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Are you on the right wavelength with the Control of Electromagnetic Fields at Work Regulations 2016?

Posted by Tracy Seward

The Electromagnetic Fields (EMFs) Directive has been in place for some time and employers who have EMF hazards have generally been well aware of their obligations under the Directive and UK legislation in the form of the Management of Health and Safety at Work Regulations.

The ‘The Control of Electromagnetic Fields at Work Regulations 2016’ due out in July will not, therefore, look too different to what is generally in place at the moment through good design and management control. So those employers in the telecommunication or broadcast industries and other organisations such as the health service, emergency services, armed forces or the contracting supply chain that support these organisations should already have management systems in place.

Those that may not be so up to speed might include manufacturing businesses that use high powered equipment which emits EMFs during plastic welding for example. Also often forgotten or not considered are landlords and employers who don’t adequately control maintenance or surveying workers visiting sites where equipment is emitting EMFs from rooftop installations or where safety exclusion zones are accidentally or unintentionally entered in to.

It looks like the regulations will follow a familiar format:

  • Assessment of risk – five steps approach
  • Consultation and participation of workers in the assessment process
  • Determination of exposure against Exposure Limit Values (ELVs) & Action Levels (ALs)
  • A hierarchy of controls depending on the findings from the assessment
  • Worker information and training
  • Health surveillance

So what’s interesting?

The main challenge or focus will be on workers at particular risk which will include those:

  • Wearing active implanted medical devices
  • With passive implanted medical devices such as artificial joints, metallic plates, pins or shrapnel, body piercings etc.
  • With medical devices worn on the body such as hormone infusion pumps
  • Pregnant workers

Workers in these categories may be at greater risk from EMFs than the general working population and should, therefore, be subject to a specific risk assessment. In considering whether workers may be at particular risk, employers should give consideration to the frequency, level and duration of exposure. Employers obviously need to find out if they have at-risk workers in their population which means that training, awareness, communication and information gathering will be an essential element of a compliance risk management approach.

In addition, there might be a bit of head-scratching about undertaking health surveillance as part of the risk assessment process when it is accepted that it’s pretty difficult to measure any long term chronic health effects from EMF exposure. In comparison, health assessments following any suspected acute exposure will, of course, form part of the employer’s risk management review process.

Finally, one area that will need some close attention will be the consultation and participation of workers in the risk assessment process and also the requirement to provide workers with information and training. To help employers there is a RoSPA approved online EMF training course available which has been used over a number of years to support the management of EMF risks.

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