Guidance for occupational health providers and appointed doctors during the coronavirus pandemic

HSE issued guidance on 20 March 2020 and updated guidance on 18 June 2020, setting out a proportionate and flexible approach to enable health surveillance to continue during the pandemic. This advice (issued on 3 September 2020) further updates that guidance.

It continues to balance the need to protect the health, safety and welfare of workers and current constraints presented by the coronavirus pandemic.  Face to face assessments can be undertaken, where appropriate, subject to a suitable and sufficient risk assessment and putting in place appropriate controls, taking into account public health advice on coronavirus. The general principles it sets out apply to both new workers and those undergoing periodic medicals.

For all health and medical surveillance, an adequate assessment of the worker should continue to take place (including specialist referral where required), with provision of appropriate advice to the worker and employer.

HSE will continue to review the guidance as appropriate.

Health surveillance using questionnaires

Where health surveillance is performed using questionnaires, they can be administered remotely. For questionnaires requiring follow up, this can be by telephone, video or face to face.

Spirometry and health/medical surveillance

Spirometry can be conducted after completing a suitable and sufficient risk assessment and putting in place appropriate controls. Each individual location where spirometry is planned should be risk assessed and appropriate controls implemented. Occupational health providers should work closely with employers when performing any ‘on site’ risk assessments.

If an occupational health provider is unable to undertake spirometry (for example a local risk assessment does not permit it), they can defer it for up to a maximum of 12 months (including any previous deferral periods). This is providing a current respiratory health questionnaire does not raise any concerns (for initial and review medicals) and previous lung function tests were normal (for review medicals). In these circumstances, a face to face assessment is not required. It is suggested that this approach is discussed with the employers for whom health surveillance is provided, so the reasons for not performing spirometry in the short term are understood.

If previous lung function was abnormal or issues are identified on the respiratory health questionnaire, spirometry may be considered necessary. In these circumstances, it may be appropriate for the occupational health provider to take advice from a relevant senior colleague.

Local restrictions due to coronavirus

Where local restrictions are implemented due to coronavirus, occupational health providers should discuss the delivery of health surveillance with an affected employer. This is to establish an appropriate course of action, such as short-term postponement of assessments or performing remote assessments with a short review period.

Control of Substances Hazardous to Health Regulations 2002 (COSHH)

For health surveillance under COSHH regulation 11 and medical surveillance under Schedule 6, occupational health professionals, occupational health technicians, responsible persons and appointed doctors can perform assessments using the relevant guidance in the previous sections on health questionnaires and spirometry.

Control of Asbestos Regulations 2012 (CAR)

For medical surveillance under CAR, appointed doctors can resume routine practice. Where spirometry cannot be performed, the worker may be assessed remotely. However, a certificate can only be issued for a maximum of one year (including any deferral periods already allowed by preceding guidance).

Doctors can follow the same approach for assessing workers who are carrying out non-licensed work with asbestos.

Ionising Radiations Regulations 2017 (IRR)

For medical surveillance of classified persons, appointed doctors can resume routine practice. This includes paper reviews conducted remotely and face to face assessments where appropriate.

Control of Lead at Work Regulations 2002 (CLAW)

For medical surveillance under CLAW, appointed doctors can resume routine practice and obtain blood lead levels at a frequency set out in the ACOP and guidance (L132).

Control of Noise at Work Regulations 2005

Occupational health professionals and audiologists can resume audiometry, including otoscopy, having carried out a suitable and sufficient risk assessment and put in place appropriate controls.

Control of Vibration at Work Regulations 2005

Routine practice for carrying out health surveillance for hand arm vibration syndrome (HAVS) can resume. This includes administering initial and screening health questionnaires remotely.

Safety critical medicals

Occupational health professionals can resume routine practice. When required, spirometry can be conducted after completing a suitable and sufficient risk assessment and putting in place appropriate controls.