Occupational Health and Safety Act, 1993 (Act No. 85 of 1993)RegulationsRegulations for Hazardous Chemical Agents, 2020AnnexuresAnnexure 3 : Hazardous Chemical Agent GuidelinesGuidance on medical surveillance and biological monitoringMedical surveillanceDesigning and implementing a programme of medical surveillance |
| 14. | The following steps should be included in any programme: |
| (a) | Risk assessment: this will determine the potential exposure to and routes of absorption of an HCA, and identify potential target-organ toxicity to direct medical surveillance. |
| (b) | Test selection: tests should have the desirable operating characteristics of appropriate sensitivity, specificity, reliability and predictive value. |
| (c) | Test schedule: the frequency of testing is laid down in general terms by regulation 7(2), but should in any case be based on an understanding of the nature of the hazard and the natural history of any adverse effects that may develop in specific target organs. |
| (d) | Development of action criteria: interpretative criteria for various types of medical tests have been published in the medical literature. However, the occupational medicine practitioner must develop pragmatic action criteria in the context of the specific workplace. |
| (e) | Standardisation of test process: quality control needs to be exercised both at the testing site and in the laboratory contracted to carry out analyses. Consistency over time should be sought to make longitudinal measurements comparable. |
| (f) | Ethical considerations: |
| i. | Information and training of employees as required by regulation 3(1) should include the rationale for doing medical surveillance, and the consequence of abnormal findings. |
| ii. | Written informed consent should be obtained for medical tests to be conducted, in accordance with requirements prescribed by the Health Professions’ Council of South Africa. Should an employee refuse to give consent, it should be explained to the employee that this means he/she cannot be offered the work for which medical surveillance is required, which may affect his/her employment. |
| iii. | An employee must be notified of the results and interpretation of his/her tests and any recommendations made, including, where appropriate, the need for medical referral for confirmation of diagnosis and related actions. |
| iv. | The confidentiality of personal medical records is laid down by regulation 9. |
| (g) | Determination of steps to be taken in the event of identifying a work-related health problem: this is detailed in paragraphs 20, 21 and 22. Cooperation of employees can be best secured by a policy of protection of conditions of service in case of medical removal from a particular job. |
| (h) | Evaluation of controls: an abnormal finding in an employee, or a pattern of findings in a group of employees, may point to inadequate primary control of exposure(s). In such cases the employer needs to be notified of such details of the medical findings as are necessary to evaluate the workplace problem and take remedial action to prevent the continued exposure of the worker and yet unexposed workers. |
| (i) | Record keeping: this includes both medical records and exposure information for every employee. While the employer is responsible for record keeping in terms of regulation 9, access to the contents of personal medical records should be restricted to the occupational health practitioner, the employee, and any person nominated by the employee in writing. |
| 15. | The medical surveillance programme should be described in a written document in which the key issues listed in paragraph 14 are addressed. The document must be made available to the Health and Safety Committee. |
| 16. | The employer must provide the occupational health practitioner with the following information about the work to be performed, which has triggered the requirement for medical surveillance: |
| (a) | the work the employee is, or will be, carrying out; |
| (b) | if the employee has started that work, how long the employee has been carrying it out; |
| (c) | a list of the HCAs to which the employee is, or will be, exposed, as detailed in the risk assessment and relevant SDSs; |
| (d) | relevant risk assessment reports and results of air monitoring carried out at the workplace; and |
| (e) | the type of personal protective equipment being used by the employee. |
| 17. | Non work-related findings include various health conditions that may be identified by the medical testing process, such as hypertension and diabetes. These findings should be shared with the employee (preferably in writing) by the occupational health practitioner to enable the employee to take appropriate action to improve his or her general health. In addition, the occupational health practitioner should refer the employee to his/her own healthcare provider for further treatment, if necessary. |
| 18. | The presence of non-occupational disease does not require notification to the employer. |