Is there a need for occupational health technicans to be regulated? How should an organisation ensure their technicans are educated to a sufficient and competent level? Pippa Crouch looks at what might need to evolve.
In the first part of this two-part series, the origins of the occupational health technician (OHT) were discussed and we compared their role with that of the health care support worker (HCSW). It considered the steps taken to delegate practice and education and identified gaps in the current provision.
This article will consider the framework recently published by the Society of Occupational Medicine (SOM) and discuss why the adoption of educational frameworks for occupational health has not mirrored that of the NHS.
Within the first article of the series, the RCN standards for OHTs, proposed in 2010, were reviewed. Unfortunately, it appears no further progress was made until the SOM picked up the mantle in 2017 and established an OHTs’ group that has been working to gain greater recognition for this role as an established career pathway (Society of Occupational Medicine, 2019). The levels of competency are outlined in the box on the right and are similar to those laid out in the RCN’s document. There is also a self-assessment matrix issued by SOM.
SOM states an OHT should be trained and assessed in the following competencies:
There have been similar initiatives from many OH providers to address the current educational imbalance and to afford some protection to the role. With no prerequisite qualifications an OHT can start immediately, with no formal training, and be offered ‘on the job’ training, which could range from in-house teaching up to a university diploma. There is no requirement for them to undertake the Care Certificate, a standalone course for anyone new working in the NHS.
Clinical governance and regulation
There is a lack of cohesion in the commercial sector as, unlike the NHS, there is no national framework for education and training. Perhaps the reason the SOM standards have not yet gained traction in the commercial setting is because of a lack of mandatory legislative drivers for clinical governance. For any care provider there is a requirement to be registered with the Care Quality Commission (CQC) and there are clear parameters for clinical governance, supervision, and training for competent staff as part of the fundamental Care Standards. Currently commercial occupational health schemes are exempted from the requirements of the CQC, as they do not provide treatments requiring hospital admission (CQC, 2015).
The Safe, Effective, Quality Occupational Health Service (SEQOHS) scheme from the Faculty of Occupational Medicine (FOM) has many similarities to the standards set by the CQC; it too requires the competency and training of all practitioners involved in service delivery to be tested. However, this is a voluntary accreditation scheme and at present there is no requirement for any OH provider to engage with it.
Whilst this article’s focus is on the training and development of the OHT role, it appears remiss not to reflect on the wider issues of a national lack of regulation within the field of OH – not all services are required or chose to register with the CQC. The end result is that technicians are unregulated, there is no legal requirement for the service providers they work for to be registered.
One option for consideration might be for technicians to gain registration with the Health and Care Professions Council, as is the case for 15 other professions, including clinical scientists. Their training would become standardised and compliant with standards set by the HCPC and the title of ‘occupational health technician’ would then become protected.
The Health and Safety Executive (HSE, undated) requires the competency of those delivering health surveillance to be checked and assured. Failing to use competent practitioners could result in prosecution as identified in R v Audio Medical Services (Personnel Today, 2012). The employer commissioning the OH service must check the qualifications of staff, however there does not appear to be any way of validating an OH provider. Is it then a responsibility of the employing company commissioning the OH service to check the qualifications of all staff involved in the contract?
The HSE guidance simply states:
“There is no governing body or recognised qualification for occupational health technicians.
- If technicians are involved in health surveillance, they should receive training from a competent training provider for the specific aspects of work they are involved in, for example spirometry and audiometry
- Their work must be supervised by an occupational health physician or nurse
- They must not interpret test results or provide feedback from health surveillance”
It is unclear from this whether it is the employing organisation’s responsibility also to check the qualification of the regulated healthcare professional accountable for their practice.
Professional identity
This must be equally frustrating for the OHT as it is employers; the lack of an accepted national framework has led to variations in their treatment and a lack of professional accreditation results in a loss of professional identity. This is reflected in the differences in pay. In 2018 SOM reviewed the annual salary of the OHT and found it to be around £22,000, (approximately comparable to a band 3 role within the NHS). This survey was repeated in 2021 and over 50% of respondents stated their salary band was over £25,000. Therefore, employers are financially recognising the service they provide but failing to offer the education pathway and status recognition.
There is significant potential for development here – it is the only HSCW role whereby the practitioner can choose to work as an employee, sole trader or establish their own company, thereby determining the course of their own employment and career trajectory. Many OHTs have successfully created and run their own occupational health companies. There remain some concerns about regulation of the industry, as rogue practitioners could establish themselves as independent OHTs without appropriate training, clinical supervision or oversight by a registered health professional. Professional regulation may address these concerns.
Regulation may not be the proclaimed panacea – unscrupulous practice occurs in many sectors, including nursing, as evidenced by the results of Nursing and Midwifery Council hearings. It goes part way to address the issue of vicarious liability, as they would be accountable for their own practice and the risk would sit with the technician as opposed to the supervising practitioner.
Many technicians would value the availability of a formal career pathway and some wish to train to become an OH nurse adviser without first completing general nurse training.”
OHT education
If there are concerns about technicians acting ultra-vires, then further development is needed in education.
At present the educational offer ranges from pure in-house training to a graduate diploma and there are no recommendations from professional bodies around best course to follow. Again, it is reliant on the service standards of the OH provider. Most appear to follow the in-house competency training pathway with specific industry courses for spirometry and audiometry. Courses for these skills generally equates to five days training and at a cost of several thousand pounds. Various providers offer a three-day technicians’ course, which provides a grounding in most of the necessary skills, and yet these are not accredited courses affiliated to educational establishments. The University of Derby offers a graduate diploma, but this is not specific to OHTs. Other universities, including Leeds Beckett and the University of South Wales, no longer offer training for OHTs.
In 2015, an OHW+ article raised the importance of OHTs and their training (Paton, 2015). Some seven years on and we now appear to be in a worse position, whereby all the courses referenced in his article are no longer running. In fact, we were unable to identify any technician-specific university courses at NVQ, diploma or degree level at the time of writing.
To optimise OH provision, we need to:
Within the author’s organisation, all staff, including technicians, undertake competency-based training pathways; they must complete annual training courses and their practice is regularly audited. OHTs are trained to fully understand the tests and their results so these can be discussed with employees where appropriate, but they are not responsible for interpreting results. OH nurse advisers and OHTs attend the same courses and there is no distinction made – attendees are assessed as either competent or not yet competent. Peer reviews (of OHTs and OHAs) form part of the appraisal process and case studies are discussed at team meetings. Should an OHT escalate a case to their clinical supervisor – a registered health care professional – they present their findings and referral rationale and discuss the outcomes with them. Whilst it remains the judgment decision of their clinical supervisor, this process further supports their learning and practice development.
Many technicians would value the availability of a formal career pathway and some wish to train to become an OH nurse adviser without first completing general nurse training. This prospect is extremely unlikely unless the Nursing and Midwifery Council approve direct entry programmes conferring SCPHN registration as they have done for registered midwives.
Need for regulation and educational pathways
This author would like to see the discipline regulated, with a clear educational pathway. Further protection for service users would be the adoption of either CQC or SEQOHS approval made mandatory for all OH providers. Looking forward, it is likely that an increasing number of OH nurses and physicians will establish themselves in commercial practice, and this measure too would further safeguard service users. Once regulation (both individual and service-based) is established, hopefully we will see a return of the university courses to further support clinical development. Technicians should be able to set up independently, with controls, as the specialism needs new people and innovative ideas to drive the occupational health agenda forward.
Covid-19 is still a global pandemic and we may only have seen the tip of the iceberg in terms of its impact on the nation’s health. The current approach to OH provision should evolve supporting a more agile workforce to address ensuing workplace health issues. Formalising and regulating the role of technicians may help to expand the OH workforce and the services which can be offered to support worker health, safeguarding the future of technicians and therefore many OH services.
Competent technicians have an important part to play in the provision of high-quality occupational services. They can become highly skilled within health surveillance, undertaking assessments such as lung function testing, audiometry, and being involved in Tiers 1 and 2 of hand arm vibration assessments. Some may also wish to gain additional competencies in other clinical skills, such as collection and chain of custody processing of specimens for drug and alcohol testing, venepuncture, recording ECGs, and contributing to fitness assessments such as the Chester Step Test.
Technicians should be applauded for wishing to develop their role and also to aspire to have access to high-quality formal education opportunities and regulation by a professional body. The likely retirement of many OH nurses in future years is likely to leave a significant gap and may hasten this process.
References
Care Quality Commission (2015). Registration under the Health and Social Care Act: The Scope of Registration. CQC: London. https://www.cqc.org.uk/sites/default/files/20151230_100001_Scope_of_registration_guidance_updated_March_2015_01.pdf
Health and Safety Executive (undated). Assessing Competence. https://www.hse.gov.uk/health-surveillance/occupational-health/assessing-competence.htm
HCPC (undated.) What is the HCPC? https://www.hcpc-uk.org/public/what-is-the-hcpc/
Paton, N (2015). Is the occupational health technician the answer to skills shortages in OH? Personnel Today, 2 July 2015. https://www.personneltoday.com/hr/occupational-health-technician-answer-skills-shortages-oh/
Personnel Today (2012). Occupational health provider fined for poor management of HAVS screening. https://www.personneltoday.com/hr/occupational-health-provider-fined-for-poor-management-of-havs-screening/
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RCN (2010). Standards and competencies for occupational health. https://studylib.net/doc/14197766/roles-and-responsibilities-of-occupational-health-support
Society of Occupational Medicine (2019). Career Path of Occupational Technician. https://www.som.org.uk/sites/som.org.uk/files/Career_Path_of_OH_Technicians_April_2019.pdf
