Monthly Archives: June 2014

COSHH Health Surveillance


Health surveillance is a subject which is not commonly addressed by SME organisations but one which can have an important role in managing the health and safety of your employees and also in controlling any civil liability which might arise from claims related to workplace health.

Perhaps the most common example would be audiometric testing for high noise level environments, most people know of a business which uses these tests but what about other workplace health problems such as dermatitis (shown right) and respiratory problems?

By taking a quick look through the hazard data sheets of the substances to which your staff are exposed your are likely to come across a range of products which refer to the potential for dermatitis and some which refer to skin or respiratory sensitisation (Risk Phrases R42 / R43).

The Case for Health Surveillance

Should you have identified substances which do carry these types of risks it is very likely that your risk assessments have identified the need to staff to wear gloves or other PPE or perhaps your have put in extraction systems or, best of all, eliminated or at least reduced exposure.

However, it is likely that some exposure will still occur, staff don’t always use all of the precautions which we would wish them to do as they are, after all, human.  Health surveillance will give you evidence that staff who are protecting themselves remain healthy and for those who might be prone to take more chances with their health it can give an early warning of future problems, for example;

A staff member experiences skin problems which are worse during the winter months (when wind, wet and rain could put skin under additional stress).  They put this down to the weather and a host of other factors when the root cause is exposure to a hazardous substance without using their gloves.  You carry on assuming that all staff are working without problems when, in the background, these unprotected exposures are growing into a health problem which could result in months away from the workplace, a RIDDOR reportable workplace disease and perhaps even a civil claim.  Health surveillance should have raised this issue through the completion of a simple annual questionnaire allowing you to act at an early stage.

Legal Requirements for Health Surveillance

The Control Of Substances Hazardous to Health Regulations 2002 Regulation 11 (COSHH) requires employers to implement a system of health surveillance where:

  • The exposure of the employee to a substance hazardous to health is such that identifiable disease or adverse health effect may be related to the exposure;
  • There is a reasonable likelihood that the disease or effect may occur under the particular conditions of the work;
  • There are valid techniques for detecting indications of the disease or effect.

When Should Health Surveillance be Applied

The best time to start is when you first employ a new member of staff.  They will most likely have experience of your industry and the substances which you use but what of their previous employer?  Will they have taken safety as seriously as you? This person could have received exposure to hazardous chemicals for years and so make sure they do not exhibit any symptoms of skin or respiratory sensitisation (contacting you HR advisor is recommended at this point).

How can we implement Health Surveillance

You may be surprised to hear that you are probably implanting a level of health surveillance already.  If you have surveyed your staff regarding the Display Screen Equipment regulations and their comfort whilst using computers you have completed health surveillance.

Whilst it would be true to say that a questionnaire will not be appropriate in every situation it will suffice for the majority of circumstances.  Once you have identified any issues you can flag those staff with concerns for further investigation but this can take the form of finding out more from them and what the causes could be before sending them to an occupational health specialist or their local GP.

What should my next steps be?

A responsible person can be trained to make basic checks such as skin inspections for first signs of redness and could, for example, be a supervisor, employee representative or a first aider.

For more complicated assessments such as medicals fitness for specific jobs, lung function tests, hearing tests etc, an Occupational Health Nurse can perform the assessment and do various examinations. Some jobs may only require the employee to fill in a questionnaire which can then be screened. This is normally done for new employees to ensure fitness for the type of post but can also be done periodically for jobs with specific hazards. For more complicated procedures, an Occupational Health Physician may be required.

Common Examples of health surveillance

Tasks Type of surveillance
DSE Use Vision Screening
Muscular Assessment
Workstation Assessment
Drivers OH Assessment
Manual Handling work OH Assessment or questionnaire
Noise Hearing test if exposure at levels of 80Db or above
Vibration Self reporting examination or questionnaire + OH examination if required
Asbestos, lead, compressed air OH assessment
Substances Hazardous to Health:
Chemicals, vapours, solvents, fumes
Dusts, gases, aerosols
Biological agents
Varies depending on substance:
Self reporting
OH assessment
Respiratory function tests
Skin surveillance
Blood test
Urine tests
Ionising Radiations Dosimetry
Personal monitoring
Laser users Eye examination
Confined spaces – use of respirators OH medical
Pregnant workers OH assessment or questionnaire
Night work OH assessment or questionnaire


Health Records

Where any health information is written such, lung function tests, records have to be kept for a minimum of 40 years, typically by the Occupational health provider.

We trust that the above provides a useful summary and food for thought but if you have further questions we here to help, just call 01453 800100 to speak to an expert COSHH Safety Consultant to guide you through your specific requirements.

Posted by Roger Hart

HSE to blitz construction sites across the UK

HSE announces that those managing health on construction sites poorly will ‘feel the full force of the law’.

As predicted this will be the year of the health section of the Health and Safety at Work Act and HSE are making a concerted effort to cover these issues.  Interestingly this series of visits will be across the whole of the UK rather than just one isolated area which would have been typical of more recent construction blitzes.

What should be your next step?

If I was a construction site manager I would be checking anything related to health and this means;

  • Staff taking adequate precaution with general dusts
  • Dust masks being face fitted
  • Dust masks being stored in bags or boxes to keep them clean when not in use
  • Good hygiene before meal and natural breaks
  • Health surveillance under R11 of COSHH (dermatitis / respiratory)
  • Contact with an occupational health expert (like ourselves) to work with if things escalate
  • Good practice when working with lead
  • Appropriate impervious gloves when using chemicals
  • Respirable Crystalline Silica (RCS)- make sure staff are still using FFP3 makss even if they are using water supression – this is essential.

We hope the above helps.  If you’re already a client then please contact us for more advice and if you’re not yet a client, please give us a call on 01453 800100 for some advice and a competitive cost on closing out all of the issues above.

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

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Posted by Roger Hart

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