Occupational Health Operational Policy

Please be advised that the Trust discourages the retention of hard copies of policies and procedures and can only guarantee that the policy on the Trust Intranet is the most up to date version (The most recent version of this template is available electronically on the Trust intranet/Frequently Used Forms/Integrated Governance. Please use this template in conjunction with the Trust SOP for Approval of MCHFT Guideline / Policy)

Document Type:

Policy

Version:

3

Date of Issue:

March 2016

Review Date:

February 2019

Lead Director:

Workforce and Organisational Development

Post Responsible for Update:

Lead Nurse Occupational Health

Approving Committee:

Workforce Governance

Approved by them in the minutes of:

31st March 2016

Distribution to:

All Trust staff via the Trust Intranet

Contents: Heading

Heading (Insert Title)

Number

Page Number

Contents / Risk rating

2

1

Introduction / Purpose

3

2

General Document (Insert title)

3

3

Definitions

18

4

Associated Documents

18

5

Duties

19

6

Consultation and Communication with

22

Stakeholders 7

Implementation

23

8

Education and training

23

9

Monitoring and review

24

10

References / Bibliography

26

11

Appendices

26

Risk Rating Who will be affected by this procedure? Is there an existing risk assessment related to this procedure? If No is one required?

Trust Employees√ Patients√ / Visitors / General Public / Contractors√ Yes / No√

Yes./No√

Yes – Date completed

Yes / No

Yes – Date completed

A Consequence (1-5)

B Likelihood of Occurrence (1-5)

Raw Risk Rating (no control measures in place)

4

4

(A x B = C) 16

Final Risk Rating (control measures in place)

4

1

4

If Yes does it require updating?

Name: Keith Williamson

Date: 15.02.16

Occupational Health Operational Policy, version 3, March 2016 Page 2 of 34

C Risk rating

1 Introduction Cheshire Occupational Health Service provides a comprehensive equitable Occupational Health Service to all its customers. It aims to ensure staff in employment experience a working environment for which they are physically and psychologically suited and that protects and promotes not only the individual employees health, but also the general well being of the patient, visitor and other employees. In so doing, the department contributes to the overall effectiveness of the Trust as a provider of health care. Cheshire Occupational Health Service is a collaborative between Mid Cheshire Hospitals NHS Foundation Trust and East Cheshire NHS Trust. It is the provider of a pro-active Occupational Health Service and will act at all times in the best interests of the Trusts and its employees. It is the policy of the Trust that no one will be discriminated against on grounds of age, disability, gender, gender re-assignment, marital status, race (including colour, nationality and ethnic or national origins), religion or belief or sexual orientation. The Trust will provide interpretation services or documentation in other mediums as requested and necessary to ensure natural justice and equality of access. Purpose: This document details the responsibilities and key functions and services provided by Cheshire Occupational Health Service. Adherence with this policy will ensure the provision of a comprehensive Occupational Health (OH) Service that meets the minimum service standards set out by the Department of Health, NHS Employers, Safe, Efficient, Occupational Health Services (SEQOHS) and NHS Health at Work standards, guidance and recommendations. This document offers a concise standardised framework for the delivery of a range of services to Mid Cheshire Hospitals NHS Foundation Trust, (MCHFT) East Cheshire NHS Trust (ECT) and external customer organisation. By compliance with the standards within this document there is assurance that the Occupational Health Service meets the standards necessary for compliance with SEQOHS, Care Quality Commission (CQC), NHS Litigation Authority (NHSLA) and National Institute for Clinical Excellence (NICE) guidance and the relevant objectives set out in the Department of Health NHS 2010 - 2015: From Good to Great (Preventative, People-Centre, Productive). 2

Process Hours of Business: 08.30 to 16.30: Monday to Friday (Excluding Bank Holidays) Appointments only, the service has limited capacity to cope with ‘drop-ins’ Premises: Leighton Hospital Middlewich Road Crewe Cheshire CW1 4QJ Macclesfield District General Hospital Victoria Road

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Macclesfield Cheshire SK10 3BL Operating Standards: 2.1. Service Leadership: The Service Manager for Occupational Health manages the Occupational Health Service. This is a non-clinical post. The Occupational Health Service is structured operationally within the Workforce Directorate with the Service Manager for Occupational Health reporting to the Director of Workforce and Organisation Development at Mid Cheshire Hospitals Foundation Trust. Responsibility for clinical service delivery lays with the Clinical Lead Nurse therefore the Occupational Health Service is essentially nurse led. The Clinical Lead Nurse is managerially responsible to the Occupational Health Service Manager this relationship is entirely managerial and will remain so at all times, as professional accountability is to the Director of Nursing and Quality at Mid Cheshire Hospitals Foundation Trust. The Clinical Lead Nurse for Occupational Health should therefore remain free from external influences thus ensuring the service remains impartial and able to act in the best interests of all parties at all times. The Occupational Health Service nursing structure is essentially flat. This facilitates internal innovation with the immediate goals of improving quality, enhancing client relationships and enhancing the service strategically. The role of the Occupational Health Nurse Advisor as an independent nurse practitioner is well established. Each practitioner recognizes the following:  Direct and indirect professional accountability for all aspects of clinical care in the Occupational Health setting  The provision of holistic care in clinical practice  The exercising of independent decision making and professional judgment within the constraints of local and national policy and established Occupational Health practice  The acknowledgement of limitations in clinical practice and accordingly declining any inappropriate duties. 2.2. Occupational Health Clinical Service Delivery: The OH Service inherently incorporates the following:  Employment assessment  Absence assessments/management referral service  Monitoring of at risk groups exposed to e.g. Cytotoxic drugs, Hepatitis B, respiratory pathogens, radiation  Immunisation/Vaccinations  Employee Assistance Programme (via service level agreement with an external provider)  Access to physiotherapy services Occupational Health Operational Policy, version 3, March 2016 Page 4 of 34

 Support services e.g. alcohol, proscribed drugs  Health Promotion activities  Staff Wellbeing  Ergonomic advice  Advice on work related health risks  General health advice 2.2.1 Occupational Health Clinical Service Objectives:  To stress the importance of comprehensive Occupational Health management being integrated in to mainstream management responsibilities, as part of Trust manager’s objectives via adherence to Occupational Health policy and procedure, and relevant Human Resource and Risk Management policies and procedures 

Highlight the potential of the Occupational Health service to help employers and managers improve effectiveness and reduce costs through the reduction of sickness absence and accidents



Aim to improve the quality of patient care and other Trust services through improved staff morale. Through comprehensive absence management and advice and an integrated Wellbeing Agenda

 Reduce ill health in the workplace caused or exacerbated by work and as a indirect consequence improve patient care and health through comprehensive targeted health surveillance programmes and appropriate response to inspection reports and risk assessments  Decrease the frequency and length of long-term sickness by helping workers back to work earlier than anticipated through rehabilitation programmes, restricted duties, referral to specialists etc. with collaboration of HR and Line-Managers  Identify patterns of frequent short-term self limiting sickness; and assist Human Resources in recognising and implementing measures to reduce such sickness and prevailing negative culture by adopting the Health and Safety Executives Management Guidelines on Sickness Absence Management and working collaboratively with Human Resources and line managers to implement early intervention strategies to address trends in specific areas  Help workers understand that the work environment can be a therapeutic environment and thus use the work environment to help people maintain or improve their health and well-being by leading and participating in monthly Wellbeing activities throughout the Trust  As required act on behalf of the organisation to obtain third party specialist information (e.g. Access to Work, Consultant assessment) to ensure individual employees health is not compromised by their job role  As required refer employees to therapy services (Occupational Therapy, Physiotherapy, Psychotherapy, counselling) that will hopefully prevent/reduce further absence. All Occupational Health services are delivered free to the employees of the Trusts 2.2.2. Confidentiality and Storage of Written and Computerised Information: Relevant Legislation:  Access to Medical Reports Act 1988  Access to Medical Records Act 1990 Occupational Health Operational Policy, version 3, March 2016 Page 5 of 34

 

Data Protection Act 1998 Control of Substances Hazardous to Health (2002)

The contents of questionnaires and any subsequent assessments or examinations following employment will be conducted in the strictest confidence and the information retained within the Occupational Health Departments. They do not and will not form part of Human Resources files or Hospital in-patient notes. No details of an applicant’s medical condition will be communicated to a third party without specific written consent of the individual employee, unless in the interests of public health, under this circumstance permission would be sought from the Director of Workforce and Organisation Development or their deputy. Generally the release of information to a third party will only be made under the following circumstances:   

The employee consents to the disclosure A court of law requires disclosure Disclosure is justified in the public interest (e.g. serious crime, notifiable disease)

The only information given to managers or heads of department is suitability for post and recommendations for training and/or restrictions to duties according to the Equality Act 2010. Employee information is stored either electronically on the Occupational Health Patient Administration System (OPAS) which is password protected with only the Occupational Health clinical staff having full access. Occupational Health administrative employees have restricted levels of access to patient medical information, sufficient only to be able to effectively manage a clinical diary and appointment system. Information in paper note format is stored in individual employee identifiable folders in locked cabinets within a designated room in the employee’s local Occupational Health Department. Access to this area is restricted to Occupational Health staff only. Copies of Occupational Health notes are only released to the employee following receipt of written request via the appropriate Information Governance channels. Occupational Health reserves the right to withhold specific data if it is deemed it would cause distress or harm to the individual. Copies requested by third parties i.e. solicitors would only be released following appropriate application via the individual Trust’s Medico-legal Department. Employee information pertaining to employment with any of the partner Trusts or external contracts will not be shared or transferred between organisations without the permission of the employee being sought and granted. Information will only be used for the purpose for which it was intended. Information sharing will be as per established Information Sharing Protocol: An agreement between the two partner organisations on control and governance of shared Occupational Health information. The protocol was ratified by the Executive Director with portfolio responsibility for governance at Mid Cheshire Hospitals Foundation Trust and East Cheshire NHS Trust. Occupational health clinical records are stored for between ten and fifty-years following termination of employment dependent on the job role of the employee and subsequent occupational exposure to potential pathogens. Occupational Health Operational Policy, version 3, March 2016 Page 6 of 34

Files on those who terminate their employment are sent to secure storage in DeepStoreTM. The period of retention will be from the date of last entry or the date of termination of employment whichever is the latter as follows: 

Ten-year general Occupational Health records, including vaccination records



Forty-year exposure to hazardous substances and health surveillance records e.g. Glytaradehyde (COSHH Regulations) Exposure to asbestos (Asbestos Regulations) Respiratory irritants, substances covered by schedule 6 of the COSHH Regulations



Fifty-years exposure to ionising radiation (Ionising Radiation Regulations)

As and when it becomes necessary to destroy files, this will be done in a manner that maintains confidentiality and renders the information permanently irretrievable. Destruction of any files will be in accordance to the relevant Trusts Information Governance Leads agreement and instruction. 2.2.3. Assessment of Suitability for Employment: Relevant Legislation:  Health and Safety at Work Act 1974  Management of Health and Safety at Work [amendment] Regulations 1999  Equality Act 2010  Control of Substances Hazardous to Health Regulations 2002 The occupational health screening procedure is designed to assess the health of new employees in relation to the physical and psychological demands of proposed employment. The assessment also aims to ensure as far as reasonably possible that the prospective employee does not represent a risk to others. All successful candidates at interview in healthcare roles will be required to complete a health declaration. Or successful candidates who identify that they have a health condition that may require adjustment to their employment. Questionnaires are also required to be updated by existing employees of the Trusts (who fall into the above categories) transferring between posts within the same Trust or between the Trusts. The Assessment Process: The health assessment consists of relevant medical, occupational and immunisation history. On receipt of a fully completed questionnaire, a qualified nurse will screen it within two working days of arrival in the Occupational Health Department. All details within the questionnaire will be risk assessed and details inputted on to the OPAS system. An immediate decision will be made if the candidate needs to attend the department for further assessment. At this point, the Recruitment Service will receive via secure email confirmation of the decision. This will be one of the following:

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

Suitable for post without restriction: Where the information in both the health questionnaire and supporting documentation satisfies all the criteria in relation to purposed employment. No appointment at the Occupational Health Service will be necessary

 Suitable for post without restriction-appointment required for update: When the information in the health questionnaire satisfies all criteria relating to proposed employment however update of vaccinations is required. 

Assessment deferred awaiting further information: in this circumstance, it will be stated on the form what information is awaited and whether the candidate is required to attend the Occupational Health Service for medical assessment. The recruitment officer is responsible for the arrangement of any necessary appointments.

Deferment may be due to: 

Requiring information from General Practitioners and/or previous Occupational Health Service



Confirmation of vaccination status or completion of serological investigations pertinent to proposed employment E.g. Exposure prone procedures

 

Confirmation of content of the questionnaire is required The screening nurse believes that the applicant requires attendance at the Occupational Health Service to see either the nurse or doctor

Deferment is in no way indicative of potential ill health and or unsuitability for employment. Following receipt of ALL information, a revised fitness statement will be sent to the recruitment officer within 24-hours of assessment. NOTE: The Occupational Health Consultant/Nurse is in no way involved in the selection process of persons for employment. The only duty of the Occupational Health Service is to advise line managers of any restriction that should be placed on the work that an individual will be engaged in, extra training that may be required and suitability on health grounds to proposed employment. In order that safety of the individual, others and the organisation is maintained Young-persons: If a young-person (14 years to 18 years) is employed in whatever capacity then a YoungPersons Risk Assessment must be completed by the supervising manager and forwarded to OH. If any hazards are identified then these must be discussed with the parent/guardian prior to commencing employment/placement. 2.2.4. Sickness Absence and Ill-health Performance: Relevant Legislation:  Health and Safety at Work etc. Act 1974  The Management of Health and Safety at Work Regulations 1999  Equality Act 2010  Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013  The Working Times Regulations 1998 (amended 2007)

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Management Referral: Referrals will be seen during normal working hours (08.30-16.30) except in the most extenuating circumstances. Appointments outside of normal working hours will be seen on an individual basis following prior discussion with the Clinical Lead Nurse for Occupational Health. Completed referral forms should be forwarded via secure email to the Occupational Health email address prior to the employee’s attendance. Referring managers must provide full details of the reason for referral and stipulate any specific information that is required. Any background information, which may aid the Occupational Health Consultant/Nurse, must be provided. E.g. in the case of frequent sickness absence how many days lost and frequency, known underlying illness etc. Referring managers should state exactly what the problem is or the problem as described by the member of staff. Ideally a current job description should accompany all referrals When received in the local Occupational Health department all referrals will be triaged by the Clinical Lead Nurse or appointed deputy; and it is their decision solely which member of the Occupational Health team sees which referral. Requests from operational managers for staff to see particular Occupational Health staff will not normally be accommodated. Exception will be made in the case of statue or law when the case must be seen by medical practitioner i.e. asbestos medicals, notifiable disease or when the employee has previously seen a particular member of staff for continuity purposes. No referrals direct to the Consultant in Occupational Medicine will be accepted without the approval of the Consultant or the Clinical Lead Nurse. The employee has a right to see the referral document during the appointment with the Occupational Health Service and the Occupational Health Consultant/Nurse will summarise the content with the employee at appointment. Reports to managers will be as helpful as possible whilst retaining the confidence of the staff member, the dedicated Human Resources Manager/Business Partner and the staff member will receive a copy of any correspondence. Wider distribution than stated above will only be undertaken with consent of the employee and only if operationally necessary. Re-release of reports after a 4-week time lapse will not be undertaken by the Occupational Health Service without expressed consent from the employee. Reports to managers will be released following informed employee consent (verbal). Employees have the right to approve the report prior to release to managers. Employee’s can ask for factually incorrect information to be changed however they cannot influence the content of the letter providing it is factually correct and does not breach confidentiality. Employees have the right to withdraw consent for a report to be released at any time during the process. In these circumstances the Occupational Health nurse/doctor should inform the employee that the organisation can proceed in the absence of medical information; which maybe to the detriment of the employee. The Occupational Health Consultant/Nurse reserves the right to withhold letters from employees if they believe that they may cause unnecessary distress. Reason for withholding must be clearly documented in the employees Occupational Health clinical notes.

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As a minimum the Occupational Health response will include whether the worker is fit for work; not a risk to others and can undertake their duties without adjustment or restriction. The Occupational Health response may include more detailed information such maters as likely length of absence, whether an occupational disease is present, if a medical condition exists which could be exacerbated by work, whether work needs to be modified/adjusted for the worker either temporary or permanent, occupational rehabilitation programmes and time scales. Return to work will be as soon as the employee is physically and mentally fit enough, having regard for their own and others health and safety. It is recognised that return to work at the right time can assist recovery, whereas undue delay can aggravate the sense of uselessness and isolation that often accompanies incapacity. It is therefore the policy of the Occupational Health Service to recommend earlier return to work rather than prolonging any sickness absence whilst adhering to Department of Works and Pensions Directives on Expected Timescales for Recovery Following Surgery and illness. Typically, any rehabilitation programme will be timed over a period of weeks depending on the condition. Most phased returns will be between two and four-week duration. Usually commencing on limited hours or restricted duties. Full details of any recommendations will be stipulated in any correspondence from the Occupational Health Consultant/Nurse and will be based on the physical and mental demands of the job on a case-by-case basis. Managers can consult with the Consultant/Nurse managing the case for clarification and/or interpretation of difficult situations. Any response will be subject to the employees consent and will not exceed what the manager reasonably needs to know. Direct questions regarding an employee’s diagnosis will not be answered. Recommendations to Managers: Recommendations to managers are for guidance only. If it is the opinion of the referring manager that the proposed rehabilitation programme is not reasonable, they should contact the Consultant/Nurse directly before effecting change. It is not recommended that managers adjust return to work programmes independent of the Occupational Health Service. If the employee is absent from work with a valid medical certificate issued by their General Practitioner but alternative work can be found which would not adversely affect the employee’s health or recovery, then the Occupational Health Service will discuss details with line managers. The line manager may be requested to complete a comprehensive risk assessment of the proposed activity. The Occupational Health Consultant/Nurse may be able to negotiate a speedier return to work with the involvement of the General Practitioner or Specialist. Similarly, if employees are off work waiting medical or surgical procedures that would not be adversely affected by alternative work then this would be considered. Where work has caused or contributed to an employee requiring absence from work due to sickness or incapacity then the risk assessment for that area of work should be reviewed to ensure that a similar event does not occur. If a manager is in receipt of a medical certificate with which they disagree (e.g. diagnosis, or recommended length of absence) in this circumstance they are encourage Occupational Health Operational Policy, version 3, March 2016 Page 10 of 34

to discuss this with the Occupational Health Consultant/Nurse. Occupational Health will support managers in challenging GP decisions where there is clear evidence that the advice given is erroneous and the employee could return to work without experiencing harm. Managers are discouraged from attempting to escalate cases to more senior members of the Occupational Health clinical team. They are encouraged to seek further clarification and guidance from the attending clinician in the first instance. Premature Medical Retirement (ill-health retirement): Retirement on medical grounds is the last resort, in cases where the individual is permanently incapacitated from any work; the individual may be dismissed and granted an early retirement pension. This is an independent decision by the NHS Pensions Authority based on medical advice; the Occupational Health Service has no influence over this decision The Occupational Health Consultant will interpret employee sickness and/or absence and will provide medical advice to enable managers to discharge their responsibilities equitably to the employee and the Trust with regard to employees who wish to pursue a claim for ill-health. Having confirmed the nature of the condition and the degree of disability the Consultant in Occupational Medicine will initially consult with the manager to establish that any reasonable adjustments to work activity, workplace or alternative employment opportunities have been exhausted. This will be impartial and objective relating solely to medical facts not necessarily employment considerations or the affect on the wider team. The Occupational Health Service will obtain any specialist reports etc. that maybe required supporting the application. The Occupational Health Service as necessary throughout the Ill-Health Retirement process will offer support for the employee. Applications for ill-health retirement should be made via Operational Managers; the Occupational Health aspects of the application will be dealt with by the Occupational Health Consultant whose responsibility it is to determine the degree of disability and its likely duration in relation to the requirements of the applicants work. Self-Referral Employees can self-refer to the Occupational Health Service providing a self-referral form is completed. Self-referral forms available on the intranet. Employees will be encouraged to discuss issues with their Line-Managers in the first instance. Occupational Health is not an alternative to GP services; self-referral to the Consultant in Occupational Medicine will not normally be permitted. Occupational Health has limited influence over specialist appointments and can only attempt to expedite hospital appointments at the NHS Trust’s it serves. It maybe necessary to write to line-Managers following self-referral, in these circumstances the Occupational Health report will clearly indicate why the employee Occupational Health Operational Policy, version 3, March 2016 Page 11 of 34

attended Occupational Health. Informed consent will be sort before writing to managers following self referral. Absence Planning Before Operative Procedures Managers are encouraged to refer employees prior to planned-surgery. The Occupational Health Consultant/Nurse will advise managers and the employee on the expected recovery period as per Department of Works and Pensions guidelines and will formulate a draft return to work plan. Return to work plans will include any necessary restrictions or adjustments, the expected return to work date and the time period before the employee can return to unrestricted working (if applicable). 2.3

Surveillance, Infection Control and Control of Substances Hazardous to Health

Relevant Legislation:     

Control of Substances Hazardous to Health Regulations 2002 Management of Health and Safety at Work [amended] Regulations 1999 Noise at Work Regulations [amended] 2005 Working Times Regulations 1998 (amended 2007) Control of Asbestos Regulations 2012

Employment Specific Health Surveillance: Management of Health and Safety at Work (Amended) Regulations 1999 and Control of Substances Hazardous to Health 2002 require that employees who work with specific substances, or in certain environments, or engage in particular employment, known to be potentially hazardous to health must have tests or examinations as laid down in the regulations applicable to the particular circumstances and as per individual risk assessment for the area. Screening will be offered to these employees on a regular basis as identified in risk assessment by agreement with the manager. The aim of occupational health surveillance and audiometric screening programme is to ensure protection of the employee’s health during and beyond employment. Food Handlers (All workers in the canteen and kitchens that have contact or involvement in food preparation) All food handlers must be screened at pre-employment All food handlers must be referred to the Occupational Health Service with any skin condition especially on the hands and with any hygiene problems. Drivers Reference: The Transport and Works Act 1992 Statutory health surveillance will be carried out on employees requiring of Group 2 licence i.e. Passenger Service Vehicles (PSV), Large Goods Vehicles (LGV) and Heavy Occupational Health Operational Policy, version 3, March 2016 Page 12 of 34

Goods Vehicles (HGV) drivers) It is the duty of all licence holders to declare any relevant disability to the licensing authorities. Drivers of public service vehicles must re-apply for licence after reaching 50, 56, 59, 62, and 65 years of age and annually after this. It is ultimately the transport manager’s responsibility to ensure this is complied with. All drivers on hospital duty are required by Trust insurers to have a vision check 2 yearly free of charge at their opticians or in the Occupational Health Department. Workers Exposed to Environmental Pathogens Reference: Control of Substances Hazardous to Health Regulations (2002) Statutory health surveillance where Control of Substances Hazardous to Health risk assessment indicates health surveillance is requisite in this circumstance to ensure the maintenance of adequate control of exposure of employees to substances hazardous to health. It is otherwise requisite for protecting the health of the employee who has significant exposure to:  Respiratory sensitizers 

Significant exposure to substances and chemical agents with serious longterm effects at low level of exposure or when there is significant risk of skin exposure

 Significant exposure to carcinogens and mutagens  

Significant risk from biological agents Substances where schedule 6 of COSHH regulations specifically applies i.e. Substances for which medical surveillance is appropriate.

Asbestos Reference: The Control of Asbestos Regulations (2012) Statutory health surveillance for employees exposed to asbestos at a level requiring surveillance under the control of Asbestos at Work Regulations Non-statutory asbestos surveillance- surveillance appropriate to workers who are not currently exposed at levels requiring surveillance however may have been so in the past. Night Worker Assessment Reference: Working Time Regulations 1998 (Amended 2003) All employees who undertake a minimum 3-hours consecutive night work on a regular basis including shift work are offered a medical assessment of their fitness for night work This will be by annual recall in the format of voluntary questionnaire. Employees Exposed to Tuberculosis Reference: Control of Substances Hazardous to Health Regulations (2002) Yearly questionnaire and signs and symptoms summary sent to all employees exposed to TB during the execution of their duties Occupational Health Operational Policy, version 3, March 2016 Page 13 of 34

Skin Health Surveillance Reference: Control of Substances Hazardous to Health Regulations (2002) All employees identified by managers via COSHH risk assessment, as being at risk due to ‘wet work’ or chemicals will require work based periodic health surveillanceOccupational Health will offer support and advice to nominated persons 2.3.9 Noise Reference: Noise at Work Regulations (2005) Statutory health surveillance where required for the protection of workers hearing who are exposed to high levels of noise by the Noise at Work Regulations 2005. All employees in defined hearing protection zone or regularly exposed to an average exposure over 85 Dba Any employees regularly exposed to noise levels between 80 and 85 Dba identified at occupational health assessment as being susceptible to noise induced hearing loss 2.3.10 Ad-hoc Exposure Incidents When required, the Occupational Health Service will advise and coordinate regarding the health surveillance requirements following accidental and ad-hoc workplace exposure incidents. This will include the necessary clinical investigations and medical follow-up as deemed necessary and submission of comprehensive report to the Trust’s Risk Management and/or Governance Leads. 2.3.11 New and Expectant Mothers Reference: Management of Health and Safety at Work Regulations (1999)  Copies of all abnormal Pregnant Worker Risk Assessments should be forwarded to the Occupational Health Service  The Occupational Health Nurse will assess the risks identify and control measures implemented by the manager to determine if the women requires an Occupational Health assessment with the Consultant/Nurse  The Occupational Health Service will monitor pregnant women with significant pregnancy related illness that adversely affects her ability to undertake her job role  Occupational Health Consultant/Nurse will advise managers on any necessary adjustments/ restrictions or temporary redeployment for pregnant women or new mothers who cannot for health reason of either mother or baby undertake their entire substantive role 2.3.12 Workstation Assessment Reference: Health and Safety (Display Screen Equipment) Regulations (1992) Occupational Health Operational Policy, version 3, March 2016 Page 14 of 34

 Where musculoskeletal injury/harm may have occurred due to inappropriate workstation set-up the Occupational Health Nurse will assess the employee in their normal working environment to undertake an ergonomic /workstation assessment.  A report will be issued to the manager and employee detailing findings and recommendations.  Managers and employees are expected to implement any reasonable adjustments recommended on a Workstation Risk Assessment. 2.4 Control of infection All staff should report to the Occupational Health Service as soon as possible with any of the following symptoms:  Gastrointestinal symptoms/ vomiting and diarrhoea (Excess of two-day duration)  Persistent sore throats, coughs (Excess of two-week duration)  Sharps injuries (Within one-hour)  Exposure to any infected agent e.g. Meningitis, Measles, Mumps, TB (Tuberculosis) immediately. 2.4.1 Vaccination and Immunisation Reference:  Occupational Health Vaccination Policy  Public Health (Control of Disease) 1984 Act  Health and Social Care Act 2012 Immunity status is ascertained at pre-employment screening to ensure appropriate immunisations are offered according to the risk assessment of job role. All staff regardless of employment are advised (and have a requirement) to keep their immunisations contemporary. The immunity status of employees is also rechecked as they transfer between departments or units (appropriate to job role). The occupational vaccination programme consists of: Poliomyelitis A primary course or booster or booster is offered to all staff under the age of 45 years who have not received previous protection. Special consideration is given to staff of laboratories and post-mortem rooms that are handling samples and should be offered Poliomyelitis booster every10 years. Tetanus / Diphtheria A primary course or booster is offered on employment where there is no-evidence of previous immunization. Tuberculosis Additional reference: Occupational Health Tuberculosis Employment Policy Occupational Health Operational Policy, version 3, March 2016 Page 15 of 34

On commencement of employment immunity status of all staff is ascertained. Healthcare workers must have a scar or documented evidence indicative of BCG vaccination; any without will be required to undergo Tuberculin testing Staff exposed to occupational or community tuberculosis infection should be referred to the Occupational Health Department as tuberculosis contacts for follow-up Measles/Mumps and Rubella vaccine (MMR) Additional reference: Measles Mumps Rubella and Varicella Zoster procedure All healthcare workers (with patient-contact) without documented evidence of two MMR vaccinations or have not been previously screened for measles or rubella antibodies, and healthcare workers who are sero-negative to either measles or rubella will require mandatory MMR vaccination. Varicella (Chicken Pox) Additional reference: Measles Mumps Rubella and Varicella Zoster procedure History of varicella infection or varicella immunisation is required for all healthcare workers who are non-immune and have direct patient contact. Staff in high risk area (I.e. Maternity, oncology, children’s) without documented history of chicken pox infection / evidence of varicella IgG or documented evidence of varicella vaccination time two are required to have a blood test to check immunity Sero-negative or equivocal individuals are required to have immunisation according to MMR and varicella procedure. Hepatitis B/ Hepatitis A/B A course of 3 injections usually provides immunity. Staff are advised to attend the Occupational Health Department 8-weeks after the final vaccination to ascertain antibody levels, the result of which will determine follow-up, a once only booster is given after 5 years this is considered to cover the individual for life without the need for further routine testing. 2.5 Exposure Prone Procedures Reference:  Occupational Health HIV Employment Procedure  Occupational Health Hepatitis B and Hepatitis C Employment Procedure All new to the NHS staff that perform exposure prone procedures in the execution of their duties or staff transferring into posts that involve exposure prone procedures for the first time are required to undergo blood testing for Hepatitis B antibody Hepatitis C antibodies and new HIV 1 &2 antibody testing (Department of Health 2007 Guidelines) Any staff member found to be an infectious carrier of a blood borne virus will require further testing and will be prohibited from performing exposure prone procedures. Their case will be managed in accordance with relevant trust policy by the Consultant in Occupational Medicine. 2.5.1 Regulation Bodies Statement of Professional Responsibilities Regarding Blood Borne Viruses Occupational Health Operational Policy, version 3, March 2016 Page 16 of 34

Reference:  General Medical Council Gateway guidance 15.5; Health Clearance and Disclosure.  Nursing Midwifery Council Circular 10/2006) If members of staff have any reason to believe that they have been exposed to a serious communicable disease they should seek and follow professional /occupational health advice without delay on whether to undergo testing and if so, what testing is appropriate. If any employee acquires a serious communicable disease, they must seek and follow advice from the Occupational Health Service regarding modifications to professional practice or the need to contact previous or prospective employers. It is the professional duty of the individual to know their immunity status and protect individuals in their care this is achieved by cooperating with the occupational health service. This ensures that vaccination status is up to date. Medical/Dental and Nursing/Midwifery employees are referred to their respective professional body’s guidance in relation to exposure to blood borne viruses and exposure prone procedures. Occupational Health staff will work collaboratively with Trust managers to encourage good practice in accordance with current/future guidelines and legislation. 2.5 Sharps Injury and Body Fluid Exposure Incidents Reference: Sharps, Needlestick and Body Fluid Exposure Management Policy and Procedure All sharps injuries should be reported to the OH Service as soon as is reasonably practicable after the event. Any sharps injury that results in administration of post exposure chemoprophylaxis should be reported under Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (2013) RIDDOR Any sharps injury from a blood borne virus positive patient where there exists risk of seroconversion must be reported to the Health and Safety Manager and via them to the Health and Safety Executive under RIDDOR Sharps injuries including bites and scratches that result in inoculation of blood must be considered a potential emergency and the recipient must seek advice immediately from either Occupational Health and outside of Occupational Health operational hours the Emergency Department.

2.7

Other Service Interventions

Clinical Services Cheshire Occupational Health Service offers a very limited clinic service which in no way is it intended as an alternative to a GP service or the Emergency Department. First aid facility is not a provision of the Occupational Health service and anyone who has an injury at work that requires treatment should attend the Emergency Department initially ensuring Occupational Health are informed of any treatment or advice as it may affect ability to work. Occupational Health Operational Policy, version 3, March 2016 Page 17 of 34

The Occupational Health Consultant/Nurse can make referral into physiotherapy, chiropody/podiatry, psychotherapy, and specialist drug and alcohol service directly following Occupational Health assessment. Prevention of Accidents and Accident reporting Every member of staff, visitor or contractor who sustains an accident, injury or near miss must complete an incident form. This notifies the employer that an incident has occurred and should be sent to the manager whose responsibility it is to investigate to prevent a similar occurrence happening again. All completed incident forms involving staff are copied to the Occupational Health Service. Incident forms are retained in the Occupational Health records of the employee for a period of between ten and forty years depending on the nature and the cause of the accident.  Fractures of any bone other than to the hand or foot.  Amputation of hand, foot, finger, thumb or toe.  The loss of sight of an eye; a penetrating injury to the eye or a chemical or hot metal burn to an eye.  Burns requiring immediate treatment or loss of consciousness resulting from an electric shock.  Loss of consciousness resulting from lack of oxygen.  Acute illness or loss of consciousness resulting from inhalation, absorption or ingestion of a substance  Acute illness requiring medical treatment where there is suspicion that it resulted from exposure to a pathogen or infected material.  Any injury that results in the person being admitted immediately to Hospital for more than Twenty-Four hours. The Occupational Health Service will assist the Operational Managers and the Risk Management team in the investigation and follow-up of incidents involving members of staff. Occupational Health is obliged to follow up sharps injuries, muscular skeletal Injuries and assault and/or bodily injury. This is in no way to be considered exhaustive, individual incidents will be assessed to determine whether Occupational Health follow up is necessary Additional reporting requirements:  

Back injury pain and handling injuries. Preferably before the member of staff leaves the premises. Prolonged exposure to noise, dust, fumes, chemicals and micro organisms.

Health Improvement and Wellbeing The Occupational Health Service provides an expanding programme of health promotion activities and can advise and refer on to third parties regarding health issues. The Occupational Health Service has facilities for the random checking of body mass index, blood sugar and diabetes risk assessment; these services are intended to compliment interventions employees are already receiving. The health improvement and wellbeing activities of the Occupational Health Service are integral to the Trust’s overall Wellbeing Agenda. Occupational Health Operational Policy, version 3, March 2016 Page 18 of 34

2.8. Complaints Management A record of all such complaints will be maintained and will be included in an exception report additional to the monthly/quarterly reporting. Where a complaint is received pertinent to OH services, or implied lack of service, the complaint will be recorded and will be subsequently investigated by the Service Manager. Where a complaint is received pertinent to OH clinical service, the complaint will be recorded and will be subsequently investigated by the Clinical Lead Nurse or Consultant in Occupational Medicine. The decision on investigating officer is dependent on the complexity of the complaint. All OH staff deemed appropriate to do so will be required to give assistance in the investigation of complaints. The investigating officer will provide a written response to the complainant no later than 28 days from the date of receipt. Where due to extenuating circumstances this is not possible an interim progress report will be issued to the complainant. All complaints regarding OH service and clinical service should be directed to the Occupational Health Service Manager 2.9. Untoward Incident Management Relevant Legislation:  Infectious Diseases 1988 Act  Public Health (Control of Diseases) 1984 Act. The Occupational Health Service will manage the employee aspects and coordinate the Trust’s response to any significant untoward incidents involving staff, this includes: Pandemic Influenza i.e. antiviral distribution, mass vaccination Infectious outbreaks i.e. contact tracing, liaison with the Health Protection Agency, Primary Care Trusts and hospital Infection Prevention and Control Services Notifiable Diseases: The Occupational Health Service will ensure the Trust meets its statutory duty to appropriately report certain notify Health Protection England of certain infectious diseases (e.g. Tuberculosis, Measles, Whooping Cough, and Malaria) and will cooperate with directives received from the Health Protection England. In accordance with the Supporting Staff involved in Traumatic Incidents Policy the Occupational Health Service will offer support to all identified staff that maybe experiencing work associated stress or anxiety due to:     

Being involved in bullying and harassment, Assault at work, Suspension from duty, Called as witness at Coroner’s, Magistrate’s or Crown Court Trust response to national emergencies, disasters, acts of terrorism

2.10. Annual Seasonal Influenza Vaccination The Occupational Health Service will assist with the planning, coordination and implementation of the annual campaign of immunization against influenza for all Trust frontline healthcare workers. This will include: Occupational Health Operational Policy, version 3, March 2016 Page 19 of 34

     

3

Procurement of sufficient vaccine to achieve Trust agreed vaccination targets. Publicity campaigns with the assistance of the Trust’s Communications Lead. Local, regional and national reporting on vaccination uptake Provision of ‘drop-in’ clinics and satellite clinics in the workplace Targeted delivery for business-critical services Training for additional volunteer vaccinators form the clinical divisions/business units

Definitions  Occupational Health: is a cross-disciplinary service concerned with protecting the safety, health and welfare of people engaged in work or employment. The goal of all occupational health programmes is to foster a safe work environment.  Health Surveillance: systematic collection, analysis, and interpretation of health data about a potential health hazard specific to work activity that has a significant impact on public health. Used in situations where the control measures are insufficient to satisfactorily control potential risk to health.  Health Promotion: the process of enabling people to increase control over their health and its determinants, and thereby improve their health through public health projects.  Ill-health Performance: the effect that an individuals health/ill-health has on their functional capability to undertake their identified job role.  Occupational Vaccination Programme: is the administration of antigenic material (the vaccine) to produce immunity to infection caused by a pathogen that an employee may come into contact with during the execution of their employment duties or one which they may contract and pass-on to immunocompromised patients. Similar to all vaccination programmes it is concerned with the wider public health issues as well as individual protection. Vaccines can prevent or ameliorate the effects of infection by the pathogen.  Exposure Prone Procedures: Exposure prone procedures are those invasive procedures where there is a risk that injury to the healthcare worker may result in the exposure of the patient's open tissues to the blood of the healthcare worker (bleed-back). These include procedures where the healthcare worker's gloved hands may be in contact with sharp instruments, needle tips or sharp tissues (e.g. spicules of bone or teeth) inside a patient's open body cavity, wound or confined anatomical space where the hands or fingertips may not be completely visible at all times.  Occupational Health Patient Administration System (OPAS): Bespoke OH administration system, for the management of OH clinical service delivery, storage of electronic patient data, data collection and analysis.  NHS Health at Work: as part of the Government's Health, Work and Wellbeing Strategy, seeks to promote the benefits of good health at work and helps build healthy and productive workforces. It provides a framework within which NHS Occupational Health Services should function, setting standards of practice and enables OH services to influence the health and wellbeing of the wider community by setting the standards by which they can provide services to small and medium sized employers outside of normal NHS operating standards. 3.1 Policy

Occupational Health Operational Policy, version 3, March 2016 Page 20 of 34

‘A policy is a statement of Trust intent for a given issue and gives a clear position statement for the Trust’s customers and employees on its values and beliefs’ (Parsley & Corrigan 1999). A policy is a “must do”; there should be no deviation from the actions as defined in the policy. Any deviation must be discussed and approved by the Strategic Integrated Governance Committee. 3.2 Guideline A guideline is an overview of processes either clinical or non-clinical, to be undertaken in certain conditions. A guideline gives practical guidance as to how to deliver best practice but allows for professional initiative and informed decision making. Any deviation from a Trust guidance document, along with the reasons why, must be documented in the Health Records.

3.3 Clinical Pathway / Standard Operating Procedure (SOP) A Clinical Pathway / SOP is a working document detailing the current agreed working practice that takes account of all the areas that are applicable to the management of a process in an individual setting 4

Associated Documents

In Accordance with: o o

Department of Health 2006: Green Book, Immunisation Against Infectious Disease (Partial update 2009) Department of Health 2009: NHS 2010 - 2015: from Good to Great. Preventative, People-Centered, Productive (Chapter 3 The Deal for NHS Staff) Integrated Governance Handbook 2006 NHS Employers 2007: The Healthy Workplace Handbook NHS Employers 2008: Occupational Health and Safety Standards (section C) NHS Plus Operating Standards 2002 SEQOHS Standards 2015

o o o o o o Relevant Legislation: o o o o o o o o o o o o o o o o o o o o

Access to Health Records Act (1990) Access to Medical Reports Act (1988) Control of Substances Hazardous to Health Regulations 2002 (COSHH) Data Protection Act (1998) Equality Act (2010) Health and Safety(Display Screen Equipment) Regulations (1992) Health and Safety at Work Etc. Act (1974) Health Act 2006 (Code of Practice for the Prevention and Control of Healthcare Associated Infections) Infectious Diseases Act (1988) Management of Health and Safety at Work (Amendment) Regulations (1999) Noise at Work Regulations (amended) 2005 Provision and Safety of Work Equipment Regulations 1998 Public Health (Control of Disease) Act 1984 Reporting of Injuries and Dangerous Occurrences Regulations (2013) Safety Representatives and Safety Committees Regulations 1977 The Control of Asbestos Regulations (2012) The Human Medicines Regulations (2012) The Working Times Regulations 1998 (Amended 2003) Transport and Works Act (1992)

Occupational Health Operational Policy, version 3, March 2016 Page 21 of 34

Related Polices and Procedures: o o o o o o o o o o o o o o o o o o o o

Mid Cheshire Hospitals Foundation Trust Attendance Policy East Cheshire Trust Attendance Policy Occupational Health : Vaccination Policy Occupational Health :Hepatitis Employment Policy Occupational Health : HIV Employment Policy Occupational Health : Tuberculosis Employment Policy Occupational Health : Measles, Mumps, Rubella and Varicella Policy Occupational Health : Health Promotion Procedure Occupational Health : Health Surveillance Procedure Occupational Health : Consent Procedure Occupational Health : Confidentiality Agreement. Sharps Injury and Body Fluid Exposure Policy and Procedure Occupational Health Service Dermatology Policy MCHFT/ECT Outbreak Policies MCHFT/ECT Infection Control Policies MCHFT/ECT COSHH Policy MCHFT/ECT Expectant and New Mothers Policy MCHFT/ECT Display Screen Equipment Policy MCHFT/ECT Control of Latex Policy MCHFT/ECT Information Governance Policies

4

Duties

The Service Manager for Cheshire Occupational Health Service has delegated responsibility for assurance of quality of service delivery; this is presented in monthly, quarterly and annual performance against standard key performance indictors regarding service access and response times to the each partner or customer Trust’s Performance Committee The Clinical Lead Nurse for Occupational Health has responsibility for assurance of the standard of clinical service delivery; compliance is demonstrated via participation in department, Trust, regional and national audit. Any pertinent results from audit will result in action plans and necessary changes to practice with subsequent review of this policy. The consistent quality and strategic direction of the Cheshire Occupational Health Service is determined and monitored by the Occupational Health Steering Group chaired by the Chief Executive for Mid Cheshire Hospitals NHS Foundation Trust . Complaints received by the Cheshire Occupational Health Service regarding the quality or standard of service delivery or clinical practice will initially be measured against this policy and will if necessary result in review of policy content. 5.1

Duties within the Organisation Chief Executive: o The ultimate responsibility for Health and Safety lies with each individual Trust’s Chief Executive; who must ensure that all parts of the organisation have a suitable Health and Safety policy and that its implementation is monitored regularly to ensure its effectiveness. o Chairman of the Cheshire Occupational Health Steering Group (MCHFT only) o o

Director of Human Resources and Organisational Development: Has Trust board level responsibility and accountability for the Occupational Health Service. Provides assurance to the Trust that the Occupational Health Service is achieving its operational targets and is compliant with relevant legislation.

Occupational Health Operational Policy, version 3, March 2016 Page 22 of 34

o

o

o o o o o o o o

o

o o o o o

o o o o o

Medical Director: Provide clinical leadership to the Consultant in Occupational Medicine (The Consultant in Occupational Medicine is clinically and professionally accountable to the Medical Director) Director of Nursing and Quality: Provide clinical leadership to the Clinical Lead Nurse for Occupational Health. (The Clinical Lead Nurse for Occupational Health is clinically and professionally accountable to the Director of Nursing) Service Manager for Cheshire Occupational Health Service: To ensure implementation of this policy and provide assurance to the organisations re: standards of practice Ensure provision of a comprehensive and effective Occupational Health Service Integral to the management of the organisation. Work collaboratively with directorate and operational managers to achieve their responsibilities under this policy Ensure the OH Service works within the guidance of law as stipulated in relevant acts of parliament and Department of Health directives. To provide an equitable service to all employees regardless of where they work; their employment or their working patterns. Ensure provision of a comprehensive OH Service that meets the minimum service standards set out in latest Department of Health, NHS Employers and NHS Health at Work guidance. Ensure provision of services to outside of the organisation, to other employers does not impact adversely on the quality of service to NHS staff within the organisation. . Provide assurance to the organisations that the service is meeting its obligations under the terms of the service level agreements (SLA) and provides monthly/quarterly performance reports against agreed key performance indicators (KPI) Analysis of the OH data to ensure the OH Service is proactive in its response to each organisations need. Consultant in Occupational Medicine: Provide comprehensive Occupational Health advice to both the individual employee and the wider organisations. Provide specialist support, guidance and advice to the OH senior nursing team. Assists the OH Clinical Lead Nurse in ensuring comprehensive, robust clinical governance. Advise the organisations regarding ill-health retirement application Provide specialist advice to the organisations regarding interpretation of relevant legislation, e.g. Equality Act 2010 Control of Substances Hazardous to Health Regulations 2002 (COSHH), Reporting of Incidents and Dangerous Occurrences Regulations 2013 (RIDDOR). Clinical Lead Nurse for Occupational Health Ensure implementation and interpretation of this policy and associated procedure within the OH Service and the wider organisation. Ensure comprehensive governance is embedded in clinical practice. Ensure arrangements exist to demonstrate OH Service compliance with local and national guidelines with reference to health and safety, infection control and immunisation and provide assurance to relevant committees on a regular basis Ensure a competent and confidential service is provided to all service users. Work collaboratively with partnership organisations at a local level in the development of Occupational Health policies and procedures in response to changes in local and national policy.

Occupational Health Operational Policy, version 3, March 2016 Page 23 of 34

o o

Provide specialist advice to the organisations regarding interpretation of Relevant legislation, e.g. Equality Act 2010, COSH.H, RIDDOR Ensure the Occupational Health Service meets its obligations regarding National Health Service Litigation Authority Risk Management Standards for Acute Trusts and Primary Care Trusts (NHSLA) and the Care Quality Commission (CQC) standards for registration

Occupational Health Specialist Practitioners/Advisors/Nurses: Fully understand the implications of this policy Ensure provision of a quality OH Service via implementation of this policy and related policies and procedures. o Support the OH Clinical Lead Nurse in offering assurance to the organisation through comprehensive clinical governance. o Provide advice to the wider organisation i.e. Human Resources and Trust managers thus enabling them to understand their duties under this policy o o

o o o o o o o

o

Trust Operational Managers: (With the aid of Occupational Health) Ensure that Occupational Health related policies are available to all employees within the Trust. Ensure that all employees have access to and are aware of the confidential Occupational Health Service. Ensure all relevant candidates for employment completed Occupational Health Screening prior to commencement of employment as part of the formal recruitment process. Ensure employees are referred following periods of sickness absence when the staff member ‘triggers’ under each organisations Management of Attendance Policy. Ensure employees are referred when work may be a contributing factor to the individuals’ ill health or for work performance related issues that may be contributed to/exacerbated by ill health. Will complete (in-full) the standardised occupational health management referral template providing a full description of any health, employment or performance issues. Will deal promptly and effectively with employees who fail to attend for planned appointments. Ensuring that they have discussed the employee’s non-attendance with the employee and gained the employees assurance that they will attend any future occupational health appointments prior to any further appointment being made. Considering service demand will endeavour to instigate Occupational Health recommendations. I.e. rehabilitation plans, risk assessments, adjustment/restriction to duties either temporary or permanent.

Health and Safety Leads: In collaboration with Operational Management colleagues assess and manage risks to health caused by the working environment, according to the Health and Safety at Work Regulations 1999, reporting any anomalies that affect staff to Occupational Health. o With the aid of the Operational Manager and recent COSHH risk assessments determine the risk to health from microbiological and chemical hazards aiming to prevent or control exposure, reporting any anomalies to Occupational Health o Inform Occupational Health of any risks identified; to enable OH to monitor exposure where requisite and institute health surveillance and or prophylactic measures as required. o

o

Employees: Be aware of purpose of the Occupational Health Service.

Occupational Health Operational Policy, version 3, March 2016 Page 24 of 34

o o o o

o o o o o

6

To attend appointments with the Occupational Health department when requested to do so by their manager To inform the Occupational Health Service of any changes in their health that may affect their work. Cooperate with occupational vaccination programmes/health surveillance Be aware of their individual responsibilities under the Health and Safety at Work Act 1974 by attendance at Statutory and Mandatory training. Human Resources: Ensure timely and accurate workforce information is available to ensure the strategic direction of the Occupational Health Service reflects the needs of the organisations Work collaboratively with Occupational Health in the delivery of a comprehensive health and wellbeing and attendance management agendas. Support Occupational Health to achieve its objectives regarding the health and wellbeing and attendance management agendas. Work collaboratively with Occupational Health and line-managers in the management of complex ill-health issues. Ensure Occupational Health is represented at board level via the Director of Workforce and Service Transformation at Mid Cheshire Hospitals Foundation Trust and the Director of Human Resources and Organisational Development at East Cheshire NHS Trust. Consultation and Communication with Stakeholders

This policy has been developed for the Cheshire Occupational Health Service (A shared service between Mid Cheshire Hospitals Foundation Trust and East Cheshire NHS Trust) the policy sets out the standards by which the service will operate and the framework against which service provision can be audited. It was initially approved in November 2009 by the Joint Communication and Negotiation Committee at Mid Cheshire Hospitals NHS Foundation Trust. Feedback was received form staff-side representatives, HR and Infection Prevention and Control at both partner Trusts following three yearly review and incorporated into version 2 and subsequent versions of this document. Consultation and approval has involved the following Committees//Groups and individuals: Workforce Governance Committee-MCHFT Joint Consultation and Negotiation Committee (information) Cheshire Occupational Health Service Steering Group Lead Nurse Infection Prevention and Control East Cheshire NHS Trust Associate Director of Infection Prevention and Control at Mid Cheshire Hospitals Foundation Trust Consultant in Occupational Medicine for Cheshire Occupational Health Services HR Business Partner Teams: East Cheshire NHS Trust, Director of Workforce and Organisational Development (MCHFT) Divisional HR Managers (MCHFT) Associate Directors of Business Units (ECT) Divisional General Managers (MCHFT) Staff-side representatives MCHFT and ECT [email protected]

Author of the document: Clinical Lead Nurse for Occupational Health 7 Implementation Implementation of this policy is a mandatory requirement of all Cheshire Occupational Health Service staff. (Clinical and non-clinical as appropriate) Occupational Health Operational Policy, version 3, March 2016 Page 25 of 34

Directors, managers and employees of the Trust and partner organisations must co-operate with Cheshire Occupational Health Service in the implementation of this policy, in-order to maintain a safe working environment for employees, patients and visitors. Implementation of this policy is required to ensure that the Occupational Health Service and the Trust meet their collective obligations under Health and Safety legislation and applicable domestic and European law therefore reducing the chances of tribunal or legal proceedings. Implementation of this policy and associated Occupational Health policies and procedures should ensure essential functions of the Occupational Health Service are achieved. Therefore successfully meeting NHS Employers, NHS Health at Work, SEQOHS, NHSLA and CQC requirements. This policy and procedure will be available on each Trust’s intranet and senior staff and managers will be alerted by the Trust’s communication processes when new policies are issued or existing polices are update and reissued. Due to the advisory and supportive function of the Cheshire Occupational Health Service the implementation of its policies, procedures and protocols is an on-going and consistent process. 8 Education and Training All Occupational Health Staff are to adhere to this policy and carry out their responsibilities under it in order to achieve the objectives outlined in section 2 of this document. All staff will undertake mandatory and specialised training for on-going personal development. Training needs will be identified through annual training needs analysis. The Clinical Lead Nurse for Cheshire Occupational Health Service will communicate changes in practice to all Occupational Health clinical staff through monthly clinical meetings or more frequently if urgency dictates. Training for Trust staff in the application of this policy will be delivered in the following ways: o o o

Ad-hoc Clinical Updates: covering strategic and clinical aspects of Occupational Health, including national initiatives, National Institute for Clinical Excellence standards, Care Quality Commission requirements. Induction: all new starters to the Trust are made aware of the functions of the Cheshire Occupational Health Service at induction by way of PowerPoint presentation and will be aware of this policy and their duties under it. On Request: specific topics can be covered for both specialist and general areas. E.g. sickness absence management, workstation ergonomic, vaccination training for influenza campaigns etc.

Specific training to assist the Occupational Health staff in the execution of this policy is delivered in the following ways: o

o

Accredited Courses: All Cheshire Occupational Health Service medical and nursing staff requires current registration with their respective governing bodies (NMC/GMC). The consultant and senior nursing staff also hold additional specialist qualifications in the speciality. Practical Updates: covering the practical application of policies and procedures and good Occupational Health delivery. Including immunisation training/update; resuscitation and anaphylaxis management, Mantoux training and delivery, management of sharps injury etc. Training will be both structured at recognised time intervals and ad hoc when required.

Occupational Health Operational Policy, version 3, March 2016 Page 26 of 34

o o

Yearly Training Needs Analysis: A yearly training plan is completed according to training needs identified via appraisal according to the KSF framework for the entire OH Service staff. Continuing Professional Development: Occupational Health Nursing staff will keep their training/development up-to-date as appropriate to satisfy the Nursing and Midwifery Council’s requirements for Revalidation in order to:  Support clients and colleagues  Enhance care  Develop clinical practice  Reduce risk  Develop personally through education.

9 Monitoring and Review This policy and associated occupational health policies and procedures will be reviewed on a three-year basis. Additional amendments will be made in conjunction with changes in Trust direction and domestic and European laws. Compliance with this policy will be measured primarily by demonstrated assurance with applicable, Safe, SEQOHS, NHSLA, NICE, and Health and Safety Executive standards and production of evidence for Care Quality Commission registration. Any failure to offer assurance to these standards will result in review of this policy and procedure. The Director of Service Transformation and Workforce has overall responsibility and accountability for ensuring that Cheshire Occupational Health Service is compliant with this policy and associated guidance and legislation and offers assurance to the Trust and affiliated organisations. The Occupational Health Service will undertake the following yearly audits which demonstrate compliance with aspects of this and associated OH policies: Monitoring and Audit Standard/process/issue required to be monitored

Process for monitoring e.g. audit

Responsible individual /group

Frequency of monitoring

Responsible committee

OH reports to managers

Audit

Occupational Health

Annual

Workforce governance

support offered to staff experiencing psychological problems

audit

Occupational Health

Annual

Workforce governance

Occupational Health Operational Policy, version 3, March 2016 Page 27 of 34

Accidental inoculation incident management

audit

Occupational Health

Annual

Workforce governance

Influenza vaccination target

Report (Nationally)

Occupational Health

Annual

Workforce governance

Performance against key performance indicators

audit

Occupational health

Monthly/qua OH steering rterly group/Perfor mance

9.1 Audit Proforma The MCHFT Audit proforma must be used to demonstrate effective monitoring and implementation of planned actions. This can be found on the intranet in frequently used forms/clinical audit. 10 1. 2. 3. 4. 5. 6. 7.

References / Bibliography Access to Health Records Act [1990] Department of Health Access to Medical Reports Act [1988] Department of Health Data Protection Act [1998] HMSO Disability Discrimination Act [1995 amended 2005] London, HMSO Equality Act 2010, London, HMSO Dermatitis Policy [2009] Occupational Health Department, MCHFT Department of Health ‘Green Book’ [2006] Immunisation against infectious Disease, London, DOH 8. Health Act [2006] Code of Practice for the prevention and Control of healthcare associated infections, DOH. 9. Health and Safety at work Act [1974] HSE 10. Health and Safety at Work Act [1999] Amendment Regulations, HSE. 11. Department of Health: Integrated Governance Handbook [2006] HMSO 12. NHS Employers [2007] Healthy Workplace Handbook. HMSO 13. NHS Employers [2008] Occupational Health and Safety Standards (sec C) HMSO 14. NHS Plus Operating Standards [2002] HMSO 15. Noise at Work Regulations (amended) [2005] HSE 16. Provision and Safety of work equipment Regulations [1998] HSE 17. Race Relations Act (amended) [2003] HMSO 18. Reporting of Injuries, diseases and dangerous occurrences Regulations [1995] HSE 18. Safety Representatives and Safety Committee Regulations [1977] HSE 19. Sex Discrimination Act [1975] HMSO Occupational Health Operational Policy, version 3, March 2016 Page 28 of 34

20. Tuberculosis Employment Policy [2009] Occupational Health, MCHFT. 21. The Working Time Regulations [1998] (amended 2003), HSE. 22. Department of Health [2009] Working for a Healthier Tomorrow, Dame Carol Black. HMSO 23. Department of Health NHS [2009]’ Health and Wellbeing Review’. Dr Steve Boorman. HMSO 24. Infectious Diseases [1988] Act. HMSO 25. Public Health (Control of Diseases) [1984] Act. HMSO 26. Department of Health [2009]: NHS 2010 - 2015: from Good to Great. Preventative, People-centered, Productive. HMSO 27. Health and Safety Executive Management Standards [2007] Work Related Stress. HSE 28. Health and Safety Executives Management Guidelines on Sickness Absence Management (On-line toolkit supported by Chartered Institute of Personnel Development CIPD and ACAS) 29. ACAS [2009], Health, Work and Wellbeing Booklet. ACAS 30. The Transport and Works [1992] Act. HMSO 31. The Clothier Report. [1994] HMSO 11

Appendices All Appendices must be in numerical order 1, 2, and 3 etc. and positioned before the mandatory appendices below. A B C

Version Control Document Communication / Training plan Equality Impact and Assessment Tool

Occupational Health Operational Policy, version 3, March 2016 Page 29 of 34

APPENIDX A - Control Sheet This must be completed and form part of the document appendices each time the document is updated and approved. VERSION CONTROL SHEET Date dd/mm/yy 31/12/09

Version 1

04.09.12

2

27.01.16

3

Author Clinical Lead for Occupational Health Clinical Lead Nurse for Occupational

Clinical Lead Nurse for Occupational

Reason for changes New version 3 year review Changes in accordance to Equality Act 2010 Minor grammatical and format changes Minor grammatical and formatting changes throughout the document Update on legislation changes e.g. RIDDOR (2013), Human Medicines Regulations (2012) Control of Asbestos Regulations (2012)

Occupational Health Operational Policy, version 3, March 2016 Page 30 of 34

APPENDIX B - Training needs analysis Communication/Training Plan (for all new / reviewed documents) Goal/purpose of the communication/training plan

Target groups for the communication/training plan Target numbers Methodology – how will the communication or training be carried out?

To ensure that all Occupational Health Staff, employees and Trust managers are aware of the services delivered by Occupational Health and their individual responsibilities All Occupational Health staff, Trust Managers, and employees of MCHFT/ECT Trust wide Policy to be available on the Trust Intranet. Trust intranet site news item.

Communication/training delivery Funding

NONE None required

Measurement of success. Learning outcomes and/or objectives Review effectiveness – learning outputs Issue date of Document

Ensure compliance with the policy by audit

Start and completion date of communication/training plan Support from Learning & Development Services

March 2016

Regular review of document March 2016

None

For assistance in completing the Communication / Training Plan please contact the MCHT Learning and Development Services

Occupational Health Operational Policy, version 3, March 2016 Page 31 of 34

APPENDIX C - Form 1 Equality Impact Screening Assessment Please read the Guide to Equality Impact Assessment before completing this form. To be completed and form part of the policy or other document appendices when submitted to [email protected] for consideration and approval or to be completed and form part of the appendices for proposals/business cases to amend, introduce or discontinue services. POLICY/DOCUMENT/SERVICE: Occupational Health Operational Policy Yes/ No A

Justification and Data Sources

Does the document, proposal or service affect one group less or more favourably than another on the basis of: This policy and procedure is applied fairly and equitably there is no evidence of discrimination on the grounds of race or ethnicity.

1

Race, ethnic origins (including gypsies and travellers) or nationality

no

Translation services are available for employees for whom English is not a first language. Adjustments will be made as necessary for overseas employees who cannot attend prior to appointment on a case-by-case basis. Currently the position of Consultant in Occupational Medicine is filled by a male. Physical examination of female employees would only be undertaken when necessary and with appropriate chaperone.

2

Sex

no

Any female employee who would feel more comfortable with a female would be seen by a female OH Practitioner, under the direction of the OH Consultant. Circumstances where the employee must be seen by a physician will be dealt with on a case-by-case basis as the need arouse. E.g. referral to external OH providers.

3

Transgender

no

Transgender has no influence on application of this policy; should any change in procedure have different implications on the basis of biological gender then this would be explained on a case-by-case basis.

4

Pregnancy or maternity

no

Expectant or breastfeeding mothers will be required undergo risk assessment of workplace hazards; this would be considered a positive impact

5

Marriage or civil partnership

no

No identified impact

Occupational Health Operational Policy, version 3, March 2016 Page 32 of 34

6

Sexual orientation including lesbian, gay and bisexual people

no

Sexuality has no influence regarding application of this policy. LGBT keyworkers/networks are available for tertiary referral for specific issues as required.

7

Religion or belief

no

Specific religious needs or beliefs will be accommodated as and when the need arises. E.g. Ramadan, Shabbat Employee’s fitness for employment is assessed on the grounds of functional capability alone regardless of age.

8

Employees under the age of 18-years require a Young Person Risk Assessment to be completed to ensure the health, safety and security of children in the workplace. As the Trust could be considered In loco parentis.

Age

Employee’s fitness for employment is assessed on the grounds of functional capability alone regardless of disability or diagnosis.

9

Disability - learning disabilities, physical disability, sensory impairment and mental health problems

The terms of the DDA1995/Equality Act 2010 are applicable to all OH activities. no

Under the Clothier Report 1994 recommendations perspective healthcare workers with psychiatric history within 2-years of application of employment will be required to attend for OH assessment. Communication in British sign language can be made available if necessary. Services provided to staff are free of charge and delivered at Macclesfield DGH and Leighton Hospital sites. Parking charges are applicable at both sites for all visitors to the Trusts regardless of socioeconomic background.

10

Economic/social background

no

Current staff on 1/2 or zero pay can apply for exemption from parking fees etc. Staff on 1/2 or zero pay can apply for tax credit for assistance with travel costs through the Department of Works and Pensions. Staff on 1/2 or zero pay due to industrial in jury can apply for temporary or permanent injury allowance.

B

Human Rights – are there any issues which may affect human rights

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1

Right to Life

no

No impact

2

Freedom from Degrading Treatment

no

No impact

3

Right to Privacy or Family Life

no

No impact

4

Other Human Rights (see guidance note)

no

No impact

NOTES If you have identified a potential discriminatory impact of this document, proposal or service, please complete form 2 or 3 as appropriate. th

Date: 27 January 2016 Name: Keith Williamson

Signature:

Job Title: Lead Nurse Occupational Health

Date: 15.02.2013 Name: Bobby Sharma Signature: ……………………………

Job Title: Service Manager

Occupational Health Operational Policy, version 3, March 2016 Page 34 of 34