2018 Procedures Health Surveillance Legal Requirements
2018 Procedures Health Surveillance Legal Requirements
2018 Procedures Health Surveillance Legal Requirements
www.bangor.ac.uk/hss
Health and Safety Services
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INDEX
Ref. Page
1. Introduction 2
Chemical exposure 6
Nanomaterials 9
Welding 9
Noise exposure 10
Vibration exposure 11
Farm workers 12
Biological Agents 13
Food Handlers 15
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1. Introduction
This document sets out how Bangor University confirms through health surveillance and health monitoring that its use
of certain hazardous products, agents, equipment and materials do not cause harm to staff and others. Where there
is a possibility of harm occurring health surveillance and monitoring seeks to detect symptoms as early as possible.
The document primarily considers guidance set out by the Control of Substances Hazardous to Health (COSHH)
Regulations, the Control of Vibration at Work Regulations and the Noise at Work Regulations. Where legislation does
not directly require health surveillance the document considers that which is advised on the basis of good practice,
most often as advised by the Health and Safety Executive (HSE).
The information contained in the document is designed as simple and pragmatic advice, outlining when health
monitoring or health surveillance may be required and what form and how often this should be provided.
Health surveillance and health monitoring are undertaken to confirm that work and activities at Bangor University are
not adversely impacting on a person’s health.
Further information on health risks from potential workplace exposures is available via www.bangor.ac.uk/hss or from
the Health and Safety Executive. Advice on Vaccinations, required for work purposes, can be found under “vaccinations”
on the University’s A-Z of Health and Safety.
2. Risk Assessments and Hierarchy of Risk Control
Risk Assessments should always seek to implement a hierarchy of risk control, through: elimination, substitution,
separation, reduction, extraction, training and standard operating procedures and personal protective equipment
(ppe). Risk Assessments must always be the first action prior to considering health surveillance or monitoring.
Health surveillance and health monitoring are not the norm and are typically only ever provided where there is an
evidential method of assessing health impact, or confirming otherwise, and there is a measured residual risk from an
activity. Very few members of staff or post-graduate research students will ever require health surveillance or health
monitoring.
Health surveillance and health monitoring are related directly to workplace activities and risks. Such should not be
confused with General Health Checks which are offered, from time to time, by the University and local GPs.
3. Different Types of Health Monitoring and Surveillance
a. Health Surveillance is normally a statutory health assessment or relates specifically to a known well-
documented risk, such as: work with COSHH Schedule 6 chemicals, use of vibrating equipment, exposure to
high levels of noise, exposure to animal allergens and for night shift workers. Health Surveillance will mostly
take the form of a face-to-face consultation with an Occupational Health specialist, or via a health
questionnaire. Sometimes a combination of both is used.
b. Health Monitoring tends to relate either to a single ‘risk’ activity or multiple activities that have a known
potential to cause harm to an individual, if not suitably controlled, or that individual may pose a risk to
themselves or others due to their own health condition. Such scenarios could include those contracted to drive
vehicles and for food handlers. Monitoring in these cases can often be undertaken locally, by line managers or
via a questionnaire.
The frequency of health surveillance and monitoring should reflect the level of risk and likelihood and can take different
forms on a rotating bases. E.g. Health surveillance may involve a face to face consultation and tests every other year,
with a health surveillance questionnaire distributed in-between.
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Following completion of ‘batches’ of health surveillance or monitoring, normally per department or ‘at risk’ staff group,
the Occupational Health Practitioner may summarise the findings and provide a short report to the relevant line
manager. This report will be made available to all who took part in the surveillance/monitoring and to trades union
representatives, if requested. The report will not contain any personal information.
If at any point the Occupational Health Practitioner has a concern emanating from the health surveillance or
monitoring they shall discuss with the Head of Health and Safety services in the first instance, and thereafter and where
necessary with other relevant occupational health specialists or professionals. In rare cases referral to an Occupational
Health Physician or other clinical specialist may be required.
If the Occupational Health Practitioner deems it necessary the member of staff or post-graduate research student may
be required to cease exposure to what may be causing an adverse health effect. Such a decision will be relayed to the
relevant Head of School or Department immediately, and confirmed with Human Resources or Student Services, if
appropriate. In the case of staff, the relevant trades’ union representative should be informed.
The Occupational Health Practitioner may temporarily suspend a work activity whilst further investigations and
assessments are being undertaken. A suspension of work activity is not an acceptance that workplace risk has caused
any harm as removal from the potential risk is considered good practice whilst further tests or assessments are
undertaken.
9. In Practice: what’s involved and when is it required?
As indicated above, the University has a variety of activities and hazards that, if not properly controlled, could pose a
risk to a person’s health. These risks can come from hazardous chemicals, inhaling minute particles in the air, through
contact with certain animal fur or excrement, and by exposure to high levels of vibration or nose.
Exposure to something with a significant harmful effect is normally very limited or infrequent, if ever. This is particularly
evident in the chemical and biological laboratory as direct exposure to a chemical will be limited by the controls and
through working methods employed (e.g. decanting and use of chemicals in fume cabinets, under good laboratory
practice controls will practically eliminate significant exposure). Risk Assessments and standard operating procedures
primary aim is to safeguard the health and safety of the operatives and others who may be affected.
In most cases exposure to trace quantities of many toxic or irritant substances will cause harm only if exposure occurs
sufficiently frequently. Though, it is noted that health surveillance may be appropriate even if very small or infrequent
exposure to hazardous substance is known to pose a potent risk to health, such as may occur with powerful respiratory
sensitizers, recognised carcinogens (i.e. those listed Schedule 6 and used outside of manufacturing process) or highly
active biological agents/toxins (such as cytotoxic drugs and neurotoxins).
Where it is considered that health surveillance or health monitoring may be required the relevant School or
Department will be asked to re-risk assess their activity to identify current control measures, potential for exposure,
length of time and extent of exposure, and to identify whether an alternative method or substance can be used so as
to reduce the risks.
For all staff that require health surveillance, information in the form of SOPs and Risk Assessments will be required by
the Occupational Health Practitioner.
Health Surveillance and Health Monitoring can take form of: Respiratory Questionnaire, Lung Function Tests (where
there is a discernable risk to a person’s respiratory system or thyroid), Eyesight Tests, Hearing Tests, Skin Health
Questionnaire, Hand/Arm pain and discomfort questionnaire (vibrating equipment), Night Workers Questionnaire,
Driver Health Assessment/Questionnaire, blood samples, and/or face to face discussions. Tests and questionnaires will
be tailored to the risks and staff potentially exposed to risks.
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10. The following section advises on particular risk areas and identifies when Health Surveillance or Health Monitoring may be required.
Schools and Departments are required to firstly review or complete their risk assessments, identifying any potential risk to a person’s health. If a level
of risk is identified the hierarchy of risk control should be employed. Normally, only if there is a residual level of risk or legislation requires should
health surveillance or monitoring be considered. In some cases health monitoring may be undertaken in order to safeguard the person and the
institution.
SMALL LABORATORY ANIMALS, REPTILES AND INSECTS For staff and post-graduate research Group 1.
students who have frequent and direct
Work with animal tissue and work with aquatic animals does Staff and research students who
contact with animals such as rats, mice
not require surveillance. undertake frequent and regular work
and pigeons and/or their used bedding,
within the Pigeon House. This is
Animal fur, feathers, dander, dried urine and saliva dusts arise may be required to attend Health
particularly applicable for those
through animal handling and cage or enclosure cleaning. These Surveillance, normally, every 12-24
cleaning pigeon waste and the pigeon-
dusts contain proteins, 'animal aeroallergens’ that may cause months, dependent on risk exposure and
house.
occupational asthma. frequency.
Staff and research students who are
In some cases spores from old used animal bedding can also Those with the greatest risk exposure
required to regularly clean cages and
pose a risk to health. (Group 1.) will undertake annual health
handle bedding of small animals (mice,
Due to possible respiratory sensitisation Health Surveillance surveillance, including completing a
etc.).
may be necessary for regular handling and direct contact with respiratory and skin questionnaire, and
perform a Lung Function Test. A pre-start Assessment will be required
live animals, such as:
for this group, followed by 6 and 12
a. Rats and mice; All Group 1 staff/researchers (who
week health evaluations.
require annual Health Surveillance) will
b. Pigeons and pigeon waste; Group 2.
normally also have a pre-start
and, for those who regularly clean cages of animals and handle Assessment, and ideally then at 6 weeks
Staff and research students who
used animal bedding. and again at 12 weeks after the individual regularly handle small laboratory
The University’s work with Insects (with hairs or scales), such as has started work to monitor symptoms of animals (e.g. mice, rats) and/or
crickets, locusts, cockroaches, is low level and does not, at possible pre-sensitization. occasionally clean cages and handle
present, constitute a significant health risk provided standard In cases where 24 monthly face to face bedding of small animals (mice, rats).
procedural controls are in place. health surveillance (Group 2) is
recommended a health questionnaire will
normally be used in the intervening year.
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DUST, PARTICULATE AND (FUNGAL) SPORES EXPOSURE Dusts and Particulates Dust & other Particulates
Note: for spores from animal bedding see ‘Laboratory animals’. Staff and research students who have Working in activities such as (1st stage)
For farm bedding see Farm Workers. significant potential exposure to dusts, seed-cotton cleaning, experiencing
such as wood and other plant materials. regular exposure to flax dust, wood
Breathing particulates into the bronchial and nasal passages,
flour, sheep-wool process
and lungs can cause both short and long terms ill health, even Workers will be required to perform a
manufacturing (including industrial
chronic harm. Lung Function test and complete a
knitting and carpet manufacture), and
Respiratory Questionnaire, every 12 to 24
Particular attention should be given to particulates (incl. fungi) where a risk assessment and air
months.
in the ranges of PM10 ("PM ten", which stands for Particulate monitoring has identified an
Matter up to 10 micrometers [micron, μm ] in size, and ranges Where health surveillance is every 24 uncontrolled residual risk.
from around 25 to 100 times thinner than a human hair) and months a respiratory questionnaire will
Note: industrial placement staff such as
PM2.5 (“PM two point five” = 100 times thinner than a human be distributed during the intervening
KTP partnerships and lengthy staff
hair). year.
secondments.
A human hair is about 50 micrometers. Health surveillance should be considered
Fungal Spores
as a final line of defense only and not as
Local Exhaust Ventilation (LEV) and suitable risk assessments
part of the primary control measures. Researchers/staff who work with fungi,
should ensure particulates from known sources are extracted
Local exhaust ventilation and good particularly in confined spaces.
away from people, and if necessary filtered.
standard operating procedures must
Fungi growth chambers/rooms are
ensure that human exposure to
normally well ventilated and workers
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WELDING For Welding staff: All welders (i.e. person who weld at
work for at least a few hours every
In addition to the considerations detailed above (Dust, Those who are regularly welding are also
month).
Particulate...) staff who undertake regular welding may be often exposed to other risks such as noise
prone to an increased respiratory (Pneumococcus) risk. and will already receive periodic health
monitoring. For those whose job is to
There is a potential association between (regular) welding and
fabricate and weld health monitoring via
the development of pneumococcal disease, particularly lobar
a questionnaire will be required,
pneumonia and therefore vaccination is recommended for this
supplemented by Lung Function test. The
staff group.
frequency of the lung function test
Good Local Exhaust Ventilation (LEV) and standard workshop should be based on frequency of
practice should reduce potential exposure to welding fumes to exposure and will normally be offered at
as low as reasonably practicable. It is recognised that for one- least every two years.
off fabrication this can prove more difficult, though the need to
For those who occasionally weld:
ensure good LEV and other forms of ventilation is always critical
to safeguarding health. Dependent upon the frequency and
extent of exposure staff may be required
Vaccinations:
complete an annual respiratory
Those who weld regularly are advised to obtain the questionnaire. Staff may also be offered a
pneumococcal polysaccharide vaccine (PPV2), via their GP. lung function test.
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VIBRATION EXPOSURE Where the HSE Tool identifies a Key ‘at risk’ staff groups:
significant risk factor staff will be
Hand-arm Vibration Syndrome Grounds & Gardens, Sports Fields
required to attend annual health
Regular or acute exposure to vibration, often through hand Groundworks Maintenance Staff
surveillance.
held equipment, can cause both short term and chronic ill Farm Workers
health conditions; including vibration white finger and joint Annual HAV’s Tier 2 Health
Health surveillance should be provided
damage. Assessment
for vibration-exposed employees, i.e.
If staff present with symptoms of
Tasks which involve the use of equipment which create a those undertaking activities involving
HAV a more comprehensive
vibration and which the operative is required to physically hold the use of hand-held vibrating tools
assessment (Tier 3) will be
on to, should be assessed to identify the ‘exposure time’ and where:
undertaken
‘vibration magnitude’. Workers likely to be exposed in
This is in addition to risk assessment and
Where exposure can be prolonged or where there are multi excess of the daily exposure action
work scheduling tailored to reduce
activity exposure during the day it will be necessary to value of 2.5m/s2 A(8) should
exposure and alternate work activities.
systematically assess personal/task exposure using the HSE undergo regular routine health
Health surveillance will not normally be
assessment tools. Prior to this, knowing what the ‘trigger time’ surveillance
provided until a risk assessment is
is essential, as is the anticipated ‘vibration magnitude’. Exposure is likely to be occasionally
received and trigger time/magnitude is
above the action value and the risk
Whole Body Vibration known.
assessment identifies the frequency
Guidance advises that health surveillance as not appropriate. and severity of exposure may pose
There are no confirmed methods that exist for the detection, or a risk to health; or,
indicate the early onset, of adverse health effects associated Where employees are identified as
with whole body vibration; i.e. lower back pain, that are particularly sensitive to vibration,
specifically related to work on vibrating equipment/machinery. e.g. previously diagnosed as
suffering from hand-arm vibration
Whilst formal health surveillance is therefore not required, the
syndrome.
guidance that accompanies the Regulations suggests an
approach of reporting and monitoring the symptoms of lower
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CONTRACTED TO DRIVE / DRIVING DUTIES Staff who are required to drive University Staff who are assigned their own
vehicles for a significant part of their University vehicle or whose job it is to
Fitness to drive is a DVLA legal requirement and the onus is
working day are required to undergo drive a University vehicle (including off-
placed on the driver to ensure they are fit to drive and do not
periodic health monitoring. road vehicles). For example:
suffer any chronic or short term medical conditions that may
render them a danger to themselves or others. For these( who drive University vehicles Catering delivery
for a significant part of their working day) Maintenance response
are required to: Security staff
Complete a health questionnaire Farm workers
Ground staff
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NIGHT (SHIFT) WORKERS Pre-start health questionnaire, then Staff who regularly work for periods of
annual health questionnaire. 3 hours or more after 11pm. These
Irregular hours of work and work patterns that include night
could include:
and early morning shifts can lead to disruption of the internal Staff offered self-referral to Occupational
body clock, sleeping difficulties and fatigue. Health every 2 years. Nightclub workers/ management
If workers are fatigued, they will be less alert, their reaction Night-shift Security and Night
time will be slower, they will find it harder to concentrate and Porters
they may make poor decisions. This can lead to accidents and Halls Wardens – frequent night
injuries. shift/call out rotations
Maintenance technical Staff on Call-
Where departments have night workers they should undertake out rotations.
a risk assessment that considers
the workload
the work activity
shift timing and duration
direction of shift rotation. It is better for the shifts to
run in a 'forward rotation', i.e.
morning/afternoon/night
the number and length of breaks within a shift
rest periods between shifts
The Working Time Regulations require all night shift workers to
be offered health surveillance/monitoring.
BIOLOGICAL AGENTS EXPOSURE Surveillance may involve blood or urine Examples of work activity requiring
samples and require specialist laboratory health surveillance would include:
Work with some pathogens (normally Hazards Group 3) may
analysis.
require health surveillance to be provided as a way of Work with schistosomiasis and
monitoring controls are effective and to confirm no ill-health NOTE: in some cases a pre-start similar parasites/parasitic zoonosis.
impact from work. Such work may also require vaccinations. questionnaire is required for work with
particular HG2 & 3 pathogens. Such
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UAV PILOTS (CAA permitted) Self-declaration required as part of Pilot Registered UAV Pilots (Pilot in Charge)
Approval.
Note: this does not necessarily include
‘Pilots under Supervision’ as there is a
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NURSING / MEDICAL STUDENTS AND STAFF No formal surveillance at the University. Staff and students working within a
Students will follow NHS Practices at their hospital or pathology environment.
also see Radiation for Radiography students & staff
Placement.
also see Biological Agents for Medical students & staff
Staff will only receive health surveillance
The potential for medical staff and students to be exposed to
or health checks if they are expose to
communicable diseases and infecting others should be assessed
specific risks, as described in the
as part of the standard risk assessment.
document. Where staff are embedded or
Student Nurses, midwives, radiologists and other related work within the NHS environment or
services will be required to follow NHS practice for inoculations control they are expected to follow NHS
and preventative treatments. health surveillance protocols and receive
appropriate vaccinations for their
Medical students and staff will be required to assess
occupational risk exposure.
pathogenic risk from biological agents (see Biological Agents
section).
RADIATION, X-RAY AND LASER & EMF WORKERS Due to low risk nature of University Ionising Radiation (sources) Lab.
activities only Personal dosimetry will be Workers
The University has no radiation activity which requires statutory
health surveillance.
used to confirm radiation exposure levels X-ray operatives (materials)
and the effectiveness of operating X-ray Operatives (human/animal),
Work with ionising radiations are strictly controlled and procedures. e.g. Radiography staff and students
personal exposure either eliminated or reduced to a level
acceptable (both short and long term) to the Ionising Radiation Due to the low risk nature of University
Regulations. All work with ionising radiations is overseen by the ionising radiation activity no staff or
University Radiation Protection Officer and monitored by an student group should be exposed to
radiations which are beyond the
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