Who Counts as a DSE User? 9 People in a Typical Office
Somebody in your organisation has decided that two hours a day makes a person a display screen equipment user. Somebody else has heard it is one hour. A third has concluded laptops are exempt.
None of those figures appears anywhere in the Regulations. There is no hours threshold. The test is a description of how somebody works, and applying it correctly decides who gets an assessment, who gets an eye test on request, and who you can reasonably leave out.
So rather than restate the definition, here it is applied to nine people you will recognise from your own floor.
The actual test
Regulation 1(2) 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 his normal work", and an operator as "a self-employed person" meeting the same description. Display screen equipment itself is defined broadly: "any alphanumeric or graphic display screen, regardless of the display process involved."
Two words carry the weight. Habitually points at regularity rather than duration, and significant at the role the screen plays in getting the job done. The HSE's guidance on display screen equipment and its short guide INDG36 set out the factors that help: whether the person depends on the screen to do the work, how much discretion they have over using it, whether the work demands high concentration, whether use is more or less daily and in spells of an hour or more.
Regulation 1(4) then excludes a specific list, two items of which decide several of the cases below: "portable systems not in prolonged use", and "display screen equipment mainly intended for public operation".
Now the nine.
1. The full-time desk-based employee
A user, and nobody argues. Underwriters, paralegals, analysts, developers, administrators. Screen-dependent, no real discretion, sustained spells, daily.
Worth stating because the rest of the list is often treated as the interesting part while the obvious population has assessments from 2021 and no review since a floor move.
2. The hybrid worker, three days at home
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A user, and the home setup is in scope. The definition attaches to the person and the work, not to the building, so splitting the week does not split the duty.
This is where most organisations are thinnest, because the assessment that exists covers a desk the person occupies twice a week. Regulation 2 requires a suitable and sufficient analysis of workstations, and for a hybrid user that means both of them.
3. The hot-desker with no fixed position
A user, and the assessment follows the person rather than the furniture. The practical answer is to assess the individual's needs and requirements once, then make the settings and equipment available wherever they sit, which is a very different exercise from assessing a desk and the reason desk-based templates fail in an unassigned office.
4. The laptop-only mobile worker
Usually a user, and this is where the exclusion is misread. Regulation 1(4) excludes "portable systems not in prolonged use". The exclusion turns on prolonged use, not on portability, so a consultant or salesperson working several hours a day on a laptop is squarely inside the Regulations and a person checking email on a train is not.
The honest finding in most professional firms is that the mobile population is both in scope and the least well equipped, because nobody has provided a separate screen, keyboard or riser for use away from the office.
5. The genuinely occasional user
Probably not a user. Twenty minutes of screen time a day, broken up, not central to the role: a facilities supervisor, a chef, a driver who logs jobs.
The point is not that you need an assessment. It is that you need the reasoning recorded. "Assessed against the user definition and found not to be a user, with reasons and a date" takes two lines and answers the question an inspector or an auditor actually asks, which is how you decided.
6. The agency temp on a six-week placement
Assess them. The person is a worker in your workplace, the task is screen work, and the practical duty to provide a suitable workstation sits with whoever controls the premises and the work.
Arguing about whether the agency or the hirer owes the duty is a contractual question that should be settled in the agreement, and it is not a reason for a twelve-week placement to go unassessed.
7. The self-employed contractor at a desk on your floor
Not a user, but not outside the picture either. A self-employed person meeting the same test is an operator, and the Regulations treat operators differently: the duties to analyse the workstation they use still bite, while the personal entitlements such as eye tests do not run from you to them.
Alongside that, section 3 of the Health and Safety at Work etc. Act 1974 requires you to conduct your undertaking so that people not in your employment are not exposed to risk. The workstation they are sitting at is yours.
8. The student or visitor at a campus terminal
Not a user, and the exclusion is explicit. Regulation 1(4) excludes display screen equipment "mainly intended for public operation", which covers a library catalogue terminal, a self-service kiosk or a visitor sign-in screen.
Students are not employees, so they fall outside the user definition in any event. That does not mean the equipment is unregulated: the section 3 duty applies, and a university with hundreds of fixed study positions should be assessing them as part of the premises rather than as part of the DSE population. A student employed by the institution in a term-time job is a different question, and may well be a user.
9. The night-shift support engineer on three monitors
A user, with other duties stacked on top. The DSE assessment is the start rather than the end, because a person working nights also attracts the free health assessment for night workers under the working time rules, and multi-monitor arrangements raise posture and neck rotation questions a standard checklist handles poorly.
Technology and financial services employers running follow-the-sun support desks have the highest-exposure DSE population in the building and frequently the oldest assessments.
The nine on one page
| Person | User, operator or neither | What follows |
|---|---|---|
| Full-time desk-based employee | User | Assessment, training, eye test on request, breaks |
| Hybrid worker | User | Assessment covering both locations |
| Hot-desker | User | Assess the person, then make settings available anywhere |
| Laptop-only mobile worker | Usually a user | In scope where use is prolonged. Provide screen, keyboard, riser |
| Genuinely occasional user | Usually neither | Record the reasoning and the date |
| Agency temp | Treat as a user | Assess; settle the contractual split separately |
| Self-employed contractor | Operator | Workstation duties apply; personal entitlements do not |
| Student or public terminal | Neither | Excluded as public operation; section 3 duty still applies |
| Night-shift engineer, multi-monitor | User | DSE plus night worker health assessment plus posture review |
Count your own population against that table. In most organisations rows two, four and six are where the uncounted users are, and row five is where the missing paperwork is.
What a user is actually entitled to
Once somebody is a user, four things follow and they are frequently treated as one.
A workstation analysis under regulation 2, reviewed when the workstation or the work changes. Breaks or changes of activity under regulation 4, which is about the pattern of work rather than a fixed rest schedule. An eye and eyesight test on request under regulation 5, repeated at intervals, which our note on DSE eye tests unpacks. And health and safety training under regulation 6, which is a separate duty from the assessment and is the one most often missing.
An organisation with assessments and no training record has done the visible half. A DSE assessment programme that bundles all four together is both cheaper and easier to evidence.
How this differs across borders
Groups running one global DSE programme usually find it is simultaneously too much and too little.
The UK Regulations implement the European display screen equipment directive 90/270/EEC, so the concepts are recognisable across the EEA while the implementation is not. Germany has no standalone DSE regulation: the requirements sit in an annex to its workplace ordinance, so a UK-format assessment does not map onto what an inspector there expects. Several member states are more prescriptive on eye examinations, treating them as a periodic entitlement rather than something provided on request, and some specify break patterns the UK leaves to the organisation of work.
The United States has no direct equivalent instrument at all. A US entity inside a UK-led group will have no document resembling a DSE assessment and may be entirely compliant locally, which is the mirror image of the German problem.
The workable pattern is the one that holds across every technical regime: one methodology and one register, with the local instrument, entitlement and interval attached per country. Holding the user list, the assessment date, the training record and the eye test requests in one place is where health and safety consultants and software are worth more in combination than either alone, because the user population changes with every joiner, leaver and desk move. Periodic health and safety audits should then test the population rather than the template, by picking three people and asking which category they fall in and who decided.
Where Arinite fits
Arinite has spent 15+ years running DSE programmes for organisations where almost everybody is a user and the population never stops moving. We support 1,500+ businesses in 50+ countries and protect 100,000+ employees, with 95%+ client retention. Our health and safety consultants work extensively with offices, legal, insurance and education clients, where the hybrid and mobile populations are the two we most often find uncounted.
For multi-country groups, our global health and safety consultants produce the local instrument and apply the local entitlement rather than exporting the UK assessment, and our international health and safety consultants can tell you which sites your current programme does not satisfy.
Take the nine rows to your HR system and count how many people fall in each. Then book a free gap analysis and we will tell you in one call how many users you have that nobody has assessed.
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Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
