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From: Chemical Hazards Handbook Section: 3 The legal framework - Control of Substances Hazardous to Health (COSHH) Regulations - Regulation 11: Health surveillanceThe ACoP says, "Where it is appropriate for the protection of the health of his employees who are, or are liable to be, exposed to a substance hazardous to health, the employer shall ensure that such employees are under suitable health surveillance." Surveillance is required for workers exposed to vinyl chloride monomer, nitro or amino derivatives of phenol or benzene, potassium or sodium chromate or dichromate, o-toluidine, dianisidine and dichlorobenzidine and their salts, auramine, magenta, carbon disulphide, disulphur dichloride, benzene (including benzol), carbon tetrachloride, trichloroethylene, and pitch. Health surveillance is also required where "an identifiable disease or adverse health effect may be related to the exposure." This would apply, for instance, to workers like Violette Hutchins who are exposed to fume from colophony-based solder flux. Surveillance can include clinical examinations, or testing body fluids or exhaled air. Employers must allow employees access to their health records. EH40 contains a handful of biological monitoring guidance values (BMGV), including BMGVs for lindane and MbOCA. These are not statutory, and are published for guidance only. Even if they are being met, this does not mean an employer need do nothing more to reduce exposure, but if they are exceeded it does mean employers should investigate the controls they are using. Just because a substance does not have a BMGV in EH40, does not mean an employer need not do any biological monitoring. The BMGVs are not an alternative to, or replacement for, occupational exposure limits.
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