Health Surveillance Policy

1.1 Purpose

It is the policy of Loughborough University to ensure that no harm comes to staff or others who use hazardous products, equipment and materials. Where guidance in legislation does not exist best practice, as advised by the Health and Safety Executive will be indicated.

Risks can be associated with hazardous chemicals, biological agents, noise, vibration, although exposure to trace quantities or irritant substances will only cause harm if exposure occurs frequently.

1.2 Scope

This policy applies to all work involving the use of hazardous materials, biological agents, vibrating tools and noise. Ensuring that the necessary controls are in place to prevent, or where this is not possible, to reduce the risk so far as is reasonably practicable to human health and safety.

The policy applies to all staff, students (both postgraduate and undergraduate) and personnel (e.g. contractors) at workplaces under the control of Loughborough University.

1.3 Definitions

Health Surveillance: a program of ongoing health checks. Some of which are required by legislation, some are best practice to prevent work place ill health and enable the early detection of work related conditions.

The HSE stated that Health surveillance is important for:

detecting ill-health effects at an early stage, so employers can introduce better controls to prevent them getting worse
providing data to help employers evaluate health risks
enabling employees to raise concerns about how work affects their health
highlighting lapses in workplace control measures, therefore providing invaluable feedback to the risk assessment
providing an opportunity to reinforce training and education of employees (eg on the impact of health effects and the use of protective equipment)

Where it is considered that health surveillance is required, the school or service will be required to re-assess their activity to identify control measures, potential, extent and duration of exposures along with determining if safer practices could be implemented. The risk assessment should be used to identify any need for health surveillance. You should not use health surveillance as a substitute for undertaking a risk assessment or using effective controls.

1.4 Is Health Surveillance Compulsory?

Yes, all health surveillance is compulsory as it is implemented in line with legislation and is required to safeguard the individual.

Some best practice health monitoring is not compulsory and is offered to provide reassurance.

Some health surveillance is required prior to starting (as a baseline recording) and upon leaving (to confirm health status) specific roles within the University.

2. Key Legislative Requirements

The Health and Safety at Work (etc) Act 1974
Provision and Use of Work Equipment Regulations 199
The Management of Health and Safety at Work Regulations 1999
Control of Substances Hazardous to Health 2002
Control of Vibration at Work Regulations 2005
The Control of Noise at Work Regulations 2005

3. Duty Holders

Deans of Schools/Heads of Professional Services shall:

Ensure that competent, suitable and sufficient numbers of staff are appointment and trained as risk assessors within their area of responsibility.
Ensure staff undertake appropriate risk assessments and implement appropriate control measures for all work which poses a risk to the health of workers
Support the nominated person(s) in implementing measures to comply with health surveillance regulations.
Ensure all managers and employees within the department discharge their responsibilities in accordance with this policy.
Seek confirmation and review from School/Service staff that arrangements are still effective

SSO’s/DSO’s/RP shall monitor the effectiveness of any control measures and make recommendations to the Dean of School/Head of Service as necessary. In particular:

Monitor that all risk assessments and health surveillance are in accordance with the policy and ensure the asset list is kept up to date.
Assist in training of all staff, students and visitors
Audit risk assessments documentation to verify that suitable and sufficient assessment are in place and up to date
Suitable personal protective equipment (PPE) is provided where appropriate and is maintained to a good order. Reusable items are regularly examined for faults, damage, wear and tear
Verify that plant, equipment and engineering controls are maintained in accordance with the agreed maintenance schedule.
Liaise with occupational health service to arrange health surveillance if its suspected that staff are at risk.

Staff who are responsible for managing the activities carried out by students and staff, have a duty to ensure the health and safety of the students/staff they supervise.

Line managers are responsible for the health and safety of the staff/students they manage and others who may be affected by their work.

Line Managers/Academic Supervisors will ensure:

Ensure appropriate risk assessments are carried out and reviewed as required- Whoever undertakes the risk assessment for the work is responsible for identifying the need for health surveillance
Ensure employees are suitably trained in all aspects of the safe operation of equipment
Identify all workers who may require health surveillance and inform Occupational Health
Ensure workers receive appropriate health surveillance from Occupational Health
Ensure workers comply with guidance given by Occupational Health

Individuals identified as requiring health surveillance must:

Attend any Occupational Health appointments required by risk assessment
Follow risk assessment and health surveillance instructions
Not put the health of themselves or others at risk by any of their actions.

The University Occupational Health provider will:

Advise on any guidance and provide advice on health surveillance for specific risks
Undertake and arrange appropriate health surveillance
If a concern is identified, Occupational Health will advise on any remedial action to be taken
Workplace recommendations and adjustments may be provided
Support any health surveillance training offered by the University
Provide statistics relating to health surveillance

4. Common examples of health surveillance/monitoring

When a risk assessment identifies potential risks to the health of the worker, health surveillance/monitoring is required. Examples of which may include:

Use of specific chemicals (eg Cadmium)
Working with biological agents
Working with respiratory sensitisers
Fumes, dusts, other substances hazardous to health
Work causing exposure to excessive noise or vibration
Working at heights
Working in confined spaces
Ionising radiation
Exposure to asbestos
Pregnant workers
University vehicle drivers
Night work

Schools/services should first complete a risk assessment which would identify any potential risks to health. The hierarchy of control should then be employed

Please be aware that it is the responsibility of the manager to notify Occupational Health of anyone who requires health surveillance.

5. Health Surveillance Guidance

Hazard	Type of work involved	Surveillance to be carried out
Noise - Compulsory	Statutory health surveillance is required for workers regularly exposed to noise identified as being 80-85dBA Work which is identified as exposing the user to levels above 85dBA over a working day	Specific audiometry questionnaire Hearing tests: New starter Annually (for 2 years) 3 yearly as recommended by HSE
Skin sensitisers/irritants – Compulsory	Potential for exposure to skin sensitisers which have been identified by COSHH assessment or data sheet. Workers exposed to regular episodes of ‘wet work’ which is prolonged submersion in water or frequent requirement for hand washing.	Baseline questionnaire and visual check on employment, then annually.
Respiratory sensitisers - compulsory	Potential for exposure to respiratory sensitisers which have been identified by COSHH assessment or data sheet	Baseline questionnaire and spirometry test on employment, then annually.
Vibration – Compulsory	Statutory health surveillance for workers exposed to hand or arm vibration- Required if daily average exposure (EAV) exceeds 2.5m/s2 A	Baseline questionnaire then annual questionnaire with formal assessment if indicated due to symptoms.
Asbestos- Compulsory	Statutory assessments required for licensed asbestos work, best practice to include non-licenced work	Baseline assessment then 3 yearly for non-licensed work or 2 yearly for licenced work
Driving - Compulsory	Fork lift truck or group 2 licence Best practice for driving university vehicles	Questionnaire -Utilising the fitness to drive standards issued by DVLA provides the basis for assessment Assessment to include: Vision assessment Hearing Mobility and flexion FLT frequency- Baseline on commencement Every 5 years until age 45 Annually after 45 University vehicles assessment frequency – baseline on commencement then 3 yearly
Biological agents		Ensure appropriate vaccination is offered where possible to individuals working with biological agents in line with COSHH Risk Assessments.
Working at heights	School/service risk assessment	Questionnaire and safety critical medical assessment taken on commencement and 3 yearly thereafter
Night work	Workers who regularly undertake a minimum of 3hrs of night work must be offered a health assessment	Annual health questionnaire followed up with referral to Occupational Health if concerns are identified. Employees do not have to undertake a health assessment
DSE assessment	All DSE users should be offered an online DSE assessment on commencement and annually thereafter	Annual assessment in the first instance – referral to local DSE assessors for more specific input but if concerns persist – referral to Occupational Health.

If an employees health changes it is their responsibility to inform their line manager and health surveillance maybe required to be undertaken at that point. The line manager would then make a specific referral to he Occupational Health department outlining this requirement.

6. Records Keeping of Health Surveillance

All health surveillance records completed by the Occupational Health department are confidential. Specific details of an individuals medical record can only be given to the manager with written informed consent by the individual.

Records relating to health surveillance will be kept for at least the minimum time required by relevant and current legislation including the General Data Protection Act (GDPR).