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Corrugated Box Medical Surveillance Requirements

Extracts from the “Occupational Health and Safety Act 85 of  1993”

  • The Act requires the Employer to identify hazards (8.2(d)) within the workplace and making arrangements for ensuring as far as reasonable practical to eliminate or mitigate any hazard to the safety and health of employees. 8.2(c).
  • Hazard in the definitions (Section 1) is defined as “a source of or exposure to danger”
  • Occupational hygiene falls within the hazard definition of the Act.
  • Section 43 authorizes the Minister to publish regulations in the interest of health and safety.

Medical surveillance are specifically required in the following regulations :

  • Hazardous chemical substances regulation – Dust
  • Noise induced Hearing loss regulation – Noise

The act defines medical surveillance in the section 1 definitions  as ”a planned program or periodic examinations of employees by an Occupational Health Practitioner or in prescribed cases by an occupational medicine practitioner”

Regulation – Noise induced hearing loss

  • Regulation 307 – If an of average 85db noise level over a period of 8 hours is exceeded hearing audiograms must be performed in terms of this regulation.
  • Where  105db noise level is exceeded 6 monthly medical audiograms are required.
  • Examples of DB measurements within a corrugated factory are as follows:
  • Exposure workers working on a Board Machine –     105 DB
  • Exposure workers working on a Rotary diecutter  – 90 DB
  • Exposure workers working on a Casemaker  –            85 DB
  • Exposure workers working on a Forklift          –            87 DB

The level of noise must be mitigated by physical actions on the machines to limit the noise levels or if not practical the use of Hearing protective devices (HPD)

  • Practical everyday examples on noise levels are as follows:
  • Over 160 db – Immediate physical damage – ie artillery fire, shotgun or fire cracker within 1m
  • Over 130 db – Immediate pain – ie oxygen torch or compactor
  • Over 115 db – fast acting hearing damage in short period – ie plane take off 10m
  • 100 db – A rock concert and loud music on earphones falls into this category
  • 90 db – Angle grinder 1m distance
  • 80 db – very loud traffic noise
  • 60 db – normal conversation
  • 25 db – Sound of breathing 1m distance
  • Guidelines used in the mining industry indicates hearing loss (no protection) under the following circumstances:
  • 97db – damage if exposure more than –              0.5 hours
  • 94db – damage if exposure more than –              1.0 hours
  • 92db – damage if exposure more than –              1.5 hours
  • 91db – damage if exposure more than –              2.0 hours
  • 89db – damage if exposure more than –              3.0 hours
  • 88db – damage if exposure more than –              4.0 hours
  • 86db – damage if exposure more than –              6.0 hours
  • 85db – damage if exposure more than –              8.0 hours
  • Regulation – Hazardous chemical substances guidelines – Annexure 1 – Dust
  • Section 36 specifies “not all dusts have been assigned occupational exposure limits but the lack of such limits should not be taken to imply an absence of hazard”
  • In the absence of a specific exposure limit for a particular dust, exposure should be adequately controlled. Where there is no indication of the need for a lower value, personal exposure should be kept below both 10 mg/m³ 8-hour time-weighted average total inhalable dust (airborne material that enters the nose and mouth during breathing)and 5 mg/m³ time-weighted average respirable (dust that penetrates to the gas exchange region of the lungs).
  • Such, or greater, dust concentrations should be taken as the substantial concentrations.
  • A substantial concentration of dust should be taken as a concentration of 10 mg/m³, 8-hour time-weighted average, of respirable dust.
  • Definition :dust consists of solid particles suspended in the air. It arises when organic or inorganic substances disintegrate due to crushing grinding or cutting. This falls under the chemical hazard definition.
  • Occupational asthma caused by organic dust is on the list of compensatable occupational diseases (ODMW Act of 1973).
  • Regulation GNR225 PDP (Professional Driving Permits)
  • A PDP is required by all truck drivers in terms of the National Road Traffic Act no 93 of 1996 – Regulation GNR225 dated 17 March 2000. A medical fitness report is required as part of the PDP.
  • Basic medicals performed on drivers by ourselves has at times given us very disturbing results.
  • General advantages of annual basic medical testing
  • Medical conditions like high blood pressure, glucose, epilepsy is identified and employees referred to medical doctors
  • Medical report to the company on medical fitness of employees
  • Most corrugated factories need to comply with the noise induced regulation
  • The effect of dust being the respiratory test is part of the basic medical
  • Vision screening is part of a basic medical. Many employees are not wearing spectacles or the correct spectacles.
  • Record keeping of all medical tests performed

In terms of section 16  of the Act, the CEO of the company is legally responsible to ensure that the duties of this Act is properly discharged. This responsibility can be delegated but such person shall act subject to the control and directions of the chief executive officer. Non compliance is a criminal offence and substantial penalties can be imposed on the company. Compliance relating to medical surveillance is relatively simple and the benefits certainly outweighs the costs.


  • Definition: “audiogram” – We can perform these tests
  • Audiogram determine the Percentage Loss of Hearing (PLH) level of the different frequencies and will also give an overall hearing percentage loss.
  • Referral to Audiologist if loss exceed & PHL 7%.
  • WCA can be claimed if loss exceed PLH 10%.
  • Baseline audiogram must be performed within 30 days of employment.
  • This exonerates the employer from liability to the point of Baseline hearing % loss.
  • If baseline at employment is not done the PHL level is assumed to be 0%.
  • The employer may be held responsible for some of the WCA claim payable if the terms of the Act (Regulations) were not followed.
  • Definition: “competent person” We are registered at SASOHN
  • All our personnel are qualified and registered by SASOHN. Certificates can be seen on our website.
  • Definition: “instruction 171” (how to claim)
  • Where PLH (Result of Audio test) to the baseline deteriorates by more than 10% this must be reported & investigated by the company & reported to the WCA by completing form WCL1/2.
  • Definition: “noise rating limit”
  • If average 85db over a period of 8 hours is exceeded hearing audiograms must be performed.
  • If this average exceed 105db audiograms must be done every 6 months

Section 3 – Exposure to noise

  • The act forbids a person to work where noise exceeds 85db except if clause 9 & 10 are complied with.
  • This area must be called a noise zone and demarcated and employees working there must Hearing protective devices (HPD) – regulation 9.
  • The employer must also take action to limit & reduce the noise levels.
  • Regulation 10 requires for engineering measures to be taken to reduce the db Level as well as administrative measures to reduce. the number of people and the time they are exposed

Section 4 – Information and training – We can consult with your safety committee

  • Safety committee must be informed of the audio risk relating 85db areas.
  • The safety committee must monitor actions taken and ensure that equipment is used properly
  • Records must be kept of a yearly training program given to all people working in 85db and above areas.

Section 6 – Assessment of exposure – We can perform the assessment of exposure as required per regulation 11

  1. Noise assessment must be done every 2 years and the results recorded as per regulation 11
  2. Safety committee must be involved

Section 7 – Noise Monitoring We can perform the assessment of exposure as required per regulation 11

  • c. Inspection to be done by Approved noise inspection authority. Require acoustic sound level meter and must be qualified
  • a. At least 3 locations must be measured. Measure must be taken of the average height of a person’s ear

Section 8 – Medical Surveillance

  • d. Where audiogram can’t be performed a referral must be generated to ENT or audiologist.
  • 3  Audiogram must be given to employee leaving service.

Section 11 – Record – We will keep a copy of your records on our system as to comply to the law

  • Records must be held for a period of 40 years and when employer ceases business this must be handed to provincial director.

Section 12 – Hearing Protective Devices (HPD)

  • B. Requirements to store HPD devices

Section 14 – Offences and Penalties

  • Imprisonment not exceeding 6 days that can be extended 90 days if not compliant and can also be fines.

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