Effective Medical Surveillance (MS) Program at the Workplace

Medical surveillance is an essential component of occupational health and safety program at the workplace, aimed at monitoring the health of employees exposed to chemicals hazardous to health (CHTH) in the workplace as required by Regulation 27 of Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous
to Health) Regulations (USECHH) 2000.

It involves systematic collection, analysis, and interpretation of selected workers’ health data to ensure early detection of work-related illnesses and to prevent further exposure with the ultimate goal of medical surveillance is to protect and promote workers’ health by identifying potential risks and implementing measures to mitigate these risks effectively.

By conducting regular health assessments and monitoring workplace environments, medical surveillance plays a crucial role in ensuring a safe and healthy workplace for all employees.

What is Medical Surveillance (MS) Program at the Workplace?

A medical surveillance program at the workplace is a structured and comprehensive approach designed to assess and monitor the health status of employees who are potentially exposed to hazardous materials or conditions during their work.

This program involves a series of activities, including baseline health assessments, periodic medical examinations, biological monitoring, and evaluation of health outcomes related to occupational exposures. The program aims to identify any adverse health effects resulting from workplace exposures, provide early intervention, and implement necessary control measures to reduce exposure risks.

Medical surveillance programs are particularly critical in industries where workers are exposed to chemicals, biological agents, physical hazards, or other potentially harmful substances or simply known as chemicals hazardous to health (CHTH).

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How is Medical Surveillance (MS) Program Conducted?

The medical surveillance is conducted in accordance with the principles outlined in the guidelines established by the Department of Occupational Safety and Health (DOSH), specifically the ‘Guidelines on Medical Surveillance Programme at the Workplace 2023‘.

Below are the steps or methodologies taken during the assessment.

The decision to implement a Medical Surveillance (MS) program is primarily based on the findings of the Chemical Health Risk Assessment (CHRA) and Chemical Exposure Monitoring (CEM). Our Occupational Health Doctor (OHD) will thoroughly review the CHRA and CEM reports to determine the necessity and scope of the MS program.

This review process follows the guidelines outlined in Chapter 3.0, “Chemical Health Risk Assessment & Exposure Monitoring Programme.” By analyzing these reports, our OHD will ensure that the medical surveillance is tailored to effectively monitor and mitigate the specific risks associated with chemical exposures in the workplace.

For all chemicals hazardous to health (CHTH) as specified by legislation, the medical surveillance (MS) program will be conducted in accordance with established guidelines. However, if a particular CHTH is not listed in the guidelines, the medical surveillance should still proceed by utilizing alternative reliable sources of information.

Detailed procedures for handling unlisted chemicals shall follow Chapter 8.0, “Searching for Information for CHTH Not Listed in the Specific Guidelines.” This ensures that all potential risks are assessed and managed effectively, even for chemicals not explicitly covered in the existing guidelines.

Two critical components of an effective medical surveillance program are the clinical examination and any applicable biological assessments. To fulfill these requirements, the following information will be collected from participating employee.

  • We will obtain samples through all possible routes of exposure, including inhalation, ingestion, skin contact, or a combination of these, to assess the Biological Exposure Indices (BEI) determinants, which reflect the overall chemical uptake by individuals. Our highly trained health personnel, including the Occupational Health Nurse (OHN) or the Occupational Health Doctor (OHD), will perform the sample collection to ensure accuracy and reliability.
  • We will utilize various sample collection methods tailored to the type and purpose of each specimen. Common techniques include blood draws (venipuncture), urine collection, tissue biopsies, and swabs for saliva or nasopharyngeal samples. In some cases, surgical procedures may be necessary to obtain sections or tissue samples. We will adhere to specific protocols for each method to ensure the safety of both employees and healthcare personnel, as well as the integrity of the collected specimens.
  • Additionally, the OHD conducting the examination will thoroughly review each employee’s occupational history, exposure levels, and medical history, including any previous or current illnesses. This comprehensive assessment will be considered in the final reporting of the medical surveillance, ensuring a detailed understanding of any potential medical conditions related to chemical exposure.

We will analyze the results of the medical examination to determine if any findings are abnormal. If abnormalities are identified, we will notify DOSH using the appropriate notification forms as outlined in Appendix 7: Medical Surveillance Recommended Forms. Similarly, these findings will be communicated to both the employer and employees promptly.

Based on the requirements for each chemical hazardous to health (CHTH), the Occupational Health Doctor (OHD) may recommend Medical Removal Protection (MRP) for the affected employee. The duration of medical removal will be limited to the time necessary for the employee’s medical condition to normalize or until the biomarker of exposure falls below the Biological Exposure Index (BEI).

Upon concluding the medical surveillance program, we will hand over a copy of the Medical Surveillance (MS) program report for your record keeping. These records will serve as a vital reference for developing recommendations and implementing control measures to protect employees’ health both during their employment and in the future. Regulation 27(4) of USECHH Regulations 2000 requires that the medical surveillance report or any related records be kept for a period of 30 years.

On top of that, we will prepare and submit a comprehensive report to the employer and DOSH within 30 days of completing the MS, ensuring that workplace conditions can be improved and proactive measures taken to prevent adverse health effects.

A worker undergoing a medical surveillance program.
An illustration of a worker undergoing medical check up.

What are Included in the MS Program Report?

The MS report is documented using USECHH forms, organized according to the process flow of an employee’s medical examination, as shown in Table 26. USECHH Forms for Reporting and Record Keeping of the guidelines. The primary objectives of the MS report are to provide the employer with the results and recommendations necessary to safeguard employee health from future exposure to chemicals hazardous to health (CHTH) and to deliver a summary report to DOSH.

The employer’s report includes the following USECHH forms arranged for each work unit:

  1. USECHH 4: Summary work unit report.
  2. USECHH 5ii: Summary of individual abnormal results with recommendations (if applicable).
  3. USECHH 5i: Medical Removal Protection (MRP) details (if applicable).
  4. USECHH 3: Fitness to work certification.
USECHH Forms Table
Updated According to OHD Flow of Work Process Name of Form and the Usage Records Kept by OHD Records Kept by Employer Submission to DOSH
USECHH 1 Examination Form: Contains the medical examination findings and the individual fitness to work and other recommendations. The USECHH 1 form can be used for more than one CHTH. Yes (7 years) No (A copy to be kept by the employee) No
USECHH 2 Summary Records of Individual Employee: Contains the results of an employee throughout the MS programme. The serial data may show progression of health status. Yes (7 years) Yes (30 years) No
USECHH 3 Certificate of Fitness: To certify whether the employee is fit or not fit to work with the CHTH. Yes (7 years) Yes (30 years) No
USECHH 4 Summary Report for MS: Represents the collective results of a work unit that include recommendations to the company for that work unit. Yes (7 years) No Yes
USECHH 5ii Summary of Individual Abnormal Result with Recommendation: A list of employees with work-related abnormalities and individual recommendations. Yes (7 years) Yes (30 years) Yes
USECHH 5i MRP MRP (Medical Removal Protection) Information Yes (7 years) Yes (30 years) Yes

What are the Benefits of MS Program to the Organization

1. Early Detection of Health Issues
Medical surveillance enables the early identification of potential health problems related to chemical exposure, allowing for timely intervention and treatment before conditions worsen.

2. Prevention of Occupational Diseases
By regularly monitoring employees’ health and exposure levels, the medical surveillance program helps prevent the onset of occupational diseases, thereby reducing long-term health risks and potential liability for the organization.

3. Compliance with Regulations
Implementing a medical surveillance program ensures that the organization complies with relevant occupational safety and health regulations, such as the Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulations (USECHH) 2000. This compliance helps avoid legal penalties and enhances the organization’s reputation.

4. Improved Workplace Safety
The program provides valuable data on workplace exposure levels and health risks, enabling the organization to implement effective control measures and safety protocols to improve overall workplace safety.

5. Enhanced Employee Well-Being
By safeguarding employees’ health, the program contributes to higher job satisfaction and morale, fostering a positive work environment and improving employee retention.

6. Informed Decision-Making
The data collected through medical surveillance supports informed decision-making regarding workplace safety policies, risk management strategies, and resource allocation.

7. Reduction in Absenteeism and Healthcare Costs
By preventing occupational illnesses and promoting early intervention, the program can lead to a reduction in absenteeism and associated healthcare costs, improving productivity and reducing financial burdens on the organization.

8. Support for Medical Removal Protection (MRP)
The program helps identify employees who need Medical Removal Protection due to exposure to hazardous chemicals, ensuring they are temporarily or permanently reassigned to safer roles, thereby minimizing health risks.

9. Promotion of a Safety Culture
Conducting regular medical surveillance reinforces the organization’s commitment to employee health and safety, promoting a culture of safety and responsibility throughout the workplace.

Medical Surveillance FAQ

Biological Monitoring (BM) means the measurement and assessment of agents and/or their metabolites either in tissues, secreta, excreta, expired air, or any combination of these to evaluate exposure and health risk compared to an appropriate reference (CHRA Manual 3rd Edition).

Meanwhile, Biological Effect Monitoring (BEM) means the measurement and assessment of the sub-clinical biological effect caused by the hazards (CHRA Manual 3rd Edition). It normally involves measuring biochemical responses that may have health consequences for the individual and may be caused by factors other than occupational exposure.

Medical Removal Protection (MRP) involves the temporary or permanent reassignment of an affected employee to prevent further exposure to chemicals hazardous to health. For instance, an affected operator may be reassigned to office-based tasks or an administrative role as an alternative.

Temporary Medical Removal Protection (MRP)
Temporary Medical Removal Protection (MRP) involves the temporary reassignment of employees to prevent further exposure to chemicals hazardous to health (CHTH). The duration of temporary MRP is determined by the following criteria:

  1. Normalization of Medical Conditions – The time required for the employee’s medical conditions to return to normal.
  2. Biological Exposure Index (BEI) – The duration required for BEI determinants to normalize, considering the chemical’s half-life.
  3. Pregnancy and Lactation -The duration of pregnancy and any specific concerns affecting lactation may extend the MRP.
  4. Workplace Conditions – Improvements in workplace hygiene and control measures must be achieved.

The initial duration of temporary MRP lasts until the next Return-to-Work (RTW) assessment, with further decisions made at that time. The Department of Occupational Safety and Health (DOSH) must be notified of any extensions. For example, in cases of lead exposure, temporary MRP typically lasts one month to allow blood lead levels to decrease significantly. To prevent recurrence, improvements to the workplace conditions that caused the removal are essential.

Permanent Removal
Permanent removal is recommended when an employee:

  1. Has a Permanent Medical Condition – The condition is directly related to CHTH exposure and would worsen with further exposure.
  2. Has Non-Exposure Related Conditions – Conditions that are not directly related to exposure but reduce the employee’s tolerance to CHTH effects, such as significant renal impairment, which affects the body’s ability to eliminate chemicals.

Permanent removal involves permanently reassigning employees to roles that do not expose them to the hazardous chemicals, ensuring their long-term health and safety.

References

  1. Occupational Safety and Health Act (OSHA) 1994.
  2. Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulations, 2000.
  3. Guidelines on Medical Surveillance Programme at the Workplace 2023.