A Company in the electronics sector has followed the HSE Health Surveillance guidelines including risk assessment. No chemicals are used which require health surveillance according to the COSHH regulations although sensitisers are used (3M Primer 94 and PC5343 and PC6144 Activator). A noise survey indicates two mandatory hearing protection zones and hearing protection is provided. The Company has decided to withdraw an offer of occupational health surveillance to employees. Please let me have your advice, comments and opinions.

Thank you Peter_OC - I'm very grateful for your helpful comments.

Thanks SteveDM. It looks like there's no statutory requirement for surveillance however having no OH surveillance at all may impact on insurances and social factors (duty of care)? Also with no monitoring the Company would have no data to rely on following potentially fraudulent claims?

In the sixth edition of the ACoP for COSHH HSE set some modified requirements regarding 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.

If you have sensitisers present and there is potential for contact (skin as well as inhalation, and skin contact can be airborne and cause skin reactions at below the WEL) then perhaps it would be wise to obtain OH advice on what you might need.

Chris