Health surveillance requirements

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Health Surveillance for Workers Exposed to Silica Dust

Health surveillance may be a legal requirement under the Control of Substances Hazardous to Health Regulations 2002 (COSHH) where workers are exposed to silica dust and the relevant conditions for health surveillance are met.

Employers must use their COSHH risk assessment, supported by competent occupational health advice where necessary, to determine whether a health surveillance programme is required.

What Is Health Surveillance?

Health surveillance is a system of ongoing health checks for employees who are exposed to particular workplace hazards. Its purpose is to identify early signs of work-related ill health and check whether existing control measures are protecting workers effectively.

Health surveillance is particularly important because diseases associated with hazardous dust can develop gradually. Workers may not notice symptoms until significant damage has already occurred.

Health surveillance cannot prevent exposure and must never be used as a substitute for effective dust controls.

Diseases Associated With Hazardous Dust Exposure

Regular exposure to silica and other hazardous workplace dusts can contribute to serious respiratory diseases, including:

  • Silicosis, which causes permanent scarring of the lungs.
  • Chronic obstructive pulmonary disease (COPD).
  • Occupational asthma.
  • Lung cancer.
  • Other forms of work-related respiratory disease.

Early detection can allow employers to review workplace exposure, improve controls and help prevent further harm. However, some occupational lung damage may be permanent, making the prevention of exposure essential.

When Is Health Surveillance Required?

Under COSHH, health surveillance is required where the relevant regulatory conditions are met. This may include situations where:

  • Workers are exposed to a substance associated with an identifiable disease or adverse health effect.
  • There is a reasonable likelihood that the disease or health effect could occur under the particular working conditions.
  • Valid techniques are available to detect indications of the disease or health effect.
  • Health surveillance is likely to benefit the workers concerned.

The decision should be based on a suitable and sufficient COSHH risk assessment, the nature and level of exposure, the effectiveness of existing controls and competent occupational health advice.

Baseline Health Assessments

Where a health surveillance programme is required, it will often begin with a baseline health assessment before, or soon after, a worker starts a role involving exposure to hazardous dust.

The baseline assessment provides an initial record of the worker's respiratory health. This can make it easier for occupational health professionals to identify relevant changes during future assessments.

A baseline assessment may consider:

  • The worker's current respiratory health.
  • Previous occupational exposure to dust or other respiratory hazards.
  • Relevant existing medical conditions.
  • Respiratory symptoms such as coughing, wheezing, breathlessness or chest tightness.

What May Ongoing Health Surveillance Include?

The type and frequency of health surveillance should be appropriate to the identified risk. It should be determined with advice from a competent occupational health professional.

Depending on the circumstances, health surveillance may include:

  • Respiratory health questionnaires.
  • Reviews of symptoms and occupational exposure.
  • Lung-function testing, such as spirometry, where appropriate.
  • Assessments by an occupational health professional.
  • Referral for further medical assessment where concerns are identified.

Symptoms that may require further investigation include persistent coughing, wheezing, chest tightness, unusual breathlessness or a noticeable reduction in a worker's ability to carry out normal activities.

What Must Employers Do When Problems Are Identified?

If health surveillance identifies a possible work-related health concern, the employer must act promptly and follow appropriate occupational health advice.

This may involve:

  • Reviewing the worker's potential exposure to silica or other hazardous dust.
  • Reassessing the relevant COSHH assessment and safe system of work.
  • Checking the effectiveness of extraction, water suppression and other controls.
  • Reducing or preventing further exposure where necessary.
  • Referring the worker for further medical evaluation.
  • Considering whether other employees may have been similarly affected.
  • Improving control measures across the workplace.

Managers should not attempt to diagnose the worker themselves. They should follow competent medical advice while addressing any workplace conditions that may have caused or contributed to the problem.

Employee Responsibilities During Health Surveillance

Employees should attend health surveillance appointments provided by their employer and give accurate information about their health and symptoms.

Health surveillance is intended to protect workers rather than penalise them. Employees should report respiratory symptoms promptly, even if those symptoms appear minor, occasional or unrelated to work.

Early reporting can allow workplace controls to be reviewed before further exposure occurs.

Confidentiality and Health Surveillance Records

Employers must maintain a suitable health record for every employee placed under health surveillance. Where COSHH requires the record, it must generally be retained for at least 40 years from the date of the last entry.

A workplace health record is different from a confidential medical record. The employer's record should contain relevant administrative details and the outcome relating to fitness for work or the need for workplace action, but it should not include confidential clinical information.

Detailed medical records must remain confidential and should normally be held by the occupational health provider. Medical information should only be disclosed in accordance with data-protection requirements and the appropriate rules of medical confidentiality.

Health Surveillance and Silica Dust Control

Health surveillance is only one part of an effective silica dust management programme. Employers must continue to prevent or adequately control exposure using measures such as:

  • Eliminating or reducing dust-producing work.
  • Using on-tool extraction.
  • Applying water-suppression methods.
  • Maintaining suitable extraction equipment.
  • Providing suitable RPE where additional protection is required.
  • Training and supervising workers.
  • Monitoring whether controls are being used effectively.

Health surveillance helps identify potential problems, but effective dust control remains the primary means of protecting workers. Ignoring symptoms, surveillance findings or evidence of ineffective controls can result in serious illness and possible enforcement action.

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