Diana Kloss

Occupational Health Law


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advise the employee of risks of further exposure, and protect the confidentiality of the information disclosed and the advice given.

      (Samuels: Medical Surveillance, Journal of Occupational Medicine, Aug. 1986)

      In previous editions of this book, I doubted whether this was an accurate reflection of the legal position. My view was supported by the High Court in Baker v. Kaye (1997). Mr Baker was a television sales executive. He was offered employment by NBC Europe, a subsidiary of General Electric (GE), as director of international sales. The offer, contained in a letter from GE’s human resources manager, was to take effect from 1 March, subject to a satisfactory medical report from the company doctor, Dr Kaye. Mr Baker heard of the offer while attending a trade convention in Monte Carlo. On his return he attended Dr Kaye’s office for the pre‐employment assessment, in the course of which a blood sample was taken. When Dr Kaye received the results of the test, he considered that there was evidence of over‐indulgence in alcohol. He telephoned the company to ask about the nature of the job, and was told that it was stressful, involving a high degree of responsibility, a great deal of business entertaining and frequent trips abroad. Dr Kaye knew that the company was intolerant of heavy drinking. He arranged to see Mr Baker again and asked about his alcohol consumption. Mr Baker admitted to having drunk slightly more than usual when he was in Monte Carlo. Dr Kaye took a second sample of blood and advised him to consult his GP, who recommended that he abstain from alcohol for several days, after which she would repeat the tests. Meanwhile, Mr Baker, not anticipating any serious problems, resigned from his previous job.

      When Dr Kaye received the results of the second test he concluded that Mr Baker had an alcohol problem. He discussed the results with a medical colleague, a consultant gastroenterologist, and with GE’s former Medical Officer, both of whom agreed with him. He informed the company that he was unable to recommend Mr Baker (though not, of course, giving the reason) and told Mr Baker of what he had done, and why. Mr Baker did not get the job. Tests taken by his GP after a short period of abstinence showed substantial improvement and after two weeks were within normal limits. A month later Professor McIntyre, a consultant physician, examined Mr Baker and advised that there was no evidence of liver damage.

      Was Dr Kaye negligent? The plaintiff was supported by the expert evidence of Professor McIntyre and of Dr Cockcroft, a consultant in occupational medicine. The defendant called Sir Anthony Dawson, an independent health care consultant. It was held that, on the facts, Dr Kaye was not negligent. The judge decided that it was not essential to explore the plaintiff’s absenteeism record, because of the high degree of independence enjoyed by senior managers (a more junior employee might be different). He decided that it was not essential to weigh the plaintiff (Mr Baker was ‘clinically corpulent’). He decided that a substantial body of reasonable medical opinion would have arrived at the same conclusions as Dr Kaye about the blood tests. Mr Baker lost the action.

      The view that a doctor owes a duty of care to a job applicant, at least as regards physical harm, is supported by the decision of the Court of Appeal in R v. Croydon Health Authority (1997). A radiologist examined a woman who was a job applicant. He negligently failed to report to the OH physician the evidence of primary pulmonary hypertension disclosed by a pre‐employment x‐ray. The court held that there was a duty of care imposed by law on the radiologist to the job applicant in relation to the pre‐employment assessment.

      In a subsequent case in 1998, Kapfunde v. Abbey National, the Court of Appeal disagreed with the decision in Baker v. Kaye. Mrs Kapfunde applied for a job with the Abbey National and completed a medical questionnaire disclosing details of her sickness absence record in her previous employment. The questionnaire was reviewed by Dr Daniel, Abbey National’s independent OH physician, who advised that the applicant’s medical history indicated that she was likely to have a higher than average absence level; she suffered from sickle cell anaemia. Mrs Kapfunde, who was not considered for the job, sued the Abbey National as Dr Daniel’s employer, arguing that Dr Daniel was negligent. The court held, first, that Dr Daniel was not an employee but an independent contractor, so that Abbey National could not be vicariously liable for her. Secondly, they decided that in any event Dr Daniel was not negligent, because she had exercised the skill and care to be expected of a reasonably competent OH physician in the circumstances. Dr Daniel never saw Mrs Kapfunde in person; she merely assessed her questionnaire. The case arose before the Disability Discrimination Act came into force. Now, there might be an argument that Mrs Kapfunde was a disabled person under the Equality Act.

      The main interest in the judgment lies in the conclusion that Dr Daniel did not owe Mrs Kapfunde a duty of care. The Court of Appeal drew an analogy with the decision of the House of Lords in X v. Bedfordshire County Council (1995), where it was held that the psychiatrists who examined children at the request of the local authority in cases of suspected child abuse owed no duty of care to those children or their parents. In later case law, after an appeal to the European Court of Human Rights, the courts have held that the psychiatrist does owe a duty of care to the child, though not to the parents (JD and Others v. East Berkshire Community Health (2003)). In Poole Borough Council v GN (2019), the Supreme Court overruled the Bedfordshire County Council decision. Thus, the authority of the Kapfunde decision has been weakened. In addition, the harm suffered by the job applicant was economic only: she did not get the job. It is submitted that had there been physical harm, the OH physician could have been liable for a negligent failure to diagnose a physical problem and to warn the job applicant of the need to consult her GP, as in the Croydon case above.

      In the United States, liability has been imposed on OH doctors who have negligently failed to diagnose medical conditions. For example, in Green v. Walker (1990), an employee was required to undergo annual health checks. The doctor carried out all the tests, found the results to be normal and classified the employee as fit. A year later the employee was diagnosed with lung cancer. It was held that the doctor owed a duty of care to the employee. This has