RMA: How a retread is made

Health Surveillance in the Rubber Industry

Introduction

The Rubber Industry Advisory Committee, appointed by the Health and Safety Commission, has prepared this guidance. It represents what is considered to be good practice by members of the Committee. Following this guidance is not compulsory and you are free to take other action.

Who should read this booklet?

This booklet is aimed at all those responsible for health surveillance in the rubber industry. Employees, trade unions and representatives of employee safety will also find it helpful.

Why carry out health surveillance?

Health surveillance aims to protect the health of people at work. It involves collecting information about work-related ill health and allows you to take action to improve controls and reduce risks.

When should you carry out health surveillance?

Health surveillance will be needed if there is an identifiable disease or adverse health effect which:

Is related to the employee's exposure to a health risk; and
A risk assessment has identified as having a reasonable likelihood of occurring under the particular work conditions involved; and
Can be detected by valid techniques.

Other health-monitoring procedures

There are other ways that you can monitor the health of your employees that is not health surveillance. An example is where a valid technique for health surveillance is not available, such as the risk of musculoskeletal disorders. In this case a system of early reporting of symptoms may be appropriate.

Another example is non-statutory, pre-employment health enquiries to check an individual's health status. This should be based on the standard of fitness required for the work the individual will be employed to do.

What are the legal requirements?

Employers have a legal duty to reduce, so far as reasonably practicable, the risks to the health and safety of employees and others who may be affected by work activity. The starting point is to assess the risks. If risk assessment is carried out properly it will show where there is a significant residual risk to health i.e. a risk that remains even after reasonably practicable control measures have been applied.

Health surveillance should be considered wherever there is a significant residual health risk to employees.

An employee's attendance for health surveillance is mandatory where a risk assessment has established that there is a genuine need for it.

What are the benefits of health surveillance?

Health surveillance allows you to:
Detect harm to the health of employees at an early stage;
Assess how well your existing control measures are working;
Improve the health of your workforce and reduce sickness absence;
Provide employees with an opportunity to raise concerns about the effect of their work on their health;
Reduce your insurance claims and premiums.

What does health surveillance involve?

Health surveillance involves the keeping and reviewing of suitable health records for individual employees who may be exposed to health risks at work. Select one or more of the methods of surveillance listed below which are relevant to the health risks to find out the information you need.

A trained 'responsible person' makes regular enquiries or inspections, e.g. checking for skin damage, administering simple questionnaires (see Appendix 1). This person could be a supervisor or first-aider.
A 'qualified person' asks employees about symptoms or inspects individuals for signs of ill health, e.g. an occupational health nurse does a lung function test for isocyanate exposure. They may train the responsible person.
A doctor does a clinical examination, e.g. looking for a reaction to chemicals or carrying out a follow-up lung function test.
Blood or urine tests, e.g. for lead or MbOCA.
Self-checks by employees. These are important but are not sufficient on their own to comply with the regulations. Employees will need sufficient training and information.
The employer must keep a health record for each individual under surveillance (see Appendix 3). Where there is no valid technique to identify a disease at an early stage, e.g. some cancers, the health record may be the only method of surveillance available.

As a general rule individual health records should be kept for as long as employees are under health surveillance, although some regulations, e.g. COSHH and CLAW, require records to be kept for longer (up to 50 years) as ill-health effects might not emerge until a long time after exposure.

Health records and questionnaires managed by the responsible person should be kept securely with other confidential personal records with restricted access. Clinical notes are retained by the doctor or nurse and are completely confidential.

Health surveillance is not a substitute for preventing or controlling health risks. But it is an essential additional requirement for protecting the health of your employees wherever a residual health risk exists.

How do you decide if health surveillance is needed?

Take the following into account to help you make your decision.

Have there been previous cases of work-related ill health in the workplace?
Is there evidence of an ill-health effect in the relevant types of work carried out in your part of the industry? (Look at insurance claims records, ill-health records, suppliers' information, HSE guidance and general industry experience.)
Do your processes involve carcinogens, such as rubber dust and fume?
Do you use respiratory or skin sensitisers such as isocyanates?
Do individuals have to rely heavily on respiratory protective equipment or other personal protective equipment?
Are there foreseeable changes that could have an adverse affect on control measures, e.g. people and working methods changing, or increased work pressure at peak times?
Is health surveillance the only way you can confirm that the control measures are working properly?

Who is likely to be at risk in the rubber industry and what surveillance is needed?

Appendix 5 gives guidance on where health surveillance is likely to be needed in the rubber industry and the types of health surveillance that are appropriate in each case.

How do you ensure that health surveillance will be successful?

Make sure you know what you are hoping to achieve.
Ensure employees understand its purpose and its benefits, how it will be carried out and what it means for them as individuals.
Involve employees and their representatives at the earliest stages and build up trust. Discuss issues of consent and confidentiality.
Get the right programme for your needs and the correct competent person to carry it out.
Be clear about roles and responsibilities.
Record and act on your results.
Deal with special cases such as young people or pregnant employees.
Monitor, evaluate and refine the programme if necessary.

What do you do with the results of health surveillance?

Regularly review your results. Ensure individual employees have the results of their health surveillance and understand the significance to them. Provide them with any advice they need.

Use the results of the health surveillance to review your risk assessment and take appropriate action where necessary. If they suggest that your control measures are not effective enough you may need to improve engineering controls, maintenance and inspection arrangements, systems of work or employee training. You may need to check that the right type of personal protective equipment is being used and that it is being worn and maintained properly.
Use the collective results of health surveillance for groups of employees involved in particular processes or activities as indicators of your success or failure in managing and controlling health risks. Collective results of health surveillance can be given to the workforce as long as they cannot lead to the identification of individuals.
Review your arrangements for health surveillance at suitable intervals.

Where can you find help?

Occupational health providers

Doctors and nurses providing a service to the workplace would normally have gained the following qualifications in occupational health.

Doctors: DoccMed, AFOM, MFOM or FFOM.

Nurses: UKCC registration and a degree, diploma or certificate in occupational health nursing.

The Employment Medical Advisory Service (EMAS) based at your local HSE office can provide advice and guidance on health surveillance and other workplace health issues. They can usually provide a list of doctors and nurses working locally who have expressed an interest in occupational health work.

Where employers have no access to an occupational health doctor or nurse they may seek help from the individual employee's general practitioner (GP). However, not all GPs have experience in addressing occupational health issues. The employer should ensure that the GP is provided with enough information about the employee's work activities, possible exposures and results of any health surveillance procedures. They should ask the GP for written advice which will help them protect the individual and review their risk assessment.

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