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Just to add to my previous reply, which was limited due to my currently
being on holiday in Spain.

The fact that there have been no clinical cases of contact dermatitis up to
now is no grounds for not carrying out skin health surveillance. This would
be akin to saying that on a construction site hard hats are not required as
no-one up to now has had anything fall on their head. Regulation 12(1) of
COSHH is quite explicit on this. It would be hard to defend the decision not
to carry out skin health surveillance were a case of occupational contact
dermatitis to occur.

Keep in mind also, that a medical diagnosis of occupational dermatitis is
reportable under RIDDOR and would then almost certainly incur a visit from
the HSE. 

"(1) Where it is appropriate for the protection of the health of his
employees who are, or are liable to be, exposure to a substance hazardous to
health, the employer shall ensure that such employees are under suitable
health surveillance.
(2) Health surveillance shall be treated as being appropriate where -
	(a) (relates to specific chemicals)
	(b) the exposure of the employee to a substance hazardous to health
is such that -
	(i) an identifiable disease or adverse health effect may be related
to exposure,
	(ii) there is a reasonable likelihood that the disease or effect may
occur under the particular conditions of his work, and
	(iii) there are valid techniques for detecting indications of the
disease or effect,
and the technique of investigation is of low risk to the employee."
COSHH (5th edition), Regulation 11

also see MS24, Medical aspects of occupational skin disease
". . . employers are required to arrange for employees to receive suitable
health surveillance where there is exposure to a substance known to be
associated with skin disease or adverse effects on the skin and where, under
particular working conditions, there is a reasonable likelihood that the
disease or effect may occur."

Both situations would appear to apply to what Tracy has described, hence our
view that skin health surveillance is essential for regulatory compliance.

At the moment my daughter, Dr. Helen Taylor, is on holiday herself, and
currently has only limited access to e-mails, hence I am replying on her
behalf as well as my own. Helen's PhD was on new techniques for skin health
surveillance. 

Chris


Chris Packham
FRSPH, FInstSMM, MCMI, MIIRSM, MBICSc
EnviroDerm Services
Unit 10, Building 11, The Mews, Mitcheldean, GL17 0SN
Tel: +44 1386 832 311 (office), Mobile: +44 7818 035 898
www.enviroderm.co.uk

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