Among the variety of tasks HSE inspectors are expected to
carry out, we have to establish – where relevant – the scope and quality of
occupational health provision in the workplace.
Where occupational health surveillance is provided they tend
to focus on:
– Whether those delivering an OH service can demonstrate an
understanding of the requirements, advice and guidance of relevant legislation
that relates to the provision of suitable occupational health surveillance.
– That the results of any health surveillance procedures
lead to appropriate action.
– That there are effective control measures in place to
ensure that any health surveillance programme is being conducted correctly and that
appropriate action is being recommended and acted upon in the interest of
– That any health records are prepared in accordance with
the legal requirements and, that useful, anonymised feedback of the
surveillance results (within the constraints of the Medical Records Act 1990)
is given to employers on a grouped basis so that the employer can assess the
effectiveness of its existing control measures.
My colleagues and myself too often come across cases where
the OH provider has failed in one or more of these aspects. For instance:
1. A GP who routinely sent paint sprayers for chest x-rays.
2. Occupational health providers who believe lung function
monitoring is not necessary for workers using flux-cored solder.
3. Occupational health providers who routinely send the
detailed results of lung function tests of paint sprayers to their employer –
without the consent of the workers concerned.
4. Occupational health providers who take the blood pressure
of paint sprayers, but fail to carry out lung function tests.
From our office we have already served an enforcement notice
on one occupational health provider in order to gain improvements in the
quality of occupational health service delivery. And we are prepared to take
similar action in other cases.