In brief
Individual examination results show a worker’s fitness for work; when the same results are brought together by unit and job, they show whether the measures are working. The Regulation on Risk Assessment lists health surveillance results among the reasons for renewing the assessment, and the workplace physician is tasked with evaluating the results and contributing to the risk assessment. In doing so, data are processed without identifying details, in sufficiently large groups and under the physician’s responsibility.
From the examination to the overall picture: why analyse?
At a metalworking plant, periodic audiometry results are assessed one by one each year, “fit for work” is written for each worker and the files are closed. No one notices that three of the twenty-four people on the press line showed a new notch in the 4000 Hz region in the same year, because the results have never been put side by side. Analysing health surveillance results means stepping out of the individual examination and asking: “what is happening in this unit?”
Individual and aggregate assessments answer different questions:
- Individual: Can this worker do this job, is a restriction needed, is there a suspected occupational disease?
- Aggregate: Are the existing measures in this unit adequate, is exposure increasing, is a measurement or a new measure needed?
The aggregate view also shows something workplace measurements can miss: a measurement is a snapshot of one day, whereas health data are the accumulation of years.
The physician’s contribution to the risk assessment: what does the legislation require?
Read together, these three provisions make the path clear: information should flow from health data to the risk assessment, but not as information about individuals, rather as de-identified and grouped findings. The physician’s contribution to the risk assessment is precisely this transformation.
Where do aggregate health data come from?
Aggregate health data do not consist only of periodic examination forms. Include the following sources in the analysis:
| Source | What can it tell you? | Points to note in interpretation |
|---|---|---|
| Pre-employment and periodic examinations (Annex 2 form) | Distribution of complaints and findings by unit | Examination intervals may differ by unit |
| Audiometry | Change in hearing threshold over time | Same device and conditions; quiet period before the test |
| Pulmonary function test | Trend of decline in lung function | Test quality, effect of smoking and age |
| Chest X-ray | Emergence of dust-related changes | Whether read with the ILO classification |
| Biological monitoring | Whether the substance has been taken into the body | Sampling time, reference values |
| Visits to the workplace infirmary | Musculoskeletal, skin and eye complaints, minor injuries | Habits of attending vary from unit to unit |
| Accident and occupational disease records | Risks that have turned into outcomes | Unreported events |
| Restricted or unfit decisions | Which jobs are putting strain on whom | Few in number, identity may be apparent |
We explained how often tests are carried out in our article on periodic medical examinations and tests, and test-by-test interpretation in our articles on audiometry, pulmonary function tests, the ILO classification of chest X-rays and biological monitoring tests.
Analysing health surveillance results: grouping without identifying details
Carry out the analysis with these steps:
- Define groups in the same way as the risk assessment. Unit, job or similar exposure group should match the coding in the risk assessment document. Otherwise you will not be able to find which row to enter the finding in.
- De-identify on the physician’s side. Names, national ID numbers and payroll numbers do not go into the analysis table. Raw data stay under the physician’s responsibility; only the grouped table goes outside.
- Merge small groups. In a unit of three people, writing “lung finding in one person” identifies that person to everyone. As a practical rule, merge groups smaller than five people with a group with similar exposure, or interpret without giving numbers.
- Use rates and trends. Write “3 out of 24” instead of “three people”; if possible, compare with previous years and with an unexposed group.
- Rule out confounders. Age, smoking, factors outside the workplace and differences in test conditions may explain a finding. Workers who become ill leaving the job also make the remaining group look healthier than it is; this “healthy worker effect” is taken into account in the interpretation.
- Translate the finding into the language of risk. For each meaningful finding, write down which hazard it may be related to, what the existing measure is and what needs to be verified.
Workplace health statistics: example table and reading
The table below is a fictitious example, prepared to show what the method looks like. A real workplace health statistics table is built according to your own groups and tests.
| Group | Workers | Indicator | This year | Previous year | Initial interpretation | Transfer to the risk assessment |
|---|---|---|---|---|---|---|
| Press line | 24 | New notch in the 4000 Hz region | 3 | 0 | Noise control may be inadequate or hearing protection compliance low | Renewal of noise measurement, observation of hearing protection compliance, reduction at source |
| Paint line | 12 | Marked decline in pulmonary function | 2 | 1 | Small number; exposure and test quality should be verified | Check of local exhaust ventilation, chemical workplace measurement, physician shortening the check interval |
| Packaging | 40 | Infirmary visits with back and shoulder pain | 11 | 5 | May be related to the new line speed and stacking height | Ergonomic risk analysis, workstation layout, rotation |
| Warehouse | 15 | No marked change | — | — | Existing measures continue | No change |
Each row in the table is a hypothesis, not a definitive conclusion. The notches on the press line suggest noise-induced hearing loss, but measurement and site observation are needed for verification. The typical finding of noise-induced hearing loss is a V-shaped notch in the 4000 Hz region; for details, see our article on noise-induced hearing loss. For the increase in the packaging row, ergonomic risk analysis with REBA and RULA is a suitable starting point.
From finding to action: updating the risk assessment
If the analysis does not feed back into the risk assessment, it is just a report. Close this loop for each finding:
- Hypothesis: Which hazard could the finding be related to?
- Verification: Site observation and, if necessary, workplace measurement. We plan measurements with authorised laboratories and enter the results in the risk assessment.
- Measure: According to the hierarchy of controls; first at source, then collective protection, and personal protective equipment last.
- Adjustment of health surveillance: The workplace physician can shorten the periodic examination interval where necessary or plan additional tests in the group.
- Monitoring: In the next period, the same indicator is recalculated and the effect of the measure is seen.
This loop is part of updating the risk assessment through change management; for the framework, see our article on change management and risk revision.
How is the health surveillance report shared?
The health surveillance report should be a grouped summary that the physician presents to the employer and the OHS committee. A short structure is sufficient: period and scope, the number of examinations and tests carried out, prominent findings by group, recommended measurements and measures, and the status of the previous period’s recommendations. This summary also provides input to the annual evaluation report; we explained the structure of the report in our article on the annual evaluation report.
For businesses in Bursa and neighbouring provinces, analysing health surveillance data by group and carrying the findings into the risk assessment is where our workplace physician and risk assessment services work together. For the test plan, see our health surveillance page; you can track periodic examination dates with the OHS calendar.
Frequently Asked Questions
Can the employer see workers’ examination results?
No. Examination and test results are personal health information and are confidential. The employer is told the worker’s fitness for work and any recommended restrictions or adjustments; in aggregate analysis, only de-identified, grouped results are shared.
Is separate consent from workers needed for aggregate analysis?
The analysis is carried out under the control of the workplace physician, who is responsible for the health data, and only results grouped so that individuals cannot be identified leave this control. Data that have genuinely been anonymised do not count as personal data; but remember that anonymity may not be achievable in small groups. In case of doubt, assess it together with your data protection adviser.
How often should this analysis be done?
We recommend doing it at least once a year, when the annual evaluation report is prepared. After changes such as a new line, a new chemical or a serious accident, an interim analysis is carried out for the group concerned.
Is this analysis meaningful in a small workplace?
When numbers are small, rates and statistics can be misleading. In small workplaces, the analysis focuses on trends over several years and on whether the same complaint is seen in more than one person; the finding is still transferred to the risk assessment by unit, without identifying details.
A physician assigned for the time your hazard class requires: pre-employment and periodic examinations, fitness-for-work reports and health surveillance.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.