looks like being something like this:

Monday
Start the day in the office and ensure that people are about their tasks without any serious delays. Hagrid is working up in Lancaster (and has been for the last few weeks) on a Wind Farm project. The only on-going issue he has at the moment is internet access! Richard is enjoying the week off as it's half-term round here. Jamie is updating the web pages and sorting the Newsletter and health and safety new items. John and Brian are out and about doing Fire Safety visits. Before going out, I needed to spend a bit of time promoting next week's Free Seminar (BTW, it would be great if you could join me).

I have also carried out a visit to a Restaurant in Nottingham who have fallen foul of the EHO and are facing enforcement action. Having visited, the restaurant has a lot to do needs to show significant progress before tomorrow's EHO revisit. I will attempt to be present for the EHO revisit, but I have some other (previous) commitments to deal with.

A call from a client to deal with a potential vibration issue has taken over some of the afternoon. Got the client chasing the manufacturers details for the equipment that they have hirered in. Provide the client with some useful HAVS information and a "Trigger Time" record for use on site. I am still chasing for the equipment specification and information so that I can assist them further.

I finished off the afternoon by completing another couple of blog posts: one on Warehouse Safety and one on Health Surveillance.

Tuesday
The morning makes me think that Ragnarok has arrived: the sun is hiding and the world is covered with a wet mist! Starting the day visiting a New Client (out in the middle of nowhere)to gather information for the first draft of their Health and Safety Policy. Following that visit, I'm heading back at the Restaurant in Nottingham to assist with the EHO revisit. Then I'll write up the site visit notes and recommendations for the Restaurant. The EHO visit turned out to be more of a County Council QC process than an enforcement meeting. I have still left the client with a bit of an Improvements List.

Hagrid is remaining up in Lancaster for the rest of the week. He is back on Saturday to run a training course for a client and then heads off to Peterhead for three weeks for another Wind Farm project. After that, he is having a bit of down time (well earned). Jamie will need to get the training materials ready for Hagrid and I'll drop them over with him.  Jamie should also be posting the new, forthcoming training course information on the website. I will also have to pick up with a client who is struggling to put together training information for a third party accreditation scheme. I will also need to check that the Confined Spaces Training course is ready for delivery (by me) on Monday next week.

Bit of a blow from a large client who is putting some of our work on hold due to economic pressures. This is okay, provided that it does not go on for too long (yes, I want the work but also the client needs the compliance ausits doing to stay on track).

Another client need assistance with a Risk Assessment and Method Statement for "making-safe" a damaged high level window unit and associated glazing. This will include cordoning off access to a city centre street for a couple of hours.

Wednesday
Visited two client sites (one in the Coventry area and the other in Stratford) to update their Fire Risk Assessment and complete an Accessibility Assessment for them. Found one site to be acceptable, but the other was exceptional. Talking through the fire safety issues with the duty manager it was refreshing to find out that they had things under control and were fully up to speed with their own procedures and arrangements.

Received a call from a Care Home in the Leeds area that was referred to me by another consultant. I'll be sending them a proposal later today and I hope to be starting work with them next week on Health and Safety as well as Food Safety. It looks as though they are interested in a retained service.

Sending an email to arrange a phone call for Thursday with a new prospective large client.

Got back into the office in the afternoon to meet with a client who is struggling with their CHAS application. I think that the light has dawned and they are now pulling together the evidence of their good practise - the proof that they are managing safety!

Janice will be in the office in the afternoon, doing a little emergency replanning following a call from a client needing us to bring some of their forwards. This will have an effect on my work early next week and on John's work.

I am running a Free Seminar next week and need to ensure that this is being promoted well (by Jamie and others) and ensure that my presentation is completed. I also need to chase up the Fire Safety Leaflets that I have commissioned to ensure that they will be delivered to me before then. I will also arrange for this leaflet to be made available through my website.

Thursday
I had an interesting site meeting with a long established client in Nottingham to review their Health and Safety Policy and to plan the site visits to their sites (Nottingham and Scotland) for the next 12 months. There was also a lot of discussion of training and on staff development.

After that, I had to pick up the new flyers (on Fire Safety) and headed back to the office to do my bit of covering the phones (you never know, a large order may come in that means that I can plan for my retirement). There were a couple of enquiries to follow up on.

I intended to use the time in the office time to catch up on some office administration and to send out a couple of letters, quotes and even some invoices. I had a couple of client questions to deal with that ate into this time.

John is visiting a few clustered sites to carry out some fire safety reviews. Hagrid has returned a day early from Lancaster, allowing him to prepared for the next Wind Farm project in Peterhead. I have just set up a meeting with the client for this work to discuss what extra assistance we can provide as we move into next year.

Friday
Carried out a series of site visits to a multi-site client in the Stevenage, Northampton and Rugby areas to review their existing Fire Risk Assessments. Early start, late finish and a fair few miles. I managed to fit in a few phone calls (over coffee) and secured a couple of site visits for next week as well as a new (small) dental practice for a client for our access audit assessment. I also dealt woith a couple of calls to ensure that everything was in place for Hagrid to carry out the Health and Safety Training on Saturday for a local roofing company (before he sets off for Peterhead).

I managed to get back home in time to make my parents feel welcome (as they are staying over for the weekend).

What should contractors do to ensure they are compliant with best practice?

I was also asked: "What should contractors do to ensure they are compliant with best practice?"

In short, my answer would be: Think. The whole of the risk assessment process should, in my opinion, be a thought process aimed at reducing the risks (to as low a level as is reasonably practicable). All to often, it is a form filling exercise aimed at appeasing the next layer up in the project. In too many cases, the risk assessment does not relate properly to the site and does not address in detail the hazards that the site presents. Rarely are the risks assessments reviewed during the project and (in too many cases) the workers have not seen them or have given them only a cursory glance.

 

Contact me through my website

Are sub-contractors and their employees sufficiently aware of the risks involved in working at height?

In a follow up question, I was asked: "Are sub-contractors and their employees sufficiently aware of the risks involved in working at height?"

In my experience, this varies a lot. Some of the small contractors are very savvy with respect to work at height while others are not. Although the same picture is evident for the larger contractors too, but I often find that there is poor perception of the risks from temporary staff brought in during a project. The fact that falls from height remain the biggest single cause of workplace fatalities shows that there is still some way to go in raising the profile up to the right level (38 out of 171 workplace fatalities in 2011-11).

Contact us through our website.

How do you assess the potential risk to employees working at height?

Recently I was asked: "How do you assess the potential risk to employees working at height?"

The risk assessment process for work at height is not different for other risk assessment, it is just more focussed. As with all risk assessments, there is a hierarchy of control that needs to be considered, in this case it is: avoid, prevent, mitigate.  There should be thought given to ways in avoiding (or at least minimising) the need for work at height in any workplace, including construction environments. Where the need for work at height cannot be avoided, consideration must be given to preventing falls from height (such as by the provision of safe work platforms with adequate edge protection, or even by the use of a harness and lanyard arrangement designed to prevent the worker from reaching the edge from which they can fall (e.g. 2m lanyard anchored 3 m from the edge). In the event of prevention not being possible, then there should be consideration of mitigation of the effects of the fall (such as by the use of safety nets, fall arrest equipment or even air bags).

 

Perhaps the thing that is most often missing from a work at height risk assessment (or the accompanying method statement) is the rescue plan - how to retrieve safely a worker from a work at height (especially a fall involving fall arrest equipment) situation should the need arise. Few people are aware of the short period of time (about 15 minutes) in which a suspended, unconscious person should be rescued in to avoid (potentially fatal) suspension trauma.

 

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COSHH not the cosh

This blog post was written by Earl Anderson, an associate consultant who works with us.

The original Control of Substances Hazardous to Health Regulations 1988 (COSHH) came into force in October 1989, it was implemented to protect those who may be exposed to hazardous substances in the workplace: not as some cynics had said “to place an unnecessary burden on the employer ie to cosh them over the head.

The regulations have been amended and replaced several times over to the present Control of Substances Hazardous to Health Regulations 2002 (as amended), yet nearly 25 years later there are some employers who remain blissfully ignorant of the requirements of the regulations.

In defence of the employer, many have come to rely on the “external Consultant”, without realising that some of whom have had very little training with regards to chemicals.  In other cases the employer has delegated the task of carrying out COSHH assessments to a member of the work force as an “add on” to their workload.

In my experience, over the years I have seen the Material Safety Data Sheet (MSDS) transposed on to a pro-forma and presented as a COSHH assessment. I have also seen it called a COSHH Sheet and the phrase a COSHH risk assessment used.  I cannot over stress that a MSDS is not a COSHH assessment. The MSDS provides general information on a substance or product which is a valuable aid in completing a COSHH assessment.

With the boom in information technology, many employers are turning to “off the shelf electronic COSHH assessments” not realising their limitations. COSHH assessments are site and task specific and are best done by those directly involved with the process or substance with the assistance of specialist  “in house advice” or  “the external consultant” depending on the complexity of the task or process.

The key to completing a suitable and sufficient COSHH assessment is ensuring the assessor is competent to do it - i.e they are adequately trained and have the relevant experience; likewise for any specialist advisor you may call upon.

Earl's background is chemistry and he attended his first COSHH assessment training course at the Institute of Occupational Health, University of Birmingham back in October 1989. Like me, Earl is a Chartered Chemist, a Chartered Safety and Health Practitioner and OSHCR Registered Consultant.

If you need help with COSHH, contact us through our website.

Finger guards for doors: Schools and Nurseries

It is established practice to install finger guards on doors where vulnerable adults or young children use your premises. But how do they prevent accidents, and when should they be fitted?  When a door closes into its frame, there are a number of trapping points for fingers including: the latch, the hinge, and the hinge cavity. Because it is established practice, we would recommend that finger guards should be fitted in crèches, nurseries, indoor play areas for young children, and also in areas used by the first two year groups in primary and infant schools. Many local authorities will insist upon it, and they are relatively cheap to buy (from about £10) and they are relatively easy to install.

Latch 

It is easy to reduce the level of risk around the latch area, self-closing devices can be installed which reduce the rate of closure. Alternatively if the door does not need to be closed fully, foam bumpers could be installed.

Hinge
When the door opens a wide gap is created in the hinge cavity, as well as on the other side of the door, where the pin for the hinges is located, this smaller gap may also pose a risk to very small children if the gap is wide enough for fingers to be poked through. It is now established practice to fit a finger guard to certain doors in nurseries, primary school and care environments.

Do they prevent accidents?
Finger guards are typically made from a semi-rigid plastic which is pressed into folds when the door is close, and opens up to cover the gap when the door is opened. It is most common to fit these over the hinge cavity, but they may also be located on the pin side too when very young children are present.

What is the cost of not addressing this issue?
By way of example of what it may cost: a nursery was prosecuted in December 2011 and ordered to pay fines and costs of £75,000 in connection with an accident in which a young child lost the tip of his finger. The cost to the child is lifelong and may pose difficulties in later life. It was considered that the injury could have been avoided if the nursery had fitted door guards to its doors.

Do you need oour help in your School or Nursery?
Contact us through our website.