Occupational Health and Safety Act, 1993 (Act No. 85 of 1993)

Regulations

Regulations for Hazardous Chemical Agents, 2020

Annexures

Annexure 3 : Hazardous Chemical Agent Guidelines

Guidance on medical surveillance and biological monitoring

Medical surveillance

Medical surveillance and biological monitoring

Purchase

Biological monitoring is discussed in detail in paragraph 23. It is often incorrectly categorised as a type of medical surveillance. Biological monitoring provides an additional means to assess the exposure to an HCA by measuring metabolites of the HCA, or other similar markers of exposure. Therefore, it does not represent an adverse effect or an occupational disease – it only reflects exposure. A positive finding during biological monitoring does not necessarily mean that there has been a breach of the safety standard, but is a positive indication of employee exposure.

The distinction between early biological effects and established disease is not always clear, there tends to be a severity gradient in which one blends into the other. An occupational disease may be said to be present when the adverse biological effect progresses to clinically detectable organ damage requiring treatment or permanent impaired function. The categorisation of the condition is, therefore, sometimes at the discretion of the responsible medical practitioner. The distinction becomes important when considering a case for statutory reporting. As described in paragraphs 20, 21 and 22, where reporting of cases of established occupational disease is legally prescribed.

9.	The presence of chemical agents in the workplace does not automatically infer the need for medical surveillance; certain criteria must be met for medical surveillance to be warranted. This principle is addressed in subregulation 7(1)(b) and is further elaborated in paragraphs 11, 12 and 13.

10.

Work-related adverse health findings, identified by medical surveillance, not only affect the individual employee’s management in the workplace but may also have important implications regarding the effectiveness of exposure control measures in the workplace and warrant further steps by the employer.

11.	Medical surveillance must be provided if an employee is using, handling, generating or storing an HCA that is known to cause adverse health effects, and—

(a)	the level of exposure is such that an occupational disease or adverse effect may reasonably be expected to occur, and

(b)	valid medical testing techniques are available to detect the adverse effect on the employee’s health.

12.

This means the employer must ensure that a health risk assessment is conducted to determine the likelihood of exposure to an HCA, in conjunction with the known health effects of the HCA, which the occupational medicine practitioner can use to decide if a programme of medical surveillance is necessary. Test selection should consider relevant target organs and test performance as referred to in paragraph 14(b).

13.	Additionally, medical surveillance should be provided if, in the opinion of an occupational medicine practitioner, it is necessary, notwithstanding the above criteria are not met.