DSE Eye Tests: The 3 Questions Employers Get Wrong
Display screen equipment is one of the few areas of health and safety where the law says something quite specific about money, and it is the area where employers most reliably get the specifics wrong in both directions.
Some organisations buy glasses for anyone who asks. Others refuse everything on the basis that eyesight is a personal matter. Both positions are wrong, and the correct one is narrower and clearer than either.
Three questions, in the order they need answering.
1. Who counts as a user?
Everything turns on this, and it is not the same as everyone who has a screen.
Regulation 1 of the Health and Safety (Display Screen Equipment) Regulations 1992 defines a user as an employee who habitually uses display screen equipment as a significant part of their normal work. Operator covers self-employed people in the equivalent position.
The definition turns on habitual use as a significant part of normal work rather than on hours logged or job title. HSE's guidance on display screen equipment sets out the factors that bear on it: whether the person depends on the equipment to do the job, whether they have discretion over using it, whether the work requires significant training or high concentration, whether use is more or less continuous on most days, and whether errors in the work would have significant consequences.
Four populations cause difficulty, and all four have grown.
Homeworkers and hybrid staff. Somebody who works at a screen from home three days a week is a user, and HSE publishes specific guidance on home working. Where they work does not change whether they are a user; it changes what the assessment has to cover.
Hot deskers. People who use a different desk each day are still users. The assessment covers the configurations they actually use rather than an assigned position that does not exist.
Agency and contract staff. Where they are working under your direction, they are within the arrangements even though they are not on your payroll, and information about the arrangements has to reach them.
Senior people who assume it does not apply. Partners, directors and executives frequently spend more time at a screen than anybody they employ and are least likely to have been assessed or offered anything. The definition does not distinguish by seniority.
Establishing who is a user is a short exercise and it is the one most organisations have never done properly, which is why the rest of this article is usually answered by guesswork.
2. When does the entitlement arise, and what is the employer providing?
Regulation 5 sets out the eyes and eyesight provision, and it is more specific than most summaries suggest.
The employer must ensure that a user is provided, at their request, with an appropriate eye and eyesight test. That obligation arises in three circumstances: as soon as practicable after the request where the person is already a user, before a person becomes a user in the case of a new starter, and at regular intervals thereafter for users who have had a test.
There is also a provision for users experiencing visual difficulties that may reasonably be considered to be caused by display screen work, who are entitled to an appropriate test.
Four practical points follow.
It is on request. You are not obliged to impose testing on people. You are obliged to make the entitlement available and, in practice, to tell people it exists, because an entitlement nobody knows about is not one they can request.
The test is at the employer's cost. This is the part organisations most often get right.
"Appropriate" and "at regular intervals" are not defined by a number. The frequency follows clinical advice for that individual rather than a fixed corporate cycle. A blanket two-year policy is a reasonable administrative default and should not override a shorter interval where the optometrist recommends one.
Before becoming a user matters for recruitment. Someone joining into a screen-based role has the entitlement before they start being a user, which most onboarding processes do not contemplate.
The test itself is an eye and eyesight test in the ordinary clinical sense, performed by a competent person. It is not health surveillance, it is not a fitness-for-work assessment, and the employer is not entitled to clinical detail from it. What the employer needs is whether corrective appliances are required for the display screen work.
3. What must you actually pay for?
Need Expert H&S Guidance?
Our qualified consultants can help you implement the right health & safety measures for your business.
The question that generates the most argument, and where both common employer positions are wrong.
Regulation 5 provides that where a test shows that the user needs special corrective appliances for the display screen work, and normal corrective appliances cannot be used, the employer must provide them. HSE's guidance on eye and eyesight tests covers the position.
Read that carefully, because three distinctions sit inside it.
Special versus normal. Special corrective appliances are those prescribed specifically for the display screen work, typically because the intermediate viewing distance of a screen is not corrected by the person's ordinary prescription. Where somebody's normal glasses work perfectly well at a screen, no appliance obligation arises, even though they wear glasses at work every day.
For the DSE work. The trigger is the screen work specifically, not general eyesight correction. An employer is not funding spectacles because an employee needs spectacles.
Basic appliance. Where the obligation does arise, it extends to the cost of a basic appliance meeting the requirement. A user who prefers designer frames or additional coatings may choose to pay the difference, and many employers set a stated contribution figure to make this simple. That is a sensible administrative approach provided the figure genuinely covers a basic appliance.
The honest summary is that the employer pays for every test a user requests, and pays for glasses only in the narrower case where the screen work specifically requires them.
The three, in short
| Question | Wrong answer | Correct position |
|---|---|---|
| Who is a user | Everyone, or only obvious desk staff | Habitual use as a significant part of normal work |
| When and what | An annual perk, or nothing | A test on request, at cost, at appropriate intervals |
| What you pay for | All glasses, or none | The test always; appliances only where special ones are needed for DSE work, at basic cost |
The middle column shows why this generates so much friction internally. Both wrong answers feel principled, and neither matches the regulation.
Getting the process right
Four steps, and they take an afternoon.
Establish your user list, including homeworkers, hot deskers and senior staff. It is usually longer than expected.
Tell people the entitlement exists, at induction and periodically. Most organisations meet the duty on paper and almost nobody uses it, because nobody knows.
Set a route that does not require a negotiation. A named provider or a stated reimbursement process removes the awkward conversation that otherwise deters people.
Record what was offered and what was provided, not the clinical outcome. The organisation needs evidence that it met the entitlement; it does not need, and should not hold, the detail of somebody's eyesight.
Eye tests are one element of a wider duty. Regulation 2 requires a suitable and sufficient analysis of workstations, and our DSE assessment service covers that alongside the eyes and eyesight provision.
For international employers
The British provision comes from a European directive, and its implementation varies more than employers expect.
Several jurisdictions covered in this series treat screen work as triggering occupational health involvement rather than an optical entitlement alone. Estonia includes work with display screens among the factors requiring mandatory health checks, alongside work in a constantly forced posture including sitting. Lithuania requires health checks where the risk assessment shows a risk, and includes display screen work within its regulatory framework. Finland routes the equivalent through its compulsory occupational health care service and its workplace survey, which can be extended to examine ergonomics specifically. Mexico applies a dedicated standard to the conditions of the place where telework is performed.
So a group policy offering an optical entitlement satisfies the British position and may not satisfy others, where the requirement is a health check delivered through an occupational health provider rather than a test at a high street optician.
Holding user lists, assessments and entitlements across every entity in one register is where health and safety consultants and software are worth more together than either alone, and periodic health and safety audits establish whether the entitlement is genuinely available or merely written down.
Where Arinite fits
Arinite handles display screen equipment as the whole duty rather than as an eye test policy, which is where most organisations have a gap. We support 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years. Our health and safety consultants work extensively with legal, finance and banking and IT and software organisations, where almost the entire workforce meets the user definition.
Where offices span several countries, our global health and safety consultants establish whether each jurisdiction requires an optical entitlement, a health check, or both, and our international health and safety consultants keep that current.
If you could not produce your list of display screen equipment users today, a free gap analysis is the right place to start.
Related Articles
Written by
Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
