In the 1930s, the application in France of certain clauses of the labour code concerning occupational hygiene demonstrated the value of providing workplace inspectors with access to consulting physicians.
The laws of 17 July 1937 and 10 May 1946 (articles L 611-7 and R 611-4) empowered the Department of Workplace Inspection to order temporary medical interventions. Over time, these interventions, originally conceived of as intermittent, evolved into ongoing activities complementary to and conducted simultaneously with workplace inspection.
The promulgation of the law of 11 October 1946 concerning occupational medicine was soon followed by the establishment of a permanent technical framework for the medical inspection of workplaces and workers. The decree of 16 January 1947 established the context, pay scales, status and functions of medical inspectors of workplaces and workers.
Since 1947, however, technical development in this area has been irregular and sporadic, and the number of medical inspectors has sometimes failed to keep pace with the number of inspection tasks; the latter has also been true of workplace inspections. Thus, while medical departments created in accordance with the law of 11 October 1946 increased in prevalence and importance, the number of medical inspectors was gradually reduced from 44, the number originally called for in 1947, to 21. These contradictory trends partially explain some of the criticism the occupational medicine system has had to face.
However, since 1970, and particularly since 1975, there has been a significant effort to create a Department of Workplace Medical Inspection capable of responding to the needs of the approximately 6,000 physicians responsible for over 12 million workers. In 1980, inspection services were allocated 39 paid positions, of which 36 were actually filled. In 1995, 43 positions were available. Priority Action Plan Number 12 of the VIIth Plan provides for 45 medical inspectors; this will bring staffing levels up to the levels originally envisaged in 1947.
At the same time that French officials were recognizing the necessity of establishing a specialized inspection department responsible for the application of legislative and regulatory directives concerning occupational hygiene and medicine, identical conclusions were being drawn in other countries. In response to this growing consensus, the ILO, in collaboration with the WHO, convened an international colloquium on the medical inspection of workplaces, in Geneva in 1963. Among the noteworthy outcomes of the colloquium were the definition of the responsibilities, duties, and knowledge and training requirements of medical inspectors, and the techniques and methods of medical inspection.
The central office of the Department of Workplace and Worker Medical Inspection is part of the Industrial Relations Department and reports directly to the Regional Director of Industrial Relations and Medical Inspection. The Regional Director, in turn, is part of the Regional Labour and Employment Board and reports directly to the Regional Director of Labour and Employment. The number of professionals and workers in France in 1995 were:
- 12.5 million workers benefiting from general coverage
- 6,337 physicians, of which 2,500 are full-time
- 4,000 nurses
- 1,500 medical departments
- 90% of workers are followed up by sectoral medical departments.
The number of medical inspectors in each region depends on the number of salaried occupational medicine positions in that region. In general, each regional medical inspector should be responsible for approximately 300,000 workers. This general rule is, however, subject to modification in either direction, depending on the size and geography of each region.
Although many of its clauses are no longer relevant or have lapsed, it is nevertheless useful to review the responsibilities of medical inspectors prescribed by the aforementioned decree of 16 January 1947.
The physician in charge of the department is responsible, among other things, for the coordination of all medical problems in the various departments of the Ministry of Labour and Social Security. His or her functions can be extended by decree.
The Medical Inspector of Workplaces and Workers will:
- maintain, with the Technical Committees of the Social Security Credit Unions, direct and permanent contact with the Workplace Inspection Department, and ensure the application of legislation concerning occupational hygiene and the protection of worker health
- carry out, on an ongoing basis, activities designed to protect worker health in the workplace; these activities will include, among other things, the supervision of the Occupational Medical Departments established by virtue of the law of 11 October 1946
- supervise, in close collaboration with psychotechnical departments, medical examinations aimed at determining workers’ fitness for work, and reclassifying and referring workers who are temporarily unfit for work or physically handicapped to rehabilitation centres
- supervise, in collaboration with the Technical Committees of the Social Security Credit Unions, the preparation, compilation and use of statistics concerning the physiopathological characteristics of the workforce.
The Medical Inspector of Workplaces will communicate information he or she possesses concerning the risk of occupational disease and accidents in different companies to the Technical Committees of the Social Security Credit Unions. The note of 15 September 1976 concerning the organization of Industrial Relations Departments assigns the following responsibilities to the Department of Workplace and Worker Medical Inspection:
- the investigation of technical aspects of occupational medicine, pathology, work physiology and ergonomics
- the investigation of questions related to the protection of wor-kers’ health and to work conditions
- the investigation of medical aspects of work
- the monitoring of progress in medicine, physiology and erg-onomics
- the coordination of regional information gathering.
Management of medical inspectors involves:
- the coordination of regional medical inspectors
- the development and application of reports, technical studies and research conducted regionally or transregionally, and ulti-mately, of specialized work groups
- the organization of meetings which provide members of the Department of Workplace and Worker Medical Inspection with an opportunity to compare experiences and define consistent approaches to new problems
- the preparation of recruitment and training procedures for medical inspectors of workplaces and workers
- the continuing education of all regional medical inspectors.
In addition to these core activities, the Department of Workplace and Worker Medical Inspection also collaborates with industrial relations and human resources departments in all cases involving medical aspects of work (especially those involving handicapped workers, candidates for continuing education and job applicants) and is responsible for managing, coordinating, recruiting and training regional medical inspectors and ensuring their continuing technical education. Finally, the central office of the Department also engages in consulting activities and is the government’s official representative in matters concerning occupational medicine.
The Department of Labour’s central or regional Departments of Workplace and Worker Medical Inspection may be called upon to intervene when other governmental departments without their own medical inspection services (most notably the Department of Health and Social Security) find themselves faced with problems related to the prevention or correction of occupational health hazards; these departments of the Department of Labour may also assist in the establishment of a department of medical prevention. Except in cases where the requesting party is another governmental work-inspection service, the Department’s role is usually limited to an advisory one.
From 7 to 10 June 1994, almost 1,500 people attended the XIIIth Journées nationales de médecine du travail (the 23rd National Occupational Medicine Conference) organized by the Société et l’Institut de médecine du travail et d’ergonomie de Franche-Comté (the Society and Institute of Occupational Medicine and Ergonomics of Franche-Comté). The following subjects were discussed:
- neurotoxicity of low-level solvent exposure
- health and the precariousness of health and work
- stress and strain of contemporary work—the role of the occup-ational physician.
The Department is the government’s representative in medicosocial, scientific and professional agencies or institutions in the field of occupational medicine. These include the Conseil National de l’Ordre des Médecins (the National Council of the Order of Physicians), le Haut Comité d’Études et d’Information contre l’alcoolisme (the High Commission for Alcoholism Research and Information) and various university and scientific institutions. In addition, the central Department of Workplace and Worker Medical Inspection is frequently called upon to present the French government’s position on medical questions to the European Economic Community, the WHO and the ILO. Regional departments have similar responsibilities, in accordance with Circular DRT No. 18-79, of 6 July 1979, on the role of cooperation between workplace inspectors and medical inspectors of workplaces in the prevention of occupational hazards. The circular identifies orientation, informational, supervisory, management and intervention activities to be carried out, as needed, in collaboration with the regional, departmental or local workplace inspection departments.
Although both workplace inspectors and medical inspectors share common goals—the prevention of occupational health ha-zards—their specific interventions may differ, depending on the technical expertise required. Other circumstances may, on the other hand, require their collaboration.
Proposed New Circular
A circular in preparation reiterates and updates the clauses of the circular of 6 July 1979. It should be noted that on 1 January 1995, the Departments of Occupational Training assumed the responsibilities of the regional Departments of Labour and Employment. The function, role and mission of medical inspectors of workplaces must therefore be reviewed.
In summary, we can say that by 1980, medical inspection departments had, for all intents and purposes, regained the role and functions originally foreseen for them in the period 1946-47. The most likely next step in medical inspection is towards increasing emphasis on promotion, management and research in workplaces. This evolution, it should be noted, parallels that of occupational medicine itself. Following a long period of development and implementation that may now be considered practically completed, occupational medicine must now embark upon a new era of qualitative improvement and scientific advance.