Group procedure

Health and medical monitoring

April 2015

Group Title: Health and medical monitoring Document no.: HSEC-C-10

Procedure Function: Health, Safety, Environment and Communities (HSEC)

No. of pages: 14

Approved : Effective: Supersedes: Auditable from:

April 2015 April 2015 Health and April 2015
medical
monitoring work
cycle

Owner: Approver: Target audience:

Global practice leader – Global head of Health, Safety, All Rio Tinto staff and
Health Environment and Communities each Rio Tinto Group
business and
function

Direct linkages to other relevant Policies, standards, Group procedures or guidance notes:
Rio Tinto management system standard; Health performance standards; HSEC performance
data recording Group procedure; Incident management Group procedure; Workplace health
exposure monitoring Group procedure.

Document purpose:
Specifies the mandatory requirements to support implementation of the Rio Tinto
management system standard: Element 13 Measuring and monitoring and the Health
performance standards, specifically in relation to health and medical monitoring.
 SUMMARY OF CORE PROCESSES

Below is a summary of the core mandatory process requirements associated with health and
medical monitoring. For detailed process requirements refer to Section II – process steps.

 Health and medical monitoring programmes must include all employees and category 1
contractors and comply with all legal and Rio Tinto requirements.
 Health and medical monitoring programmes must be based on a person’s role within the
business, their similar exposure group (SEG), the environment in which they work and the
associated occupational health and safety risks.
 Health and medical monitoring programmes must incorporate planned medical services at
defined intervals, including:
• prior to commencement of employment (pre-employment medical);
• change in role or location (pre-placement / transfer / pre-assignment medical);
• periodically during employment (periodic medical); and
• termination of employment (exit medical).

Medical examinations and biological testing must only be conducted by a physician, nurse or
other appropriate health professional, as allowed by legislative requirements.
Rio Tinto biological test limits (BTLs) or criteria (e.g. for audiometry), as provided in this procedure,
must be used, except in the case of where there are more strict legislated BTLs.
A personal occupational medical file must be maintained for each individual at risk of an adverse
health impact. All health and medical monitoring data must be recorded and stored securely in
accordance with Rio Tinto requirements and local privacy legislation to ensure medical
confidentiality is maintained at all times.
Health and medical monitoring results must be regularly validated and analysed using
descriptive statistics by relevant technical specialists.
A physician, nurse or other appropriate health professional must make a determination of
acceptability for employment based on pre-employment or pre-placement medical examination
results.
Appropriate action must be taken in response to concerns identified from analysis of periodic
medical results to ensure the person’s health is not being impacted by their job or work
environment and their medical suitability (e.g. fitness for work) remains adequate for the required
work.
An explanation of health and medical monitoring results must be reported back to the person
concerned within a reasonable timeframe from when the results are available.
Table of Contents

SUMMARY OF CORE PROCESSES ........................................................................................... 2

SECTION I – OVERVIEW .............................................................................................................. 4
Purpose....................................................................................................................................... 4
Scope .......................................................................................................................................... 4
General description .................................................................................................................... 4
Terms ........................................................................................................................................... 5
Supporting documentation ........................................................................................................ 5
Supporting technical systems.................................................................................................... 6
SECTION II – PROCESS STEPS ................................................................................................. 7
1. Monitoring programme design............................................................................................ 7
2. Conduct monitoring ............................................................................................................. 9
3. Record monitoring results................................................................................................. 10
4. Analyse monitoring results................................................................................................ 10
5. Report monitoring results.................................................................................................. 12
SECTION III - APPENDIX ............................................................................................................ 13
SECTION I – OVERVIEW

Purpose
This Group procedure expands on the requirements outlined in the Rio Tinto management system
standard: Element 13 Measuring and monitoring and the Health performance standards, to ensure
there is a common process for the development and implementation of a health and medical
monitoring programme.

Scope
This Group procedure is triggered by the requirements of the Rio Tinto management system and
Health performance standards and is mandatory for all managed businesses within the Rio Tinto
Group. It applies to health and medical monitoring of employees and category 1 contractors.

Management of health and medical monitoring for category 2 and 3 contractors should be risk based
and incorporated into the agreed scope of work to be undertaken by the contractor (Contractor
management Group procedure). Risk assessment should consider contractors working at our
operations or projects for more than 12 months, where workplace exposures are due to hazardous
agents that are likely to be of high or critical risk derived from our operations.

This Group procedure does not include industrial / occupational hygiene workplace exposure
monitoring. This type of monitoring is outlined in the Workplace health exposure monitoring Group
procedure.

General description
Health and medical monitoring programmes (also known as health and medical surveillance
programmes) are designed to enable the management and documentation of medical services for the
provision of treatment, and the monitoring of on-going health for the detection of conditions caused or
exacerbated by workplace conditions, or conditions that might be risk factors for poor adaptation
to work conditions. Health and medical monitoring programmes are designed to assess the health
of both the individual and the group (similar exposure group (SEG)).

The health and medical monitoring required to be undertaken is defined based on the role the
person holds within the business, their SEG, the environment in which they work, the associated legal
requirements and occupational health and safety risks. Medical services associated with health
and medical monitoring programmes occur at defined intervals to ensure individuals meet any specific
health requirements of their role (e.g. fitness for work) and to detect any adverse health effects due to
work conditions.

These include:

• Pre-employment medical: assessment completed prior to offer of employment to assess the

medical suitability (physical and psychological) of the person for the role and environment in which
they will work.

• Pre-placement / transfer / pre-assignment medical: assessment completed prior to the person’s

1
transfer into a new role or location which alters the exposure of the person (e.g. change in SEG),
to assess the medical suitability of the person for the new role and environment in which they will
work.

• Periodic medical: assessment completed periodically during employment to assess the on-going
medical condition of a person to determine if their role or work environment is impacting on their

1
Locational changes may include personnel placed on an international assignment.

Group procedure: Health and medical monitoring Page 4

 health and whether the person’s medical suitability (e.g. fitness for work) remains adequate for the
required role.

Note: Periodic medicals may include:

- personal protective equipment (PPE) fit testing - conducted at regular intervals to ensure PPE,
2
such as respirators, fit and are appropriate for the person and the exposure hazards.
- travel medical –conducted prior to a person’s work related travel, on return to home if there are
3
health concerns or on a periodic basis for persons required to undertake regular travel.
- fitness for work testing – where legally allowable, conducted at any time during a shift to
4
ensure the person is fit for work (e.g. drug and alcohol testing, hydration testing, etc).
- return to work medical – conducted after prolonged absence (e.g. 30 days or more) for health
reasons, to ensure the person is fit for work.

• Exit medical: assessment completed prior to ceasing employment to determine any adverse health
impacts of the work the person performed whilst employed by the business.

The required medical services are scheduled and performed; making sure the person is informed of
the purpose of the service to be undertaken. All results are recorded in the individual’s medical
file and securely stored to ensure medical confidentiality is maintained. Medical service results are
validated and analysed for quality assurance purposes and to determine compliance with legal
5
requirements and internal criteria, including Rio Tinto specified biological test limits (BTLs).
Appropriate action is taken in response to concerns identified from medical service results. This may
include a determination on acceptability for new employment or transfer to a new role / location (pre-
employment / pre-placement medical) or a change in existing role, current duties or workplace
conditions (periodic medical).

An explanation of monitoring results are communicated to the person concerned and reported to
6
management personnel in a form that respects the privacy of the individual while allowing
management to fulfil their duty of care obligations.

Terms
The definitions for all technical terms within this document are located in the HSEC definitions
database. The HSEC definitions database is found on the Rio Tinto Health, Safety, Environment and
Communities intranet portal page.

Supporting documentation
The following documents provide additional guidance in the execution of this Group procedure.
These documents are found on the Rio Tinto HSEC intranet portal page:

Document name Description

Health performance standards Group procedure

Workplace health exposure Outlines mandatory process requirements for the management of an
monitoring (HSEC-C-09) environment and health exposure monitoring programme as required
by the Health performance standards.

2
For further detail refer to Health standard H1 – Chemicals and hazardous substances exposure control.
3
For further detail refer to Health standard H5 – Vector-borne and infectious disease control.
4
For further detail refer to Health standard H4 – Fitness for work in safety critical jobs.
5
For BTL values refer to Appendix.
6
For further detail on data privacy refer to the Rio Tinto Data privacy standard, available on the Rio Tinto Compliance System
Information section on Prospect (http://compliance.riotinto.org/privacy.asp).

Group procedure: Health and medical monitoring Page 5

 Guidance notes

Medical surveillance Outlines guidance for pre-employment and pre-placement medical

examinations conducted on prospective employees, as well as periodic
health surveillance.

Incident reporting - health impacts Outlines guidance on the recording and reporting of incidents with a
health impact, including an exceedence from a biological test limit
(BTL).

Supporting technical systems

The industrial hygiene and medical monitoring (IH&MM) solution (Medgate™) is the Rio Tinto
preferred technical system for recording health and medical monitoring data. The system can be
integrated with the Rio Tinto business solution (RTBS) and is recommended for use where RTBS has
been implemented.

Group procedure: Health and medical monitoring Page 6

SECTION II – PROCESS STEPS

1. Monitoring programme design

1.1 The process and accountability required to complete health and medical monitoring, as outlined
in this Group procedure, must be documented and understood by relevant personnel.
Documentation must be readily available and regularly reviewed and updated.

1.2 Health and medical monitoring programmes must comply with all legal and Rio Tinto
requirements, and should align with appropriate national / international standards, guidelines
and industry best practice.

1.3 Health and medical monitoring programmes must support Group and business objectives and
targets.

1.4 Health and medical monitoring programmes must be based on a person’s role within the
business, their similar exposure group (SEG), the tasks which they undertake, and the
environment in which they work. The programme must be consistent with work area and
SEG occupational health and safety risks.

1.5 Biological testing / monitoring associated with health and medical monitoring programmes
must not be a substitute for monitoring the working environment and the assessment of
7
individual occupational health exposures.

1.6 Health and medical monitoring programmes must pay particular attention to workers where
risk assessments indicate the potential for exposure to high-risk hazardous substances,
including carcinogens, mutagens, teratogens and reproductive toxicants.

1.7 Workers must be encouraged to report health conditions (and associated medication
requirements and medical implants) that could affect their ability to do their job safely, or that
might be further impacted by job exposures. Where a possible increased health risk is
identified, workers must be encouraged to participate in the health and medical monitoring
programmes.

1.8 All employees and category 1 contractors must be included in the health and medical
monitoring programmes, where legally allowable.

1.9 Persons responsible for design and implementation of health and medical monitoring
programmes must be able to demonstrate appropriate competencies for assigned tasks,
through suitable training and/or experience.

1.10 Occupational physicians or medical practitioners must retain overall responsibility for medical
examinations and biological testing.

1.11 Health and medical monitoring programmes must incorporate planned medical services at
defined intervals, including:
• Prior to offer of employment (pre-employment medical);
• Change in role or location (pre-placement and pre-assignment medical);
• Periodically during employment (periodic medical); and
• Termination of employment (exit medical).

1.12 Pre-employment, pre-placement, pre-assignment and periodic medicals must be conducted in

7
Refer to the Workplace health exposure monitoring Group procedure

Group procedure: Health and medical monitoring Page 7

 the following situations:
• The proposed job has specific health requirements (i.e. fitness for work criteria);
8

• There is a risk that work conditions could adversely affect an individual’s health; or
9

• There is a legal or Rio Tinto requirement.

1.13 Pre-employment, pre-placement and pre-assignment medicals must comply with anti-
discrimination laws and be appropriate to the actual or foreseeable health risks from the
proposed role and work environment. Examinations must be related directly to genuine
requirements of the job and must not unfairly discriminate against people with disabilities or
impairments.

1.14 There must be a process to inform the appropriate personnel about changes to roles or
locations (such as new employees, transfers or departures) such that the required medical
10
services are conducted and records updated.

1.15 The specific nature and frequency of periodic medicals must be based on legal and Rio Tinto
11
requirements; considering the person’s role, work location and exposure hazards. If such
requirements do not exist or are inadequate, a risk based approach must be used to determine
the specific nature and frequency of periodic medicals, considering the person’s health risk
and the speed of progression of any illness.

1.16 Employees must undergo an examination on resumption of work after a prolonged absence
(eg. 30 days or more), where the absence was undertaken for health reasons and there is a
concern for fitness for work.

1.17 An exit medical must be offered to the employee on termination of employment in the
following situations:
• There is a possibility that health changes could have occurred;
• There is a need to document the degree of health changes during employment; or
• There is a legal requirement.

1.18 Medical clinic visits must be scheduled in accordance with the health and medical monitoring
programmes. Medical services completed external to the business should still be scheduled
internally to allow tracking of progress against scheduled requirements.

1.19 Health and medical monitoring equipment should be appropriate to the required precision,
accuracy and reliability of the required data, and should consider the appropriateness of
data backups and availability of servicing.

1.20 Health and medical monitoring methods must be consistent with local legislative and Rio
Tinto requirements and should align with national / international standards, industry best
practice guidelines and equipment manufacturer’s instructions. Monitoring methods must be
documented, including the frequency, nature of medicals and any relevant legal or internal
criteria for analysis.

1.21 The health and medical monitoring programmes should be reviewed annually by a relevant
health specialist, taking into consideration monitoring results and any changes to occupational
health risks, SEGs, work activities, the working environment, legal and other requirements
and business objectives and targets.

8
Refer to Health performance standard H4 – Fitness for work in safety critical jobs.
9
Work conditions may include workplace exposures (e.g. dusts, gases, noise etc.) as well as general environmental conditions
(e.g. thermal, altitude, malaria prevalence etc.).
10
Refer to Rio Tinto management system standard Element 11: Management of change.
11
Refer to Health performance standards and Safety performance standards.

Group procedure: Health and medical monitoring Page 8

1.22 Where a service provider or a general practice is used, standards for the level of service
provided must be established. Professional responsibility for the provision of the medical
services must also be defined.

1.23 Where SEG average exposure is greater than 85 dB(A) but less than or equal to 94 dB(A), then
audiometric testing can be 2-yearly. Where SEG average exposure is greater than 94 dB(A),
then audiometric testing should be annually. When a standard threshold shift (STS) is detected
and exposure is greater than 85 dB(A), the affected employee or category 1 contractor should
be tested annually or another frequently as determined by the site physician.

2. Conduct monitoring
2.1 Personnel must be encouraged to participate in health and medical monitoring programmes
as scheduled. Processes must be in place to track progress against scheduled requirements,
and appropriate action taken to address non-conformance.

2.2 Personnel should be informed of the purpose of medical clinic visits, what testing is required,
how it relates to their job, any potential risks and how the results will be used.

2.3 Medical examinations and biological testing must only be conducted by a qualified physician,
nurse or other appropriate health professional, as allowed by legislative requirements. Persons
performing medical examinations should be familiar with the workers job requirements and the
capacities required to perform them.

2.4 Any invasive medical examinations or biological testing must only be undertaken when
indicated by the nature of the current or future job and with the written consent of the individual.

2.5 Monitoring equipment must be maintained in good working order, undergo regular
preventative maintenance in accordance with equipment manufacturer’s instructions and be
calibrated or verified against a traceable standard at specific frequencies.

2.6 External service providers must be competent to perform the required type of medical
examination or biological testing and must maintain a credible quality assurance programme.

2.7 Where risk assessment shows a risk of a respiratory condition, assessment programmes must
include chest x-rays and/or lung function tests. The tests chosen must be able to detect any
signs of harm from the exposure of concern at the earliest opportunity. Where indicated, they
must meet the following standards:

a) High quality chest x-rays will be taken every 5 years, unless local legislation requires
these to be more frequent;
b) All chest x-rays for pneumoconiosis surveillance will be read to ILO standards by an ILO
B reader, wherever possible, and if not, by a competent radiologist using verifiable
quality criteria;
c) Any progression of more than one step on the ILO extended scheme to a reading above
1/0 will be reviewed by a physician;
d) Any reading suggesting active lung disease will be reviewed by a physician; and
e) All spirometry will be performed by trained staff following the American Thoracic Society
guidelines or equivalent and be offered at a frequency determined by the likely rate of
detectable change in lung function. The IAI / ICMM criteria for accelerated lung function
decline should be used for assessing aluminium smelter workers.

2.8 Where an audiometry programme is required, it must meet the following standards:

Group procedure: Health and medical monitoring Page 9

 a) All testing must be by pure tone audiometry in an audiometry booth or quiet room, with
measured background noise levels less than those stipulated in the relevant standard (are
dependent on the type of headphones being used with the audiometer);
b) The initial audiogram must be taken prior (minimum of 16 hours) to exposure to significant
noise. Further audiograms must be taken periodically as per clause 1.23;
c) Testing and analysis must be performed by trained and competent personnel; and
d) Audiometers must be calibrated according to the manufacturer’s guidelines. This should
include a weekly biological calibration using a member of staff unexposed to noise, or a bio-
acoustic simulator, and an annual quantitative check. All results must be documented.

3. Record monitoring results

3.1 Medical examination reports must be dated and signed by the examining physician, nurse or
other appropriate health professional. They must be legible and include a printed name to assist
with identification and authentication of the results (electronic signature is acceptable).

3.2 Health and medical monitoring data must be recorded and stored securely, in accordance
with Rio Tinto standards and local privacy legislation, to ensure medical confidentiality is
maintained at all times. Access to health and medical records must be restricted. Authorised
personnel with access to health and medical records must sign a confidentiality agreement.

3.3 A personal occupational medical file must be maintained for each individual to ensure it is
possible to report on information over the life of their employment. A copy of the individual’s
SEG monitoring data should also be maintained on their personal file or should be linked to the
file to allow easy access.

3.4 Health and medical monitoring records must be retained in line with legal requirements and
12
in accordance with the business defined data retention schedule.

3.5 If an internally scheduled health or medical service is conducted by an external provider, a copy
of the results must be requested from the provider, in accordance with local privacy legislation
and the individuals consent, and recorded in the individual’s medical file.

3.6 All health and medical records must be made available to the individual and with consent,
to their personal doctor / other health specialist upon request, in accordance with local privacy
legislation.

4. Analyse monitoring results

4.1 The processes required to validate and analyse health and medical monitoring results must
be documented and implemented, to ensure recorded data is complete, comparable, accurate,
representative and appropriate for its intended use.

4.2 Rio Tinto or local legislated biological test limits (BTLs) must be adopted where there is
significant potential risk to personnel and the BTL value is suitable to the relevant adverse
13
health effect.

Note: Rio Tinto BTL values must take precedence above all other published BTL values,
except where a lower legal limit is applicable.

4.3 Where Rio Tinto or local legislation has both a workplace environment standard (occupational

12
Refer to Rio Tinto management system standard, Element 15: Data and records management.
13
Refer to Appendix for Rio Tinto BTL values.

Group procedure: Health and medical monitoring Page 10

 exposure limit (OEL)) and a BTL, compliance with both must be achieved. Compliance with one
value must not be used to excuse non-compliance with the other.

4.4 Audiometry results showing a work-related noise induced downward shift in hearing in one or
both ears must be interpreted according to the following criteria, derived from the US
Occupational Safety and Health Administration (OSHA) Regulations (Standards – 29 CFR),
Part 1904.10:

a) An average age-adjusted loss from baseline equal to or greater than 10 dB at 2, 3 and 4 kHz
that persists on retesting following removal from noise for a minimum of 16 hours, usually
after a days-off period, must be recorded as a STS case.
b) Meeting the diagnosis of a STS and having an average non-age-adjusted loss from
audiometric zero of equal to or greater than 25 dB at 2, 3 and 4 kHz must be recorded as a
noise induced hearing loss (NIHL) case.

4.5 Health and medical monitoring results must be regularly validated and analysed using
descriptive statistics by relevant technical specialists to identify:
• Results exceeding legal requirements or Rio Tinto BTL values;
• Results inconsistent with previous records;
• Inaccurate, incomplete or unusual results (outliers);
• Trends of results over time or across similar exposure groups (SEGs); and
• Accuracy of relevant risk evaluations and effectiveness of operational controls.

4.6 A physician, nurse or other appropriate health professional must make a determination of
acceptability for new or continued employment based on pre-employment/pre-placement
medical assessment results.

Note: The decision not to employ a person on the basis of impairments or physical features
must only be made if necessary to protect the health and safety of any person (including the
candidate) or of the public generally.

4.7 Appropriate action must be taken in response to concerns identified from analysis of periodic
medical results to ensure the person’s health is not being impacted by their job or work
environment and their medical suitability (e.g. fitness for work) remains adequate for the
required work.

Note: The results of a periodic medical may lead to restricted or alternate duties, a short term
or permanent change in role, or to a change in the nature or frequency of medical monitoring.

4.8 Health and medical monitoring results that are identified and validated as not being
compliant with legal requirements or BTL values, or identify an occupational illness or a
significant result, must be managed as an incident and be appropriately recorded, investigated
14
and reported in accordance with local privacy legislation.

Note: When a confirmed non-compliance with a legal requirement or Rio Tinto BTL value is first
identified, or is unexpected, it is to be recorded as an incident. Recording of subsequent repeat
(expected) non-compliant events is not required if appropriate management strategies are in
place and recording and reporting of the incident is not mandated by legal and other
requirements.

14
Refer to the Incident management Group procedure and guidance note: Incident reporting for health impacts, and the HSEC
performance data recording Group procedure.

Group procedure: Health and medical monitoring Page 11

5. Report monitoring results
5.1 An explanation of health and medical monitoring results must be reported back to the person
concerned within a reasonable timeframe from when the results are available.

Note: If results indicate that work place restrictions or alternate duties are required, discussions
regarding modified work for the employee must be undertaken with the person’s supervisor.

5.2 Results from health and medical monitoring should be periodically summarised and
reported to relevant management personnel, outlining conformance with legal and internal
criteria, trends over time, effectiveness of operational controls and any continual improvement
opportunities; whilst respecting the privacy of the individual personnel.

5.3 Information originating from health and medical monitoring must be reported in a form that
adheres to legal requirements and respects the privacy of the individual, but enables
management to fulfil their duty of care obligations to employees. The names of individuals
must not be disclosed without their written authorisation.

5.4 If a pre-employment, pre-placement or exit medical has been conducted human resources
(HR) personnel should be advised that the service has been completed, along with the decision
as to fitness or otherwise for work.

5.5 Results from health and medical monitoring must be considered during the management
review process and revision and update of qualitative (level 2) and quantitative (level 3) risk
15
assessments.

15
Refer to HSEC risk management Group procedure and Rio Tinto management system standard Element 17: Management
review.

Group procedure: Health and medical monitoring Page 12

SECTION III - APPENDIX

Rio Tinto biological test limit (BTL) values

Agents Rio Tinto Biological Test Limit

Arsenic in urine (creatinine corrected) 50 µg/g CR (end work week)
Cadmium in blood 5 µg/L (any time)
Cadmium in urine (creatinine corrected) 5 µg/g CR (any time)
Carbon monoxide in end-exhaled air 30 ppm (post-shift)
Carboxyhaemoglobin in blood 5% (post-shift)
Chromium (VI) in urine (creatinine corrected) 30 µg/g CR (end work week)
Fluoride in urine (creatinine corrected) 3 mg/g CR (pre-shift) & 10 mg/g CR (post-shift)
Lead in blood – male 30 µg/dL (any time)
Lead in blood – female of reproductive capacity 20 µg/dL (any time)
Mercury in urine (creatinine corrected) 40 µg/g CR (pre-shift)
Uranium in urine 40 µg/L

Group procedure: Health and medical monitoring Page 13

REVISION HISTORY

Version Revision Author(s) Approver(s) Revision Notes

Date

v1.0 March 2013 Steven Delacy, Klaus Initial publication after review and
Ian Firth Eppinger, consolidation of legacy work cycle:
Manoel Arruda health and medical monitoring
(WC2040) and associated work
practices (1240-01 to 1240-04).

v2.0 March 2015 Ian Firth Manoel Arruda Adaptation of WCMS1302 and
alignment with revised Rio Tinto
management system standard and
Health standards.

Group procedure: Health and medical monitoring Page 14