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hsherwoo  
#1 Posted : 20 February 2019 23:26:06(UTC)
Rank: Forum user
hsherwoo

Just wondering how other H&S peeps are interpreting this.  The amended HSE guidance in January 2016 states:

- Health surveillance for silicosis should be considered for workers who are involved in high-risk occupations, including construction, foundry work, brick and tile work, ceramics, slate, manufacturing, quarries and stonework.

- Where workers are regularly exposed to RCS dust and there is a reasonable likelihood that silicosis may develop, health surveillance must be provided.

It is the second statement above that I consider to be unclear.  The words 'exposed to RCS dust' and 'reasonable likelihood' suggest where no control measures are in place.  Or does it mean anyone regularly exposed to silica dust as a HAZARD (regardless of whether a full range of control measures are in place)?

chris.packham  
#2 Posted : 21 February 2019 07:51:06(UTC)
Rank: Super forum user
chris.packham

Consider what the ACoP for COSHH states:

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.

Note the last paragraph. This seems to say that even if you do not feel that your workforce is at risk if others working with the same occupational sector are experiencing problems then health surveillance becomes mandatory for you too.

Chris

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