POLICIES & PROCEDURES Pregnancy in the Workplace
1.
This document outlines the following areas relating to pregnancy in the workplace:
the legal responsibilities of PHI and its staff pertaining to health and safety;
the potential areas of concern for women who are pregnant or breastfeeding (being, specifically, potential transfer of hazardous substances to babies);
the procedures for reducing risks to pregnant women, unborn babies and those being breastfed; and
the responsibilities of supervisors to women who are pregnant or breastfeeding.
2. Scope
2.1 This document applies to all staff employed by PHI, and contractors engaged by PHI and their employees.
2.2 It applies to PHI-related activities performed within the premises of PHI and elsewhere.
2.3 It addresses only the occupational health and safety aspects of pregnancy
associated with PHI-related activities.
3. Legal Responsibilities
3.1 PHI is required, by the Occupational Health and Safety Act (Vic) 2004, to provide a working environment that is safe and without risks to health, so far as is reasonably practicable.
3.2 Under the Occupational Health and Safety Act (Vic) 2004, all employees are required to cooperate with employers in all efforts to provide a safe working environment. Pregnant women therefore have a responsibility to cooperate fully with any efforts made by PHI to modify their duties in order to minimise risks and maximise the health and safety of themselves and their unborn children. This responsibility to comply with implemented safety measures applies also to breastfeeding mothers.
3.3 Under the Radiation Act (Vic) 2005, it is an offence to knowingly, recklessly or negligently cause a person to receive a radiation dose greater than the prescribed safe dose limit. The Radiation Regulations (Vic) 2007 prescribe a fifty-fold lower yearly dose limit for the uterus of a pregnant woman compared with a nonpregnant woman. This prescribed dose applies to a pregnant woman who has notified the radiation license holder.
3.4 Pregnancy and breastfeeding are attributes for which discrimination is prohibited in employment by the Equal Opportunity Act (Vic) 1995. However, under this Act, discrimination against a person on the basis of pregnancy may occur if this is reasonably necessary to protect the health and safety of that person or any other person.
4. Policy
4.1 PHI maintains awareness that all women of childbearing age may possibly be pregnant at any time, and acts accordingly with respect to health and safety measures. PHI will take every possible action to ensure that the workplace conditions of women who are pregnant or breastfeeding are safe for both the women and their babies. These actions will include ensuring radiation doses are within the prescribed limit. In addition, PHI will ensure that co-workers or supervisors of pregnant women do not engage in work practices that may endanger unborn children.
4.2 PHI will not unlawfully discriminate in any way against a woman on the basis of pregnancy.
4.3 PHI may disallow particular work practices if they may pose a health and/or safety risk to a pregnant or breastfeeding person who is persisting in undertaking them. This action is permissible under the Equal Opportunity Act (Vic) 1995 and consistent with responsibilities under the Occupational Health and Safety Act (Vic) 2004.
5. General Points
5.1 All women who are pregnant, or intending to become pregnant, are advised to obtain medical advice about the work performed and the hazards involved.
5.2 The woman involved has the right to decide whether or not work with chemicals, biological material or animals will be undertaken during the period of pregnancy
and breastfeeding. This right is subject to PHI’s decision with regard to items 3.4 and 4.3.
5.3 Any concerns about possible hazards should be discussed with the supervisor. Consideration of alterations to work practices or assigned work type, possible protective measures or appropriate monitoring will then be undertaken to provide the safest work environment for the pregnant or breastfeeding woman. The agreement of the woman will be paramount for all measures to be taken, and for all arrangements for working throughout the pregnancy and breastfeeding period (subject to items 3.4 and 4.3).
6. Communication with Supervisors
6.1 Women are encouraged to inform supervisors of their pregnancy as soon as possible after receiving confirmation, accompanied by a medical practitionersupplied certificate of confinement. This will allow discussion and implementation of protective measures or altered work practices where necessary. The form provided in Appendix 1 should be completed as early as possible in a pregnancy. Copies of the completed form should be lodged with Human Resources for filing in the person’s confidential file, as well as any other relevant persons on the dates agreed to by the person. Declarations of pregnancy will be afforded absolute confidentiality, according to the preference of the woman, subject to item 7.4.
6.2 Pregnant or potentially pregnant women should report any suspected high exposures to any hazard type to their supervisor immediately, so that any possible monitoring actions or medical advice may be arranged. A Hazard and Incident Report form should be completed and submitted (http://phimr.med.monash.edu.au/forms_&_templates/OH&S/2012/OHS-122-Hazard and Incident Report FORM 2012.pdf).
7. Responsibilities of Supervisors
7.1 Declarations of pregnancy by women for the purpose of determining safe work conditions will be kept utterly confidential by supervisors, should this be the woman’s preference, subject to item 7.4.
7.2 As soon as notification of pregnancy is made by a woman working under a supervisor’s direction, a work practices assessment must be completed using the form provided as Appendix 1. Supervisors must carefully consider all aspects of the woman’s work and determine alterations or safety measures to be implemented as necessary. Risk assessments should be used, or carried out if necessary using the procedures provided on the intranet (http://phimr.med.monash.edu.au/Policies_&_Procedures.htm). See OHS 201 Occupational Health and Safety Risk Management Overview and associated documents given therein.
7.3 Potentially hazardous practices performed within the environment of the woman by others must also be examined, and changes to the practices or the woman’s proximity to them implemented as necessary. These practices and the changes implemented must be documented in the record to be completed (see Appendix 1). This record should be updated as often as necessary during a pregnancy.
7.4 Supervisors must make arrangements with the Laboratory and Technical Services (LATS) Manager if any alterations to work practices or equipment under their control are required. Supervisors must also ensure that these alterations are implemented in a timely manner. This includes informing the LATS Manager to implement monthly monitoring of the personal dosimeter worn by the woman, and
ensuring both that this occurs and that the dosimeter results are satisfactory.
7.5 Any suspected high exposure to hazards reported by the woman must be acted upon immediately. This may involve arrangement of testing or seeking of medical advice. A Hazard and Incident Report form must be completed and submitted (http://phimr.med.monash.edu.au/forms_&_templates/OH&S/2012/OHS-122-Hazard and Incident Report FORM 2012.pdf).
8. Manual Handling Work
8.1 Excessive physical work or heavy lifting may pose a risk, especially towards the end of pregnancy. If work tasks involve prolonged standing, repetitive lifting, maintaining awkward postures or manual handling of weights causing any degree of strain, medical advice should be sought.
8.2 The option of altering work so that manual handling risks are eliminated as far as possible is available to all pregnant women. This should be discussed with the supervisor without delay if this option is chosen.
9. Chemical Hazard Exposure
9.1 Teratogens are agents that cause congenital malformations, growth retardation, functional disorder and sometimes death in the embryo or foetus. A substance is generally considered to be a teratogen if it has adverse effects on the unborn child at doses below which it has adverse effects on the mother. It should be emphasised that most drugs and chemicals can be shown to cause adverse effects to the embryo or foetus (often the only data available is from animal studies), at high doses under laboratory conditions. However, this does not mean that most drugs or chemicals are considered to be teratogens.
9.2 There are thousands of chemicals that have been identified as having reproductive effects, including teratogenicity, in animal studies. However, very few chemicals have been definitely identified as teratogens in humans due to lack of test data, species differences in effects, dosages causing the effects, and severity of the effects.
9.3 Exposure to chemicals at levels below recognised exposure limits should not present a risk to women or unborn children during pregnancy or the breastfeeding period. In general, the higher the exposure (due to high frequency and duration of contact), the greater the chance and severity of an undesirable effect. Infrequent exposure to low levels of chemicals is less of a risk than frequent exposure to concentrated chemicals in poorly ventilated areas. The risk is also usually greater during the early stages of pregnancy.
9.4 Material Safety Data Sheets and labels of chemical and substances being used should be carefully examined. In particular, the terms “unborn child” and “pregnancy” should be noted with all associated warnings and recommendations for safe usage.
9.5 Inhalation is the most common route of exposure to chemicals. Conducting work in a fume cupboard that meets Australian Standard performance requirements will prevent exposure by inhalation. Be aware that biological safety cabinets will not provide protection against chemical exposure. Refer to the Standard Operating Procedures: SOP-EQ-008 Biological Safety Cabinets (Class II) and Laminar Flow Hoods and SOP-EQ-009 Fume Cupboards, which are available via the intranet (http://phimr.med.monash.edu.au/Policies_&_Procedures.htm), for further information on the structure and functioning of these units.
9.6 Skin absorption and ingestion are rarely significant routes of entry into the body, provided safe work practices such as suitable gloves and regular washing of hands (particularly before eating) are observed. Skin exposure may be a significant risk for certain chemicals that are also teratogens (refer to items 9.1, 9.2 and 9.4).
9.7 Ill-effects of chemicals and substances on breastfed children are almost entirely due to chemical exposure of the mother. This is because some chemicals that may enter the mother’s body during exposure are excreted in the breast milk. However, there is very little information available on excretion in breast milk for most chemicals. Vigilance about protection from exposure is of the utmost importance.
9.8 Information should be sought if there are any concerns about a chemical being used, or the procedures for its safe use, during pregnancy or while breastfeeding. The supervisor, the Occupational Health and Safety (OH&S) Officer and/or the LATS Manager should be consulted if assistance is needed in obtaining information.
9.9 Exposure to chemicals and substances should be minimised as much as possible by cooperating fully with any alterations made to work procedures or conditions in order to reduce the risks of exposure. In addition, particular attention should be paid to wearing and regularly changing suitable gloves, regularly washing hands, minimising areas of skin open to exposure and using fume cupboards.
10. Biohazard Exposure
10.1 Work with animals presents a risk of acquiring infections. Extra care must be taken to prevent infections that could have serious effects on foetal development. The possibility of such infections should be examined with the supervisor, and information and/or advice sought if necessary. Alterations to work practices, which may involve elimination of animal contact, should be implemented.
10.2 Consideration should be given to the existence of allergies in determining whether animal contact work should continue during pregnancy. Due to lack of data, medications against allergic symptoms are not rated as safe for administration during pregnancy.
10.3 Work with biological material should be examined for infection risk. It is expected that existing safety measures resulting from risk assessments will be sufficient in most cases. However, each case should be assessed individually.
11. Vaccinations
11.1 Vaccinations against infections, such as hepatitis B, hepatitis A, rabies, meningococcal meningitis, typhoid, Q fever and tuberculosis, may be advised for work involving exposure to particular biological material types. Ideally, vaccinations against infectious agents that may be encountered due to workrelated exposure to biological material should be obtained prior to becoming pregnant. The vaccination program provided by PHI is detailed in OHS 501 Immunisation Program which is available via the intranet (http://phimr.med.monash.edu.au/Policies_&_Procedures.htm).
11.2 Most vaccinations should not be given during pregnancy. Medical advice should be sought about the work performed and vaccination status prior to becoming pregnant, and if there are concerns while pregnant.
11.3 Some vaccinations are regarded as safe while breastfeeding. Medical advice
should be sought if vaccination is required while breastfeeding, or if there are concerns about vaccination status while breastfeeding.
12. Ionising Radiation Exposure
12.1 Levels of exposure to ionising radiation that do not harm a pregnant woman may harm a developing embryo/foetus, particularly up to 25 weeks of gestation.
12.2 The option of altering work so that exposure to ionising radiation is eliminated is available to all pregnant women. This should be discussed with the supervisor without delay if this option is chosen.
12.3 If the woman chooses to continue to perform work with ionising radiation, the supervisor will ensure any agreed protective measures or additional monitoring are implemented prior to continued exposure to radiation.
12.4 The prescribed dose limit per year for the uterus of a pregnant woman (who has notified the radiation license holder (i.e. PHI)) is 1 millisievert, which is fifty-fold lower than for a non-pregnant woman. The personal dosimeter should be worn at the level of the uterus so that the radiation dose received can be monitored.
12.5 Monitoring by personal dosimeter can be performed monthly for pregnant women. The supervisor will ensure the LATS Manager is informed to arrange this if required.
13. References
Equal Opportunity Act (Vic) 2010
Occupational Health and Safety Act (Vic) 2004
Radiation Act (Vic) 2005
Radiation Regulations (Vic) 2007
Monash University Procedures for Protecting Unborn and Breast-fed Children from the Effects of Maternal Exposure to Chemicals, Biologicals and Animals v2.1 (November 2010)
Monash University Procedures for Protecting the Unborn Child from the Effects of Ionising Radiation v2 (June 2010)
Monash University OHS Information Sheet 18: Pregnancy and Work (August 2010)
Appendix 1: Record of Notification of Pregnancy, and Work Practices Assessment and Alteration Plan
This form should be completed as soon as possible after confirmation of pregnancy, and updated as necessary during the pregnancy. As many sheets as necessary should be used to list all work practice issues. A copy of the completed form should be kept by the notifying person and the supervisor or other person involved in the work practice assessment, according to confidentiality preferences. Copies should be lodged with the Human Resources (HR) Officer and all other relevant persons on the dates agreed to by the notifying person.
Name: Supervisor:
Person(s) hereby notified:
Person(s) to be notified: □ LATS Manager □ Radiation Officer □ OH&S Officer □ HR Officer
□ Other(s):
Comments/restrictions, etc:
I agree with the work practice alterations listed above and the notification of the people listed above.
Signature of Notifying Person:
Signature of □ Supervisor or □ Person hereby notified: