Select Committee on Work and Pensions Written Evidence


Memorandum submitted by British Occupational Hygiene Society

1.  EXECUTIVE SUMMARY

    —    In general HSE and HSC have done a good job of managing the health and safety system in Great Britain, although insufficient effort has been made to reduce chronic work-related ill-health such as occupational cancer;

    —    Deaths from occupational illnesses are probably more than forty times the number dying from accidents at work, although reliable data on workplace ill-health is not collected by HSE;

    —    HSE has reduced the number of occupational health and hygiene specialists it employs. This action has indirectly and unintentionally discouraged employers from employing or seeking advice from specialists themselves;

    —    HSE must put more effort into reducing the risks to health from chemicals and other hazardous agents at work;

    —    Better systems are needed to monitor the number of people at risk from these diseases from the main causes (eg diesel exhaust particles, crystalline silica, radon and asbestos) and the magnitude of the risks; and

    —    HSE should promote higher standards of education, training and qualifications in occupational hygiene, which would help in reducing the above risks.

2.  INTRODUCTION

  2.1  The British Occupational Hygiene Society (BOHS) is the primary member organization for those concerned with the management of risks from chemical, physical and biological hazards in the workplace. We have about 1,200 members who work for industry, government agencies—including the HSE, universities, other public bodies, scientific research organizations, and as consultants.

  2.2  BOHS's aim is to help to reduce work-related ill-health. We do this by promoting public and professional awareness of occupational risks, developing good practice and standards, and by researching and advancing education in the science of occupational health and hygiene.

  2.3  BOHS publishes the leading international scientific journal in the field of occupational hygiene. We also provide a range of professional qualifications by examination in occupational hygiene.

3.  FACTUAL INFORMATION

  3.1  We have a good working relationship with senior officials in the HSE and have an ongoing dialogue with one of the HSC Commissioners. We believe that overall HSE and HSC have done a good job in managing the health and safety system in Great Britain. We have previously expressed support for the merger of HSC and HSE, and we reiterate that this is likely to benefit the health and safety system in Britain.

  3.2  We acknowledge the work done by HSE in recent years under the Disease Reduction Programme (DRP), and their willingness to develop partnership working with BOHS and others in this area. Nonetheless the HSEs emphasis remains stronger on conventional safety aspects than health issues. For example, DRP is one part of the overall Fit3 delivery programme together with Injuries and Absence Management/Return to Work elements. The DRP accounts for only about 10% of the Fit3 budget. BOHS is increasingly concerned that too little emphasis is being put on preventing chronic illness arising from workplace exposures.

  3.3  We feel the DRP, which is only concerned with chemicals, is focused on the right issues: ie cancer, respiratory illnesses and skin diseases—but this programme needs more emphasis and resources.

  3.4  HSE has funded a research study to define the number of cancer cases that are caused by occupational exposures.[30] The first phase of this work has shown that about 8% of all cancer deaths in men and 1.6% in women were attributable to work, which corresponds to over 7,000 deaths each year. The main contributors were exposure to asbestos, crystalline silica, diesel exhaust and radon. To put the figures into context, the estimated number of deaths from occupational cancer is 30 times more than the 212 people killed at work because of accidents in 2005-06. The HSE funded research also estimated that there are more than 13,000 occupational cancer registrations each year, with non-melanoma skin cancer making the largest contribution to non-fatal cases. The occupational cancer burden estimates are similar to those made in the 1980s by Professor Richard Doll and Richard Peto and the main cause of this has been the enormous rise in asbestos-related mesothelioma and lung cancer—mesothelioma up from just over 400 in 1981 to almost 2,000 in 2004.

  3.5  There are similar health consequences from other occupational exposures. For example, HSE cite estimates of the number of deaths from chronic obstructive pulmonary disease (COPD) due to work. They note that although smoking is the most important risk factor for COPD, occupational exposures to fumes, chemicals and dusts may together account for around 4,000 deaths each year.[31] There are probably in excess of 75,000 people suffering from work related hearing problems and many other cases of ill-health due to workplace exposures.

  3.6  In truth we know very little about the extent of the chronic occupational health problems that exist in our workplaces. HSE have no reliable statistics about the numbers of people exposed to harmful agents at work and currently have few data on the magnitude of the risks. The estimates for the cancer and other chronic diseases cited above have considerable uncertainty because of this lack of appropriate intelligence.

  3.7  HSE has made progress in developing guidance for employers and employees concerning good control practice for hazardous substances. For example, through the COSHH Essential initiative and the associated guidance sheets.[32] However, stronger efforts are needed to encourage employers to follow this type of guidance. We believe that the most effective way of achieving this would be by greater promotion of these ideas through visits by inspectors to workplaces. Our members also have a great deal of experience and expertise in this area and we believe that employers should be further encouraged to seek out the advice of BOHS members.

  3.8  Over the last 10 years HSE has cut back its specialist resource, but particularly in occupation health and hygiene. It has downplayed the importance of specialist advisors and promoted the view that employers can tackle most occupational health problems without specialist advice. As HSE is a key player in the occupational hygiene field, it is not only the direct impact of the cutbacks but the influence they have on the practice of occupational hygiene throughout the UK. The unremitting funding restrictions have started to undermine previous achievements in controlling chemical exposures, leading to:

    —    reduced numbers of occupational hygiene specialists in HSE;

    —    minimal enforcement of occupational hygiene regulations;

    —    severe cutbacks in the production of guidance to industry;

    —    reduction in funding for research into longer term hygiene issues;

    —    reduced support for occupational health and hygiene educational programmes and institutions;

    —    loss of the UK leadership once enjoyed in the setting of Occupational Exposure Limits; and

    —    the near cessation in the collection of exposure data by HSE, rendering the National Exposure Database essentially dysfunctional.

  3.9  BOHS is the main organization that provides professional qualifications in relation to prevention of ill-health from workplace exposures to harmful agents such as asbestos or loud noise. We believe that these qualifications underpin the effectiveness of the risk management. Our qualifications for asbestos management have been widely recognized and incorporated into official guidance from HSE. However, we have noted a general decline in interest in these qualifications and a decrease in the number of professional occupational hygienists. HSE are reluctant to similarly recognize our qualifications in other areas of occupational health.

  3.10  Finally we believe that HSE has lagged behind in partnership working with organizations and agencies outside health and safety. Many diseases that are caused by occupational exposures are also caused by other non-occupational exposures. For example, COPD is mainly caused by smoking but exposure to dust, fumes and other hazardous materials at work also contribute to the death toll from this disease. To solve this problem it is important to tackle both occupational and non-occupational risks in a consistent coordinated way. HSE need to strengthen links between occupational, public and primary health communities in tackling many of these challenges, as the smoking ban has demonstrated. The Government Health Work and Wellbeing (HWWB) initiative could provide a vehicle to achieve this but it will need some vision to look beyond its initial goal of reducing sickness absence towards making a greater impact on the prevention of occupational ill-health.

4.  RECOMMENDATIONS FOR ACTION

  4.1  We consider that HSE should have a much greater priority on controlling the health risks from harmful agents at work. This action is likely to have a major long-term benefit for the health and safety of working people in Britain.

  4.2  The broad range of priorities identified in the current Disease Reduction Programme (ie occupational cancer, respiratory disease and skin disease) are in our view appropriate. In addition, there should be a similar emphasis on occupational hearing loss and health problems caused by vibrating equipment. We suggest that a much larger budget is needed for these activities.

  4.3  It is clear that HSE does not have the resources available to increase its focus on occupational disease reduction, neither in terms of its budget nor the availability of experienced trained occupational health and hygiene staff. We recommend that HSEs budget for occupational disease reduction activities should be increased, ie the increased emphasis should not be paid for by cuts elsewhere in HSEs budget.

  4.4  We further recommend that HSE should reverse the decline in specialist occupational health and hygiene professionals in their organization so that there is an appropriate base of expertise available. HSE should also provide enhanced training in occupational health and hygiene for its front line inspectors.

  4.5  HSE should strengthen its guidance to employers to seek advice and support from people appropriately qualified in occupational hygiene, either by training their own staff or by using external consultants.

  4.6  HSE should have a clear obligation to collect information about the numbers of people at risk from the most important harmful agents at work and the level of exposure that they experience. This data is the only way that we can properly track progress towards eliminating the chronic work-related health problems.

British Occupational Hygiene Society







30   http://oem.bmj.com/cgi/content/abstract/oem.2007.037002v1 Back

31   http://www.hse.gov.uk/statistics/causdis/copd/ Back

32   http://www.hse.gov.uk/pubns/guidance/index.htm Back


 
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