Respirable crystalline silica health surveillance – are you compliant?

Outsource Safety LtdSafety newsRespirable crystalline silica health surveillance – are you compliant?
July 18, 2018 Posted by Roger Hart

There’s a huge amount being written about respirable crystalline silica of late.  We’ve been speaking about this for the past 22 years and have completed many monitoring and sampling programs for respirable crystalline silica (RCS) since our consultancy first started back in the early 90’s and we think you need to know more about what’s expected of your respirable crystalline silica health surveillance programme.

In the past 22 years we like to think we’ve played a part in raising awareness amongst a lot of different people through construction and related trades through free talks at Working Well Together events through to stopping people I’ve walked past or even had in as trades at home and speaking to them about the real risks and the misconceptions on the dangers of RCS exposure.

Respirable crystalline silica health surveillance

For most contractors, the message is getting to them and we now see more people wearing the right equipment more of the time.  Yes, we still have a long way to go but things are improving.  But what about those businesses that have raised awareness in their workforces and supply chains.  The slightly bigger companies which have really started to address risks from RCS, and also construction dust in general, at their sites – are they now compliant?  Are they managing risks to the correct standards?

We think that the answer to that question is No.

HSE document G404: COSHH Essentials. Health surveillance for those exposed to respirable crystalline silica gives good advice on what you are expected to do to monitor the health of your workforce and we’d suggest that you review it.  Particularly because Regulation 11 of COSHH (Health Surveillance) is a key area of fines under HSE’s Fee For Intervention scheme, as we stated in our White Paper on Fee For Intervention.

If you’d like to delve a little deeper and make sure your occupational health provider is as competent as your Occupational Hygienist (that’s us) then also review the supplementary document here which provide questionnaires and more specific advice on what to include in this health surveillance programme and who the competent person should be for carrying out each stage of the health surveillance programme.

Summary of health surveillance for RCS exposed employees

Check the below and see if your current arrangements are compliant (extracted form the HSE supplemetatry guidance document available here

Baseline assessment for new entrants, before or shortly after first exposure to RCS, would include:
  • respiratory questionnaire (Example 1);
  • lung function testing (spirometry) to measure forced expiratory volume (FEV1) and forced vital capacity (FVC). FEV 1 is measured to within current American Thoracic Society (ATS)/European Respiratory Society (ERS) stipulated accuracy of 150 mls (or 100 mls if below 1 litre). The results should be recorded to monitor how values change with time (see Example 1B); and
  • consideration of a baseline chest X-ray for comparison with future chest X-rays.
After that, for both new-entrant and pre-existing employees, annual health surveillance would include:
  • respiratory questionnaire; and
  • lung function testing.
After 15 years of exposure to RCS
For employees who have had 15 years of exposure to RCS while working for one
or more employer(s), the health surveillance for that year would include:
  • respiratory questionnaire;
  • lung function testing; and
  • PA (posterior to anterior) chest X-ray.
(This includes pre-existing employees with previous RCS exposure of 15 or more years at the time of introducing the health surveillance programme.)

Subsequent health surveillance (as detailed in Example 2) would be repeated annually (or earlier if indicated by the results of health surveillance or if a worker complained of symptoms in the intervening period). The employer may appoint a responsible person (supported by an appropriate health professional) so that workers can report symptoms.

Annual health surveillance would include:
  • respiratory questionnaire;
  • lung function testing; and
  • every 3 years, a PA chest X-ray.
In summary
To summarise the above health surveillance programme:
  • questionnaires and lung function tests at baseline and annually thereafter; and
  • PA chest X-rays at baseline, after 15 years, and every 3 years after that, unless advised otherwise by a health professional.