Health surveillance

Health surveillance is intended 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.

(a) When is health surveillance required?

Health surveillance will be required in the following circumstances.

(i) where workers are exposed to a hazardous substance that is linked to an identifiable disease or adverse health effect; and

(ii) where there is a reasonable likelihood that the disease or health effect may occur under the particular conditions of their work; and

 (iii) where there are valid techniques for detecting the disease or health effect.

(b) Occupational Health Service (OHS) registration

Where the criteria in (a) are met, departments must register workers with the OHS.  Work with the following classes of hazardous substances may require registration, depending on the circumstances of exposure:

(i) substances of recognised systemic toxicity (i.e. those that can be inhaled, ingested, or absorbed through skin or mucus membranes and affect parts of the body other than those where they entered), e.g. metals like mercury, thallium, lead and their salts.

(ii) substances known to cause occupational asthma, e.g. laboratory animal excreta and secreta, colophony (rosin-based solder flux fume), some wood dusts, glutaraldehyde, some plant pollens.

(iii) substances known to cause dermatitis or severe irritation of the mucous membranes, e.g. nickel, cobalt, arsenic and chromium compounds; some adhesives or their components.

(iv) some pathogens or genetically modified organisms.

Where workers are registered with the OHS, departments will need to provide the OHS with adequate information so an appropriate health surveillance programme may be devised.

This will include the properties of the substance, the potential exposure routes, the intensity, frequency, and duration of exposure, and any other information that may be considered relevant. The OHS or the University Safety Office will advise in cases where there is any doubt about the necessity for health surveillance.

Departments should ensure that individuals are re-registered with the OHS whenever there has been a change in exposure and that the OHS is notified when exposure ceases. Where no such changes have occurred, then individuals should be re-registered every two years.

 (c) Health records

The format of the record of health surveillance (the health record) is prescribed by COSHH. It does not include clinically confidential information (i.e. it is not a medical record). Where health surveillance is required, the OHS keeps these records on behalf of the University and they will be retained for at least 40 years.

The OHS will inform individuals of the results of their health surveillance. They will also inform departments of the collective results of health surveillance, so as to provide assurances about their workers’ continuing fitness to work.

There will be circumstances where health surveillance is not appropriate, but where records of exposure to substances hazardous to health are required, for instance in the case of known or suspected carcinogens, man-made fibres, and carbon nanotubes or other biopersistent high-aspect ratio nanomaterials (HARNs). These records will not be prepared or kept by the OHS, but should be generated by the department. 

       (d) Health surveillance appointments

In order to provide more meaningful information to departments to use in reviewing their control measures, the OHS will attempt to assess groups of workers from the same working environment at the same time and, wherever possible, at a location close their workplace.

If this is not possible, then appointments will be offered at an OHS centre. Attendance for health surveillance is compulsory and departments are responsible for ensuring that their staff attend. Failure to attend will result in steps being taken to ensure that the worker is removed from the work that requires health surveillance.

(e) Instances of suspected ill health

If an individual (either between planned health surveillance appointments, or not undergoing health surveillance at all) shows symptoms that may be associated with exposure to a hazardous substance then they should report this to their supervisor and the department should refer them to the OHS. Alternatively, they may wish to self-refer to the OHS.  Where an individual is given a medical certificate linking sickness absence to possible work-related illness, then the department should refer them to the OHS and provide a copy of the certificate.

Whenever health surveillance indicates that ill health may be associated with exposure to hazardous substances, then the department, together with the Safety Office and the OHS, must review the control measures. Every effort will be made to allow individuals to continue with their work, using appropriate control measures. Where this is not practicable, then the individual will need to be removed from further exposure and further risk to their health.