The purpose of health surveillance is to protect employees through the early detection of adverse health effects which may occur as the result of exposure to chemicals or other processes in the workplace. Health surveillance is not a preventative measure, and it is not a substitute for proper control measures.
The aims of health surveillance are to:
Evaluate the harmful effects of exposure at an early stage
Evaluate the effectiveness of control measures
Prevent further deterioration in the worker’s health
Assess fitness for a particular type of work through pre-employment and pre-placement health checks
Ensure that requirements under legislation are met.1
Risk assessment should identify exposures to chemicals or other processes which may pose a risk to the health of staff. Control measures should be implemented to eliminate the risk or reduce it as far as is reasonably practicable. Where the risk cannot be reduced or controlled sufficiently to prevent harm to health, surveillance will be required.
The type of health surveillance required may range from keeping records of exposure to an examination by a doctor.
The general criteria for carrying out health surveillance, as set out in the Management of Health and Safety at Work Regulations 19992 and the Control of Substances Hazardous to Health Regulations 20023 is as follows:
There is an identifiable disease or other adverse health outcome from exposure or process and
There are valid techniques for detecting indications of the disease or health effect
There is a reasonable likelihood that the disease or effect may occur under the conditions of the work
Surveillance is likely to further the protection of the health and safety of workers.
Here are two examples of situations where health surveillance is appropriate:
1. Exposure to colophony fumes
Colophony, which is produced during soldering with rosin-cored solder wire, is a known respiratory sensitiser.
It may cause asthma, which is an identifiable disease.
There are valid techniques available for the detection of asthma – symptom questionnaires, lung function testing, and allergy testing.
In this case, health surveillance will benefit the employee through the early detection of asthma.
Exposure to high levels of noise is known to cause hearing loss.
A valid technique – audiometry – is available to detect the effects of noise on hearing.
In this case, health surveillance will benefit the employee through the early detection of noise-induced hearing loss.
Several pieces of health and safety legislation require the employer to carry out health surveillance. These include:
1. Management of Health and Safety at Work Regulations 19994
These regulations require employers to carry out appropriate health surveillance as identified by risk assessment.
Table 1: Skin and respiratory sensitisers
2. The Control of Substances Hazardous to Health Regulations 20025
Regulation 11 requires employers to carry out health surveillance where staff are exposed to:
Substances which may cause respiratory sensitisation and asthma
Substances which may cause skin sensitisation and occupational dermatitis
Substances known to cause or suspected of causing cancer
Contact with chrome solutions, chromic salts or other chromium compounds
Exposure to biological agents
Substances of recognised systemic toxicity – for example, those that can be inhaled, absorbed through the skin, or swallowed; and that affect parts of the body other than where they enter, such as some solvents which may be inhaled or absorbed through the skin, but may affect the liver.
A list of respiratory and skin sensitisers is given in Table 1 (see right). This list is not exhaustive, and there may be other substances which may also cause respiratory or skin sensitisation. These should be identified as a result of risk assessment.
These regulations require that health surveillance is carried out on workers who are regularly exposed to noise above the upper exposure action values, without taking into account any noise reduction provided by hearing protection.
The upper exposure action values are:
A daily or weekly personal exposure of 85dB (A-weighted)
A peak sound pressure of 137 dB (C-weighted).
These regulations require health surveillance to be carried out for employees who undertake licensable asbestos work. Additionally, where workers are inadvertently exposed to asbestos fibres, a record of exposure must be maintained.
These regulations require health surveillance to be carried out where exposure to lead may occur through inhalation, ingestion or absorption through the skin, and where the exposure is likely to be significant.
These regulations require heath surveillance to be carried out where:
The risk assessment indicates that there is a risk to the health of staff who are or are about to be exposed to vibration – eg, employees who may be particularly sensitive to vibration because of existing health conditions
Where staff are likely to be exposed to vibration at or above an exposure action value.
Those at risk of developing health problems from exposure to vibration will include staff who regularly use hand-held or hand-guided power tools and machines such as:
Sanders, grinders, disc cutters
Chainsaws, brush cutters, hedge trimmers
Scabblers or needle guns
Holding work-pieces which vibrate while being processed by powered machinery, such as pedestal grinders.
Health surveillance for vibration is not appropriate for individuals whose daily exposure only exceeds the exposure action value on rare occasions, and where the assessment identifies that the risk to health is consequently very low.
Setting up a programme
Generally, the occupational health adviser (OHA) will be responsible for either carrying out the health surveillance programme or setting up systems for and overseeing the programme – eg, a programme for surveillance for staff who are exposed to vibration where specialist advice and input may be required.
The starting point for any health surveillance programme will be the risk assessment, which should identify exposures where health surveillance needs to be carried out. OHAs will need to work closely with their health and safety colleagues to ensure that they are aware of the result of the risk assessment for the tasks or process that may give rise to health effects requiring health surveillance.
Other sources of information that may be useful include manufacturers’ data sheets, results of workplace monitoring, published research/information, and relevant legislation. Complaints from staff about any health effects from exposure may also indicate that health surveillance may be necessary. Complaints may also indicate that existing control measures are not working properly or are not adequate, and this line of inquiry should be exhausted before health surveillance is considered.
Generally, asking the following questions will help the decision-making process:
Is there a health hazard arising from the exposure?
Is there a significant risk?
Have appropriate measures to eliminate the risk been implemented?
Is there a residual risk to health which cannot be controlled in any other way?
Is health surveillance appropriate?
If health surveillance is appropriate, the level, frequency and procedure for carrying out the surveillance should be determined.
Health surveillance, where it is required as indicated by the results of risk assessment, is extremely important in protecting the health of staff. It will also impact on the individual and the organisation. It is important that sufficient attention is given to setting up a programme to ensure that the aims of the programme are met through:
Involving employees and their representatives
Getting specialist advice if appropriate
Identifying the most suitable health surveillance procedures
Designing the system and putting someone in charge
Carrying out the procedures and providing feedback information
Monitoring and evaluating the programme.
Involving staff and their safety representatives is key to ensuring the aims of a health surveillance programme are met. Staff need to be made aware of why health surveillance is being carried out, what the surveillance will entail, how the information obtained as a result of the surveillance will be managed, and what information will be made available to management. They will also need to know what will happen if the health surveillance results indicate that they can no longer do their job.
Carrying out health surveillance is not an end in itself, and there are a number of actions that should be taken to ensure that the aims of a health surveillance programme are met and that it is effective in protecting the health of staff, particularly if the results indicate that the health of staff may be affected. These include:
Informing the employee and management of the results
Preventing further harm by temporarily or permanently removing the employee from exposure
Referring the individual for further examination and/or treatment as required
Reviewing the health of similarly exposed staff
Reviewing the risk assessment
Reviewing and improving control measures if necessary.
Suitable health surveillance will always include keeping health records. Individual health surveillance records should include an up-to-date health record for each individual undergoing health surveillance. All records of health surveillance must be retained for 40 years from the date of the last entry.
Mary Guinness is principal OH and safety adviser at Her Majesty’s Prison Service.
1 Agius, RM (2007) Health Surveillance, the Intranet, http://www.agius.com/hew/audit/.hmt.
2 The Management of Health and Safety at Work Regulations 1999, London, HMSO.
3 The Control of Substances Hazardous to Health Regulations 2002, London, HMSO.
4 The Management of Health and Safety at Work Regulations 1999, London, HMSO.
5 The Control of Substances Hazardous to Health Regulations 2002, London, HMSO.
6 The Control of Noise at Work Regulations 2005, London, HMSO.
7 The Control of Asbestos at Work Regulations 2006, London, HMSO.
8 The Control of Lead at Work Regulations 1998, London, HMSO.
9 The Control of Vibration at Work Regulations 2005, London, HMSO.