How to stay healthy with DSE
Howard Fidderman reviews the HSE's revised advice on working with display screen equipment.
Ten years after the Health and Safety (Display Screen Equipment) Regulations 1992 (DSE) came into force, the HSE has revised its core guidance on their requirements.1 The Regulations implemented the 1990 DSE Directive (no.90/270/EEC) and require employers to:
The Regulations were amended late last year by the Health and Safety (Miscellaneous Amendments) Regulations 2002 (HSC changes eight sets of Regs to allay EC criticisms), and the new guidance reflects these changes and developments in technology, knowledge and risk avoidance that have occurred since the initial guidance was published at the end of 1992.
Although the legislative changes were not substantial, we are reviewing the guidance in depth here because:
The main health risks
The main risks associated with DSE work are:
Although the risks from DSE to individuals are low, they are significant because: good practice is not always followed; and the large number of workers who use DSE means that there will be a significant incidence of ill health.
While the guidance on the health risks to the eye and eyesight is essentially unchanged, the advice on musculoskeletal and stress risks is significantly expanded. It is now much more insistent about the role of psychosocial factors, which "may have as important an influence as physical risk factors" on health in general and musculoskeletal problems in particular. Such factors include the design, organisation and management of the work, the overall social environment, and the content of the work. "It is very likely", states the guidance, "that physical and psychosocial risk factors combine, and the greatest benefits will be achieved when both are identified and controlled . . . Many effects of psychosocial factors may be linked to musculoskeletal disorders via stress-related processes, which include direct biochemical and physiological changes in the body." The advice on fatigue and stress is also expanded, with a longer list of "undesirable" factors (see Box 1).
Of the four other health concerns that have been linked to DSE, the advice on photosensitive epilepsy, electromagnetic radiation and pregnant women remains unchanged, ie there is no evidence to support any fears of ill health. As to the fourth, the guidance again attributes rare problems of facial dermatitis to environmental factors, such as low relative humidity or static electricity, although it now attributes a role to "individual susceptibility".
The section on health risks also includes, for the first time, advice on treatment and rehabilitation. This urges employers to encourage early reporting of symptoms by workers, provide advice, arrange referrals to health professionals and help sufferers to continue working.
DO THE REGULATIONS AFFECT YOU?
The Regulations cover any alphanumeric or graphic display screen, regardless of the display process involved. Reflecting technological developments, the new guidance mentions not just cathode-ray tube and liquid crystal screens, but also plasma and touch-screen displays, as well as "other emerging technologies". Non-electronic systems, such as microfiche, still count as DSE. One development sees the new guidance include within DSE "screens used in work with television or film pictures"; the 1992 guidance had excluded "screens whose main use is to show television or film pictures". Not all of the regulations, however, will necessarily apply to screens used for process control or closed-circuit TV.
The "workstation" covered by the Regulations comprises:
The Regulations do not cover:
There is also a potential exemption for the armed forces, but only for a limited period and in the interests of national security. Employers should always remember that workers using the equipment above are still covered by the HSW Act and other Regulations.
Who's covered, and who's not
The Regulations apply wherever there are:
Users are covered by all of the Regulations regardless of whether their workstation is located at their employer's premises, home or another employer's premises. Operators who work at another employer's workstation are covered by the provisions on risk analysis and reduction, minimum requirements and provision of information (see Box 3).
The determination of whether or not a worker is a user/operator, and therefore whether an employer must comply with the Regulations, remains as nebulous as ever, ie the worker must habitually use DSE as a significant part of his or her normal work. The meaning of "habitual" and "significant" has perplexed some employers although, in practice, it is generally a matter of common sense whether a worker is a DSE user/operator.
The HSE's advice here for employers shows that there is no debate where DSE use is more or less continuous; data word processing workers, secretaries, typists, data input operators, news sub-editors, journalists, tele-sales workers, customer complaints handlers, air traffic controllers, financial dealers, librarians and graphic designers are, as in 1992, all likely to be users or operators. Additional categories in the 2003 guidance include microelectronics assembly or testing operatives, television editing technicians and security control room operatives.
But where DSE use is less frequent or continuous, a worker will qualify as a user or operator if he or she satisfies three criteria based on continuity of use, daily use and fast transfer of information, as well as one of four further criteria. Table 1 lists these criteria and shows how they have evolved from the seven criteria used in 1992, most or all of which had to be satisfied. Possible users and operators here include scientists, technical advisers, client managers, bank customer support officers, airline check-in clerks, community care workers and receptionists.
WORKSTATION ANALYSIS
The Regulations require every employer to "perform a suitable and sufficient analysis" of workstations that are either used by users or that it has provided for operators. The analysis should:
A suitable and sufficient analysis should:
Employers should note that the analysis will satisfy the general risk assessment required by the Management of Health and Safety Regulations 1999 in so far as DSE workstations are concerned. (Similarly, compliance with DSE requirements on lighting and glare will satisfy relevant duties in the Provision and Use of Work Equipment Regulations 1998 and the Workplace (Health, Safety and Welfare) Regulations 1992.)
The guidance advises employers to keep a readily-available paper or electronic record in most instances. The exceptions are "the simplest and most obvious cases that can be easily repeated or explained at any time" and temporary workstations that do not present significant risks.
The HSE has boosted its guidance on the value of input from DSE users, stressing to employers that: "The inclusion of such views is likely to result in better information on existing conditions and provide a feeling of ownership over the findings. Employees who are actively involved in the risk assessment process are also more likely to report problems as they arise." The guidance also urges employers to encourage safety representatives to play a full part in the process.
What type of assessment?
One way to secure the views of employees is by using a checklist questionnaire. The 2003 guidance includes, for the first time, a model checklist (see Table 2) that, preferably, should be completed by users or with their input, providing they are trained to do so. Other tools for informing the analysis, which are carried over from the earlier guidance, include generic assessments for particular types of equipment or groups of workers performing the same tasks. But the HSE cautions that an employer would still have to assess the subjective aspects, for example comfort and hotdesking, on an individual basis. Where a workstation is shared by more than one worker, the analysis should cover each worker.
The assessment must be appropriate to the tasks and the complexity of the workstation. In many offices, an employer need only base its judgment on the responses to the checklist. A more detailed assessment would be appropriate where there are particular risks, complex situations or where the safety of others is a critical factor. A more detailed survey might include recording of posture or quantitative surveys of lighting and glare.
The assessor
Assessments can be carried out by health and safety personnel or other in-house staff with the necessary abilities. The assessor should be familiar with the DSE Regulations and be able to:
Where in-house staff have been trained, employers should check that they have understood the information provided and are competent to do the task. An employer could, for example, ask the trainer to check a sample of the assessor's work.
Reviewing the assessment
The DSE Regulations require an employer to review the assessment if there is reason to suspect it is no longer valid or where there has been a significant and relevant change, for example:
MINIMUM WORKSTATION REQUIREMENTS
In addition to the duty to reduce the risks to the lowest level reasonably practicable, the Regulations also require employers to ensure that all workstations used for the purposes of its undertaking meet the requirements laid down in a Schedule. The minimum requirements cover the equipment, working environment and the interface between the computer and the user/operator. The checklist below covers many of the minimum requirements.
This duty was amended in 2002 to reflect a European Court of Justice ruling that the requirement applies to all DSE workstations and not just those worked at by users/operators. The HSE has also simplified the wording of the Regulation by removing obsolete transitional periods for older equipment, and has updated its guidance on the Schedule, particularly the information on European equipment standards.
Most employers should not, however, be affected in practice by these changes to the Regulations, particularly given that they already had responsibilities under other legislation to ensure that the workstation was safe, regardless of who was using it.
The duty to comply with the minimum requirements is still limited to the extent that:
DAILY WORK ROUTINE
The employer has a duty to plan the activities of DSE users so that their daily DSE work is periodically interrupted by breaks or changes in activity that reduce their DSE workload. The 2003 guidance now explicitly includes within DSE work any use of a mouse or input device; the earlier version was restricted to keyboards (see Box 4). The employer should also encourage, facilitate and provide information and training on the taking of breaks and changes in activity.
Many tasks will involve natural breaks or combinations of DSE and non-DSE work, but where DSE spells are intensive, the guidance advises employers to break up the tasks with non-intensive, non-DSE work. Where this is not possible, for example in jobs that are restricted to data entry, an employer must introduce breaks or pauses that do not demand broadly similar hand and arm movements. Other points to note include:
Break pointers
The new guidance maintains its predecessor's insistence that while it is not appropriate to lay down requirements for breaks that apply to all types of work, it can provide general guidance:
In a new section in the guidance, the HSE accepts that some break-monitoring software packages might be helpful. But it cautions that:
EYE AND EYESIGHT TESTING
The DSE regulation that provoked most fury among employers introduced a duty, on request, to ensure that users have an appropriate eye and eyesight test. Had there still been a free NHS test, this regulation would probably have gone unnoticed, but the government had removed the entitlement shortly beforehand. Nor was employer antipathy dampened by the HSE's insistence - which is maintained in the 2003 guidance - that there is no reliable evidence that DSE work causes permanent damage to the eye or eyesight. All the HSE will concede is that DSE work may increase a person's awareness of pre-existing defects and lead to temporary visual fatigue or headache, particularly if working conditions are poor.
Although the regulation was amended in 2002, it was only to make the duty clearer. The entitlement to a test continues, and the guidance is clear that the employer must bear the costs. It can, however, decide how to provide the test, for example through a single optometrist, reimbursing employees who use their own optometrist or, included for the first time in 2003, vouchers.
The test must be carried out by a competent person before a worker becomes a user or, if already a user, as soon as practicable. The test should also be repeated:
Appropriate and inappropriate tests
An appropriate test means a standard "sight test" - an examination of the eyes and a test of vision - carried out by a registered ophthalmic optician or medical practitioner with suitable qualifications. The HSE points out that all registered medical practitioners, including company occupational health departments, are entitled to carry out sight tests, but only those with an ophthalmic qualification tend to do so.
The new guidance is clear that vision screening techniques, which are still used by some employers, "are not an eye and eyesight test and hence do not satisfy the DSE Regulations". The 1992 guidance, while not denying this position, had been much more circumspect, stating that screening was "a means of identifying individuals with defective vision who need a full sight test". The HSE's attitude in 1992 was probably an attempt to assuage employer hostility to the duty, offering them the illusion of a cheap alternative to a full test by conflating the "need" for a full test with their duty to provide one.
The 2003 guidance states only that an employer may offer vision screening as an "extra". The person conducting the screening should have basic knowledge of the eye and its functions and be competent to operate the instrument or tests. The results, and any need for referral, should be assessed by a person with medical, ophthalmic, nursing or paramedical skills. Where used, screening should test vision at 50cm-60cm, which is the normal distance between the screen and eye. The screener should tell users where a defect has been diagnosed and refer them to an optometrist.
Free glasses, but not for all
DSE users have a statutory entitlement to "special corrective appliances" appropriate for the work they do where:
"Special corrective appliances" are spectacles (the guidance does not mention contact lenses) that "correct vision defects at the viewing distance or distances used specifically for the display screen work concerned". "Normal" appliances are those prescribed for any other purpose. The guidance is also clear that: "Employers are not responsible for any corrections for vision defects or examinations for eye complaints that are not related to display screen work". There is no change to the estimate that less than 10% of the working population need special corrective appliances for DSE work.
Employers must pay the cost of "a basic appliance, ie of a type and quality adequate for the user's work". It must pay for the spectacles even if the user works at another employer's workstation. If the user chooses spectacles to correct vision defects for purposes that include DSE work but go further to cover non-DSE purposes, then an employer is liable only for the costs attributable to the job. Similarly, where a user chooses more expensive spectacles, for example designer frames, the employer can either provide a basic appliance or contribute a portion of the cost equivalent to the cost of a basic appliance.
Bifocals
The 2003 guidance introduces advice on bifocal and varifocal lenses. It states that, as a first, it is good practice to bring other objects, for example documents, into the same viewing plane so that a single lens prescription will cover all DSE needs. But it accepts that there will be circumstances in which bifocals or varifocals are needed, for example where the user mixes DSE work with other tasks, such as dealing with people. "If the user would repeatedly have to change from one pair of spectacles to another to cope with this, a pair with multiple-focus lenses might be a solution."
Even here, the HSE advises caution because the use of multi-focals can result in repeated adjustments to the head and neck or the adoption of an awkward position. Where such lenses are called for, employers should consult the optometrist, providing information about the tasks and the workstation.
The 2003 guidance specifies that: "Where bifocal or varifocal spectacles are prescribed as special corrective appliances, the employer is required to meet the costs associated with providing a basic frame and the prescribed lenses". This is important: anecdotal evidence shows that some employers refuse to pay more than a proportion of bifocal lenses, ie the part of the prescription that relates to the distance between the eyes and the screen.
TRAINING PROVISION
Employers must provide health and safety training to DSE users, and to workers who are to become users. Further training will be necessary when the workstation is substantially modified, and desirable where users have been away from work for long periods. The guidance recommends that the training is carried out with general training, such as keyboard skills, because the issues will overlap and reinforce each other. It adds that the training should target musculoskeletal risks, visual fatigue and mental stress, and cover:
Information too
The employer must also ensure that it provides information to:
The information should also reinforce the training through posters, memos, wallcharts, health and safety instructions, computer discs, electronic bulletin boards and verbal briefings. Employers should ensure that the workers are able to gain access to and use the information, and suggests consulting staff about how they would like to receive the information. The guidance is also explicit, for the first time, that the duties under the MHSW Regulations to provide information to employees, employers of other employees on site, visiting employees and the self employed also apply, as does the duty to provide information to safety representatives.
Revisions can only help
The initial employer furore in the early 1990s soon died down as employers either ignored the DSE Regulations or realised that they could prove beneficial, particularly in their attempts to tackle WRULDs and associated compensation claims. Nor has the HSE shown any enthusiasm for formal enforcement - just 18 improvement notices and no prosecutions in 2001/02.
A 1998 review found that the DSE Regulations and guidance had exerted a positive impact on safety standards. Nine in 10 large and two in three small employers were aware of the Regulations - the joint highest of the six-pack Regulations. Almost three-quarters of large employers had carried out a DSE risk assessment (although only 15% of small employers had done so); and most employers said that complying with the Regulations had resulted in greater benefit than cost. These findings showed a marked improvement on a 1996 review that found only 39% of employers had carried out DSE assessments and that two in three employers did not provide free eyesight tests.
The new guidance is certainly an improvement on its 1992 predecessor (which was, in any case, easy to use). The new sections cover many of the issues that have arisen in the past decade, such as portable computers. It does not, however, answer some of the criticisms levelled in the 1996 review. For example, employers said that they found it difficult to distinguish between actions required as a result of the risk assessment and those that are needed to conform to the minimum requirements. The 2003 guidance is no clearer than its predecessor on this, although it can be argued that it does not need to be. More importantly, the 2003 guidance does not fully address problems that were identified in research published last year on court judgments in WRULD claims. This showed that courts and employers were not always uniformly interpreting the HSE's 1992 DSE guidance, and that the guidance did not always adequately address an employer's common law duties in relation to claims for upper-limb disorders. With that caveat, the revised DSE guidance will undoubtedly prove to be as useful to employers as its predecessor has for a decade.
Table 1: How to determine who is a DSE user/operator
Whereas the 1992 guidance required an individual to satisfy "most or all" of seven criteria in order to qualify as a user or operator, the 2003 guidance requires an individual to satisfy three criteria and one of four further criteria.
2003 GUIDANCE |
1992 GUIDANCE |
The individual normally uses DSE for continuous or near-continuous spells of an hour or more at a time; AND |
The individual normally uses DSE for continuous spells of an hour or more at a time; AND |
the individual uses DSE in this way more or less daily; AND |
the individual uses DSE in this way more or less daily; AND |
the individual has to transfer information quickly to or from DSE; AND ONE OF |
the fast transfer of information between the user and screen is an important requirement of the job; AND |
the individual needs to apply high levels of attention and concentration; OR |
the performance requirements of the system demand high levels of attention and concentration by the user, for example where the consequences of an error may be critical; AND |
the individual Is highly dependent on DSE; OR |
the individual depends on the use of DSE to do the job as alternative means are not readily available for achieving the same results; AND |
the individual has little choice about using DSE; OR |
the individual has no discretion as to use or non-use of the DSE; AND |
the individual needs special training or skills to use the DSE. |
the individual needs special training and/or particular skills in the use of DSE to do the job. |
The 2003 guidance includes a new section on agency workers. Where the agency worker becomes an employee of the host employer, the host employer assumes the duties of the Regulations. But when the worker is employed by the agency or is self-employed, the duties split. The host employer must:
The agency should:
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Table 2: Display screen equipment workstation checklist
Things to consider |
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1. Display screens |
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Are the characters clear and readable? |
Make sure the screen is clean and that cleaning materials are available. Check that text and background colours work well together. |
Is the text size comfortable to read? |
Software settings may need adjusting to change text size. |
Is the image stable, ie free of flicker and jitter? |
Try using different screen colours to reduce flicker, eg darker background and lighter text. If problems still exist, get the set-up checked, eg by the equipment supplier. |
Is the screen's specification suitable for its intended use? |
For example, intensive graphic work or work requiring fine attention to small details may require large display screens. |
Are the brightness and/or contrast adjustable? |
Separate adjustment controls are not essential, provided the user can read the screen easily at all times. |
Does the screen swivel and tilt? |
Swivel and tilt need not be built in; you can add a swivel and tilt mechanism. But you may need to replace the screen if:
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Is the screen free from glare and reflections? |
Use a mirror placed in front of the screen to check where reflections are coming from. You might need to move the screen or even the desk and/or shield the screen from the source of reflections. Screens that use dark characters on a light background are less prone to glare and reflections. |
Are adjustable window coverings provided and in adequate condition? |
Check that blinds work. Blinds with vertical slats can be more suitable than horizontal ones. If these measures do not work, consider anti-glare screen filters as a last resort and seek specialist help. |
2. Keyboards |
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Is the keyboard separate from the screen? |
This is a requirement, unless the task makes it impracticable, eg where there is a need to use a portable computer. |
Does the keyboard tilt? |
Tilt need not be built in. |
Is it possible to find a comfortable keying position? |
Try pushing the display screen further back to create more room for the keyboard, hands and wrists. Users of thick, raised keyboards may need a wrist rest. |
Does the user have a good keyboard technique? |
Training can be used to prevent:
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Are the characters on the keys easily readable? |
Keyboards should be kept clean. If characters still can't be read, the keyboard may need modifying or replacing. Use a keyboard with a matt finish to reduce glare and/or reflection. |
3. Mouse, trackball, etc |
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Is the device suitable for the tasks for which it is used? |
If the user is having problems, try a different device. The mouse and trackball are general-purpose devices suitable for many tasks, and available in a variety of shapes and sizes. Alternative devices, such as touchscreens may be better for some tasks (but can be worse for others). |
Is the device positioned close to the user? |
Most devices are best placed as close as possible, eg right beside the keyboard. Training may be needed to:
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Is there support for the device user's wrist and forearm? |
Support can be gained from, for example, the desk surface or arm of a chair. If not, a separate supporting device may help. The user should be able to find a comfortable working position with the device. |
Does the device work smoothly at a speed that suits the user? |
See if cleaning is required (eg of mouse ball and rollers). Check the work surface is suitable. A mouse mat may be needed. |
Can the user easily adjust software settings for speed and accuracy of pointer? |
Users may need training in how to adjust device settings. |
4. Software |
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Is the software suitable for the task? |
Software should help the user carry out the task, minimise stress and be user-friendly. Check users have had appropriate training in using the software. Software should respond quickly and clearly to user input, with adequate feedback, such as clear help messages. |
5. Furniture |
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Is the work surface large enough for all the necessary equipment, papers, etc? |
Create more room by moving printers, reference materials, etc, elsewhere. If necessary, consider providing new power and telecoms sockets, so that equipment can be moved. There should be some scope for flexible rearrangement. |
Can the user comfortably reach all the equipment and papers they need to use? |
Rearrange equipment, papers, etc, to bring frequently used things within easy reach. A document holder may be needed, and positioned to minimise uncomfortable head and eye movements. |
Are surfaces free from glare and reflection? |
Consider mats or blotters to reduce reflections and glare. |
Is the chair suitable? Is the chair stable? Does the chair have working components? |
The chair may need repairing or replacing if the user is uncomfortable, or cannot use the adjustment mechanisms. The chair's components should include adjustable seat back height and tilt, adjustable seat height, swivel mechanism and castors or glides. |
Is the chair adjusted correctly? |
The user should be able to work sitting comfortably. Consider training the user in how to adopt suitable postures while working. The arms of chairs can stop the user getting close enough to use the equipment comfortably. Move all obstructions from under the desk. |
Is the small of the back supported by the chair's backrest? |
The user should have a straight back, supported by the chair, with relaxed shoulders. |
Are forearms horizontal and eyes at roughly the same height as the top of the VDU? |
Adjust the chair height to get the user's arms in the right position, then adjust the VDU height, if necessary. |
Are feet flat on the floor? |
There should not be too much pressure from the seat on the backs of the legs. If not, a footrest may be needed. |
6. Environment |
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Is there enough room to change position and vary movement? |
Space is needed to move, stretch and fidget. Consider reorganising the office layout and check for obstructions. Cables should be tidy and not a trip or snag hazard. |
Is the lighting suitable, eg not too bright or too dim to work comfortably? |
Users should be able to control light levels, eg by adjusting window blinds or light switches. Consider shading or repositioning light sources or providing local lighting, eg desk lamps (but make sure lights don't cause glare by reflecting off walls or other surfaces). |
Does the air feel comfortable? |
VDUs and other equipment may dry the air. Circulate fresh air if possible. Plants may help. Consider a humidifier if discomfort is severe. |
Are levels of heat comfortable? |
Can heating be controlled better? More ventilation or air-conditioning may be required if there is a lot of electronic equipment in the room. Or, can users be moved away from the heat source? |
Are levels of noise comfortable? |
Consider moving sources of noise, eg printers, away from the user. If it is not possible, consider soundproofing. |
7. Final questions to users . . . |
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Has the checklist covered all the VDU problems the user may have experienced? |
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Has the user experienced any discomfort or other symptoms attributed to working with the VDU? |
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Has the user has been advised of the entitlement to eye and eyesight testing? |
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Does the user takes regular breaks working away from the VDU? |
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Source: adapted from HSE checklist in guidance L26. |
1"Work with display screen equipment. Guidance on Regulations", HSE, L26, HSE Books, ISBN 0 7176 2582 6, £8.95.