Notifiable Non-Licensed Work (NNLW): Do you Conduct Health Surveillance?

Notifiable Non-Licensed Work (NNLW): Do you Conduct Health Surveillance?

  • Date: Thursday 8th October 2015

Since 30 April 2015, all workers carrying out NNLW must have a medical examination. Examinations will then need to be repeated at least every 3 years, as long as the worker continues to do NNLW. An examination must be carried out before they can start such work.

  • The examination must include an examination of the chest and a lung function test and must be carried out by a licensed medical practitioner, e.g. a GP
  • Those workers already under surveillance via a licensed contractor and in possession of a valid certificate do not need to have the NNLW medical
  • Medical examinations should be carried out in work time at the employers' expense
  • The fee should be agreed with the doctor before the examination is carried out ; the HSE can accept no responsibility for remuneration matters
  • The doctor must issue a certificate to confirm the examination has taken place and on what date; the employer needs to keep this certificate for 4 years

Record keeping

Employers must keep a register (health record) of NNLW with asbestos for each employee exposed to asbestos. This must include:

  • the nature and duration of work with asbestos and estimated exposure for each individual worker
  • dates of the worker's medical examinations

Record keeping may be as simple as writing down the names of workers on the job on your copy of the notification or keeping copies of the notification form for each person carrying out NNLW work, as the notification copy will document the nature of the job and type of asbestos from which likely exposure can be estimated. More detailed medical records will be kept by the doctor.

Registers of work (health records) must be kept for 40 years (and offered to HSE or the individual concerned should the business cease trading).

The need to record exposure does not mean that every non licensed task must have air sampling. There will often be published exposure figures or knowledge within the industry about exposures found at similar lower risk work done in the past. If a task is unusual, then sampling may be required.

Further information can be researched through the following link. Alternatively contact SSG and we will be happy to advise you.

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