Memorandum submitted by British Occupational
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.
2.1 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 agenciesincluding the HSE, universities,
other public bodies, scientific research organizations, and as
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 diseasesbut 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.
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 cancermesothelioma 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
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.
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
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
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
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.
4.1 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
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
British Occupational Hygiene Society
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