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Requirements of the schedule, and use of laptops and non-keyboard inputting devices

OC 202/1 (Sup 3)
Back to main paper OC 202/1

Health and safety (display screen equipment) regulations 1992

Use of laptops and non-keyboard inputting devices

This supplement to OC 202/1 provides clarification on the interpretation of the Schedule to the Health and Safety (Display Screen Equipment) Regulations 1992 (DSE Regulations). It also gives guidance on the application of the DSE Regulations to portable computers and non-keyboard inputting devices (such as mice).

Recipients of this supplement who do not have a copy of the main OC and would like one should contact:

Roland Roberts, FOD SIU, Room 708, Daniel House, Bootle, Tel: 0151 951 4080.

The schedule

Background

1 Regulation 3 of the DSE Regulations requires that workstations meet the requirements of the schedule, to the extent specified in its first paragraph. This requirement was immediate for workstations first put into service on or after 1 January 1993, but was not mandatory for other workstations until 1 January 1997.

2 It has become apparent that this legal duty can easily be misinterpreted. As a result some suppliers of equipment have produced advertising material that attempts to persuade employers that their workstations will be illegal after 31 December 1996, whereas this may not be the case. Field offices have also received similar complaints from safety representatives etc.

Legal interpretation

3 The schedule sets out requirements for the display screen, keyboard, desk, chair, work environment (including working space, lighting, reflection and glare, noise, heat and humidity), task requirements and software. Requirements are set out in fairly general terms, eg "The seat shall be adjustable in height". The schedule does not contain technical detail.

4 Regulation 3 requires that the workstation meets the requirements of the schedule only "to the extent specified in paragraph 1 thereof".

5 As a consequence the list of requirements in paras 2, 3 and 4 of the Schedule have to be considered only to the extent specified in para 1; in particular, only to the extent that they "relate to worker health, safety and welfare" (para 1(b)) and "the inherent requirements or characteristics of the task make compliance appropriate" (para 1(c)). This is clearly emphasised in para* Current guidance: L26, HS(G) 90, IND(G)36L - file 202 .s 38-40 of the guidance to the regulations (L26).

6 The effect of para 1(b) is that employers are only required to comply with the provisions of paras 2, 3 and 4 if risk assessment has shown that failure to do so would have an adverse effect of health and safety.

7 The assessment should be applied to the entire workstation rather than to individual components. In many cases the adverse effect of one component may be offset by the others, eg in a particular situation good lighting and fully adjustable seating may mean that a fixed screen has no adverse health and safety effects. It follows that the assessment is workstation- specific and it is rarely appropriate to generalise.

Examples of common misinterpretations

Refresh rates and flicker

8 The schedule states that screens should have no flicker. However, it is not technically possible to eliminate flicker completely for all users. Individual perceptions of flicker vary. HSE's advice is that screens that are flicker-free to 90% of users are satisfactory and do not give rise to risk, and therefore comply with the regulations. (The 90% criterion is taken from part 3 of EN 29241.)

9 There are no specified screen refresh rates in the Regulations. Therefore, there is no legal requirement to comply with the rates indicated in international standards (EN 29241 or ISO 9241), although such compliance is one way to demonstrate that equipment does meet the Regulations.

Brightness and contrast controls

10 Paragraph 2(b) of the schedule requires brightness and contrast to be easily adjustable by the user. However, this is qualified by para 1 of the schedule. In HSE's view, therefore, this does not mean that separate brightness and contrast controls are a requirement of the Regulations in all cases. Where equipment has one control, adjusting both brightness and contrast (or either one of them but not the other), the results in practice can be satisfactory in terms of health and safety of the user.

Screen swivel and tilt/provision of work surface and chair

11 In some applications (eg certain screens in control rooms), screens may be used in a standing position, and a work surface and chair may be unnecessary. In some cases, swivelling screens may be undesirable. See L26 para 40 for further examples.

Use of laptops

12 The use of laptops, notebook computers and similar portable equipment appears to have increased considerably during the last few years.

13 This has led to queries about the extent to which portable equipment is in scope of the DSE Regulations and also to concerns as to whether portable equipment and non-keyboard inputting devices can cause adverse health effects which are distinct from those experienced with 'conventional' PCs.

14 Portable DSE (such as laptop computers) is exempt from the Regulations if it is not in "prolonged" use (reg.1(4)(d)). However, the guidance in L26 advises that portable DSE that is habitually in use by a display screen user for a significant part of his or her normal work should be regarded as covered by the Regulations (reg.1(4) and para 16 of L26).

15 HSE's recommended approach on how the Regulations apply to the use of portable DSE is that employers should ensure that users have sufficient training to enable them to recognise and avoid risk factors when using portable DSE.

Use of non-keyboard inputting devices

16 The use of the mouse and various other non-keyboard input devices, eg trackballs, styluses and touchpads, also appears to have increased recently.

17 There have been suggestions in the press that intensive use of a computer mouse can cause work-related upper limb disorder. However, the evidence is largely anecdotal and the extent of any risk uncertain. HSE is currently considering whether to commission research in this area. In the meantime, where mice are in intensive use, inspectors should advise employers to apply relevant principles from the existing guidance:

(1) conduct, and act on, risk assessments;

(2) ensure there is adequate working space; and

(3) give users suitable training, eg in seating, posture, work breaks and avoiding excessive force when using either the mouse or the keyboard.

Review of current DSE guidance

18 Following the recent evaluation of the DSE Regulations, the current HSE guidance* on DSE is under review. When the guidance is re-issued, HSE plans to provide additional practical guidance, wherever possible, on points to consider for the use of both laptops and non-keyboard input devices.

Action by field staff

19 Field staff who receive enquiries on the schedule should ensure that the enquirer realises that requirements in paras 2, 3 and 4 only need to be considered if the constraints of para 1 are satisfied. They should refer the enquirer to paras 38-40 of L26 if necessary.

20 Please direct any queries on this supplement to OHEU, Belford House, 59 Belford Rd, Edinburgh.

Annotation of instructions

21 OC 202/1 - note: "See OC 202/1 Supplement 3 for requirements of the schedule, and use of laptops and non-keyboard inputting devices".

17 July 1997

(220/FOD/138/1997)

Disc: J:\Editors\CA1\OCFILES\202_1s3.sam\GK

ASI headings

Computer(s): display screen equipment: Health and Safety (Display Screen Equipment) Regulations 1992: ergonomics: occupational ill-health: visual display units.

Updated 2012-03-27