I was wondering if someone could give me a definitive answer to my question as I am getting conflicting advice from all over the place and quite frankly I am tying myself up in knots. I work in an engineering company using mainly CNC's for machining metal parts, they are in daily contact with metal working fluids. Procedures are in place to minimise contact as much as possible however this cant be eliminated completely. My question is do we need to provide health surveillance for skin and respiratory conditions? If so is it compulsory or voluntary for employees? I appreciate your time Angela

Angela Metalworking fluids are a favourite topic of mine as I worked for some years in metalworking/metalforming industries. Yes, you will definitely need skin health surveillance. You might also need to check lung function unless you can be certain that the machine guarding is adequately preventing respiratory exposure to aerosol. You can easily check this using the Tyndall beam method. For skin health surveillance my daughter has developed a package. Her PhD was on new techniques for skin health surveillance. Most skin damage will take the form of irritant contact dermatitis. However, even sub-clinical irritant damage can predispose to allergy. So detection of this sub-clinical damage is important. How you can do that is something that we can help you with. If you would like more on this let me have your e-mail address (mine is chris@enviroderm.co.uk). Best regards Chris

The 6th edition of the COSHH ACoP moved the goalposts for skin health surveillance: Examples where health surveillance is appropriate under the criteria in regulation 11(2)(b) are: where there have been previous cases of work-related ill health in the workforce/place; where there is reliance on PPE, eg gloves or respirators, as an exposure control measure; eg printers wearing gloves to protect against solvents used during press cleaning, or paint sprayers using two-pack paints wearing respirators to prevent asthma. Even with the closest supervision there is no guarantee that PPE will be effective at all times; where there is evidence of ill health in jobs within the industry; eg frequent or prolonged contact with water (termed ‘wet-working’) causing dermatitis in hairdressers and healthcare workers, or breathing in mists from chrome plating baths causing chrome ulcers in platers. Paragraph 238 amplifies this: This is not a definitive or exhaustive list and there will be many other instances where health surveillance is required. Employers will need to seek information or advice on the specific health risks identified in the risk assessment, or through any topic-specific HSE guidance, trade associations or other professional sources. So in theory even if your workplace has never had any cases of occupational skin disease if others doing the same work have you will need to consider skin health surveillance! Note also that the wearing of protective gloves also requires skin health surveillance. Chris