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    HAND-ARM VIBRATION POLICY

    EQUALITY IMPACTThe Trust strives to ensure equality of opportunity for all both as a major employerand as a provider of health care. This policy has therefore been equality impactassessed by the Risk Management Committee to ensure fairness and consistencyfor all those covered by it regardless of their individual differences, and the resultsare shown in Appendix 4

    Version: 1.0 FinalAuthorised by: Risk Management CommitteeDate authorised: 4 November 2010Next review date: 1 November 2012Document author: Vicky GloudonAuthor designation: Occupational Health Team Manager

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    TAMESIDE HOSPITAL NHS FOUNDATION TRUST October 2010AUTHOR OCCUPATIONAL HEALTH TEAM MANAGER

    control of vibration at work

    VERSION 1.0 Final November 2010 Page 2 of 27Check the Intranet for the latest version

    VERSION CONTROL SCHEDULE

    control of vibration at work

    Version Number Issue Date Revisions from previous issue0.1 September 2010 New policy based on HSE regulations

    20051.0 (final) November 2010 Ratified

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    TABLE OF CONTENTS

    1 INTRODUCTION................................................................................................. 4

    2

    PURPOSE........................................................................................................... 43 SCOPE................................................................................................................ 5

    4 DEFINITIONS...................................................................................................... 55 DUTIES............................................................................................................... 5

    5.1 Chief Executive ............................................................................................ 55.2 Directors....................................................................................................... 65.3 Managers ..................................................................................................... 65.4 Occupational Health Department ................................................................. 65.5 All Staff......................................................................................................... 6

    6 POLICY STATEMENT......................................................................................... 67 LEGAL DUTIES................................................................................................... 7

    7.1

    Exposure action value (EAV) and exposure limit value (ELV)...................... 7

    7.2 Assessing the risks....................................................................................... 77.3 Duties of Manufacturers and suppliers......................................................... 87.4 Workplace vibration measurements ............................................................. 9

    8 Control of risks .................................................................................................... 99 Health surveillance ............................................................................................ 1110 POLICY DEVELOPMENT & CONSULTATION ............................................. 1111 IMPLEMENTATION....................................................................................... 1112 REVIEW......................................................................................................... 1213 MONITORING ............................................................................................... 1214 REFERENCES .............................................................................................. 1215

    BIBLIOGRAPHY ............................................................................................ 12

    APPENDICES .......................................................................................................... 13Appendix 1 - Exposure points system and ready-reckoner.................................. 13Appendix 2 Tier Assessment ............................................................................. 15Appendix 3 Health Surveillance Questionnaire.................................................... 17Appendix 4 - Equality Impact Assessment........................................................ 27

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    control of vibration at work

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    1 INTRODUCTION

    In accordance with the Health and Safety at Work Act (1974), the Management of

    Health and Safety at Work Regulations (1992) and the Control of Vibration at WorkRegulations (2005) as well as other relevant legislation and guidance in keeping withexposures encountered in the workplace, all employers are under a general duty toassess the risks to the health and safety of their employees.

    Hand-arm vibration is defined as vibration transmitted from work processes intoworkers hands and arms. Hand Arm Vibration Syndrome (HAVS) is a widespreadhazard in industry and in certain occupations and is caused by the use of hand-heldpower tools or hand guided/hand fed machinery.Regular and prolonged exposure to hand-arm vibration can lead to permanent illhealth effects. This is most likely when contact with a vobrating tool or work process

    is a regular part of a persons job. Occasional exposure is unlikely to cause ill health.

    HAVS is preventable by controlling the risk and by early identification and monitoringof employees who are at risk of developing the disease.

    In accordance with Regulation 7 of the Control of Vibration at WorkRegulations (2005), employers are required to provide suitable healthsurveillance if:

    The risk assessment indicates that there is a risk to the health of theemployees who are, or liable to be, exposed to vibration:or

    Employees are likely to be exposed to vibration at or above the ExposureAction Value (EAV) 2.5m/sA(8).

    Employees already have a diagnosis of HAVs (even when they are exposedbelow the exposure action level).

    2 PURPOSE

    This policy statement outlines the Trusts arrangements for dealing with the risksarising from working with hand held power tools and details the responsibilities ofmanagers and employees.

    The objectives of this policy are:

    To minimize the risk of harm from the use of hand-held power tools:

    By identifying all those employees who utilize hand held power tools;

    By ensuring that risks associated with hand held power tool use will bereduced to the lowest practicable level.

    To ensure that the Trust meets the legal obligations to protect its employees underthe Health and Safety Law, more specifically under the Control of Vibration at WorkRegulations.

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    3 SCOPE

    This policy applies to all Trust employees, bank, agency and locum staff who may be

    exposed to hand-arm vibration from work processes that include the use of vibratingtools.This policy is especially directed at Managers responsible for purchasingtools/equipment or supervising staff who work with such tools..

    4 DEFINITIONS

    Certain occupations involve the use of vibratory tools; use of the following equipment,although not an exhaustive list, has been identified as potential hazards in causingHAVS:

    Road breakers ChainsawsDemolition Hammers Chipping hammersHammer drills/combi hammers Angle grindersNeedle Scalers SandersPlaster sawsSome gardening equipment e.g. hedge cutters, strimmers etc

    Hand Arm Vibration Syndrome (HAVS) is a disorder affecting the blood vessels,and/or nerves, and/or muscles or joints of the hand, wrist and arm.

    Clinical Effects:

    Neurological numbness, tingling in fingers, reduced sense of touch andtemperature, difficulty working with small objects and painful parasthesia in hands atnight;Vascular episodic blanching of fingers with the main trigger being exposure to thecold, in severe cases if circulation is impaired, fingers may take on a black/blueappearance;Muscular and soft tissue reduction of grip strength, joint pains and stiffness ofhands and arms, Carpel Tunnel Syndrome.

    5 DUTIES

    5.1 Chief Executive

    The Chief Executive has overall responsibility for ensuring that the Trust meets itsstatutory and non-statutory obligations for the prevention of harm to defined vibratingtool users.

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    5.2 Directors

    Directors are responsible for ensuring that the requirements of the Trusts Control ofHand-Arm Vibration at Work Policy are effectively managed within their Directorate

    and that their staff are aware of and implement those requirements.

    5.3 Managers

    Managers will be responsible for the execution of the Hand-Arm Vibration riskassessments for their staff. The risk assessments should determine who are usersand should establish the suitability of the vibratory tools/machinery and the practices.The assessment must be recorded and actioned where required.Each manager must ensure that all those identified as users have received adequatetraining for the use of vibratory tools/machinery.Managers are also responsible for monitoring compliance with the policy (see section

    13 Monitoring).

    5.4 Occupational Health Department

    The Occupational Health Department will provide the required health surveillance ifthe risk assessment indicates a risk to the employees health.

    5.5 All Staff

    Staff identified as users of vibratory tools/machinery are expected to:

    Participate in Risk Assessments relevant to this policy Observe advice given by the manager or others acting in an advisory capacity

    Report any health problems related to the use of vibrating tools/machinery

    6 POLICY STATEMENT

    Tameside Hospital NHS Foundation Trust is committed to ensuring the health, safetyand welfare of its employees and others who may be affected by Trust activities, sofar as is reasonably practicable.

    The Trust will ensure all users of vibratory tools/machinery receive sufficientinformation, instruction and training relating to associated risks to reduce anyhazards to the lowest practicable level on a day to day basis.

    The policy will detail what hand-arm vibration syndrome (HAVS) is, the ill health it cancause, what the Control of Vibration at Work Regulations (2005) require the Trust todo, explain how to identify the level of risk and control measures that can be used.

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    control of vibration at work

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    7 LEGAL DUTIES

    The Control of Vibration at Work Regulations requires the Trust to assess the vibration risk toour employees, decide if they are likely to be exposed above the daily exposure action value

    (EAV) and if they are; Introduce a programme of controls to eliminate risk, or reduce exposure to a low a

    level as is reasonably practicable. Provide health surveillance to those employees who continue to be regularly exposed

    above the exposure action value or otherwise continue to be at risk.Decide if they are likely to be exposed above the daily exposure limit value (ELV) and if theyare;

    Take immediate action to reduce their exposure below the limit.Provide information and training to employees on health risks and the actions being taken tocontrol those risks, consult your trade union safety representative on the proposals to controlrisk and to provide health surveillance, keep a record of the risk assessment and controlactions, keep health records for employees under health surveillance and review and update

    your risk assessment regularly.

    7.1 Exposure action value (EAV) and exposure limit value (ELV)

    Vibration magnitude is the level of vibration at the hand position on the tool. This isexpressed as an acceleration value in metres per second squared (m/s). The exposureaction value (EAV) is a daily amount of vibration exposure (A(8)), above which the Trust isrequired to take action to control exposure. The greater the exposure level, the greater therisk and the more action the Trust will need to take to reduce the risk. For hand-arm vibrationthe EAV is a daily exposure of 2.5 m/s A(8).The exposure limit value (ELV) is the maximum amount of vibration an employee may be

    exposed to on any single day. For hand-arm vibration the ELV is a daily exposure of 5 m/sA(8). It represents a high risk above which employees should not be exposed.

    7.2 Assessing the risks

    Managers within the Trust will need to identify whether there is likely to be a significant riskfrom hand-arm vibration from their areas of responsibility.

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    Managers should

    Identify if any processes or work activity involve regular exposure to vibration. Ask employees if they have any of the HAVS symptoms described in this policy.

    If there is likely to be a risk then the Manager needs to assess who is at risk and to whatdegree. The risk assessment needs to enable the Manager to decide whether theemployees exposures are likely to be above the EAV or ELV and to identify which workactivities you need to control.

    The Manager could do the risk assessment themselves or appoint a competent person to doit for them. This may be a employee who has attended the appropriate training course or anexternal consultant. They will need to;

    Make a list of equipment that may cause vibration, and what sort of work it is usedfor; Collect information about the equipment from equipment handbooks (make, model,

    power, vibration risks, vibration information etc);

    Make a list of employees who use the vibrating equipment and which jobs they do; Note as accurately as possible how long employees hands are actually in contact

    with the equipment while it is vibrating in some cases this triggertime may only bea few minutes in several hours of work with the equipment;

    Ask employees which equipment seems to have high vibration and about any otherproblems they may have in using it, e.g. its weight, awkward postures needed to usethe tool, difficulty in holding and operating it;

    Record the relevant information they have collected and their assessment of who is

    likely to be at risk.

    7.3 Duties of Manufacturers and suppliers

    Tool and machine manufacturers and suppliers are obliged by the Supply ofMachinery (Safety) Regulations 1992 (as amended) to design equipment which willreduce vibration risks to as low as possible, making use of the latest technology. Theequipment should be CE marked to show that it complies with these requirements.Health and safety information should be provided in an instruction book. This shouldinclude:

    Warnings about any vibration-related risk from using the equipment; Information on safe use and, where necessary, training requirements;

    Information on how to maintain the equipment;

    A statement of the vibration emission (or a statement that the vibration testhas produced a vibration emission of less than 2.5m/s) together withinformation on the test method used.

    For most types of tool, manufacturers use internationally agreed methods forvibrating testing.This allows comparison of the vibration performance of differentbrands and models of the same type of tool. Unfortunately, many of these testmethods do not represent the way tools perform at work and vibration levels in the

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    workplace may be much higher than those in this type of laboratory test, thereforevibration levels should be monitored in the place of work.

    7.4 Workplace vibration measurements

    If the Manager wants to obtain vibration measurements for tools within their teams thenarrangements need to be made for a competent person to perform these tests usingspecialised equipment. Measurement results can be highly variable, depending on manyfactors, including the operators technique, the condition of the work equipment, the materialbeing processed and the measurement method. The competence and experience of theperson who makes the measurements is important so that they can recognise and takeaccount of these uncertainties in producing representative vibration data.

    Estimating exposure

    Suitable vibration data may be available in the equipment handbook, or from theequipment supplier or from the HSE web-pages (see www.hse.gov.uk/vibration).

    If the manufacturers vibration data is to be used, the Manager should check that itrepresents the way the equipment is used in the workplace as mentioned above. Askthe manufacturer for an indication of the likely vibration emission of the tool whenyour employees are using it. If vibration data from the manufacturer is available,which is reasonably representative of the way you use the equipment, it should besuitable to use in estimating the employees exposure.

    Managers also need to check, by observing them, how long employees are actuallyexposed to the vibration (i.e. the total daily trigger timewith the equipment operatingand in contact with the employees hand(s).

    If the employee is exposed to vibration from more than one tool or work process

    during a typical day, you will need to collect information on likely vibration level andtrigger time for each one. Once you have collected relevant vibration data andexposure times you will need to use an exposure calculator to assess eachemployees daily exposure (see Appendix 1 - HSEs vibration exposure points systemand ready reckoner).

    Using the information gathered in the assessment

    Once the information has been gathered and the vibration assessment has been completed,the Manager will be able to identify whether exposure limits are likely to exceed the exposureaction value and the exposure limit value. This will allow the Manager to plan and prioritiserisk controls.

    8 CONTROL OF RISKS

    When the risk has been identified, consideration needs to given on how you can reduce therisks. The Trust must do all that is reasonable to control the risk.

    Alternative work methods Look for alternative work methods which eliminate or reduce exposure to vibration.

    Your trade association, other industry contacts, equipment suppliers and tradejournals may help identify good practice in industry.

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    Mechanise or automate the work.

    Equipment selection Make sure that equipment selected or allocated for tasks is suitable and can do the

    work efficiently. Equipment that is unsuitable, too small or not powerful enough islikely to take much longer to complete the task and expose employees to vibration forlonger than is necessary.

    Select the lowest vibration tool that is suitable and can do the work efficiently.

    Limit the use of high-vibration tools wherever possible.

    Purchasing policy for replacing old equipment and tools Work equipment is likely to be replaced over time as it becomes worn out, and it is

    important that you choose replacements, so far as is reasonably practicable, whichare suitable for the work, efficient and of lower vibration.

    Discuss your requirements with a range of suppliers. Check with suppliers that their equipment is suitable and will be effective for the work,

    compare vibration emission information for different brands/models of equipment, askfor vibration information for the way equipment will be used, and ask for informationon any training requirements for safe operation.

    Get the employees to try the different models and brands of equipment and takeaccount of their opinions before deciding which to buy.

    Find out about the equipments vibration-reduction features and how to use andmaintain the equipment to make these features effective.

    Train purchasing staff on the issues relating to vibration so that they can dealeffectively with equipment suppliers.

    Maintenance

    Introduce appropriate maintenance programmes for the equipment to preventavoidable increases in vibration (following the manufacturers recommendationswhere appropriate).

    Do not use blunt or damaged cutters or blades and replace consumable items suchas grinding wheels, so that equipment is efficient and keeps employee exposure asshort as possible.

    Work schedules Limit the time that employees are exposed to vibration. Plan works to avoid individuals being exposed to vibration for long, continuous

    periods several shorter periods are preferable.

    Where tools require continual or frequent use, introduce employee rotas to limit

    exposure times (you should avoid employees being exposed for periods which arelong enough to put them in the high risk group (see High risk (above the ELV).

    Clothing Provide employees with protective clothing when necessary to keep them warm and

    dry. This will encourage good blood circulation which should help protect them fromdeveloping vibration white finger.

    Gloves can be used to keep hands warm, but should not be relied upon to provideprotection from vibration.

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    9 HEALTH SURVEILLANCE

    Health surveillance for HAVS is required when risk assessment indicates a risk toemployees health. Health surveillance should operate alongside a programme of vibration

    risk control measures.

    The purpose of health surveillance is to: identify anyone exposed to or about to be exposed to hand-arm vibration who may be

    at particular risk

    check the effectiveness of vibration control measures

    identify any vibration-related disease at an early stage in employees regularly

    exposed to hand-arm vibration

    help prevent disease progression and eventual disability and help employees stay in

    work.

    Only the at risk population should be put forward for health surveillance: All employees likely to be regularly exposed above the daily exposure action value of

    2.5 m/s2A(8) must be under suitable health surveillance.

    Health surveillance should also be instituted for: Employees likely to be occasionally exposed above the exposure action value where

    the risk assessment identifies that the frequency and severity of exposure may pose

    a risk to health.

    Employees who have a diagnosis of HAVS (even when exposed below the exposure

    action value)

    To avoid unnecessary use of specialist resources, the HSE Guidance on Regulations, Hand-arm vibration: The Control of Vibration at Work Regulations 2005 (HSE Books 2005) sets outa tiered approach to health surveillance:

    Tier 1 Initial or baseline assessment

    Tier 2 Annual (screening) questionnaire

    Tier 3 Assessment by a qualified person

    Tier 4 Formal diagnosis

    Tier 5 Use of standardised tests (optional)

    When health surveillance is required, it should be carried out annually. Both initial (or

    baseline) assessment and routine health surveillance are needed for HAVS (see Appendix2).

    10 POLICY DEVELOPMENT & CONSULTATION

    This policy was developed by the Occupational Health Team Manager anddistributed in draft to memebers of the Risk Management Committee for comments.

    11 IMPLEMENTATION

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    The policy will be disseminated through the Risk Management Committee. It will beuploaded onto the Trust intranet after approval to ensure availability to staff.

    12 REVIEW

    This policy will be formally reviewed in October 2012 after approval or review, orearlier depending on:

    Significant changes to practice which require change in policy

    It is deemed appropriate by the author (ie. changes to legislation), sponsoringbody or authorising body

    A significant incident, or a series of incidents, concerning the operation of thepolicy occurs

    Highlighted concerns from the enforcement authority (the Health and SafetyExecutive)

    13 MONITORING

    Risk Officer will check annually, in the form of an audit, that the programme of controls thathave been introduced are being carried out by Line Managers and employees.

    Line Managers, supervisors, employees and trade union safety representative or employeerepresentative should inform the Trust Risk Officer about whether there are any vibrationproblems with the equipment or the way it is being used.

    Line Managers should review the results of health surveillance and discuss with the healthservice provider whether the controls appear to be effective or need to be changed.

    Compliance with the policy will be monitored by an annual health and safety audit,the results of which will be forwarded to relevant divisional managers. The audit willbe monitored via the Risk Management Committee.

    14 REFERENCES

    Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR)1995The Health and Safety at Work etc Act 1974

    The Management of Health and Safety at Work Regulations 1999The Control of Vibration at Work Regulation 2005The Supply of Machinery (Safety) Regulations 1992www.hse.gov.uk/vibration

    15 BIBLIOGRAPHY

    Hand Arm Vibration (Faculty of Occupational Medicine) Accredited Course May2010, Health and Safety Laboratory, Buxton

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    APPENDICES

    Appendix 1 - Exposure points system and ready-reckoner

    The table below is a ready reckoner for calculating daily vibration exposures. All you need isthe vibration magnitude (level) and exposure time. The ready-reckoner covers a range ofvibration magnitudes up to 40 m/s and a range of exposure times up to 10 hours.

    The exposures for different combinations of vibration magnitude and exposure time aregiven in exposure points instead of values in m/s A(8). You may find the exposure pointseasier to work with thanthe A(8) values:

    exposure points change simply with time: twice the exposure time, twice the number ofpoints;

    exposure points can be added together, for example where a worker is exposed to two ormore different sources of vibration in a day;

    the exposure action value (2.5 m/s A(8)) is equal to 100 points; the exposure limit value (5 m/s A(8)) is equal to 400 points;

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    Using the ready reckoner

    1. Find the vibration magnitude (level) for the tool or process (or the nearest value) on the

    grey scale on the left of the table.

    2. Find the exposure time (or the nearest value) on the grey scale across the bottom of the

    table.

    3. Find the value in the table that lines up with the magnitude and time. The illustration shows

    how it works for a magnitude of 5 m/s and an exposure time of 3 hours: in this case the

    exposure corresponds to 150 points.

    4. Compare the points value with the exposure action and limit values (100 and 400 points

    respectively). In this example the score of 150 points lies above the exposure action value.

    The colour of the square containing the exposure points value tells you whether the exposure

    exceeds, or is likely to exceed, the exposure action or limit value:

    5. If a worker is exposed to more than one tool or process during the day, repeat steps 1 3

    for each one, add the points, and compare the total with the exposure action value (100) and

    the exposure limit value (400).

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    Appendix 2 Tier Assessment

    Tier 1 Initial or baseline assessment

    An initial assessment is needed for any new or existing employee before they beginexposure to hand-arm vibration (see Appendix 2). One reason for this is that a baselineshould be available from which to judge the results of routine health surveillance.A self-administered questionnaire that includes questions about the persons medical historyreturned in confidence to the Occupational Health Department forms Tier 1.Employees with no relevant medical history or symptoms suggestive of HAVS should beconsidered fit for work with exposure to vibration. Those who have a relevant medical historyor with possible symptoms of HAVS will be seen by a qualified occupational healthprofessional who will decide whether the person is fit to work with vibration exposure.Tier 1 also provides an opportunity to educate workers about measures under an employeescontrol that will help to reduce the risks from transmission of vibration. New employees, orthose changing jobs, who will be exposed for the first time, should be given suitable

    information about the hazards of hand-arm vibration (for example, the HSE pocket cardHand-arm vibration: Advice for employees).

    Tier 2 Annual (screening) questionnaire

    A self-administered questionnaire should be repeated annually for employees who are at riskbut who have not reported any symptoms suggestive of HAVS. Completed questionnairesshould be sent directly to the Occupational Health Department. If the worker indicates yesto any of the questions on the form, this does not mean that HAVS has been identified.Instead, the yes triggers entry into a more detailed clinical assessment process. The workerwill be further assessed by a specialist occupational health nurse or doctor, described hereunder Tiers 3 and 4.

    Tier 3 Assessment by a qualified person

    The occupational health nurse is responsible for differentiating between normal andabnormal responses to baseline or annual questionnaires and to make a decision whether toproceed to the next tier of health surveillance or to discuss such cases with a competentdoctor.If symptoms are reported in Tiers 1 or 2, further assessment is recommended. Astandardised questionnaire is used to record information about the individuals history ofexposure to hand-arm vibration at work, any significant leisure time exposure, currentmedication, symptomatology, and the results of a targeted clinical examination. A

    presumptive diagnosis may be recorded in Tier 3 as the role of the occupational health nursedevelops, but formal diagnosis is made by a doctor in Tier 4.

    Tier 4 Formal diagnosis

    The occupational physician is responsible for formal diagnosis at Tier 4 and fitness for workdecisions in employees with symptoms.Formal diagnosis, made by a doctor, is required for certain actions including reporting by

    employers of cases under the Reporting of Injuries, Diseases and Dangerous Occurrences

    Regulations (RIDDOR), 1995.

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    Tier 5 Use of standardised tests

    In addition to clinical findings from Tiers 3 and 4, specialist tests can be conducted at referral

    centres (HSE Laboratory in Buxton) for a worker who has symptoms or signs of HAVS.

    These tests are optional and aimed at providing a quantitative assessment for comparisonagainst normal data. Tier 5 does not form part of routine health surveillance.

    Competency and trainingIt is essential that health professionals involved in the health surveillance programme forhand-arm vibration syndrome (HAVS) can demonstrate that they have the necessaryexpertise. The management of the health surveillance programme for workers exposed tohand-arm vibration should be under the supervision of an occupational physician who hassatisfactorily completed a Faculty of Occupational Medicine (FOM) approved hand-armvibration syndrome (HAVS) course and is competent to carry out clinical examinations anddiagnosis of hand-arm vibration syndrome (HAVS).As always, occupational health professionals should work within their personal capabilities,

    and seek advice of more experienced colleagues if necessary. All health professionalsinvolved in health surveillance for HAVS are expected to maintain up to date knowledge ofthe subject.

    OutcomeAs part of the health surveillance programme, workers will be informed of the confidentialresults of each assessment and of any implications of the findings, such as the likely effectsof their continuing to work with vibration. The results of health surveillance with respect tofitness for work will be disclosed to their employer, but no clinical information will be releasedwithout consent. A record-keeping system for holding results of medical examinations andreports of symptoms is needed as part of the health surveillance programme.When HAVS or carpal tunnel syndrome in association with hand-arm vibration are diagnosedby a doctor, it is reportable by the employer in accordance with the Reporting of Injuries,Diseases and Dangerous Occurrences Regulations (RIDDOR), 1995.

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    Appendix 3Health Surveillance Questionnaire

    Health Surveillance Questionnaire

    White British British Bangladesh

    White Irish Asian Other

    White Other Background British Asian Other

    Mixed White & Black Caribbean Black Caribbean

    Mixed White & Black African British Black Caribbean

    Mixed White & Asian Black African

    Mixed Other Background British Black African

    Asian Indian Black Other

    British Indian British Black Other

    Asian Pakistani Chinese

    British Pakistani Other Ethnic Group

    Asian Bangladeshi Do not wish to disclose

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    Occupational Health Physician/Nurse

    Appendix 4 - Equality Impact Assessment.

    Yes/No Comments

    1. Does the policy/guidance affect onegroup less or more favourably thananother on the basis of:

    Race No

    Ethnic origins (including gypsies andtravellers)

    No

    Nationality No

    Gender No

    Culture No

    Religion or belief No

    Sexual orientation including lesbian,gay and bisexual people

    No

    Age No

    Disability - learning disabilities, physicaldisability, sensory impairment andmental health problems

    No

    2. Is there any evidence that somegroups are affected differently?

    No

    3. If you have identified potentialdiscrimination, are any exceptionsvalid, legal and/or justifiable?

    N/A

    4. Is the impact of the policy/guidancelikely to be negative?

    No

    5. If so can the impact be avoided? N/A

    6. What alternatives are there toachieving the policy/guidancewithout the impact?

    N/A

    7. Can we reduce the impact by takingdifferent action?

    N/A


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