Rank: Super forum user
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Friends,
is there anything as simple as a straighforward 'Here's the risk phrase, here's the health surveillance for it'?
I'm having real trouble coming up with policy that gets further than 'health surveillance might be appropriate'. Which just seems a bit wishy-washy to me.
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Rank: Super forum user
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For surveillance to be an appropriate control, there are some preconditions, including:
- Measured exposures at or near the defined WEL (workplace exposure limit), and no short-term options for reducing these.
- A measurable medical symptom or condition that indicates exposure.
It would clearly be an over-reaction to pay for surveillance if over-exposure isn't a possibility. If you need more advice, go to a competent Occupation/Industrial Hygienist rather than a doctor or nurse, unless the latter have good occupational health qualifications and experience of the health hazardous you're concerned about.
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Rank: Super forum user
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The latest edition of the ACoP for COSHH has revised conditions for when health surveillance is needed. It is more specific about the way in which the requirement, as contained within the regulations, should be interpreted. Paragraph 237, in particular, indicates where health surveillance is required.
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."
Paragraph 237 in particular indicates that the operation of a system of health surveillance applies to a much wider range of occupational environments than might have been apparent from earlier versions. In particular it suggests that the employer (or his representative) should inform themselves of the potential for health problems to arise in their particular workplace based on what has happened in other similar workplaces. The fact that the employer has had no cases of occupational disease does not indicate that health surveillance is not required. Note also that wherever gloves are worn for protection against chemicals (presumably also including water) (skin) health surveillance is required.
Simply being below the WEL does not negate the need for health surveillance. For example, someone with the potential for an allergic skin reaction may develop this on the face due to airborne exposure at well below the WEL.
Wet work, i.e. frequent and/or extended exposure to water or extensive wearing of occlusive gloves would also dictate skin health surveillance.
If you need more then PM me with your e-mail address.
Chris
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Rank: Super forum user
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I wrote this an hour ago but the system froze; so here it is (although a bit late)- “Is there anything as simple as a straightforward 'Here's the risk phrase, here's the health surveillance for it'?”
Well no. First risk phrases have gone the way of all old legislation and are now replaced by hazard statements, which is a better definition as they describe the hazard (potential for harm) for a particular substance not the likelihood of harm(which is, of course, the risk).
So whether you require health surveillance depends in part on the risk of exposure but also whether there is suitable health surveillance available. The HSE has loads of guidance about what sort of health surveillance is used in what sort of circumstances. It ranges from someone looking to see if someone is developing rash to blood and urine test. The lower end stuff can be done locally by a manager let’s say but the upper end stuff should be done by an occupational health specialist or hygienist.
Basically do what Chris Packham says…
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Rank: Super forum user
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Rank: Super forum user
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I cannot speak about other aspects of health surveillance, but for my particular area (skin) the HSE guidance does not reflect some of the new techniques that are now available and that can help us to be more pro-active and effective.
Chris
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Rank: Super forum user
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I cannot speak about other aspects of health surveillance, but for my particular area (skin) the HSE guidance does not reflect some of the new techniques that are now available and that can help us to be more pro-active and effective.
Chris
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Rank: Super forum user
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Thank you for all this, folks.
It seems the short answer is 'no'. That's a shame. I'd like to be sure that when someone says "no, it's not necessary for that", they're sure of what they've decided.
Thanks again.
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Rank: Super forum user
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Think Chis is right if you go down that route you will get conflicting standards or none atall..go for job role and there is some guidnace available from the construction better health to give you a guide. :)
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