Health records for those at risk of BBVs
It is a statutory requirement to keep health records in relation to work involving risk of exposure to blood-borne viruses, under COSHH (Regulation 11 (3).
Health records are not medically confidential documents. They provide feedback to management on the results of health surveillance for the purpose of safely deploying individual employees, as well as collectively monitoring the effectiveness of immunisation in staff at risk.
Health records also allow outcome analysis of ill health, in relation to BBV exposure at a later stage, should this prove necessary (required under Regulation 5 of Management of Health and Safety at Work Regulations, the duty on employers to monitor and review their control measures).
Health records should be held by and available to managers even when separate occupational medical records are also kept. (Unless the employer can demonstrate that reasonable access to these records is available to deploying managers at all times that the relevant staff are working, eg through some other means, such as health records retention within an occupational health department.)
Health records for those working with biological agents
Health records for those working with biological agents require more detail. For example, a historical record of work with - or exposure to - BBVs
This is particularly relevant for:
- infectious agents that have the potential to cause persistent or latent infections, or which may have serious long-term consequences (ie Hazard Group 3 biological agents); and
- BBVs with potential for causing sub-clinical, chronic infections (regarded as Category 1 Carcinogens), such as hepatitis B and hepatitis C.