Health Surveillance under COSHH

OHS Memo M1/05

The University policy was recently revised in accordance with the new 5th edition of the COSHH Approved Code of Practice. These changes are designed to allow departments to more readily meet their responsibilities under the COSHH Regulations 2002. This memorandum is designed to advise and assist departments on the changes in the University COSHH policy that directly relate to health surveillance.

Under the COSHH regulations, health surveillance is ‘appropriate’ where staff, or other individuals in the workplace (e.g. students and academic visitors) have exposure to hazardous substances arising from work activities, and where:

  • Exposures to the substance have generally been linked to identifiable disease or health effects, and
  • Levels of workplace exposure are potentially significant, and
  • Valid techniques exist for detecting the link to ill health or disease, and
  • The techniques of investigation are of low risk to the employee

For the majority of substances arising from University work activities, health surveillance is not required as a result of a COSHH assessment because those activities do not fall into all of the above groups.

Where health surveillance is appropriate, it is a legal requirement that it be undertaken -to protect individual employees by the early detection of work-related adverse health changes; to help evaluate the efficiency of control measures; and to evaluate hazards to health by collecting and analysing data. Examples of hazardous substances within the University context that require health surveillance include laboratory animal allergens, infectious agents such as Hepatitis B, heavy metals and latex.

Under the revised University policy, health surveillance will only be undertaken where it has been deemed ‘appropriate’ by a departmental COSHH risk assessment – not, as in the past, independently by the Occupational Health Service (OHS). Where health surveillance is deemed to be appropriate, staff or at-risk individuals, will need to be referred to the OHS by their department using the HIS registration form.

In most cases, it would be expected that coordination of this process will be devolved to the respective Area Safety Officer (ASO). Once registration has occurred, the nature of any health surveillance required will be determined by the OHS. To ‘close the circle’, feedback from surveillance will be provided to the individual and to the department for information or action as appropriate. To assist departments, however, the Statutory Health Record as required under the COSHH legislation will be maintained by the OHS.

If registered individuals do not attend for either their initial or necessary ongoing surveillance appointments as required under the COSHH regulations, departments are required to ensure that those individuals refrain from those work activities, or work within facilities, which involve exposure to the respective hazardous substance(s). Similarly, if health surveillance indicates health problems associated with exposure to hazardous substances, and these exposures cannot be reasonably adjusted for, the person will usually be required to be deployed to an area where there is no risk of ongoing exposure.

Because of the association between health surveillance under COSHH and employment issues (e.g. new/retiring employees, attendance and redeployment), and also the need for audit trails, departments may wish to establish clear lines of communication between the Head of Department’s nominee for COSHH and the respective ASO.

It is intended that the new system of registration will commence on 1st February 2006. From that date all new staff/individuals should be registered with the OHS via the HS1 registration form.

For those individuals already on health surveillance, updates to their registration via the departments should occur during the 2006 calendar year. For assistance see the COSHH Health Surveillance flowchart. When using Internet Explorer you may need to adjust your browser setting to view this full size on the screen, but it will print out full size.

Representatives from the OHS on (01865 2) 82676 and/or the Safety Office (01865 2) 70811 will be available to provide briefings to individual administrators, or answer queries at any time.

Dr Phil Carrivick

28 November 2005