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Anne L Raynal, Robbert G Hermanns, Implementation of the Directive 89/391/EEC in Europe, Occupational Medicine, Volume 68, Issue 2, March 2018, Page 147, https://doi.org/10.1093/occmed/kqx177
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Dear Sir,
We read the paper on workers’ health surveillance (HS) in response to the European directive with interest [1]. However, we believe that the respondent for the UK provided, at best, debatable information for this survey. The answers provided for the UK state that article 14 of the directive has been implemented in the UK. The respondent also noted that all workers are provided with regular HS related to the risks at work, that employers are (legally) obliged to offer HS programmes to employees and that workers are (legally) obliged to participate. We believe that the information provided by the respondent could be perceived as unduly positive by our European neighbours.
In Great Britain, the only legally mandated statutory HS is termed medical surveillance. This is only provided by appointed and approved doctors on behalf of the regulator (the Health & Safety Executive (HSE)) who cover about 40000 workers in six high-risk industries. These are workplaces with significant exposures to ionizing radiation, lead, asbestos, a number of hazardous substances under the Control of Substances Hazardous to Health Regulations, compressed air and professional diving. This represents just 0.1% of the 31 million working people, i.e. 99.9% of workers are not covered by mandatory HS [2].