guide to display screen regulations[1]

8/8/2019 Guide to Display Screen Regulations[1]

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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


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.


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.


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.


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.


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.


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

guide to display screen regulations[1]

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