This element, as previously unpacks the whole area of checking that the controls you put in place are working adequately. If you’ve ever read the UK COSHH Regulations you’ll know that it does frame what it means by “adequate control” not only in terms of the principles of good practice and the hierarchy of control, but also in terms of not exceeding any applicable workplace exposure limit (WEL). So, element B4 is mostly about “WEL-ness” if you like. Monitoring exposure checks that everything you have in place is actually working properly, as designed.
First up in this section again you learn all about the concept of WELs, how they are formulated and where they can be found (not just a hole in the ground…). You might initially worry that lead appears to have disappeared, but the blood lead discussion has just moved to biological monitoring later in this element. The asbestos control limits have moved to an earlier element.
The whole section on monitoring strategy is also reproduced, but there are some subtle changes. Firstly we have something that seems to have been imported from the health and wellbeing certificate – making the link between occupational hygiene and occupational health policy and targets.
We also see a more explicit mention of static vs personal monitoring. This was always implied previously, even from a cursory reading of HSG173, it would have made sense to include it. The discussion of the monitoring methods is now much better organised – taking its cue directly from the equivalent section in the international diploma. It is now much clearer which methods you would select for different contaminants, how you would go about it and how you would interpret the results.
The final section on biological monitoring collects a whole load of ideas which were previously awkwardly spread throughout B4 and B11. So, general concepts of health surveillance/medical surveillance are included to set the scene (biological monitoring simply being a specific example). But new here is explicit inclusion of the HSE health surveillance cycle. This is nothing especially new – it seems that you are just a nobody these days if you can’t express concepts as some kind of wheel or cycle. These used to be expressed as flow charts but there has been a growing realisation that systems (including management systems) cannot just be setup as a one-time fix and just left to it. They need constant fiddling. It’s called continuous improvement, but it’s fiddling really for incremental gains, but in a systematic way. The health surveillance cycle basically starts as a consideration from your risk assessment, looking honestly at the controls you’ve already got. You need to ask yourself whether you need health surveillance – don’t assume that you actually do need it. HSE are well aware that you can waste lots of money on stuff like this – and end up diverting it away from having decent controls in the first place. So, deciding whether health surveillance is going to add any value in the first place is a very sensible first step. The rest is just common sense and, although it doesn’t display it this way, fits neatly into the Plan-Do-Check-Act business improvement cycle. So Plan (what sort, when, who), Do (implement it), Check (interpret and review the results – so if things are actually under control), Act (make any identified changes you need to, including perhaps upgrading your controls). It’s always nice when the world fits into 4 boxes isn’t it? I’m working on a grand unification theory to marry up the 5 steps to risk assessment with the 4 steps of business improvement. The maths is quite difficult – I’m sure I’ll find the answer in Density Matrix Theory or Quantum Relaxation Theory (as applied to beds and chesterfield armchairs). Or maybe I’m just worrying over nothing…..