General Note

NHS Fife acknowledges and agrees with the importance of regular and timely review of policy/procedure statements and aims to review policies within the timescales set out.
New policies/procedures will be subject to a review date of no more than 1 year from the date of first issue.

Reviewed policies/procedures will have a review date set that is relevant to the content (advised by the author) but will be no longer than 3 years.

If a policy/procedure is past its review date then the content will remain extant until such time as the policy/procedure review is complete and the new version published, or there are national policy or legislative changes.

1. FUNCTION

1.1. The function of this policy is to support managers in identifying when statutory health surveillance will be required in compliance with the Management of Health and Safety at Work Regulations 1999, The Control of Substances Hazardous to Health Regulations 2002, The Control of Vibration at Work Regulations 2005, The Control of Noise at Work Regulations 2005, The Control of Asbestos Regulations 2012, The Control of Lead at Work Regulations 2002 and The Ionising Radiation Regulations 2017

1.2. NHS Fife recognises its duty to make arrangements for health surveillance to be conducted and employees are required to co-operate according to this legislation. There may be requirements for health surveillance to continue even after cessation of the work activity or exposure. 

1.3. “Health Surveillance” is distinct from “Health Screening” see Appendix 1 for further information [Ref 6.1 Appendix 1: Health Surveillance v Health Screening Guidance Note]

2. LOCATION

2.1 The policy applies to all employees of NHS Fife working in NHS Fife and the Fife Health and Social Care Partnership including domiciliary settings.

3. RESPONSIBILITY

3.1. Senior and Line Managers are responsible for;

• ensuring that a risk assessment is carried out of all work activities that may require staff to undergo health surveillance;
• providing facilities and working arrangements that minimise the likelihood of health problems, and prevent health problems that can be anticipated;
• ensuring that all staff are aware of this policy, understand its content and those of local and associated procedures;
• ensuring that staff groups and individuals identified as being at risk are given appropriate information, instruction, training and supervision to minimise the risk to health;
• ensuring that staff comply with the requirements of the agreed health surveillance;
• keeping records of health surveillance outcomes within a “personal health record”. For skin health surveillance the personal health record comprises the responsible person’s skin check form and any relevant outcomes from Occupational Health (OH). For any other health surveillance, the personal health record will consist of the outcomes from OH. These personal health records should be kept separately from personnel/ HR records for staff to ensure appropriate archiving;
• identifying staff requiring health surveillance to Occupational Health Department; and
• implementing any recommendations / alterations/ restrictions relating to fitness or exposures in the workplace, as advised by Occupational Health Department.

3.2. Employees are responsible for

• attending Occupational Health Department for required health surveillance as requested;
• complying with the employer’s health surveillance requirements;
• taking reasonable care of themselves and others who may be affected by their actions;
• co-operating by working in a manner which controls risk to as low a level as is reasonably practicable;
• reporting all unsafe conditions, incidents (including near misses) that did or could result in loss, injury or damage; and
• taking part in training, education and any health surveillance programme designed to meet the requirements of the policy.

4. OPERATIONAL PROCEDURE

4.1. Health Surveillance is generally indicated where staff are engaged in work activities which involve exposure to or work with;

• high noise levels (above 85dB(A) daily/ weekly personal noise exposure) [Ref 6.3 Appendix 3: GP/N1 Noise at Work Procedure];
• vibrating hand tools (where exposure is regularly above 2.5m/s2) [Ref 6.4 Appendix 4: GP/V1 Control of Vibration at Work Procedure];
• ionising radiation [Ref 6.5 Appendix 5: R3 NHS Fife Wide Radiation Protection Policy];
• wet work / chemicals (including constituents of gloves) [Ref 6.6 Appendix 6: NHS Fife Skin Health Advice (StaffLink); [Ref 6.11 Appendix 11: GP/ G1.1 Glove Selection Procedure];
• asbestos [Ref 6.7 Appendix 7: GP/A1 Asbestos Policy];
• lead [Ref 6.8 Appendix 8: GP/L2 Dealing with Lead at Work Procedure];
• high levels of dust, aerosolised medications (e.g. Pentamidine), solvents, methyl methacrylate, solder, etc. where exposure is at, or above, levels documented in EH40 Workplace Exposure Limits; and
• certain biological agents where there is deliberate intent to work with them (e.g. lab work)

4.2. The requirement for health surveillance will be identified through risk assessments of work activities being undertaken by staff.

4.3. Senior and Line Managers must ensure that an adequate and detailed risk assessment on tasks and processes is completed to identify any health risks and determine the need for health surveillance.
During the risk assessment process managers must also consider whether there is a statutory requirement to undertake health surveillance for this task. 

4.3.1. The risk assessment must identify the health hazards within the workplace, who is at risk, and what measure are in place to control this risk. Where residual risk remains, health surveillance can be considered in discussion with OH or Health & Safety (H&S) teams. However, it is important to remember that health surveillance is not a substitute for controlling the risk at source as far as is reasonably practicable.

4.3.2. Manager will email assessment to fife.occhealth@nhs.scot requesting “Consideration of Health Surveillance Needs Assessment". If more than one member of staff is affected, indication of number of staff should be given.

4.3.3. Health surveillance will normally be undertaken annually, but frequency may vary dependent upon risk assessment, exposure levels and OH outcomes. Bespoke guidance for teams or individual staff will be communicated to managers by OH as part of surveillance response.

4.4. Occupational Health

4.4.1. If Health Surveillance is indicated, this will be confirmed in writing to manager.

4.4.2. After health surveillance the Occupational Health report to the manager will confirm whether the individual is fit to continue to work with the hazard(s) concerned and whether any limits or restrictions on work activities are required.   Occupational Health clinicians will not disclose confidential medical information to the manager unless the individual undergoing assessment or surveillance has given consent.

4.4.3. Grouped anonymised reports will be provided at organisational level.

5. RISK MANAGEMENT

5.1. This procedure is a part of NHS Fife’s system for managing risk as described in the NHS Fife Risk Assessment and Risk Register Policy. [Ref 6.12: Appendix 12: GP/R7 - Risk Register and Risk Assessment Policy]

6. RELATED DOCUMENTS

6.1. Appendix 1: Health Surveillance v Health Screening Guidance Note
6.2. Appendix 2: Health Surveillance Flowchart
6.3. Appendix 3: GP/N1 - Noise At Work Procedure
6.4. Appendix 4: GP/V1 - Control of Vibration at Work Procedure
6.5. Appendix 5: R3 NHS Fife Wide Radiation Protection Policy
6.6. Appendix 6: NHS Fife Skin Health Advice (Stafflink)
6.7. Appendix 7: GP/A1 - Asbestos Policy
6.8. Appendix 8: GP/L2 - Dealing with Lead at Work
6.9. Appendix 9: GP/C3 - Control Of Substances Hazardous To Health Procedure
6.10. Appendix 10: GP/P4 - Personal Protective Equipment (PPE)
6.11. Appendix 11: GP/G1.1 Glove Selection Procedure
6.12. Appendix 12: GP/R7 - Risk Register and Risk Assessment Policy

7. REFERENCES

7.1. Health & Safety at Work Act 1974
7.2. Management of Health and Safety at Work Regulations 1999
7.3. Control of Substances Hazardous to Health Regulations 2002 (as amended)
7.4. Control of Lead at Work Regulations 2002
7.5. Control of Asbestos at Work Regulations 2006
7.6. Confined Space Regulations 1997
7.7. Control of Noise at Work Regulations 2005
7.8. Working Time (Amendment) Regulations 2006