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102paul  
#1 Posted : 02 August 2017 09:09:49(UTC)
Rank: Forum user
102paul

The company I work for is a domestic electrical installation company. I am having trouble with getting my company re-certified with CHAS which may end up costing me my job. 

We have held CHAS for a number of years. I re-applied online for our annual certification 2 weeks (13th July) before our current certificate expiry of 27th July, the assessor failed our re-assessment on Sunday 30th July.

We were failed on the subject of health surveillance despite this not being a problem from past re-certifcations.

A statement from the MD explaining duration of work and exposure times not requiring HS has always previously sufficed. The following HSE advice been followed in deciding if HS is required with statement 2 being applicable after control measures applied;

•There is an identifiable disease/adverse health effect & evidence of a link with workplace exposure

•It is likely the disease/health effect may occur

•There are valid techniques for detecting early signs of the disease/health effect

•These techniques do not pose a risk to employees

How does CHAS work with us not having HS at present but programming it in for the future? Can we still 'pass' without HS here and now? 

We have in the meantime no certification with Clients and Customers emailing my MD threatening to pull work.

Alfasev  
#2 Posted : 02 August 2017 10:13:17(UTC)
Rank: Super forum user
Alfasev

With disease/adverse health they are probably looking at the long term cumulative effect. Go back to basics and include it in your risk assessments. For domestic electricians they will probably be looking for intermittent exposure asbestos, dust, noise & vibration from drilling, and COSHH.

If the risks are low after your controls (and you will need controls) say it is and say formal health surveillance by an occupational health professional is not required. I would also write a brief one page policy and include the topic in a tool box talk.  It may be worth considering an annual self-assessment and a procedure to escalate issues to occupational health professionals (doctor).

I am guessing but across your whole submission you’re probably a little week in this topic. 

Centurion  
#3 Posted : 02 August 2017 11:02:44(UTC)
Rank: Forum user
Centurion

Hi,

You have mentioned that previous assessors didn’t raise anything with regards to this.

The glaring problem with CHAS is the inconsistencies of their Assessors.

When I was assisting contractors with CHAS it soon became obvious that independent self-employed assessors were more easy going whereas assessors from companies were more nit picking as if they had to raise something just for the sake of doing so.

It is annoying but you have to give them what they want.

A way forward for CHAS would be for them to simply state what issues have to be addressed and how.

This then would be a common working platform for both parties.

Cheers

Andy

chris.packham  
#4 Posted : 02 August 2017 11:17:08(UTC)
Rank: Super forum user
chris.packham

The ACoP for CSHH (sixth edition) significantly changed the goal posts on health surveillance. I have a document with the relevant section taken from the ACoP. If you PM me with your e-mail I will happily e-mail this to you. I think it might explain why your health surveillance system was found lacking.

Chris

peter gotch  
#5 Posted : 02 August 2017 12:17:20(UTC)
Rank: Super forum user
peter gotch

Suggest you write to assessor to point out that HSE guidance indicates you don't need to do Health Surveillance.

Copy to their boss.

RayRapp  
#6 Posted : 02 August 2017 13:40:37(UTC)
Rank: Super forum user
RayRapp

I think it would do your cause no harm if you were to highlight your failed re-assessment followed after your expiry date despite the fact you had re-applied two weeks prior to the expiry date. Poor form in my book.

stevewilliams  
#7 Posted : 02 August 2017 15:21:21(UTC)
Rank: Forum user
stevewilliams

Hi Paul,

I work closely with a CHAS assessor of 15 years, please get intouch if I can be of assistance and find a solution for you - stevewilliams@beaconrisk.co.uk.

chris.packham  
#8 Posted : 02 August 2017 16:57:43(UTC)
Rank: Super forum user
chris.packham

Extracted from one of my occasional newsletters re skin in the working environment:

With regard to skin health surveillance, the new ACoP is more specific about the way in which the requirement, as contained with the COSHH regulation 11, should be interpreted. Paragraph 237, in particular, indicates where skin 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 skin health surveillance applies to a much wider range of occupational environments than might have been apparent from earlier versions of the ACoP. In particular it suggests that the employer (or his representative) should inform themselves of the potential for skin 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 skin disease does not indicate that skin 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.

Hope that this is of some help

Chris

A Kurdziel  
#9 Posted : 03 August 2017 08:08:29(UTC)
Rank: Super forum user
A Kurdziel

What did the assessor say about “health surveillance”?  He should not simply say you failed this or that without explaining what they expected you to do. You are not a mind reader. A lot of so called auditors are simply people with long check lists and they just tick things off, without understanding what it is they really want.

Health surveillance can include a whole range of things from fully fledged regular medical check-ups by a doctor, to managers just asking their staff if they are developing some work related skin complaint. What do they think you need? Ask or even demand that they tell you?

If they can’t or won’t take them to court as they have failed to do their job and as a result your company’s livelihood is at risk. That’s negligence.

By the way what does your MD expect? How can the failure of the assessor be your fault?

 

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