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Health surveillance and safety critical medicals during the coronavirus (COVID-19) pandemic

Guidance for occupational health providers and appointed doctors

HSE issued updated guidance on 3 September 2020, setting out a proportionate and flexible approach to enable health surveillance to continue during the pandemic. This advice (issued on 4 January 2021) further updates that guidance. It continues to balance the need to protect the health, safety and welfare of workers and practitioners with the current constraints due to the pandemic.

For all health 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. This guidance sets out options for conducting health surveillance remotely. Face to face assessments can be carried out if considered necessary, subject to a suitable and sufficient risk assessment to provide a COVID-secure environment, taking into account public health advice on coronavirus. The general principles set out in the guidance apply to both new workers and those undergoing periodic medicals.

Where local or national restrictions are implemented due to coronavirus, occupational health providers should discuss the delivery of health surveillance with an affected employer to establish an appropriate course of action.

HSE will continue to review this 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, if considered necessary, face to face assessment in a COVID-secure environment.

Respiratory health surveillance

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), occupational health providers can defer spirometry for up to 12 months (including any previous deferral periods) and face to face assessment is not necessary.

Spirometry should be performed only when necessary, where it changes the assessment (such as a safety critical medical) or management of the worker (such as where there is clinical concern or known lung function abnormality). Where spirometry is considered necessary in these types of circumstances, the potential for aerosols containing coronavirus should be taken into account. It should be subject to a suitable and sufficient risk assessment and appropriate controls put in place, including the provision of suitable personal protective equipment (PPE). The reasons for performing spirometry should be documented.

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 following relevant guidance in the sections on health questionnaires and respiratory health surveillance.

Control of Asbestos Regulations 2012 (CAR)

For medical surveillance under CAR, appointed doctors can perform assessments remotely, following the guidance in the sections on health questionnaires and respiratory health surveillance. Where no problems are identified, they can issue a certificate for up to 12 months (including any deferral periods already allowed by preceding guidance). Where a face to face assessment is considered necessary, it should be carried out in a COVID-secure environment.

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 carry out remote assessments. For a remote assessment requiring follow up, this can be by telephone, video or, if considered necessary, face to face assessment in a COVID-secure environment.

Control of Lead at Work Regulations 2002 (CLAW)

For medical surveillance under CLAW, appointed doctors can obtain blood lead levels and perform assessments in accordance with the Approved Code of Practice and guidance (L132).

Face to face contacts (eg blood taking) should be carried out in a COVID-secure environment.

Control of Noise at Work Regulations 2005

Occupational health professionals and audiologists can defer audiometry for up to 12 months (including any deferral periods already allowed by preceding guidance). If audiometry is likely to change the assessment or management of the worker, it can be performed subject to a suitable and sufficient risk assessment to provide a COVID-secure environment.

Control of Vibration at Work Regulations 2005

Health surveillance for hand arm vibration syndrome (HAVS) can continue using initial and screening health questionnaires administered remotely. If a remote assessment requires follow up and a face to face assessment is considered necessary, it should be subject to a suitable and sufficient risk assessment to provide a COVID-secure environment.

Safety critical medicals

Safety critical medicals can be carried out subject to a suitable and sufficient risk assessment to provide a COVID-secure environment.

Contacting us if you have questions

If you have any questions, please contact [email protected].

Page last reviewed: 4 January 2021

Next review due: 1 February 2021

2021-01-04