Some employers don't realise they have a legal duty to carry out Display Screen Equipment (DSE) risk assessments at all. I have been having conversations with Northern Ireland businesses and organisations recently and this is a pattern that keeps emerging. Others know assessments should happen but treat them as something triggered by a problem, an employee reporting discomfort, or returning from absence. And some are carrying out assessments, but in a way that may not meet the standard the regulations actually require.

All three of these are compliance gaps. This article sets out what the law requires, where businesses commonly fall short, and what a properly structured approach looks like.

What the law requires

The Health and Safety (Display Screen Equipment) Regulations (Northern Ireland) 1992 [1] place a clear duty on employers to protect workers from the health risks of working with DSE, including PCs, laptops, tablets and smartphones. The Regulations apply to any worker who uses DSE daily, for continuous periods of an hour or more. All references to DSE users in this article refer to workers who meet this definition.

For each DSE user, a suitable and sufficient workstation assessment is a legal requirement. This is not discretionary. It is not triggered by a complaint. It applies to all DSE users as a baseline obligation.

It is worth noting that the Regulations do not apply to workers who use DSE infrequently or only for a short time.

Your duties as an employer

If you employ DSE users, HSENI [2] sets out what you are required to do:

Assess the risks associated with DSE equipment used in the workplace or at home
Analyse DSE user workstations to assess and reduce risks
Identify any individual needs of DSE users
Identify if workers require any additional equipment when working at home
Implement suitable DSE risk controls
Provide DSE users with appropriate information and training
Provide DSE users with eye and eyesight tests on request, and appropriate safety spectacles where necessary
Review the assessment when there are any changes to DSE including workstations or users, or when workers report that they are experiencing any pain or discomfort

On recording, HSENI [2] is clear: employers of five or more employees are legally required to record the significant findings of the DSE risk assessment. For employers of fewer than five employees it is not a legal requirement, but it is beneficial to do so so that the record can be reviewed if something changes.

Where individual needs require additional consideration, HSENI [2] is clear that competent advice should be sought from a competent DSE assessor. As a Chartered Ergonomist I am able to provide that competent advice.

Hybrid working

The Regulations can also apply to workers who work at home on a permanent or long-term basis, or routinely split their time between their workplace and home. Where this applies and the worker meets the definition of a DSE user, a separate assessment covering the home working environment will be required.

The reactive misconception

One of the most common misunderstandings I encounter is the belief that DSE risk assessments are something you do when a problem has already arisen, when someone reports back pain, neck pain, upper or lower limb discomfort, or eye strain, or when an employee is returning to work following an absence.

Assessments in those circumstances are of course appropriate and necessary. But they do not replace the baseline requirement. The Health and Safety (Display Screen Equipment) Regulations (Northern Ireland) 1992 [1] require employers to assess risks for all DSE users as a matter of course, not as a response to reported symptoms.

Treating DSE risk assessment as reactive rather than proactive means risks are only identified after harm has begun to occur. That is precisely what the Regulations are designed to prevent.

When assessments need to be reviewed

Even where a baseline assessment has been carried out, it is not a one-off exercise. L26 [3], the HSE's authoritative guidance document on the Regulations, sets out specific triggers for review, including major changes to equipment, furniture, software or the work environment, a change in workstation, a substantial increase in DSE use and significant changes to task requirements. Assessments should also be reviewed where a worker reports symptoms that may be connected to their DSE use.

For most office-based businesses, a review cycle of every one to two years as a minimum is reasonable practice, alongside review at any of the above trigger points.

Hotdesking

Where more than one worker uses the same workstation, whether simultaneously or in shifts, L26 [3] is clear that the workstation must be assessed in relation to all those who use it. A single assessment of the workstation is not sufficient where multiple workers with different physical requirements are using it.

This makes workstation adjustment knowledge particularly important. Where workers are hotdesking, every worker using that workstation needs to understand how to adjust it correctly for their own needs, including seat height, screen position, keyboard and mouse placement. Without that knowledge, the benefits of even a well-designed workstation are lost.

Eye and eyesight tests

Employers are legally required to arrange an eye test for DSE users upon request. Should a worker require glasses specifically for DSE use, these must be provided by the employer.

The competence gap

Where assessments are being carried out, the question of who is doing them and how is critical.

Many businesses rely on workers completing an online checklist and submitting it to their line manager, or a manager reviewing a form without any formal training. This is where a significant and often unrecognised compliance gap exists.

L26 [3] is clear on the role of checklists. It describes worker input via a checklist as a useful way of obtaining information but explicitly frames it as one component of the assessment process, not the assessment itself. The same document states directly that whatever type of checklist is used, employers should ensure workers have received the necessary training before being asked to complete one.

HSENI [2] is clear that DSE users may carry out a self-assessment provided they have been suitably trained. The HSE brief guide INDG36 [4] reflects this: suitability and training are prerequisites, not assumptions.

On who should carry out or oversee assessments, L26 [3] is equally specific. The person responsible must have the ability to:

Identify hazards including less obvious ones
Draw valid and reliable conclusions from assessments
Make a clear record of findings and communicate them appropriately
Recognise their own limitations so that further expertise can be called on if necessary

Where in-house personnel are trained to act as assessors, suitable checks should be made to confirm they have reached an adequate level of competence.

A manager reviewing a submitted checklist without training, or a worker completing a checklist who has not received suitable training to do so, does not meet this standard. Where individual needs are more complex, HSENI [2] advises seeking competent advice from a competent DSE assessor.

A proactive approach: what compliance looks like

A compliant and effective DSE risk assessment approach has a few defining features:

Covers all DSE users as a baseline, not just those who have raised concerns
Built into new starter induction, so every employee who meets the definition of a DSE user is assessed before or at the point they begin regular DSE work, not months later when problems have already developed
Reviewed at least every one to two years and at the trigger points set out in the guidance
Carried out or overseen by someone who meets the competence standard the Regulations require

Getting the approach right

For employers with many DSE users, INDG36 [4] notes that it may help to appoint someone competent to act as an assessor. HSENI [2] is equally clear that competent advice should be sought where needed, for example from a competent DSE assessor.

For organisations looking to develop that competence in-house, investing in DSE Assessor Training equips people to identify who is covered by the Regulations, assess workstation risks properly, put control measures in place and provide training to users.

L26 [3] also notes that outside expertise may be necessary for more complex assessments. These include situations where a worker is experiencing discomfort or symptoms, where an individual is returning to work following an absence, where workstation design is particularly complex, or where the nature of the work demands a higher level of scrutiny. In those circumstances, or where businesses simply want the reassurance of an independent assessment, an external specialist is the appropriate route. A Chartered Ergonomist is well placed to provide that expertise, and it is worth noting that a competent person carrying out assessments regularly will typically complete them more thoroughly and efficiently than someone doing so without specialist training.

Whether the right approach is developing internal assessor competence, bringing in external support, or a combination of both will depend on the size of your organisation, the number of DSE users and your existing internal capacity.

How I can help

As a Chartered Ergonomist and experienced DSE assessor having carried out hundreds of assessments, I offer DSE assessments and DSE Assessor Training across Northern Ireland and would be happy to discuss your requirements.

As part of every assessment I take time to explain to each worker what an optimal workstation setup looks like, how to adjust their equipment correctly and why it matters for their comfort and health. The assessment is not just an evaluation, it is an opportunity to educate and enable workers to take responsibility for their own workstation setup.

Not sure where you stand?

If you are unsure whether your current arrangements are compliant, or whether the approach you are using meets the standard the Regulations require, feel free to get in touch to discuss your requirements.

References

Health and Safety (Display Screen Equipment) Regulations (Northern Ireland) 1992. Available at: https://www.legislation.gov.uk/nisr/1992/513/contents/made
Health and Safety Executive for Northern Ireland (HSENI) - Display Screen Equipment. Available at: https://www.hseni.gov.uk/topics/display-screen-equipment
L26: Work with display screen equipment - Health and Safety (Display Screen Equipment) Regulations 1992 as amended by the Health and Safety (Miscellaneous Amendments) Regulations 2002: Guidance on Regulations. HSE Books, 2003. Available at: www.hse.gov.uk/pubns/books/l26.htm
INDG36: Working with display screen equipment (DSE) - a brief guide. HSE, 2013. Available at: www.hse.gov.uk/pubns/indg36.pdf
CK1: Display screen equipment (DSE) workstation checklist. HSE, 2013. Available at: www.hse.gov.uk/pubns/ck1.htm