Memorandum by the Health & Safety
Executive
BACKGROUND
The Health and Safety Commission is responsible
for health and safety regulation in Great Britain. The Health
and Safety Executive (HSE) and local government are the enforcing
authorities who work in support of the Commission.
HSE's mission is to protect people's health
and safety by ensuring risks in the changing workplace are properly
controlled.
HSE regulates health and safety in nuclear installations
and mines, factories, farms, hospitals, laboratories and schools,
offshore gas and oil installations, the safety of the gas grid
and the movement of dangerous goods and substances, and many other
aspects of the protection both of workers and the public.
RESPONSE TO
ENQUIRIES
In responding to the inquiry, HSE's comments
are restricted to risks to people at work and those who may be
affected by those work activities rather than any public health
role. The responses provided are where work related issues are
pertinent to the question being posed and may affect the global
spread of infectious diseases and in particular avian influenza,
tuberculosis and HIV (less so malaria) and the intergovernmental
response:
Q1) Increasing emergence or reemergence
of infectious diseases may be influenced by the following work
related matters:
— Worker/animal interface is pivotal
in the spread of zoonotic diseases (eg avian influenza) and changing
animal husbandry practices (eg scale, location) may increase the
potential for exposure of humans (eg Q fever outbreak at meat
processing plant).
— Movement of migratory workers from
endemic to non-endemic areas—different strains & resistances
from different geographical areas.
— Movement of contaminated materials
(eg animals & their byproducts, bush meat).
— Increased frequency and distribution
of work-related international travel.
Q2-5) No comment
Q6) HSE regulates organisations who may
be deliberately working with pathogens; or who may be inadvertently
exposed to pathogens as a result of their work activities—HSE's
role is to check compliance with legislative requirements and
consequently provide reassurance to Government and the public,
that such organisms will not be released into the environment
and community. In addition to its regulatory role, HSE is involved
in cross-government initiatives (eg Pandemic Influenza Planning);
provision of guidance (eg Protection against blood borne infections
in the workplace; Protection of Poultry workers against avian
influenza); research on protective measures against infection
(eg evaluation of respiratory protection against influenza); and
international guidelines on vaccine manufacture (eg WHO guidelines
for H5N1 vaccine manufacture).
In order to deliver these initiatives, HSE works
with other government departments and agencies (eg Department
of Health, Department for Transport, Department for Environment,
Food & Fisheries, Health Protection Agency, Environment Agency)
and across international boundaries (World Health Organisation,
European Biosafety Association); as well as with UK & international
Scientific and Expert Advisory committees (eg Advisory Committee
for Dangerous Pathogens).
Q7-9) No comment
Q10) No specific comment on Stockholm Convention,
however, international legislation on the rationalisation and
review of biocides and chemicals (ie Biocidal Products Directive;
and the Registration, Evaluation, Authorisation and Restriction
of Chemicals [REACH] Regulations) means that access to some disinfectants
and the range of disinfectants available is likely to be reduced
(eg Phenolic disinfectants for use against tuberculosis).
Q11) The UK government is preparing a unified
cross-government response to the potential threat of an influenza
pandemic, to which HSE is in agreement—this includes a Pandemic
Preparedness Plan and associated guidance and contingency planning.
Q12) No comment
Q13) HSE is currently exploring with healthcare
regulators and government departments in England, Scotland and
Wales how its role as an independent health and safety regulator
can contribute to reducing the incidence of healthcare associated
infection (HCAI). This may involve HSE working in partnership
with those other agencies in proactive inspection of infection
prevention and control practice and in reactive investigation
of HCAI incidents.
Q14-15) No comment
Q16) The International Health Regulations
place requirements on countries to develop, strengthen and maintain
core surveillance and response capacities to detect, assess, notify
and report public health events to WHO and respond to public health
risks and public health emergencies. In the work environment,
the potential for laboratory incidents resulting in public health
events is recognised (eg Re-emergence of 1977 H1N1 influenza virus
worldwide is generally accepted as emerging from a laboratory;
Release of SARS from laboratories in Singapore and China; Distribution
of non-contemporary influenza H2N2 laboratory testing specimens
internationally). The IHR will provide additional powers to limit
movement of individuals who may have acquired an infection at
work in the laboratory thereby reducing the possibility of such
an event becoming a public health matter.
Q17) HSE works closely with the Home Office
and the National Counter Terrorism and Security Office to provide
training for police officers who visit laboratories to assess
biosecurity and technical advice on the Schedule of biological
agents which may be used by bioterrorists. HSE participates in
HO-led incident response exercises related to deliberate releases
and working groups/meetings to assess the development of "dual-use"[25]
microorganisms.
Q18) The majority of new and emerging infectious
diseases are zoonotic in origin. The human/animal interface is
therefore of paramount importance in addressing the spread of
such communicable diseases. Certain worker/animal interfaces may
magnify this interaction through animal husbandry practices that
are of increasing scale and greater distribution (eg avian influenza
in poultry houses involving hundreds of thousands of animals;
Q fever exposure of workers in high intensity abattoirs).
Q19) No comment
Q20) Polio eradication programme presents
a scenario where the consequences of release of the virus from
a laboratory are magnified, particularly when vaccination ceases.
Consequently HSE has participated in WHO working groups to establish
the proposed laboratory containment for working with polio post
eradication and to establish an inventory and audit of sites holding
polio virus or contaminated materials.
February 2008
25 Dual use refers to legitimate scientific research
undertake for societal benefit (eg technical advances in molecular
biology) being potentially applied to malicious or harmful endeavours. Back
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