In this White Paper I want to open a discussion and debate on the whole issue of Women’s health and safety at work in Ireland. For far too long we have “lumped” women in with men when planning for health and safety in terms of equipment and PPE, but it has not worked.
In this White Paper I will briefly outline my thoughts on the unsuitability of workplaces, equipment, tools and personal protective equipment (PPE) for many women. I will deal with the issue of pregnancy and the specific regulations that were put in place to protect pregnant women, which has in some cases backfired. I will also open up the topic of the effect of the Menopause on women at work, and why it is causing highly experienced women to leave employers who do not show an understanding of, or flexibility towards, menopause.
I will make the argument that if we pay attention to the needs of women (create safe and healthy workplaces, provide suitable PPE, have flexibility re hours including shorter working weeks, provision of creches at work, decent healthcare, empathy and support for menopausal women and sick pay schemes etc.) then highly qualified, experienced women will be queuing up to work with employers who value them.
When I use the term "Women" in this White Paper I want to include non-binary and transgender/trans persons, (women who are transitioning, or who have already transitioned, to a man but still retain their ovaries) and anyone else who can experience Menopause symptoms. (18).
The health and safety of women at work is a work in progress and some good work has been done. One factor that will move women’s safety up the agenda is the large number of female health and safety professionals now working in the field. It used to be an all-male domain and there was no acknowledgement that there were issues re women that needed to be addressed.
There is still limited anthropometric data on women and limited knowledge of their work and their specific needs. Work equipment is not always specifically designed for women who use it – available anthropometric data is predominantly male data. Many women are engaged in part-time, low paid, repetitive, stressful work, with major health and safety issues that are not being addressed.
Existing legal health and safety protection of women while pregnant is primarily focused on the health of the foetus and not the woman.
We still have a situation where women are not included or facilitated to participate in research and action on health and safety aspects of their work in many workplaces. In some cases their needs and concerns are not being taken seriously and are being dismissed as a weakness.
We need to shatter the widely held assumption is that women’s work is safe and therefore no further research is needed which then means no action is being taken on current hazards and risks.
The issue of the Menopause will grow in importance in all organisations where mature women work and will need to be risk assessed and managed.
If employers fail to address the keys issues affecting the health and safety of women (including menopause) businesses will suffer in terms of loss of key, experienced employees, loss of productivity and ultimately profits. They also run the risk of legal cases being taken against them for breaches of health and safety and discrimination law.
We need more research on what works for women in terms of equipment, tools, PPE etc.
One of the key conclusions of previous EU-OSHA research is: “Work-related risks to women’s safety and health have been underestimated and neglected compared to men’s, regarding both research and prevention. This imbalance should be addressed in research, awareness-raising and prevention activities.”(5)
In Ireland and in most of the rest of the developed world there are laws, regulations and codes of practice covering most, if not all, aspects of health and safety at work. These laws and regulations can be quite specific e.g. Noise Regulations 2007, Display Screen Equipment Regulations 2007 and Construction Regulations 2013. All of these laws impose general duties on employers, employees, the self-employed, manufacturers, designers and builders. (4).
Most of our health and safety laws and regulations come from Europe as EU Directives but the approach to occupational health and safety in the EU is ‘gender neutral’. That may be what was intended but in practice that is not the effect they have in workplaces today.
Yes men and women are equal but different and workplaces, equipment, tools and personal protective equipment have for the most part been designed by men for men with negative consequences for women. This stemmed from the fact that for centuries workplaces were exclusively male domains – indeed some still are.
So in essence our myriad of health and safety laws, regulations, Codes of Practice and detailed guidance deals with men and women as equals in the workplace. But are they equal?
In reviewing Health and Safety Authority’s Programme of Work for 2022 released in January 2022, like all previous Programmes, there is no specific reference to women or gender. Two of their stated core elements of their mandate is summarised as follows:
(these have barely changed over the last few years) (16).
Central Statistics figures for 2019 (the latest available) tell us that there were
1,058,100 women at work and 1,242,000 men at work in Ireland. The employment rate for women dropped from 62.5% in 2008 to 56.3% in 2012 and then increased 63.7% by 2019, above the level in 2008. The employment rate for women in the EU increased from 53% in 2008 to 64% in 2019 so we are slightly below the EU average. So women’s’ participation in the workforce in Ireland has risen dramatically over the years. (1)
Women in employment by occupation - 2018
(Source CSO – Table 5.6 (1) )
As the chart shows there is some segregation by occupation which leads to exposure to particular occupational health and safety hazards. For instance over 77% of those in administrative and secretarial roles are women. Unless good ergonomics are in place together with good quality chairs, properly adjusted, work in this segment can create a whole range musculoskeletal disorders including carpal tunnel syndrome, tendinitis, rotator cuff injuries (affects the shoulder), epicondylitis (affects the elbow), trigger finger, muscle strains and low back injuries.
Similarly a high proportion of back injuries of women working in the health sector is related to the nature of the work and the concentration of women workers in nursing and caring roles, where they represent 79.3%.
According to the International Labour Organisation (ILO) women can be concentrated in particular occupations, and as a result can be subject to a specific pattern of injury and disease. Due to the organisational issues such as repetitive work leading to muscle strain and to fatigue, interruptions (considerably more frequent in female jobs) and lower autonomy, together with less access to training, women may face specific risks for acute and chronic work-related conditions. For example, women are increasingly affected by Musculoskeletal Disorders (MSDs) and have a higher risk of developing MSDs when compared to men working in the same tasks.
In home-based online platform work, women are exposed to risks that come about due to the lack of basic employment rights and risks of domestic violence, which represents a double burden for safety and health (ILO, 2017b). In addition, the growth of the platform economy has blurred the lines between home and work, adding psychosocial pressures to women who are increasingly balancing the demands of work-life and home-based responsibilities, such as childcare. Moreover, the growing participation of women in digitalised work and information technology (IT) has led to increased online harassment, cyberbullying and trolling, resulting in psychosocial risks and work-related stress for female workers. (EU-OSHA, 2013). (2)
Those in administration and secretarial jobs may not have their workstations ergonomically assessed, maybe sit on unsuitable chairs, may not be able to avail of frequent breaks and maybe develop musculoskeletal disorders with no occupational health service.
Many women have a dual role, as paid workers at work and as unpaid workers at home. A woman works an average of one to three hours per day longer than a man in the same society due to their role at home looking after family and other dependants. Special health problems can arise from this situation including stress, chronic fatigue, premature ageing and other psycho-social and health effects. (3).
Compared to the 1950s when women were not allowed to work or their participation in the workforce was not approved, women now work in all industries and across almost all occupations. But are they being protected at work? Do our existing health and safety laws really take women’s needs into account?
Pregnancy Regulations 2007
However, very few health and safety laws mention gender as an issue and none deal with it specifically with the exception of Pregnancy Regulations 2007 which lists specific Chemical and Biological Agents that are dangerous for the unborn child. Even in these pieces of gender-related legislation, the focus is on the protection of the foetus and not the woman.
These regulations place an obligation on employers to carry out a detailed risk assessment of work activities being performed by pregnant women to ensure that these women and their unborn babies are not endangered at work by such activities and to make appropriate adjustments if that is found to be the case.
Research has shown that the Pregnancy Regulations 2007 have in some cases backfired and where it was designed to enhance health and safety protection for pregnant women it has been abused by poor employers who have used Section 18 of the Maternity Protection Act 1994 to “get rid of women” as soon as they announce they are pregnant using the clause that they have no safe work for the woman. This decision then has the potential to create a job or task that can never be performed by a woman ever in case she is pregnant and few employers ever consider this precedent.
By their very nature, these are generic and relate to all workers, men and women.
Accidents at work
It is accepted that men are more likely to experience accidents at work, because of their involvement in more ‘high accident risk’ sectors but, overall, there has been a decrease in the rate of accidents. According to an EU study (Eurostat, 2009a, 2010a), when women do experience accidents at work it is most likely when they work in the ‘agriculture, hunting and forestry’, ‘hotels and restaurants and ‘health and social work’ sectors. Unlike the accident rates, the rates for work-related health problems are similar in both genders. Female workers with work-related health problems most often report MSDs (60 %), of which 16 % also report symptoms of stress, depression and anxiety. (5)
Often the type of work performed by women is “perceived” to be light in nature i.e. operating a checkout at a supermarket when compared to a male worker on a building site. Yet the weights moved by the woman in an 8-hour shift may be greater than those moved by the man.
The European Risk Observatory Report – “New risks and trends in the safety
and health of women” at work makes the point that “Women are increasingly affected by musculoskeletal disorders (MSDs) and stress. This puts into question the misconception that women’s work is less physically and mentally demanding. The combination of work organisational and physical risks, the links between women’s paid and unpaid work, including combined risk exposures and less free time, and the difficulties in finding a
stable job, and their impact on the health and safety of women should be further explored.(5)
What has Ergonomics to do with women’s health and safety?
The word ergonomics — “the science of work” is derived from the Greek ergon (work) and nomos (laws). Ergonomics (or human factors) is the scientific discipline concerned with the understanding of interactions among humans and other elements of a system, and the profession that applies theory, principles, data, and methods to design in order to optimise human well-being and overall system performance. (6)
Those that have studied ergonomics know that when it is done right and takes full account of women in that workplace ensuring that they feel comfortable, they are more productive and take less sick leave. It includes looking at workstation design, the methods of transferring objects, the placement and accessibility of tools, the opportunities to perform one’s work either sitting down or standing up, and lighting in the workplace.
Workplaces, equipment and tools
Most ergonomics textbooks will draw upon Anthropometric data but it needs to be remembered that the basic anthropometric data comes from studies of US armed forces personnel who were generally male, fit and similar in size and dimensions. (7)
Workers in workplaces tend to be more varied with tall and short persons needing to be accommodated and women are rarely considered.
How many workstations in manufacturing industries are adjustable? Very few so shorter people like me can find them too high and high seats may not be the most comfortable for an 8-hour shift. If and when adjustable workstations are installed then men and women both benefit.
In assembly plants the issue of parts supply is not always considered. Can all operators reach all of the components they need when they need them?. All grab distances should be as short as possible. Grab containers and parts containers should be placed within the reach envelope which is smaller for a woman. These issues are often overlooked.
Trolleys can be bought that accommodate tall and short persons which have upright handles where the user can grip at the height that suits them in every case.
When it comes to tools, are all hand tools easy to reach, lightweight, suspended and easy to use without the need for excessive grip? Good ergonomics can address many of these issues and can benefit all workers, both male and female.
Lone working for women
There is no outright ban on anyone doing work alone. It is all down to risk assessment of what they are doing, where, how, why and what hazards and risks exist to do with that work.
Definition of Lone working
A lone worker is someone who is alone at work, is on their own in a workplace; where they cannot be seen or heard by another person; and when they cannot expect a visit from another worker.
In an ideal world, no one should perform lone working but good risk assessment can reduce the risks and lead to comprehensive protection for employees.
These are the issues that are normally considered when risk assessing lone work for men:
Training of the Lone Worker
This training would ensure they fully understand the issues around their proposed lone working and how to deal with problems – feeling unwell, dealing with intruders, de-escalating violence etc.
Is it a secure building?
How good is the lighting?
The individual capabilities of the employee e.g. existing medical conditions such as diabetes, tendency to faint, epilepsy and their reaction to stressful situations.
The nature of the work
Is it hazardous (e.g. in a laboratory) or non - hazardous in an office?
High risk work would not be permitted to be done alone and they would include:
How to call for help in an emergency?
Will it be done:
Will the worker be monitored by the camera by someone who can assist?
Will they be phoned periodically by a Supervisor or visited by a roving Security Officer?
Is there access to a panic button?
Is there an agreed code word if the lone worker phones another employee?
Will they carry a bleep to call for help?
Will that bleep have a “man down” aspect to it that automatically goes off?
Will it broadcast a conversation that may take place between the lone worker and the potential attacker which can bring help?
If the lone worker is a female then additional issues need to be considered as follows:
Is she pregnant?
If she is then she could become unwell, her waters could break, she could go into premature labour etc. and then she will need help.
In my professional career as a health and safety consultant, I have prohibited pregnant women from carrying out lone work full stop as the risks are too great.
Is she carrying out work off-site alone?
In what circumstances?
What risks exist?
Is she carrying valuables (going to a bank to bank cash etc.)?
Will she be leaving the building in the dark?
What security precautions are in place to protect her while she walks to her car, bus, train etc.
Can she park her car next to the building?
Can a Security Officer escort her to her car etc.?
Personal Protective Equipment (PPE)
We all accept that the primary purpose of PPE is to prevent an injury. However, comfort and fit are also important because these features can dramatically influence whether workers actually wear their PPE. So what do women say they want from PPE? It is an appropriate fit. This sounds reasonable but, in reality, it is not always available.
If and when PPE is uncomfortable and possibly too big for women to wear, it can become a safety hazard. Oversized safety jackets issued to women can be cumbersome, especially with excess fabric at the sleeves that can get caught in machinery. Oversize boots can become tripping hazards. Gloves that do not fit will reduce dexterity and may interfere with the use of tools and the operation of equipment.
“For women who need PPE shirts and jackets, the mantra has too often been “just buy a man’s garment but one size smaller.” The problem is that men’s garments are simply designed differently than those made for women. Jackets designed for men are longer and larger than those made for women. The waist cut design is higher for women, and there’s more space in the chest area. The shoulders on men’s jackets are much broader compared with women’s jackets. Women’s jackets are curve-friendly and flare near the waist. Even the position of buttons is different.” Finding comfortable safety shoes for women is also a problem as few are designed with extra arch support. (8)
In 2016 the TUC in the UK received 2,655 responses to a TUC survey and 3,086 responses to a joint survey carried out by trade union Prospect and the Women's Engineering Society. Those who responded worked in various sectors, including emergency services, retail and manufacturing, engineering and scientific research. The findings led to the development of a very useful guide – “ Personal protective Equipment and women” - Guidance for workplace representatives on ensuring it is a safe fit.(9) (10)
This guidance called on employers to avoid PPE suppliers that do not provide a range of sizes for both sexes, after only three in ten women (29%) told the survey that the PPE they wear at work has been specifically designed for them. They pointed out that most PPE is designed to fit the sizes and characteristics of male populations from Europe and the US. As a result most women - and also many men - who do not fit this profile, struggle to find suitable PPE.
The female body does not have the same musculoskeletal frames as the male body therefore it is often the case that oversized PPE is issued in order t ensure PPE can be worn by women. This in turn does not just cause discomfort but can create additional risks. Employers cannot knowingly expose employees to risk without doing something about it. While the Hierarchy of Control has PPE at the bottom of its control measures it is still important if hazards cannot be controlled any other way.
If we want all employees to be safe at work, then whatever PPE they require needs to be made for them taking into account their size, shape, height, pregnancy, length of arms and legs etc. If it does not fit them correctly employers are not fulfilling their duty of care and injuries that result from ill-fitting PPE may lead to claims that employers could have difficulty defending. If injuries result then employees have the right to sue for compensation and there may be grounds for the Health and Safety Authority to prosecute for a breach of statutory duty as well.
Prevention is always better and cheaper than cure.
Effect of menopause on women at work
In Ireland, nearly 600,000 women are affected by perimenopause or menopause at any one time. Many in the workforce are therefore affected, so employers need to be aware of the issues and how best to provide support. Menopause typically affects women between 45 and 55 years of age who are often reaching senior positions and/or are well established in their careers.
In 2021 there has been increased media coverage, Fianna Fáil TD Niamh Smyth brought a motion before their parliamentary party meeting on 12 May 2021 calling for a campaign to support women experiencing menopause. Health Minister Stephen Donnelly recently told the Dáil that the development of a menopause workplace policy is underway and that the Department of Health is working on a range of other actions including the provision of specialist support and a national awareness campaign. (11)
What is menopause?
Menopause is said to have occurred when there have been no menstrual cycles for 12 consecutive months, but a woman can be affected by the symptoms for a long time before then. This perimenopausal period (typically referred to as ‘going through the menopause’) can last four to six years before the natural menopause.
Surgical menopause is where surgery to remove a woman’s ovaries begins the menopause process, regardless of the woman’s age. Transgender men and people who are intersex or identify as non-binary may also experience menopause and the symptoms that go with it. The average age to go through menopause is 51, but there is a lot of variation. It can happen at any point between 30 and 60 years of age. (11)
So how is it a health and safety issue?
More than 1 million women in the UK could be forced out of their jobs this year (2022) because their employers are failing to support them as they go through menopause. What support does your organisation offer? (17).
Risk assessments must consider the specific needs of menopausal workers and ensure the working environment will not make their symptoms worse. Issues that need to be considered include temperature and ventilation. The assessments should also address welfare issues, such as toilet facilities and access to cold drinking water.
Improved welfare facilities could also include a quiet place to rest and easily adjustable temperature and humidity controls. Employers already have statutory duties to provide and maintain facilities and arrangements for the welfare of his or her employees at work under the Safety, Health and Welfare at Work Act 2005.
Employers should bear in mind that all workplaces are different. For example, in some workplaces, it is not possible to open windows to improve ventilation. Employees who wear a uniform will be less able to change the type of clothing they are wearing when they are having hot flushes or sweating. Examples of how managers have adapted to the needs of staff with menopausal symptoms include:
Hormones can fluctuate during menopause, leading to a variety of symptoms such as irregular and/or heavy periods, hot flushes, mood swings, anxiety, difficulty concentrating, migraines, fatigue and difficulty sleeping.
In 2019, the UK surveyed 1,409 women who were experiencing menopause symptoms. Three out of five (59%) said that menopause was having a negative impact on them at work. Of those who were affected negatively at work, they reported the following issues:
The need for better support is further highlighted by the fact that more women say they feel supported by their colleagues (48%) when going through menopause, than by their managers (32%).
Impact on quality and productivity
These are issues being reported by women going through the menopause
There are other legal issues that can arise including:
Sex discrimination - Women who are treated less favourably than men can bring a claim of direct sex discrimination.
Age discrimination - Given that perimenopause and menopause are typically age-related, employers also need to be aware of age discrimination risks affecting this group.
Disability discrimination - Whether or not menopause amounts to a disability will depend upon the individual’s particular circumstances. Some may only experience minor symptoms, while others can be more severely affected. The legal definition of a disability in Ireland is extremely broad, so disabilities that are temporary in nature may come within the protection of the legislation.
Failure to carry out risk assessments will lead to claims of sex discrimination, possibly age discrimination and more. Employers cannot ignore this issue any longer as it affects such a large proportion of the workforce and is causing highly qualified, experienced women to leave organisations who cannot easily replace them.
Employment Tribunal cases have already emerged in the UK where menopause was deemed to have been discriminated against in some way and I feel we can expect cases like this in Ireland too.
Depending on their symptoms and support available some women are forced to leave their workplaces and wonderful talent and a wealth of experience is being lost to the organisation when this happens.
The cost of recruiting and training new employees far outweighs the costs of making small adjustments to the working practices of menopausal employees so that they can stay in their jobs. (12)
So what should employers be doing?
Action that can be taken come under 4 headings:
Women are embarrassed speaking to their employer about menopausal symptoms, and some are even embarrassed to speak to their colleagues. This is not surprising when symptoms are extremely personal. A large number of women find their symptoms negatively affect their job performance and they lose their confidence.
Businesses should be able to recognise when support is needed and facilitate open conversations with employees about what they are experiencing. More education should be provided for managers and line managers to do this.
Break the taboo
Menopause should not be taboo, and everyone should feel confident to have a conversation with their manager, especially when they need help and advice.
We need to create open cultures where women feel comfortable to say they’re struggling with symptoms. Internal campaigns or webinars for staff are a great way to do this, enabling and starting a conversation for people. If you’re struggling to find speakers internally, think of bringing in an external expert.
Don’t wait for colleagues experiencing menopause to start discussions, find ways to open these topics across the organisation.
It is important managers are trained not only on the symptoms of
menopause but also on how to talk about it sensitively. Managers/Line managers are not expected to be experts on menopause.
Colleagues also need training about why they need to talk about menopause, what it is and how it could affect themselves and their colleagues, how to get help and support and how to manage menopause.
Provide access to support
Businesses should invest in services that support women. Even though many companies are currently operating remotely, out of sight does not mean out of mind when it comes to menopause. Women need access to healthcare services, even if remote, including GP or virtual GP services, so they can still get support and treatment from a medical professional.
The last year has been tough on everyone’s mental health, but for women experiencing menopause, the pandemic, work pressures and anxiety or low mood that they’re already experiencing due to menopause may have been exacerbated. Many women may need support and having access to EAPs or mental health first aiders who women can contact anytime, anywhere, is incredibly important.
Policies should be updated to ensure menopause is included. This could be covered within sickness and flexible working policies or a specific menopause policy may be necessary.
While menopause may have been easier for some women to manage whilst working from home, night sweats is a key symptom that can lead to lack of sleep and fatigue. Employers need to be flexible to your team’s needs, allowing them to be change meetings and work hours that suit them. This is also a key thing to consider when returning to the office.
Many employees fear change and it is a by-product of policies, education around topics and access to services. We must support women and make changes within our organisations.
In conclusion, there is much that employers could do to proactively support and value employees who are going through this natural process. Awareness of the symptoms of menopause and their impact on the workplace is increasing. Employers risk legal claims as well as employee discontent if they fail to manage menopause in the workplace with appropriate care and sensitivity.
Women represent a talented and experienced cohort of the working population, and yet most workplaces are silent on their needs during menopause with many managers lacking adequate knowledge to address work-related issues.
We need to create menopause friendly workplaces that achieve a much-needed level playing field for women at work allowing them to continue to achieve their full potential as members of the working community. (14)
Menopause and personal protective equipment (PPE)
The health and social care sectors are challenging workplaces for women undergoing menopause. This is because institutions such as hospitals and care homes are required to provide a warm environment for patients and clients, the staff are usually required to wear a uniform and access to cold drinking water and toilet facilities can be difficult when emergencies occur.
In the UK, the NHS employer's website has guidance for HR departments to produce policies on menopause in the workplace. However, little attention appears to have been paid to circumstances when staff have to wear protective clothing. In conditions demanding infection control, staff working with vulnerable populations and patients are required to wear Personal Protective Equipment (PPE). PPE can exacerbate heat stress and thus worsen the vasomotor symptoms of menopause (hot flushes, night sweats), sleep disturbance and menorrhagia, which may be severe enough to cause menstrual flooding.
The use of PPE has increased dramatically since March 2020 as the health and social care sector had to respond urgently to the COVID-19 pandemic. Many menopausal women suffer from anxiety and this will have been exacerbated by the general fear and anxiety among staff, patients, their relatives and the public, as health and social care organisations sought to control infection rates for both COVID-19 and non-COVID-19 patients. Yet, one year on, there is little information concerning health and social care staff regarding the effect of wearing PPE on vasomotor symptoms. (15)
2. Safety and health at the heart of the future of work - Building on 100 years of experience – published by International Labour Organisation 2019
3. Women workers and gender issues on occupational safety and health by
Valentina Forastieri, International Programme on Safety Health and the Environment 2010
4. Raymond Byrne – Safety and Health Acts, Annotated and Consolidated 2013 – page 14 – ISBN 978-0-41403-291-0
5. New risks and trends in the safety and health of women at work - European Risk Observatory Literature review published by European Agency for Safety and Health at Work, 2013
6. International Ergonomics Association definition
7. The Evolution of Anthropometrics and User Control
What We Know: Anthropometrics
8. The need for unique women’s PPE by Randal Fisher, vice president of marketing, Black Stallion (Revco Industries), Santa Fe Springs, CA.https://www.safetyandhealthmagazine.com/articles/19752-the-need-for-unique-womens-ppe
9. Personal protective equipment and women - Guidance for workplace representatives on ensuring it is a safe fit, published by TUC.
10. More than half of women say PPE prevents them doing their job
11. The menopause: legal and practical issues for Irish employers by Linda Hynes Partner - Ireland Lewis Silkin (Ireland) Shane Gallen Associate - Ireland Lewis Silkin (Ireland)
12. Menopause Presentation by Jane Shearer, CMIOSH, Safety Advisor, Newcastle University UK – courtesy of IOSH UK
13. How businesses can better support menopausal women – by Alanna Woods, Commercial Director at Bupa Health Clinics, SHP October 2021
14. Menopause for thought: managing the change at work - World Menopause Day 2021
IOSH Webinar 18 October 2021
15. Menopause and personal protective equipment: How does this meet acceptable working conditions? By Angela Kydd
16. Programme of Work 2022 published by Health and Safety Authority
17. PositivePause.co.uk – Newsletter published 17th January 2022
18. Terminology surrounding gender identify and expression published by Outright Action International
Mary Darlington – BSc., CFIOSH
Safety Leadership Expert
Chartered Safety and Health Practitioner
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