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Display Screen Regulations
An employer's guide to getting the best out of the regulations
Tom Stewart, System Concepts
Updated February 2000
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CONTENTS
PREFACEACKNOWLEDGEMENTS
1. INTRODUCTION
2. AN OVERVIEW OF THE REGULATIONS
3. DEVELOP AN ACTION PLAN
3.1 Establish who is involved3.2 Identify display screen equipment and exclusions
3.3 Update existing health and safety policies
3.3.1 Plan display screen work to provide regular breaks or changes of activity
3.3.2 Offer users eye and eyesight tests and, if necessary, special eyesight
correction
3.3.3 Inform, train and consult users
3.4 Review current practice and determine appropriate action
3.4.1 Assess workstations and reduce risks
3.4.2 Ensure workstations meet minimum ergonomics requirements
4. UNDERSTAND DISPLAY SCREEN ERGONOMICS
4.1 Display
4.2 Keyboard
4.3 Work desk or work surface
4.4 Work chair
4.5 Environment
4.6 User/computer interface
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5. USE ERGONOMICS STANDARDS FOR PROCUREMENT AND DESIGN
5.1 Introduction to ergonomics standards
5.2 Ergonomics standards making bodies
5.3 Current ergonomics standards mainly dealing with hardware5.4 Future ergonomics standards mainly dealing with software
5.5 Develop an ergonomics standards policy
6. WHAT IF ...
6.1 What if you wish to address software usability?
6.2 What if staff complain?
6.3 What if you are planning a new installation?6.4 What if you wish to involve users in the system development process?
6.5 What if it is a special or non-standard environment?
7. CONCLUSION
APPENDICES
A. Checklists
A1 Level 1 assessment checklistA2 Level 2 assessment checklist (problem solving aid)
B. Sources of help references etc
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PREFACE
From 1st January 1993, employers have a number of specific obligations to users of
display screens in their undertakings, under the Health and Safety (Display ScreenEquipment ) Regulations 1992. The purpose of this management guide is to help
employers fulfil their obligations and understand the implications of the Regulations
for the way they introduce, manage and use display screens in their organisations.
For many employers, this document should be sufficient. However, the focus on
practical issues means that some topics receive little attention or some complex
situations may be oversimplified and therefore in cases of doubt, the full Regulations
should be consulted.
Although the Regulations are important as part of the law of the land and aretherefore legally enforceable with a wide range of penalties, there are also more
positive reasons why employers should understand display screen ergonomics.
Computer displays have become an indispensable business tool, almost as
ubiquitous as the telephone. For many organisations, computer systems have
progressed from being a convenient support for administration to becoming the
prime engine of the business process itself. Manufacturing concerns could no
longer operate without computer driven parts ordering, scheduling and inventory
control. Service industries such as insurance, banking, finance, travel could not
operate without integrated computer based systems providing information andrecording the business activity. Yet many users find computer based work
unnecessarily tiring and many computer systems unfriendly and intimidating.
The Regulations contain many sensible and practical provisions to help make display
work safer, more comfortable, more efficient and more productive. Understanding
the reasons behind these provisions will enable employers to prioritise their efforts
and gain maximum advantage from the changes the Regulations may require.
The prime focus of this guide is not simply how can I avoid being sued?, validthough that is as a concern. Rather the prime focus is how can employers make
best use of the Regulations to improve the safety, comfort, efficiency and
productivity of display screen work? This does not mean that you must employ
consultants or that it must be very expensive or complex. Many organisations have
already found that the requirements are quite straightforward and that with a little
help and training their own staff can carry out much of the work themselves. They
have also found that taking the opportunity to improve display screen work makes
good business sense.
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We start the guide with an executive summary of the Regulations, then we spell out
an action plan to comply with the employer's obligations. Next, we discuss the
minimum ergonomics requirements for workstations in sufficient detail for the
reader to understand what is required and why. Then we explain how national and
international ergonomics standards may be used to guide procurement and thenoffer some advice on dealing with some key software ergonomics issues. In the last
main section, we discuss what an employer should do if, for example, staff complain,
or a new installation is planned. Finally, the Appendix contains a number of practical
checklists and details about sources of help.
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ACKNOWLEDGEMENTS
Having worked in the field of display screen ergonomics for nearly twenty five
years, I have an enormous debt to acknowledge to the many colleagues and clientswho have contributed to my knowledge, shaped my ideas and listened to my views.
In some ways, little changes in the world of display screen ergonomics and some of
the source material for this book has appeared in different forms over a long period
of time. None the less, I have attempted to pull together several different strands
into one volume for the first time. I have also tried to make the information and
explanation as accessible as possible. It has not always been possible and I know
this book cannot be regarded as an easy read. But I believe it is important for
employers and all those concerned with improving display screen work to try tounderstand what lies behind the concerns, the discomforts and the health problems.
In an attempt to user test the book, I have inflicted earlier versions of this
manuscript on many people and I would like to acknowledge some of them here in
alphabetical order. Stephen Gray of the Federation of Electronics Industry and John
Hughes of IBM have helped to keep me aware of the industry perspective and the
views of the responsible manufacturers. Dr Doreen Miller, Registrar of the College
of Occupational Medicine has helped with advice on occupational health aspects and
Dr Janet Asherson of the CBI advised on the employers perspective. AnneGreaves of UNISON provided a down to earth trade union viewpoint and Peter
Smith of the Association of Optometrists advised on eye tests and optometric
issues. Mr Peter Crabbe at BSI who acted as secretary to the Applied Ergonomics
Committee for many years and was an active supporter of ergonomics and
ergonomics standardisation. Dr Colin Mackay at the Health and Safety Executive
has long been a friend and a valuable source of guidance and information about the
legislation and official viewpoint.
Over the years, many clients have helped me understand display screen ergonomicsproblems and have allowed me to use material based on earlier work for them. I
would particularly like to acknowledge Pat Mitchell of Project Office Furniture,
Colin Smith of the National Health Service Information Management Group, Ferry
Koer of the European Patent Office and his colleague Thomas Muller who drew the
excellent cartoons.
The practical ideas and checklists have also been developed by colleagues within
System Concepts and I would particularly like to acknowledge the help and input
from Marilyn Joyce, President of the Joyce Institute, our US collaborators based in
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Seattle. I would also like to thank the large army of anonymous users whose
experiences have contributed to this book.
Finally I must thank four important women in my life. My daughter Amy Stewart
who has helped me with advice and inspiration for some time with a maturitybeyond her sixteen years (she has been my personal help desk when dealing with
obtuse software for several years). My business colleague and fellow director of
System Concepts, Andrea Caws, with whom I have worked for longer than either
of us care to admit. She has read all the manuscript, sorted out lots of errors,
helped develop many of the ideas and practical procedures and she has kept a tight
rein on some of my more outspoken comments. My wife, Fiona Stewart, who has
read almost everything I have ever written - sometimes several times. She has
probably learned far more about display screen ergonomics over the last twenty
five years than she ever wanted to. She has certainly been a strong support andinvaluable partner. I owe her a great deal. Finally, I must thank my mother, Agnes
Stewart, for her unfailing faith in me, her encouragement and her positive outlook.
She has a readiness to listen and to accept new ideas which puts those half her age
to shame.
Of course I have not always listened to the advice of my friends and colleagues and
so cannot blame them for any errors or omissions in the text, they remain my
responsibility.
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1. INTRODUCTION
Information technology is rapidly becoming the enabling technology for many
industrial and commercial processes. Just as the electric motor is a common powercomponent in all manner of machines, so the computer is an information
component in vehicles, machine tools, consumer products, office equipment and so
on. For many staff, this means a move away from paper-based methods towards
work with display screen equipment.
Rigorous scientific research studies have identified a number of potential problems
which reduce the comfort, well-being and efficiency of display screen users.
Although the vast majority of these problems can be avoided relatively easily,
computer manufacturers and employers have been criticised for being slow to takeeffective action.
Over the last few years, regulatory and other official bodies have developed
standards, guidelines and regulations in order to protect the health, safety, comfort
and efficiency of display screen users. Although, they have largely failed to endorse
the more extreme, scientifically unsupported, claims in the mass media, they have
recognised the importance of good ergonomics in the design and use of display
screen equipment.
Ergonomics, from Ergon and Nomos, the Greek words for work and
laws respectively, is the multi-disciplinary science which involves
applying knowledge about the strengths and limitations of people to
the design of equipment, workplaces and environments
The Display Screen Directive is one of a series of European 'daughter' Directives
dealing with specific aspects of health and safety. The 'parent' or 'Framework'
Directive (89/391/EEC) sets out the general principles of the EuropeanCommunity's approach to Health and Safety.
The first six of these Directives (known as the six-pack) have been implemented in
Great Britain as Regulations under the Health and Safety at Work etc Act 1974.
EUROPEAN-BASED HEALTH AND SAFETY LEGISLATION
THE 'SIX-PACK' Management of Health and Safety at Work Regulations 1992
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Provision and Use of Work Equipment Regulations 1992 Workplace (Health, Safety and Welfare) Regulations 1992 Personal Protective Equipment at Work Regulations 1992 Manual Handling Operations Regulations 1992 Health and Safety (Display Screen Equipment) Regulations 1992Although they address quite different aspects of working life and very different
levels of risk, these Directives are based on a common set of health and safety
principles. These common principles include the avoidance of risk by eliminating the
source, where possible, and by the encouragement of collective protective
measures instead of individual protective measures. Where risk is unavoidable, it
must be properly evaluated and measures must be taken which are appropriate to
the level of risk. Thus if the assessment shows that the level of risk is slight,
informal measures may be entirely adequate. However, where significant risk isidentified, then stringent measures must be taken.
KEY POINTS OF THE OTHER REGULATIONS
Management of Health and Safety at Work Regulations 1992 Assess risks to health and safety Plan, organise, control, monitor and review measures
Provide health surveillance Appoint competent people Set up emergency procedures Provide information and training
Provision and Use of Work Equipment Regulations 1992
Select safe equipment for working conditions Ensure it is suitable and maintained
Provide information, instruction and training Specifics on
odangerous partsohazardsotemperatureocontrolsopower sourcesostabilityolightingo
warnings and marking
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Workplace (Health, Safety and Welfare) Regulations 1992
Working environment - heat, light, space, seating Safety - passage, windows, doors, floors, falls Facilities - toilets, washing, eating, rest areas Housekeeping - maintenance, cleaning, waste
Personal Protective Equipment at Work Regulations 1992
Provide suitable personal protective equipment as a last resort Ensure compatibility of PPE Assess suitability of PPE Maintain and replace PPE as required Provide storage for PPE Provide information and training on proper use Supervise proper use
Manual Handling Operations Regulations 1992
Avoid manual handling operations where possible Assess and reduce risks of remaining operations task load working environment individual capability Employees must take care and co-operate
Concern about display screen equipment should not be seen in isolation from more
general concern about the safety, health and well-being of staff. Traditionally, office
work has been regarded as safe, and indeed compared to work in factories or on
building sites it is extremely safe. Nonetheless, the increased pace of modern office
work and changed attitudes to stress and health now put health and safety in the
office firmly on management's agenda.
There are a growing number of display screen equipment users reporting
discomfort and other short term problems. Whilst many of these are temporary
and disappear after work, they are nonetheless unpleasant and should be avoided in
the interests of the user' s health. If ignored, such symptoms can escalate into
longer term and chronic health problems.
However, a sense of proportion is important. The requirements of staff who work
intensively with display screen equipment, performing highly complex work withlittle variation are quite different from those of a senior manager who occasionally
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uses a personal computer to revise his budget on a spreadsheet. The technology
may be similar or even identical but the nature of the task and the circumstances
are quite different. Therefore different levels of concern and safeguard are
appropriate and these Regulations reflect this reality.
The display screen health debate has been clouded by a failure to distinguish
between health risks, for example visual and postural discomfort, and potential or
perceived health risks, for example from display screen radiation. It is
unquestionable that there has been much concern amongst users about reports of
long term effects of display screen work. Some of the reports which gave rise to
widespread publicity have been ill-founded.
FIGURE 1.1 NEAR HERE
Nonetheless, there are many well researched real problems and the concern
experienced by users is also real and should be taken seriously by responsible
employers. Failure to take employee concerns seriously has been extremely
damaging both to staff morale in general and to anxious individuals in particular.
Although the prime focus of the Regulations is to protect users, there are also good
commercial reasons for applying ergonomics to display screen systems.
Organisations which have taken ergonomics seriously in the past have not done so
because the law forced them. They have applied ergonomics in order to get the
best out of their investment in people and in technology. They have also avoided
the consequential costs of accidents and ill-health which include the costs of
medical treatment, staff cover, insurance premiums, compensation and the largely
hidden cost of management time and effort dealing with problems.
This remains a worthwhile objective and a cost effective way of gaining business
benefit from ergonomics and information technology.
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2. AN OVERVIEW OF THE REGULATIONS
2.1 There are six main obligations on employers
The Health and Safety (Display Screen Equipment) Regulations 1992 set out six
main obligations on employers of those who work with display screen equipment.
Health and Safety (Display Screen Equipment) Regulations 1992 analyse workstations and reduce health and safety risks ensure workstations meet minimum ergonomic requirements provide information about risks and measures plan daily work routine for users
offer eye tests and special glasses if necessary provide health and safety training
The Regulations only apply where there are 'users' or operators. Although both
these terms are common in the computer industry, the Health and Safety Executive
has chosen to give them specific meanings under the Regulations. A 'user', in terms
of the Regulations, is an employee who habitually uses display screen equipment as
a significant part of his normal work. Some of the employers responsibilities extend
to users employed by others (eg Temp agency staff) who are working on the
employers premises or equipment.
The Regulations also apply to the self-employed. An operator in terms of the
Regulations, is any self-employed person who habitually uses display screen
equipment as a significant part of his normal work. As a self employed person, some
of the obligations are their own responsibility e.g. training. However, other
responsibilities fall on the employer who has hired them for display screen work.
Thus the first step in understanding the obligations is to identify all the users,
operators and potential display screen equipment workstations in the organisation.
Some definitions from the Regulations
"display screen equipment" means any alphanumeric or graphic display screen,regardless of the display process involved;
"user" means an employee who habitually uses display screen equipment as asignificant part of his normal work;
"operator" means any self-employed person who habitually uses display screen
equipment as a significant part of his normal work;
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"workstation" means an assembly comprising - display screen equipment (whether provided with software determining the
interface between the equipment and its operator or user, a keyboard or any
other input device),
any optional accessories to the display screen equipment, any disk drive, telephone, modem, printer, document holder, work chair, work
desk, work surface or other item peripheral to the display screen equipment;
and
the immediate work environment around the display screen equipment.
For each user and operator working in his undertaking, the employer must:
a. assess the risks arising from their use of display screen workstations and take
steps to reduce any risks identified to the 'lowest extent reasonably practicable'
b. ensure that new workstations ('first put into service after 1st January 1993') meet
minimum ergonomics standards set out in a schedule to the Regulations. Existing
workstations have a further four years to meet the minimum requirements,
provided that they are not posing a risk to their users.
c. inform users about the results of the assessments, the actions the employer is
taking and the users' entitlements under the Regulations
For each user, whether working for him or another employer (but not each
operator)
d. plan display screen work to provide regular breaks or changes of activity
In addition, for his own employees who are users,
e. offer eye tests before display screen use, at regular intervals and if they are
experiencing visual problems. If the tests show that they are necessary and normalglasses cannot be used, then special glasses must be provided.
f. provide appropriate health and safety training for users before display screen use
or whenever the workstation is 'substantially modified'
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TABLE 2.1 Employers obligations towards display screen users and
operators
Obligation towards ownemployee who is a
user
towards otheremployee (eg
works for Temp
agency) who is a
user
towards selfemployed person
who is an operator
Assess risks at
display screen
workstation
YES YES YES
Ensure
workstation meetsminimum
ergonomics
requirements
YES YES YES
Inform staff about
rights and what has
been done
YES YES YES
Plan work and
provide breaks
YES YES NO (individual
responsibility)
Offer eyetest andspecial glasses if
necessary
YES NO (mainemployer is
responsible)
NO (individualresponsibility)
Provide training in
safe use
YES NO (main
employer is
responsible)
NO (individual
responsibility)
2.2 The Regulations are a political response to public concern
The Regulations represent the implementation in Great Britain of the European
Directive (90/270/EEC) on display screen work. The Display Screen Directive was
one of a series of 'daughter' Directives dealing with specific aspects of health and
safety. The Directives were essentially political and legal documents. They were
intended to set general requirements and not to require revision as the technology
developed. In the recitals to the Display Screen Directive, there was an obligation
on the employer to keep up to date with ergonomics and health and safety findings
in order to achieve the objectives of the Directive rather than simply follow the
letter of the law.
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There are many work activities which are clearly much more dangerous, eg work
on construction sites, which were apparently lower in priority in the European
legislative process. In justifying its decision to introduce a Directive on display
screen equipment, the Commission emphasised that it did not regard display screen
equipment work as particularly dangerous for the individual. However, it arguedthat taking account of the impact of potential ergonomic problems on the comfort
and well-being of workers and the increasing number of display screen workers
justified such a measure.
Managers and clerical workers account for 14% of
reportable occupational accidents (according to the HSE
report 'The costs to the British Economy of work
accidents and work-related ill health', HSE Books 1994).
Failure to take employee concerns seriously has been extremely damaging both to
staff morale in general and to anxious individuals.
2.3 The main responsibility lies with the employer
The Regulations set out obligations under the Health and Safety at Work Act
(1974) for employers responsible for display screen users and operators. As with
other aspects of health and safety, many of the duties fall to individual managers.
However, the users and operators themselves have a responsibility to co-operate
with management on appropriate measures and to play their part in avoiding risks
by following safe systems of work, reporting faults and using equipment sensibly.
Under the Management of Health and Safety at Work Regulations (which
transposed the Framework Directive), employers must consult with staff and their
representatives, especially safety representatives if they exist in the organisation, on
matters of health and safety.
2.4 The Regulations are implemented and enforced in Great Britain as part of the
Health and Safety at Work etc Act 1974
The Regulations were made under Section 15 of the Health and Safety at Work Act
1974. Thus they have the full force of the law behind them and are part of the
statutory duty of employers to their employees. Enforcement is through the Health
and Safety Executive's Factory Inspectorate and Local Authority Environmental
Health Officers as appropriate.
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The Regulations and the Schedule of minimum requirements for workstations
contain little that is not already covered by the existing legislation and guidance.
However, in view of the greater level of detail and specification in the Regulations,
it is anticipated that the initial emphasis of the Inspectorate will be on providing
guidance and information. Nonetheless, the full range of penalties associated withthe HSAW are available to inspectors including improvement notices, prohibition
orders and legal proceedings, in extreme cases.
2.5 The Regulations came into effect on 1st January 1993
The Regulations came into force on 1st January 1993. From that date, employers
have been obliged to assess and reduce risk, provide information and training, plan
display screen work for users and offer suitable eye and eyesight tests. They arealso obliged to ensure that new workstations meet the minimum ergonomics
requirements in the Schedule.
Existing workstations must be assessed for risks to the user's or operators health.
Where this assessment shows no risk, the workstation does not need to brought
into line with the minimum requirements until 1st January 1997. However, if the
assessment reveals a risk, then the risk should be reduced to the lowest extent
reasonably practicable as soon as possible.
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3. DEVELOP AN ACTION PLAN
Establish who is involved Identify display screen equipment and exclusions Update existing health and safety policies Plan display screen work to provide regular breaks or changes of activity Offer users eye and eyesight tests and, if necessary, special eyesight correction Inform, train and consult users Review current practice and determine appropriate action Assess workstations and reduce risks Ensure new workstations meet minimum ergonomics requirements
The scope of the Regulations is very broad and they are already having a significant
impact on many different aspects of organisational life. Some of these impacts were
intended by the legislators, for example, more communication about health and
safety issues between employer and employee.
However, other impacts may be more subtle and were probably never anticipated
let alone intended eg a trend towards designing automatic features into systems
such as time-outs and activity monitors to force users to follow arbitrary rules
about work time on screen.
In order to ensure that you not only comply fully with the Regulations but also gain
maximum benefit from the inevitable investment, this change process must be
planned and managed carefully.
Developing an action plan will also demonstrate to enforcers and to staff that you
are taking your responsibilities seriously. The plan should cover how you will:
establish who is involved identify display screen equipment and exclusions update existing health and safety policies review current practices and determine appropriate action
We consider these steps in detail in sections 3.1 to 3.4 below in relation to the
obligations set out in the Regulations.
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TABLE 3.1 The Action Plan and the Regulations
Regulation Number Action to meet
obligations1. Citation,
commencement,
interpretation and
application
Establish who is
involved
Identify display
screen equipment
and exclusions
2. Analysis of
workstations
Assess risks at
display screenworkstation
3. Requirements for
workstations
Ensure workstations
meet minimum
ergonomics
requirements
4. Daily work
routine of users
Plan display screen
work to provide
regular breaks or
changes of activity5. Eyes and eyesight Offer users eye and
eyesight tests and, if
necessary, special
eyesight correction
6. Provision of
training
Inform, train and
consult users
7. Provision of
information
Inform, train and
consult users
8. Exemption
Certificates
allows exemption to
military forces in the
interests of national
security
9. Extension outside
Great Britain
explains how they
apply outside Great
Britain
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In addition, the Action Plan should cover how you will make financial and other
provision for implementing changes and keep up-to-date with changing
requirements.
Many organisations fix budgets far in advance and these may be difficult to changewhen new requirements emerge. It is therefore important to anticipate the extent
to which the organisation and its current practices, equipment and furnishings may
have to change. For example, a brief sample audit, in advance of full assessments,
can give a good indication of the scale of the changes necessary, if any. This will
allow suitable provision to be made in budgets and development plans.
It is also important for the employer to keep up to date with the state of the art to
achieve the objectives of the Regulations rather than simply follow the letter of the
law. Display screen work is increasing round the world and as the technologyadvances, so too does our understanding of how to use it properly. Employers are
not expected to change their policies and practices with every new and
unsubstantiated research finding. Nonetheless, they are expected to be aware of
HSE guidance, of developments in standards and of recognised industry practice.
3.1 Establish who is involved
The Regulations set out a wide range of duties for employers which cut across
traditional responsibilities. Although Health and Safety specialists might be expectedto take the lead, they are seldom involved in such issues as working patterns, staff
consultation and software design. Many are not involved in procurement or
refurbishment programmes on a routine basis.
Thus the first step is to establish who is responsible for:
managing display screen users and operators procuring display screen equipment, furniture, accessories and software
installing systems and furniture managing premises including refurbishing and planning new accommodation managing environmental services health and safety occupational health personnel policies staff consultation staff training and selection software development
job design and work organisation
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and ensure that they are aware of their duties and responsibilities.
The Regulations only apply formally where there are users or operators (self
employed users) of display screen workstations. However, in practice, many of the
measures are appropriate for anyone who uses (in the conventional sense) displayscreen equipment or similar equipment. It is therefore sensible to identify
potential users and workstations. This will allow you to decide at a later date
whether it is more practical for administrative or employee relations reasons to
extend the provisions to other staff. Indeed, all staff are covered by the
Management of Health and Safety Regulations 1992 and the Health and Safety
(Workplace) Regulations 1992. These also require employers to assess risks arising
from the nature of the work or the equipment used. It is reasonable to assume that
staff who use similar equipment may be exposed to similar risks, even though
technically their equipment is excluded from the Display Screen Regulations.
Who is a user?
A user, in terms of the Regulations, is defined as 'an employee who habitually uses
display screen equipment as a significant part of his normal work'. However, some
of the employer's responsibilities extend to users employed by others or to the self
employed who work in a similar way to users on the employer's premises or
equipment..
In terms of health, the most widespread problems are visual and muscular fatigue
and stress, all of which are related to the duration and intensity of work. It is self
evident, although often not fully appreciated when work is planned, that the harder
and longer you work the more tired you become. Thus the main focus of the
Regulations is to protect those most at risk ie prolonged, intensive users. However,
it is not just hours of display screen work which are important.
The Guidance published with the Regulations identified a number of factors whichshould be considered in cases where there is doubt about whether an individual
should be considered as a user.
These include:
degree of dependence on the equipment to do the job lack of discretion over whether to use display screens or not use of special skills or high levels of attention or concentration use most days for more than one hour at a time
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If most of these apply, then they suggest that the individual should be classified as a
user.
One of the basic principles of ergonomics is that the workstation should be
designed around the user's tasks. The most frequent or critical activities should takeplace within easy reach and without undue stretching or twisting. Thus in thinking
about who are users, we should ask ourselves if it makes sense to organise their
workstation around the display screen work.
If their primary task (or tasks) involves display screen use, then they are clearly
users.
Typical jobs types which are likely to be considered as users include:
telesales staff entering customer orders into a computer based sales system data entry operators insurance clerks maintaining computer based records engineers designing components on a CAD/CAM system dealers using multiple display screens to access financial markets and to process
transactions
journalists writing their copy or editing on display screens.
PHOTO 3.1 NEAR HERE
If their use of the display screen is very infrequent, of short duration and incidental
to their main tasks, then they are not users, for example, a manager who uses a
display screen to check the company's share price once a day for a few minutes, a
salesman who only occasionally refers to a computer based price list or a doctor
who briefly accesses pharmacy records.
If it is not clear, then a more detailed analysis may be required. In many cases, it
may be more practical to consider everyone with a display screen on their desk as a
user unless there are good reasons for excluding them. Also excluded are those
who are simply manufacturing, selling, maintaining or cleaning the equipment, rather
than using it themselves.
But for many organisations, it makes little sense to be restrictive in defining users.
The managerial and administrative burden of distinguishing display screen equipment
users and others can be considerable, given the reality that display screen work is
increasing and rapidly displacing other types of office work.
Any definition or formula based on the amount of time spent on 'display screen
equipment work' immediately runs into enormous difficulties of definition, for
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example, what about time spent not looking at the screen? if a telephone call
interrupts the work should allowance be made? must the screen be switched off?
The administrative burden in monitoring such matters will encourage many
organisations to regard the Regulations as applying to all staff who use display
screens in the conventional sense of the word.
The same factors which affect our decision to classify individuals as users under
the Regulations, also apply to the self employed operators.
3.2 Identify display screen equipment and exclusions
The Regulations define display screen equipment as 'any alphanumeric or graphic
display screen, regardless of the display process involved'. As written, even a 35mmslide projector used in a presentation to display text or graphics could be
interpreted as 'display screen equipment'. However, this is not the intention of the
Regulations.
The main focus of the Regulations is visual display terminals, whether based on
cathode ray tube displays, flat panel or any other display technology, whether in use
in the office, factory, control rooms or elsewhere. The Regulations are not
restricted to electronic displays and include microfiche and microfilm viewers.
The terms 'alphanumeric or graphic' display screens include line drawings, graphs
and charts but excludes displays solely for showing moving television images and
close circuit security displays. If the main use of the screen is to display text or
graphics, then it is covered, even if it also shows TV images. In general, multimedia
displays are included (which allow text, graphics, television, animation and sound to
be presented on a computer display).
The use of the term workstation can be misleading. Clearly the entire working
conditions are important in ergonomics terms. However, in the computer industry,workstation usually means a high powered personal computer and does not include
the desk, chair, environment and so on. In these Regulations, the usage is closer to
that in the furniture industry, and includes:
the display screen equipment itself, including: peripherals accessories interface software
the furniture, chair, desking and other worksurfaces the immediate working environment
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lighting acoustics humidity heating and ventilation
FIGURE 3.1 NEAR HERE
The Regulations are therefore far reaching in their scope and application. They
apply to all users and operators of display screen equipment, with a number of
specific exclusions.
drivers' cabs or control cabs for vehicles or machinery display screen equipment on board a means of transport display screen equipment mainly intended for public use portable systems not in prolonged use as part of a workstation calculators, cash registers or any equipment having a small data or measurement
display required for direct use of the equipment
window typewriters
These exclusions do not mean that ergonomics is unimportant for users of such
systems. Indeed, arguably, the ergonomics requirements in some of the excluded
areas are even more important and should be applied more stringently than in the
areas covered by the Regulations. For example, the ergonomics of a railway engine
cab, which may well contain display screen equipment, can have a direct
consequence on the safety of large numbers of passengers.
Why then are there exclusions?
The reasons are partly technical and partly historical. The Directive on which the
Regulations are based, like many measures in display screen health and safety, has
its origins in a well intentioned desire to protect display workers from the kind of
'sweat shop' conditions which were common in the early days of computing.
In these office factories, large numbers of operators would in effect work as part
of the equipment, often in physically cramped conditions, for long periods of time
without breaks and would be under considerable pressure to enter data accurately
and quickly. Such working environments and practices led to problems caused by
constrained postures, poor visual quality of screens, repetitive and intensive
keyboard operation and highly paced and controlled patterns of work. Similar
problems to those experienced in industrial assembly lines.
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Many of the specific requirements in the Directive and in its Annex still reflect such
a concern. However, the technology has moved on and there are many other types
of workstation using display screen equipment. Although the same general
ergonomics principles apply, the specific requirements and their importance relative
to other factors vary.
PHOTO 3.2 NEAR HERE
Thus, for example, although control cabs for vehicles or machinery may contain a
display screen and even a keyboard which appear familiar to an office worker, the
effects of vibration and acceleration may require very different key-top sizes and
operation forces. Similarly, the requirements for safety would take priority over
other factors.
The exclusion of display screen equipment on board a means of transport is
intended to remove from the scope of the Regulations both specialised systems
involved in the operation of the transport as well as portable equipment used by
travellers eg railway passengers using laptop computers. Such users still require
good ergonomics and suitable equipment (as required under existing health and
safety legislation) but they are excluded from the specific requirements of the
Display Screen Regulations.
Display screen equipment mainly intended for public use, includes Automatic Teller
Machines in banks and Ticket Vending Machines. In some situations, eg libraries,
display screens attached to information systems for the public may also be used by
staff. Under these circumstances, they would be covered by the Regulations,
although members of the public would not count as users.
Portable equipment is only excluded if it is not in prolonged use at a workstation.
Clearly, if a personal computer is to be carried about and used frequently on trains,
planes and elsewhere, then weight and practicality may outweigh the need for the
keyboard to be separate from the display screen. However, if it is to be used for
more than one or two hours at a time, then it should be regarded as covered by
these Regulations and an external monitor (or keyboard) and suitable furniture may
be required.
The exclusion of calculators, cash registers, equipment with small data or
measurement displays and window typewriters is problematical. Regular display
screen equipment can be, and increasingly is being, used for all these purposes, and
remains covered by these Regulations. The reason for the exclusion is to avoid
unnecessary constraints on the use of pocket or desk top calculators, shop tills,
oscilloscopes, laboratory and medical equipment.
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Where the display screen is only used within such equipment and cannot be used
for other tasks, then it makes sense to exclude it from consideration under these
Regulations. However, the technology is developing faster than the regulators and
standards makers can act. For example, when the Directive was first drafted,window typewriters had one or two line displays. Nowadays, they may have ten or
more lines and are becoming indistinguishable from display screen equipment. What
seemed like sensible definitions rapidly became tortuous and misleading. If the
window typewriter displays more than a few lines of text, then it should be treated
as display screen equipment and meet the minimum ergonomics requirements, for
example by having the keyboard tiltable and separate from the screen.
The essential point is that good ergonomics depends on the tasks of the users, the
environment and other contextual factors. Employers still have obligations underthe Workplace (Health, Safety and Welfare) Regulations 1992 and the Provision and
Use of Work Equipment Regulations 1992 to provide safe work equipment even
where the items are excluded under the Display Screen Regulations. It therefore
makes sense to follow similar ergonomics guidelines in buying or installing such
equipment, for example, ensuring that displays are legible and keyboards can be
used comfortably.
Are there special requirements?
When identifying which display screen equipment is covered by the Regulations, be
aware of special requirements which may affect the appropriateness of the
minimum requirements specified in the Schedule. The most important obligation is
to ensure that the use of the display screen equipment does not pose a risk for the
health of the user.
In some tasks or environments, or for some users, the Schedule may be
inappropriate. In a chemical plant control room, it may be necessary to cover
keyboards with plastic membranes to avoid sparks or to protect them fromcorrosive chemicals. These may be more important safety requirements than
ensuring that the keyboard has a good typing action. Some users may have specific
requirements which should be accommodated. For example, users in wheelchairs
or with disabilities may require special adaptations to the workstation in order to
comply with the spirit of the Schedule.
PHOTO 3.3 NEAR HERE
In other environments, the safety of the public may override concerns about the
comfort of the individual. For example, an emergency control display may have alimited range of adjustment to avoid it being turned down too much or an
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emergency keyboard may not be detachable from its screen to ensure that it is
always consistently accessible to all users.
The Regulations are intended to be applied intelligently and with common sense. If
in intepreting these requirements, they seem neither reasonable nor practical, thenyou have probably misunderstood them. They are broadly in line with the previous
HSE Guidance on the subject and existing duties under the Health and Safety at
Work Act, and largely make explicit what was previously implicit.
Action list
Identify all display screen equipment in use Identify all display screen equipment users
Determine possible exclusions Establish which workstations have special requirements Assess the costs and benefits of applying Regulations to all staff Assess the costs and benefits of applying Schedule to all workstations
3.3 Update existing health and safety policies
It is a statutory duty for employers with more than 5 employees to have a written
health and safety policy. This should therefore be updated to include the obligationsunder these Regulations. Some organisations will find that they already address
many of the requirements and will need to change little. Others may find that
although they already do much that is required, they fall short in some areas, for
example they may not keep adequate records.
Other policy issues which may need to be reviewed include financial and physical
write-off periods for display screen equipment and workstations. It is quite
common for computer equipment to be written-off financially in three years and
physically in four or five. Replacing it early to meet the minimum requirements istherefore unlikely to be a major problem. However, furniture is expected to last
much longer and any replacement justified much more carefully. Nonetheless,
retaining a mixture of suitable and unsuitable furniture or equipment places an extra
load on management to ensure that it is used correctly. Some organisations may
choose to avoid this problem by bringing forward replacement schedules.
PHOTO 3.4 NEAR HERE
There are three obligations in the Regulations which some companies already
address in their health and safety policies. These concern the requirement to:
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plan display screen work to provide regular breaks or changes of activity
offer users eye and eyesight tests and, if necessary, special eyesight correction
inform, train and consult users
We discuss the implications of these policy issues next.
3.3.1 Plan display screen work to provide regular breaks or changes of
activity
It is self evident that the longer people work at a display screen, the more fatigued
they will become and the less productive they will be. Breaks, ideally before the
onset of symptoms, can reduce fatigue or help to avoid it completely as well as
maintain productivity.
Prolonged display screen work, like any other visually demanding work, is tiring on
the eyes. Breaks or changes of activity are necessary to allow users to focus at a
distance and relax their eye muscles. Most of the visual work takes place with the
eyes focused at around 500 to 600 mm. Opportunities to re-focus at a distance
restore the natural longer focus of the eyes and reduce muscle tension.
FIGURE 3.2 NEAR HERE
Display screen work also encourages fixed postures. Using the keyboard virtually
fixes the position of the hands. Reading the screen determines head position and
sitting on a chair locates the rest of the body. There is little scope for movement
and with increasing facilities available through computer systems, little opportunity
for the incidental breaks which accompanied paperwork, eg collecting files, changing
paper in typewriters, referring to ledgers and so on.
To make matters worse, the postures people are forced to adopt when using
displays are sometimes awkward and involve twisting and stretching as people
adjust themselves to suit the technology and workstation layout. But even when
seated, the muscle system has to work to support the head, to hold the body
upright, to keep the arms and hands in the right position to operate keyboards and
so on. Surprisingly, this static muscle work is more tiring than the dynamic muscle
work involved in walking, lifting and moving about. In static postures, there is less
opportunity for the chemical by-products from muscle contraction and extension of
muscles to be flushed away and they build up and produce pain.
A further reason for introducing breaks or changes of activity is to reduce stress by
interrupting the intense concentration which often characterises display screen
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work. Many people find computers almost addictive and get 'carried away' not
realising that they have been working intensely at the screen for several hours.
Unfortunately the short term productivity gains tend to be diminished by the fatigue
and discomfort which such patterns of work produce.
Thus introducing breaks or changes of activity (which use different skills, muscles,
postures etc) not only contributes to user health and well-being but actually
increases productivity.
What breaks are required?
Early research on working time at display screens looked at how performance and
discomfort were affected by up to four hours of work. This was the maximumperiod of time studied in the experiments. The results showed that after four hours
work subjects were tired.
These findings have been used to substantiate the view that four hours should be
the maximum amount of time for display screen work. However, such an arbitrary
period of work time is inappropriate for several reasons.
First, work at a display screen varies enormously in intensity, visual and mental load
and postural strain. Some display screen work is so demanding that breaks arerequired after 30 minutes eg air traffic control. Other work is little different from
any other office type activity.
Secondly, there is considerable research evidence that it is not only the total time
that is important but also the pattern of work. Thus short, frequent, breaks taken
before the onset of fatigue may allow users to work without problems for a normal
working day. For example, a 5 to 10 minute break after 50 to 60 minutes intensive
display screen work is likely to be more effective than a 15 minute break after 2
hours. Indeed, even a 1 to 2 minute break, taken at the workstation can berecuperative and avoid the build-up of fatigue.
FIGURE 3.3 NEAR HERE
Imposed break schedules and fixed working times may be appropriate in some
environments eg in a data preparation office where opportunities for natural breaks
are limited due to the restricted variety of different activities taking place. However,
in other environments, imposing breaks would actually be a significant source of
stress. Engineers involved in complex calculations or journalists working to meet
tight deadlines do not relax and reduce their stress by being prevented fromworking at fixed times or at a time which clashes with their tasks.
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Furthermore, rigid rest break regimes require precise timing of display screen
work. This in turn requires precise definition of display screen work and raises
more problems than it answers. It has led to the kind of 'rule driven' extremes
where bizarre work patterns have been created with staff switching off theircomputers after every use so that work time can be calculated precisely.
The final result of such extreme regimes may be the exact opposite of what the
Directive and hence the Regulations are aiming to achieve. Rather than improve the
quality of display screen work, it may result in the work being tightly defined,
closely monitored and externally controlled - the very factors which most research
shows reduce job satisfaction and cause stress.
What is required is a corporate culture where staff take appropriate breaks, ideallybefore the onset of fatigue and under their own control. However, staff should be
discouraged from skipping short breaks and amalgamating them into a few long
breaks. These are much less effective at avoiding undue fatigue. Indeed, employers
have a responsibility to ensure that staff take suitable breaks and may, in some
circumstances, find it necessary to set out minimum break patterns.
However, the responsibility to plan display screen work does not imply a need for a
precise timetable of display screen work and breaks. Providing a degree of flexibility
and some training to encourage users to organise their own work patterns will notonly satisfy the statutory requirements but is likely to be more productive and
effective.
Suitable activities in breaks
It should be obvious that the changes of activity or breaks must involve different
types of activity, postures and skills. It is certainly not appropriate to regard
switching from display screen work to playing a computer game or reading
electronic mail on the same type of equipment as a suitable break.
Take frequent breaks from intensive display screen and keyboard work.
Consider:
gentle exercise walking about stretching looking into the distance
to help you use different muscles in the hands, arms, back and eyes
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Avoid:
computer games similar tasks eg checking email fine manual activities eg knitting too much tea, coffee or smoking
to get maximum benefit from the break or change of activity
Similarly, non-display screen work may involve similar postures or skills and
therefore what is required is a completely different activity. Staff who work
intensively on keyboards may find that activities such as knitting during breaks do
not provide sufficient relaxation for the arms and wrists. Tea and coffee breaks are
obviously helpful but again care should be taken to avoid excessive consumption ofcaffeine or clearly unhealthy activities such as smoking if the objective is to protect
and promote health.
Should breaks be forced by software?
Controlling work time at display screens can be difficult and even when
management wish to encourage users to take breaks, it is not clear how this can be
achieved. Software packages have been developed to calculate keyboard 'idle time'so that they can lock the keyboard and hence force staff to take 'rest breaks'.
This is a result of a complete failure to understand the reasons behind rest breaks
and the importance of control in users' perception of pressure and stress. The
purpose of breaks is to allow people to use different muscles and skills and to
receive some respite from machine intensive work. Such software treats the human
beings as little more than another component in the system and is likely to
encourage inappropriate management styles and staff attitudes.
Action list
Identify jobs which solely involve display screen work Assess scope for building in more variety in skills and tasks Review facilities for rest breaks away from workplace.
3.3.2 Offer users eye and eyesight tests and, if necessary, special eyesight
correction
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The purpose of this Regulation is to prevent users from experiencing problems as a
result of uncorrected visual defects, not to protect their eyes from the display
screen.
One of the early concerns about display screen work was that it could lead to longterm damage to eyes or eyesight. Studies of users over several years have not found
any evidence of such effects. There is evidence of short term visual discomfort and
this should be avoided by good ergonomics design of displays and working
environments as well as appropriate work patterns.
Inadequate visual correction may be a source of additional strain. Therefore it
makes sense to ensure that users have any visual defects corrected before display
screen use and their eyes checked at regular intervals.
Surveys have shown that, at any one time, approximately 30% of the working
population have an uncorrected or under-corrected visual defect. On starting
display screen work, such staff may report discomfort, seek an optometric
examination and discover that they require corrective glasses. This leads them to
believe that their eyes have deteriorated as a result of display screen use. For a
number of years, many employers have offered some form of testing before use to
prevent such misunderstandings.
What tests are necessary?
The Regulations give users an entitlement to an appropriate eye and eyesight test to
be provided by their employer (in the absence of free tests under the National
Health Service).
In Great Britain, this means a 'sight test' as defined in the Opticians Act 1989. The
sight test includes an examination of the eye as well as a test of vision. Only
registered optometrists or medical practitioners are entitled to perform such tests.Employers may offer this entitlement by arranging for users to visit an optometrist
or medical practitioner individually or by providing facilities at their own premises
for a visiting optometrist or occupational health physician.
If the 'sight test' indicates that the user is suffering eye injury or disease, then they
will be referred to a registered medical practitioner for arrangements to be made
for an opthalmological examination (under the General Optical Council Rules, SI
1960 No 1936). These examinations are free of charge under the National Health
Service.
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If the 'sight test' identifies a requirement for 'special corrective appliances' for
typical display reading distances (usually spectacles), then these must be paid for by
the employer.
Can visual screening be used?
Visual screening using a specially designed screening machine can be useful for
identifying individuals with defective vision who require a sight test. Screeners do
not, however, identify eye injury or disease although they will detect such
conditions if they affect vision, nor do they detect all visual defects or measure
them.
Some employers already offer or even require employees to undergo screening and
in such organisations, some users may use the results of the screening to decidewhether they wish to exercise their entitlement to a full sight test. It is important
that screening instruments are capable of testing at appropriate display screen
reading distances (500 to 600mm) and that users are advised about the results and
the limitations of screening tests. The screening instrument operators should have a
basic knowledge of the eye and its function. The test results and the need for
further referral should be assessed by those with medical or paramedical skills (eg
doctors, occupational health nurses etc)
Screening may be offered as a precursor to a sight test but cannot be used torestrict the entitlement of a user to a full sight test.
When, and how often?
Existing users at 1st January 1993 were entitled to a test as soon as practicable after
that date. The employer must also provide, if requested, tests for employees who
are to become users and for users who are experiencing visual difficulties.
Under the Regulations, users are entitled to tests at regular intervals, which shouldbe based on the guidance of the optometrist or doctor. The British College of
Optometrists has produced a Code of Practice to guide its members on
appropriate frequency and other matters relating to testing display screen users.
Note that the employer is only responsible for examinations or corrections which
are directly related to display screen work, not for the normal eye care of the user.
What are special corrective appliances?
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Many users read their display screens at a distance from the eyes of around 500 to
600mm. This can be an awkward distance for some users who need glasses with a
limited depth of field for normal reading or for long distance viewing. Some users
who wear bifocals may find that the height of the screen is difficult for them. Thus
the Regulations require employers to provide special glasses if required for suchusers.
Only a minority of users who require glasses will require such 'special corrective
appliances'. Estimates vary, and it will depend on the age of the users, but typically
no more than 10% of users overall should require special glasses.
FOR QUALIFYING USERS EMPLOYERS MUST PAY FOR
eye and eyesight test basic prescription glasses for DSE reading distance (where normal reading
glasses are unsuitable or not required)
EMPLOYERS ARE NOT OBLIGED TO PAY FOR
normal reading glasses designer frames anti-reflection coatings tinting (but may choose to as a staff benefit)
The employer's liability for the costs only extends to a basic appliance of a type and
quality adequate for its function. In practice, users may choose more costly
appliances (eg designer frames or anti-reflection coatings) or combine correction
for display screen work with correction for other activities. In such cases, the
employer is only required to pay the costs attributable to display screen work.
However, some employers may choose to be more flexible in their interpretation
and regard such costs a staff benefit.
Note that special corrective appliances do not include specially tinted 'VDUglasses', which may be little more than fancy sunglasses with a hefty price tag.
Some recent research has suggested that people who experience headaches and
discomfort from flicker sensitivity may find tinted glasses helpful. This is largely a
problem with fluorescent tubes, though the flicker itself (at 100Hz) is not obvious
to the naked eye, even in the periphery of the visual field which is most sensitive to
flicker. The brain registers the 100 Hz signal of the tube and the effects of this
flicker can be reduced by reducing the brightness of the lighting by turning it down
or by using tinted glasses. Some so-called 'VDU' glasses do improve on this effect byselectively suppressing the certain wavelengths common in fluorescent lighting.
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However, some suppliers go further and claim significant benefits for display screen
use. This is far more questionable and seems unjustified on current evidence.
Certainly claims such as '*** enable employers to legally comply with the regulations
instantly and inexpensively' are misleading and ridiculous.
As with other provisions in these Regulations, a common sense approach may
result in some of the entitlements being extended to other staff. Many employers
already provide eye care under the Protection of Eyes Regulations and regard such
benefits as appropriate for ensuring a healthy, comfortable and efficient workforce.
Action list
Review policy on the provision of eye tests
Consider offering testing in-house Identify suitable optometrist(s) Negotiate rate and level of service required Ensure users are aware of provisions Monitor take-up Monitor results especially special corrective appliances Arrange re-testing at suitable intervals
3.3.3 Inform, train and consult users
Employers are required by the Display Screen Regulations to provide information
to all users and operators working in their undertaking. In addition, they must
provide training for their own employees who are users.
The Management of Health and Safety Regulations 1992 make it clear that health
and safety should involve co-operation between management and staff. Both parties
have responsibilities and duties. However, for the staff to carry out theirresponsibilities, they must receive training and information in all aspects of
ergonomics and health and safety which relate to their display screen equipment
workstation.
Many organisations already provide such training and benefit from it, both in terms
of productivity and staff well-being. Employers must also inform users and
operators of the results of their assessments of workstations, of any risks identified
and of any remedial actions taken. The modern office is becoming more complex
and staff need additional skills to get the best out the organisation's investment inthe workstation.
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There are many well documented examples of surveys where the problems
experienced by the users could be solved completely if they only knew how to use
the equipment and furniture that they already possess. It is all too common for
display screen equipment users to suffer backache because they did not know howto adjust their expensive, ergonomically sound, chair.
PHOTO 3.5 NEAR HERE
Under the Management of Health and Safety Regulations, employers have a
responsibility to provide information on risks to health to all their own employees,
the self employed and the employers of anyone working on their premises. The
Display Screen Regulations go further and require employers to provide specific
information on risks, assessment results including any remedial action, breaks,
training and the provision of eye and eyesight tests to employees who are users.Other users and operators using their equipment or on their premises should be
provided with similar information, although the eye tests and information about
them are the responsibility of their employers.
What should training cover?
Regulation 7 requires employers to ensure that all users who work in their
undertakings receive health and safety training before using display screens and
whenever the workstation is substantially modified.
The training is in addition to any training required simply to perform the work
although in practice there is obviously some overlap. For example, keyboard
training often includes some guidance on how to sit and adopt a correct posture,
ergonomics training will usually promote efficiency as well as health and comfort.
The level and extent of the training will depend on the users and their tasks. For
some users, where the level of risk is low, a video followed by guided discussion
may be sufficient. In other situations, a formal classroom session will be moreappropriate. The more extensive the training, the more the user can take
responsibility for assessments and for avoiding potential risks at source.
The training should concentrate on reducing or minimising the visual, postural and
stress risks and should emphasise the importance of the user's role in health and
safety.
In particular, the training should help the user:
understand their entitlements and responsibilities under these Regulations
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understand and identify potential visual, postural and stress risks know the importance of changing postures to avoid discomfort use adjustability in equipment, furniture and environment appropriately organise their own workstation to avoid awkward and constrained postures set up their screen to avoid glare and reflections keep their screen clean and properly adjusted organise their own work patterns and breaks (where possible) find out who to contact if they experience problems or need help (eg to replace
a broken chair)
take part in assessments (if the training is sufficiently detailed, the users may beable to conduct the assessment and document it themselves)
Who is competent to offer it?
There are several public and commercial training organisations which offer suitable
ergonomics training aimed at users, at potential assessors and managers. As with
any training, it is important to ensure that those providing the training have the
necessary expertise. Unfortunately, anyone can call themselves an ergonomist just
as anyone can call themselves an engineer.
However, there is a professional body - The Ergonomics Society - and it has a
register of recognised practitioners who have to be professionally qualified inergonomics, have relevant practical experience and are bound by a code of practice.
(Information on how to contact the Society is given in Appendix B) Of course, you
can get good advice and training from other sources also. Many suppliers of display
screens and furniture will provide training if you buy their products. Although, if it
comes free with the furniture, it is unlikely to be completely unbiased or
independent.
Forms of consultation
The original Directive had an Article which dealt specifically with involving and
consulting staff. This has not been transposed in the British Display Screen
Regulations - not because consultation is not important - but because it is also
covered in the Management of Health and Safety Regulations 1992. The Directive is
a component of the Social Programme within the European Community which
encourages more co-operation between employers and employees - a principle
already enshrined in British Health and Safety legislation.
Consultation does not necessarily mean that managers must incorporateemployees views. However, organisations which have adopted a co-operative
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approach have found it much more successful. In some organisations, display screen
work has been a source of dispute between managers and staff and it is clear that
this is both unnecessary and unhelpful.
Staff consultation is a vital ingredient in achieving safe, comfortable and effectiveworking conditions. However, mechanisms for consultation through representatives
or committees may not be adequate for the additional load these and other recent
Regulations will bring. Procedures should be reviewed to ensure that display screen
health and safety do not become an industrial relations football.
In unionised workplaces, Trades Union Safety Representatives can play an
important part in encouraging a positive attitude to health and safety and in
identifying and reducing risks.
Action list
Establish what information and training is already provided Collate information on publicly provided training Assess range of training requirements for different users Plan training programme for users and assessors Monitor effectiveness and take-up of training
3.4 Review current practices and determine appropriate action
There is little that is in the Regulations or the Schedule that was not already
required under the Health and Safety at Work Act (1974). However, the
obligations are now much more explicit and even good employers may find that
they need to make some changes.
The two main obligations are to:
assess workstations and reduce risks
ensure workstations meet minimum ergonomics requirements
We discuss these below.
3.4.1 Assess workstations and reduce risks
Every employer must make a suitable and sufficient assessment of the risks to the
health and safety of all users and operators working on display screen equipment in
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his undertaking. Any such risks identified must be reduced to the lowest extent
reasonably practicable.
The concept of risk assessment and reduction is common to all the Regulations
transposing the Framework and its daughter Directives. The employer has anexplicit obligation to assess risk and not simply follow up employee complaints or
accident reports. This proactive approach aims to prevent a risk, eg from an
unstable chair, resulting in injury or ill-health eg backache. Thus the assessor aims to
identify potential problems and prevent them from escalating. Of course, someone
may sit on a faulty chair and through good luck avoid an accident or injury
occurring. The purpose of risk assessment is to avoid relying on luck.
What are the risks from display screen work?
The principal risks identified in the Guidance accompanying the Regulations concern
musculo-skeletal problems, visual discomfort and mental stress.
Musculo-skeletal problems, ie problems in the muscles, tendons, nerves and
joints, can arise from prolonged intensive work in awkward or constrained
postures. Display screen work encourages fixed postures, which are sometimes
awkward as people adjust themselves to accommodate the technology, the
furniture or the environment. Even when seated, the muscle system has to work tosupport the head, to hold the body upright, to keep the arms and hands in the right
position to operate keyboards and so on. Surprisingly, this static muscle work is
more tiring than the dynamic muscle work involved in walking, lifting and moving
about.
FIGURE 3.4 NEAR HERE
These musculo-skeletal problems may be no more than short term aches and pains,
a normal occurrence after muscle work, or they may develop into chronic
disorders loosely referred to as 'RSI' - repetitive strain injuries. Although theprecise cause of such problems are often unclear in individual cases, avoiding
prolonged and excessive short term discomfort are key factors in risk reduction
and problem prevention.
Although properly conducted scientific studies in a number of countries show no
long term damage to visual function, short term visual discomfort is common
amongst users of display screen equipment. Such problems typically arise from
insufficient attention to ergonomics in equipment design leading to poor image
quality, inadequate control over natural light - especially direct sunlight,
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inappropriate artificial lighting, prolonged visually intensive work without any
opportunity to rest the eyes and to uncorrected visual defects.
FIGURE 3.5 NEAR HERE
The risks ofmental stress are more difficult to assess but include stresses fromenvironmental problems such as insufficient ventilation as well as poor job design,
'unfriendly' computer interfaces and organisational problems. There is a growing
body of literature on the importance of designing jobs, not just display screen jobs,
to take account of human needs. Many display screen jobs are the result of
software design decisions taken for reasons of computing efficiency and may take
little account of such human needs as autonomy, self esteem, variety, control over
work pace or social interaction.
FIGURE 3.6 NEAR HERE
Although most of these risks do not appear to result in permanent damage to
users,
such problems should be regarded as health problems and should be avoided where
possible by appropriate ergonomic design, not only of the display screen equipment,
but also of the workstation, the working environment, the job and organisational
factors.
Pregnancy problems
One of the most emotive occupational health issues in recent years has been the
suggestion that prolonged display screen work may have an adverse impact on
pregnancy. The main impetus for this suggestion was the reporting of clusters of
adverse outcomes. Several studies have demonstrated that statistical chance is quite
sufficient to explain the reported clusters.
However, reassuring though such explanations are to those who are not pregnant,
there was no guarantee that chance was the correct explanation. Many reliable
epidemiological studies have now been conducted world-wide on long term display
screen workers and these have failed to find any link between miscarriages or birth
defects and display screens.
The National Radiological Protection Board considers that radiation from display
screens does not put unborn children at risk. The current occupational health view
is that there is nothing about display screens which should prevent a pregnant
woman from using them safely.
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Some pregnant women may still be concerned and though they are able to accept
the risks of crossing the road, driving a car or even smoking, may feel unwilling to
accept the risks of display screen work. However, the right of transfer to non-
display screen work is not only unrealistic in many organisations (especially withdisplays becoming widely used as a general office tool) but may actually be counter
productive and create anxiety. There is no guarantee that any other work to which
a pregnant woman might transfer would pose any less risk to her baby. Lifting heavy
weights, prolonged standing and even unemployment may be more risky.
Many women find it difficult to carry out their normal duties during pregnancy and
responsible employers should be helpful, sympathetic and flexible whether the work
concerned involves display screens or not. In some situations, transfer may be the
right solution but the problem is one of coping with the demands of pregnancy notdisplay screen work per se. Women who are pregnant or planning children and are
worried about display screen work should be given the opportunity to discuss their
concerns with someone adequately informed about the issues and the scientific
evidence.
Health issues research and uncertainty
It is in the very nature of research that new findings disturb the status quo and
reveal shortcomings in our previous understanding of a problem area. Display
screens are no exception and so it is not only inevitable but highly desirable that
researchers should continually question our assumptions and seek out relationships
which we had not previously appreciated. This has two major consequences for
user organisations.
First, it is essential to monitor this research and to be willing to admit that our
understanding and assumptions may indeed be invalid. We must avoid the kind ofcomplacency which has given some of the medical establishment a tarnished
reputation in the past. At present, the evidence on radiation, for example, indicates
that display screens do not pose a hazard to health. But we must never use this as
an excuse for ignoring legitimate concerns or new research findings. Keeping up
with research knowledge is therefore an essential part of an organisation's display
screen equipment health policy and is required by the Regulations.
Second, the recognition that we cannot be absolutely certain about anything should
not be interpreted to mean that we must wait and see. Of course display screenuse may carry some risk but then again so does everything else. We should not
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ignore any risk but until we know exactly what the risk is, if any, we should avoid
precipitate remedial action which may actually increase the overall danger rather
than reduce it. For example, adding additional circuitry to a CRT to reduce stray
electric fields to the extent that image quality is reduced. As far as display screen
use is concerned, it is sensible to accept some uncertainty but to minimise theknown risks as far as is reasonably practicable.
What does an assessment involve?
Employers must assess the risks, primarily musculo-skeletal, visual and stress
related, which users (whether employed by them, others or self employed) may
experience as a result of display screen work in their undertaking.
Therefore individual workstations must be assessed, if they are used by any of these
people. If users share a workstation on different shifts, the workstation must be
assessed for each user. This may sound like unnecessary perfection but it is really
just common sense. What poses a risk for one user may be completely safe for
another and vice versa. For example, a desk leg which restricts posture for a long
legged user, may be so far away from a short user that it poses no risk.
The risk assessment involves: identifying potential hazards evaluating the likelihood and severity of the risk
It should identify undesirable features of the workstation as well as note the
absence of desirable features.
The guidance supporting the Regulations points out that a suitable and sufficient risk
assessment should be systematic, appropriate, comprehensive and must involve the
user.
It should be systematic in assessing all relevant risks, especially those which may not
be obvious at first. For example, users may complain about draughts and cold feet
when the real problem is that when they sit high enough to key comfortably, the
front of their chair restricts the circulation of warm blood in their legs. The
solution may be to provide a suitable footrest so that they can support their feet
comfortably and key in comfort.
The assessment should be comprehensive and cover the ergonomics of the: display screen equipment (hardware and software)
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desking and work surfaces physical environment
as well as
job design work organisation individual factors which may affect risks to health.
Finally, the assessment should be appropriate to the level of risk. If staff work
intensively with display screen equipment, performing highly complex work with
little variation and frequently complain of problems, then a detailed assessment will
be required. Whereas for a manager who uses a personal computer to revise his
budget on a spreadsheet at his own pace and with control over his own
environment, a much more modest assessment may be sufficient. The technologymay be similar or even identical but the nature of the task and the circumstances
quite different.
The risks depend on the users and their tasks, not just on external factors. Thus an
office which appears bright and airy to a visitor may cause severe glare problems to
a user who has to concentrate on fine screen detail or may feel draughty to users
who have little opportunity to move away from their workstations.
Thus it is vital that the assessment incorporates information from the user. Oneway of achieving this is to provide users with a brief checklist which, with training,
they can use to set-up and assess their own workstation. An example of such a
checklist is shown in Appendix A1.
In some low risk situations, this may be all that is required. In other sit