UNIVERSITY OF GLASGOW

HEALTH SURVEILLANCE POLICY

Introduction

The objectives of health surveillance are: -

(a) Protect the health of individuals by detecting as early as possible, diseases or adverse
health effects which may be work-related, e.g exposure to hazardous substances,
including biological agents, and physical agents.
(b) Assist in evaluating the effectiveness of existing risk management measures and identify
where any further action may be necessary.
(c) Obtain, use, keep up to date and retain data and information for determining and
evaluating risks to health.

Legislative Requirements for Health Surveillance

Regulations that specifically identify health surveillance and the situations where such surveillance is
deemed appropriate that are most relevant to the University’s areas of work and activities are given at
Appendix 1 to this policy.

Other current regulations that specifically identify health surveillance are

- The control of Asbestos at Work Regulations;

- The Control of Lead at Work Regulations; and
- The Ionising Radiation Regulations.

Health Surveillance Responsibilities

Heads of Schools and Directors of Support Services

Heads of Schools and Directors of Support Services have overall responsibility for ensuring local
arrangements are in place that:

(a) Ensure appropriate risk assessments take account of health surveillance requirements.
(b) Identify and inform staff groups for whom health surveillance is required.
(c) Ensure liaison with the Occupational Health Unit to assist in identifying where health
surveillance requirements are necessary or have been identified.
(d) Immediately advise the Occupational Health Unit of any event resulting in the accidental
release of, or exposure to, substances hazardous to health.
(e) Ensure those with the responsibility for carrying out risk assessments are fully aware of
health surveillance requirements and the arrangements to follow where a need, or
potential need, is identified.
(f) Ensure staff requiring health surveillance are able to attend the health surveillance
programmes.
(g) Ensure adequate and up to date records are maintained.

Occupational Health Unit

The Occupational Health Unit is responsible for: -

(a) Advising and assisting managers, following the risk assessment, to incorporate suitable
health surveillance requirements, including on an individual’s commencement of
employment or assignment to a particular activity.
(b) Working with managers and others to advise on adjustments and modifications to the
work of individuals aimed at protection of health.
(c) The review of intervals for health surveillance following any untoward occurrence within
the University working environment.

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 (d) Maintaining awareness of health and safety legislation, guidelines and evidence for health
surveillance programmes, and advising the University of any changes.
(e) The Occupational Health Manager is responsible for supervising and checking the
competency of staff delivering health surveillance programmes. The Occupational Health
Advisers will deliver these programmes on behalf of the Occupational Health Manager
and will:

i) Coordinate and assist in the delivery of timely and relevant health surveillance
programmes, at times and locations to suit best the needs of services requiring them.
ii) Identify staff that may be at risk of work related ill health on the basis of pre employment
health declarations.
iii) Advise managers and subjects of health surveillance regarding outcomes, fitness for work
status and any recommended restrictions in work practice.
iv) Liaise with and provide information to general practitioners and other specialists
regarding adverse outcomes of health surveillance.
v) Identify complex cases where referral to The Occupational Health Physician or other
relevant specialist is necessary to underpin advice to management.
vi) Advise relevant personnel of any health surveillance subjects failing to attend
programmes.
vii) Maintain health surveillance records in accordance with current legislation and guidelines.
viii) Advise relevant personnel regarding record keeping to meet statutory requirements and
satisfy external agencies.
ix) Report the relevant outcomes of health surveillance programmes to the appropriate
personnel within the University Health and Safety Committee.

Individuals Undergoing Health Surveillance

Those undergoing health surveillance are responsible for: -

(a) Advising the Occupational Health Unit of any significant health issues.
(b) Reporting any significant changes in their health to the Occupational Health Unit in
intervals between health surveillance sessions.
(c) Cooperating with health surveillance programmes and other risk reduction measures for
the protection of their health.

Access to Health Surveillance Information and Records

Following a particular aspect of an individual’s health surveillance programme, the Occupational

Health Adviser will bring the findings to the attention of the individual and discuss any implications as
a result.

The Occupational Health Unit will bring to the attention of an individual’s line manager the relevant
findings of a health surveillance programme. Such findings could include:

(a) Exposure to hazardous substances, physical agents etc indicating a risk to the
individual’s health.
(b) Indication of the non-performance or under performance of risk control measures.
(c) Whether the individual is deemed fit to undertake a particular work activity.
(d) Individuals who are subject to health surveillance are entitled to access the records held
in respect of that health surveillance, and can be routinely supplied with a copy of the
examination outcome at the time it is carried out..
(e) Requests for access to an individual’s health records by any third party must be in writing
and be accompanied by the individual’s written consent to access these records.
(f) Where a request is made by the Health and Safety Executive to the University to provide
access to an individual’s health record, that request must be in writing and the information
will be restricted to that given by the relevant regulations and/or accompanying approved
code of practice.

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Maintenance and Retention of Health Surveillance Records

a) Individual’s health surveillance records will be maintained and retained in accordance with
the prescribed periods given by the regulations under which that health surveillance has
been carried out. These periods are given in Appendix 1 to this policy.
b) Where no prescribed period is given in respect of health surveillance carried out as
required by specific legislation, the records for that health surveillance will be retained in
accordance with Appendix 1.
c) Individuals health surveillance records will be held securely and confidentially by the
Occupational Health Unit

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 APPENDIX 1: LEGISLATIVE REQUIREMENTS FOR HEALTH SURVEILLANCE

The Management of Health and Safety at Work Regulations

What the Regulations Require Application of the Regulations Requirements Retention of Health Surveillance Records

Regulation 6

Employers are required to ensure employees are Risk assessments carried out under the Regulations will There is no prescribed time period for the retention of
provided with appropriate health surveillance in relation to identify circumstances where health surveillance is records of health surveillance carried out under the
risks to health and safety identified by risk assessments required by specific health and safety regulations, eg Regulations.
carried out in accordance with the Regulations. Control of Substance Hazardous to Health Regulations
(COSHH). Good practice is to retain an individual’s health
surveillance record whilst they remain an employee and,
In addition, health surveillance will be appropriate where once an individual’s employment has ceased, whilst
risk assessments identify the following criteria: enquiries could still be made.

a) There is an identifiable disease or adverse health Any records of health surveillance carried out under the
effect related to employees’ work; Regulations will be retained for at least 40 years after
the date of last entry
b) Valid techniques are available to detect
indications of the disease or health effect;

c) There is reasonable likelihood the disease or

health effect may occur under particular
conditions of the work; and

d) The surveillance is likely to further protection of

the health and safety of the employees it will
cover, eg maintaining the effectiveness of a risk
assessment and the controls implemented as a
result.

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The Control of Substances Hazardous to Health Regulations

What the Regulations Require Application of the Regulations Requirements Retention of Health Surveillance Records

Regulation 11

Where it is appropriate for the protection of the health of In addition to the specific conditions given by the The Regulations require that each employee is subject to
employees who are, or liable to be, exposed to Regulations in relation to substances and activities given health surveillance; the records of that health surveillance
hazardous substances, those employees will be under in Schedule 6 to the Regulations, examples of where shall be maintained and retained for at least 40 years
suitable health surveillance. health surveillance would be appropriate under the other from the date of last entry.
criteria given in regulation 11 would include: -
Health surveillance is appropriate where:
a) Exposure to substances having recognised adverse
a) Exposure is to a substance, or engagement in a health effects on other parts of the body, eg
process specified in COSHH to the Regulations and mutagens, carcinogens, biological agents and micro-
there is a reasonable likelihood that an identifiable organisms, from where they enter, ie, by inhalation,
disease will result. ingestion, skin absorption or skin puncture;

Health surveillance in these circumstances will b) Substances known to be respiratory sensitisers,

include medical surveillance under the supervision of cause occupational asthma; and
a relevant doctor at intervals not exceeding 12
months, or more frequent if the doctor requires. In c) Substances known to be skin sensitisers, cause
addition, where the doctor has certified: severe dermatitis.

i. An employee should not be engaged in work that Valid health surveillance techniques need to be
results in exposure to a specified substance, or sufficiently sensitive and specific to detect the disease or
specifies specific conditions whilst carrying out health effect related to the type and level of exposure
that work, those conditions must be complied concerned. However, the techniques should not be
with until the doctor indicates otherwise; and carried out where there is a risk of the employee’s health
being harmed.
ii. Medical surveillance should be continued after
exposure to a specified substance has ceased,
that medical surveillance must continue whilst the
employee is still employed until the doctor
indicates otherwise.

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The Control of Substances Hazardous to Health Regulations (continued)

Regulation 11 (continued)

b) An employee’s exposure to a hazardous substance is

such that:

i. An identifiable disease or adverse health effect

may result;

ii. There is a reasonable likelihood the disease or

health effect may occur under the particular
conditions of the employee’s work; and

iii. There are valid techniques to detect the

indications of the disease or health effect, and
these techniques are of low risk to the employee.

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The Control of Noise at Work Regulations

What the Regulations Require Application of the Regulations Requirements Retention of Health Surveillance Records

Regulation 9

If a risk assessment carried out in accordance with the The Regulations give both lower and upper action values. There is no prescribed time period for the retention of
Regulations identifies employees are, or likely to be, These values are: records of health surveillance carried out under the
exposed to noise levels presenting a risk to health, those Regulations.
employees shall be subject to suitable health Lower Action Values
surveillance. Good practice is to retain an individual’s health
 80dB average daily or weekly exposure; and surveillance record whilst they remain an employee and,
Where health surveillance identifies hearing damage and,  135dB peak single exposure. once an individual’s employment has ceased, whilst
in the opinion of the doctor who the affected employee is enquiries could still be made.
referred to, this damage is likely to have resulted from Upper Action Values
exposure to noise: Any records of health surveillance carried out under the
 85dB average daily or weekly exposure; and Regulations will be retained for at least 40 years after
a) the affected employee shall be subject to continued  137dB peak single exposure. the date of last entry.
health surveillance; and
Health surveillance will be required where employees are
b) A review of the health of any other employee who has regularly exposed above the upper action values.
been similarly exposed is undertaken.
Where an employee is regularly exposed between the
lower and upper action values or occasionally above the
upper action value, health surveillance should be
provided if the particular employee is sensitive to noise,
eg through previous exposures.

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The Control of Vibration at Work Regulations

What the Regulations Require Application of the Regulations Requirements Retention of Health Surveillance Records

Regulation 7 Hand-arm Vibration Syndrome

Employees shall be subject to suitable health surveillance Health surveillance should be provided for vibration- There is no prescribed time period for the retention of
if a risk assessment, carried out in accordance with the exposed employees, ie those undertaking activities records of health surveillance carried out under the
Regulations indicates: involving the use of hand-held vibrating tools where: Regulations.

a) A risk to the health of employees exposed, or liable to Exposure is likely to be regularly above the action value Good practice is to retain an individual’s health
be exposed, to vibration; or of 2.5m/s2 A(8) as given by the Regulations; surveillance record whilst they remain an employee and,
b) Employees are likely to be exposed to vibration at or once an individual’s employment has ceased, whilst
above an exposure action value. Exposure is likely to be occasionally above the action enquiries could still be made
value and the risk assessment identifies the frequency
Suitable health surveillance is considered appropriate and severity of exposure may pose a risk to health; and Any records of health surveillance carried out under the
where exposure to vibration is such that: Regulations will be retained for at least 40 years after
Employees are identified as particularly sensitive to the date of last entry.
i. A link can be established between the exposure vibration, eg previously diagnosed as suffering from
and an identifiable disease or adverse health hand-arm vibration syndrome.
effect;
Whole Body Vibration
ii. The disease or health effect may occur under the
circumstances of the employee’s work; and Guidance accompanying the Regulations identifies health
surveillance as not appropriate. There are no methods
iii. There are valid detection techniques for the that exist for the detection, or indicate the early onset, of
disease or health effect. adverse health effects associated with whole body
vibration, ie, lower back pain, that are specifically related
to work.

Whilst formal health surveillance is not identified as

required, the guidance that accompanies the Regulations
suggests an approach of reporting and monitoring the
symptoms of lower back pain to assist in assessing the
need for action on whole body vibration. This ‘health
monitoring’ approach is not a legal requirement under the
Regulations

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The Ionising Radiation Regulations

What the Regulations Require Application of the Regulations Requirements Retention of Health Surveillance Records
Medical Surveillance

24

1) This regulation shall apply in relation to— The following employees are required to be under
(a)classified persons and persons whom an employer medical surveillance by an 'Appointed Doctor' (AD) or
intends to designate as classified persons; Employment Medical Adviser (EMA) (at University of
(b)employees who have received an overexposure Glasgow this will be the Consultant OH Physician)
and are not classified persons;
(c)employees who are engaged in work with ionising  Those persons about to be classified; [initial medical]
radiation subject to conditions imposed by an  Classified persons; [periodic medical to demonstrate
Appointed Doctor or Employment Medical Adviser continued fitness for radiation work]
under paragraph (6).  Non-classified persons who have received an
'overexposure'
2) The employer shall ensure that each employee to  Employees working according to conditions imposed
whom this regulation relates is under adequate by an approved dosimetry service or Employment
medical surveillance by an Appointed Doctor or Medical Adviser (EMA)
Employment Medical Adviser for the purpose of
determining the fitness of each employee for the work
with ionising radiation which they are to carry out.

3) The employer shall ensure that a health record, The employer will create a health record for each Records of Health Surveillance carried out under IRR
containing the particulars referred to in Schedule 7, in classified person (and others to whom this Regulation regulations will be retained in Archives for 50 years from
respect of each of their employees to whom this applies) and maintain for at least 50 years from the date the date of last entry in the record.
regulation relates is made and maintained and that of the last entry. The OHU will maintain the medical
that record or a copy thereof is kept until the person record for each classified person.
to whom the record relates has or would have
attained the age of 75 years but in any event for at
least 50 years from the date of the last entry made in
it.

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The Ionising Radiation Regulations (Continued)

What the Regulations Require Application of the Regulations Requirements Retention of Health Surveillance Records
4) Subject to paragraph (5), the employer shall ensure
that there is a valid entry in the health record of each
employee to whom this regulation relates (other than
employees who have received an overexposure and
who are not classified persons) made by an
Appointed Doctor or Employment Medical Adviser
and an entry in the health record shall be valid— An entry must be made in the individual's health record
(a)for 12 months from the date it was made or treated by either an AD or EMA and remains valid for 12 months.
as made by virtue of paragraph (5);
(b)for such shorter period as is specified in the entry
by the Appointed Doctor or Employment Medical
Adviser; or
(c)until cancelled by an Appointed Doctor or
Employment Medical Adviser by a further entry in the
record.

5) For the purposes of paragraph (4)(a), a further entry

in the health record of the same employee shall,
where made not less than 11 months nor more than
13 months after the start of the current period of
validity, be treated as if made at the end of that
period.

6) Where the Appointed Doctor or Employment Medical

Adviser has certified in the health record of an The Doctor may certify that in their professional opinion
employee to whom this regulation relates that in the the employee concerned should not be engaged in work
Doctor’s professional opinion that employee should with radiation or that work should continue only in
not be engaged in work with ionising radiation or that accordance with conditions specified by the Doctor.
he should only be so engaged under conditions he
has specified in the health record, the employer shall
not permit that employee to be engaged in the work
with ionising radiation except in accordance with the
conditions, if any, so specified.

7) Where, for the purpose of carrying out his functions

under these Regulations, an Appointed Doctor or
Employment Medical Adviser requires to inspect any
workplace, the employer shall permit them to do so.

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The Ionising Radiation Regulations (Continued)

What the Regulations Require Application of the Regulations Requirements Retention of Health Surveillance Records
8) The employer shall make available to the Appointed Dosimetry and other relevant records must be provided to
Doctor or Employment Medical Adviser the summary the OH Physician usually around the time of the medical
of the dose record kept by the employer pursuant to examination
regulation 21(7) and such other records kept for the
purposes of these Regulations as the Appointed
Doctor or Employment Medical Adviser may
reasonably require.

9) Where an employee is aggrieved by a decision Where an employee is aggrieved by a decision recorded

recorded in the health record by an Appointed Doctor in the health record they may apply to the HSE for a
or Employment Medical Adviser they may, by an review of that decision provided the application is made
application in writing to the Executive made within 3 within 3 months of the date on which they were notified of
months of the date on which they were notified of the the decision.
decision, apply for that decision to be reviewed in
accordance with a procedure approved for the
purposes of this paragraph by the Health and Safety
Commission, and the result of that review shall be
notified to the employee and entered in their health
record in accordance with the approved procedure.

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The Ionising Radiation Regulations (Continued)

What the Regulations Require Application of the Regulations Requirements Retention of Health Surveillance Records
34

1) Employees must not knowingly expose themselves or

any other person to radiation to an extent greater
than that which is necessary for the work being
undertaken and all work is to be carried out with
reasonable care.
It is the duty of employees to make themselves available
2) Where personal protective equipment is provided for for medical surveillance during working hours, if required
an employee's benefit, they must make full and by the employer, and to provide the Doctor with such
proper use of it, report any defects to the employer health information as they may require.
and, as far as possible, return it to its proper storage Female employees must notify their employer as
place when not in use. soon as possible if they become pregnant or if
they are breast feeding
3) It is the duty of every outside worker not to misuse
their shared reporting record or attempt to falsify any
of the information in it.

5) All employees Appointed as classified persons must

make themselves available for annual medical
examinations during work time and shall provide the
Doctor with such health information that is asked for.

6) Where an employee has reasonable cause to

believe that: -
a) the individual has received an overexposure
b) an occurrence mentioned in paragraph (1) or (3)
of regulation 30 has occurred; or – (involving
overexposure by accident loss or theft)
c) an incident mentioned in regulation 32 (6) has
occurred –(overexposure due to malfunctioning
equipment)

the individual shall forthwith notify his employer of

that belief.

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 APPENDIX 2: EXAMPLES OF TYPES OF HEALTH SURVEILLANCE AVAILABLE AT UNIVERSITY OF GLASGOW OCCUPATIONAL HEALTH UNIT

The Management of Health and Safety at Work Regulations

Risk Item Type of Appropriate Health Surveillance

Noise levels presenting a risk to health Enquiry about symptoms, inspection of ears, Audiometry

Chemicals/substances causing skin irritation (chronic toxins, potent steroids, cytotoxic drugs, toxic pesticides) Enquiry about symptoms, inspection and examination

Vibrating machinery/equipment Enquiry about symptoms, inspection and examination

Ionising Radiation Enquiry about symptoms, medical examination, blood tests

Non-Ionising (laser) class 3R, 3B and 4 laser Specific laser vision screens by appointed optometrist

Asbestos No routine health surveillance requirement for those routinely

exposed to asbestos to have medical examination every 2 years

Respiratory Sensitisers (Lab animals, wood dust, agricultural grains and dust, Latex, formaldehyde ) Enquiry about symptoms, lung function test

Other

Fork-lift truck drivers. Group 2 licence (PSV, LGV & HGV drivers) Medical examination and eyesight testing

Night-worker assessments (voluntary) Enquiry about symptoms, medical examination

Confined space workers Enquiry about symptoms, lung function testing if respirator
(SCBA) wearer medical examination, medical examination

Employees who work at heights Enquiry about symptoms, medical examination

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