Health surveillance at work

When health surveillance is legally required at work and how to set it up. Covers COSHH hazardous substances, noise, hand-arm vibration, lead, asbestos, ionising radiation, and compressed air. Explains employer duties, appointing occupational health providers, record retention (40 years), and acting on results.

UK-wide
Guide summary

You must set up health surveillance for employees exposed to specific hazards like chemicals, noise, or vibration. This involves regular health checks by a qualified professional. Keep records for 40 years. Failure to comply risks fines and harm to workers.

  • Check if your risk assessment shows exposure to hazardous substances or noise above 85 dB(A)
  • Arrange regular health checks with an occupational health professional
  • Keep detailed records of health surveillance for 40 years
  • Act on abnormal results to prevent further harm
  • Specific checks include lung tests for dust exposure and skin checks for chemicals
  • Noise exposure requires hearing tests
  • Vibration exposure needs hand-arm assessments
  • HSE can enforce penalties for non-compliance
  • Employees must have access to their health records
  • First health check must be before exposure starts
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UK-wide

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When this applies to you

Health surveillance means systematic, regular health checks on employees to detect early signs of work-related ill health. It is a legal requirement when your risk assessment identifies that workers face a residual risk of harm from specific hazards -- even after you have put control measures in place.

Health surveillance is not a general wellness programme or a pre-employment medical. It targets specific health effects caused by specific workplace exposures. You need it when employees are exposed to hazardous substances under COSHH, noise above the upper action value, hand-arm vibration, lead, asbestos, ionising radiation, or compressed air.

If a worker develops an occupational disease that health surveillance would have detected earlier, you face enforcement action from HSE, civil claims for compensation, and the knowledge that preventable harm occurred.

Hazards that trigger health surveillance

Your risk assessment determines whether health surveillance is needed. The following hazards have specific legal requirements for health surveillance when workers are exposed:

COSHH health surveillance

COSHH Regulation 11 requires health surveillance when your risk assessment shows employees are exposed to substances linked to identifiable diseases or adverse health effects, there is a reasonable likelihood of that disease occurring, and valid techniques exist to detect it.

Common COSHH-triggered surveillance includes:

  • Lung function testing (spirometry): For workers exposed to respiratory sensitisers such as isocyanates, flour dust, wood dust, or silica dust. Baseline test before first exposure, then at 6-weekly intervals for the first year, then annually.
  • Skin checks: For workers regularly handling substances causing occupational dermatitis -- epoxy resins, wet cement, cutting oils, cleaning chemicals. Regular skin inspections by a trained responsible person, with referral to occupational health if problems are found.
  • Urine or blood testing: For specific substances such as mercury (urinary mercury levels) or lead (blood lead levels under the Control of Lead at Work Regulations 2002).

Noise and vibration health surveillance

Noise (hearing checks)

The Control of Noise at Work Regulations 2005 require audiometric testing when workers are regularly exposed at or above the upper exposure action value of 85 dB(A), or when they are at risk for any other reason such as existing hearing loss.

Audiometric testing involves:

  • Baseline audiogram: Before first noise exposure or as soon as possible after starting work
  • Follow-up tests: Annually for the first two years, then every three years if no significant change is detected
  • Referral: If audiometry shows deterioration, refer the worker to an occupational health professional and review your noise controls

Hand-arm vibration (HAVS checks)

The Control of Vibration at Work Regulations 2005 require health surveillance for workers regularly exposed above the exposure action value of 2.5 m/s2 A(8). Surveillance uses a tiered approach:

  • Tier 1: Worker self-reported questionnaire asking about symptoms (tingling, numbness, blanching of fingers)
  • Tier 2: Structured interview by a trained person to confirm questionnaire responses
  • Tier 3: Clinical assessment by a qualified doctor using standardised staging (Stockholm Workshop Scale)
  • Tier 4/5: Specialist laboratory tests (only needed in rare or complex cases)

Carry out an initial assessment before or soon after first exposure, then screen annually using Tier 1-2.

Other regulated hazards

Lead: The Control of Lead at Work Regulations 2002 require blood lead monitoring at intervals not exceeding 3 months and medical examination at least every 12 months. An appointed doctor must suspend a worker from lead work if their blood lead level reaches the suspension concentration.

Asbestos: The Control of Asbestos Regulations 2012 require a medical examination every 3 years for licensable asbestos work. The examination must be by a doctor appointed by HSE. A certificate of fitness is issued.

Ionising radiation: The Ionising Radiations Regulations 2017 require dose monitoring and medical surveillance for classified workers. An appointed doctor assesses fitness for continued radiation work.

Compressed air: The Work in Compressed Air Regulations 1996 require fitness-to-work examinations before a worker enters compressed air and at regular intervals thereafter.

How to set up health surveillance

  1. 1

    1. Review your risk assessments

    Check your COSHH assessments, noise assessments, and vibration assessments. Identify which workers are exposed to hazards that trigger a health surveillance requirement. If you have not carried out these assessments, do so first -- health surveillance does not replace proper exposure controls.

  2. 2

    2. Appoint a qualified health professional

    Health surveillance must be carried out by a competent person. For COSHH substances with AMES (appointed medical examiner schedule) entries, an HSE-appointed doctor is required. For audiometry, a trained technician can conduct tests under medical supervision. For skin checks, a trained responsible person such as a first aider with additional training can carry out initial screening. Contact the Society of Occupational Medicine or the Faculty of Occupational Health Nursing to find qualified providers.

  3. 3

    3. Establish baseline health records

    Before workers are first exposed to a hazard, or as soon as possible after, arrange baseline health assessments. These provide the reference point against which future results are compared. For noise, this is a baseline audiogram. For COSHH respiratory sensitisers, it is baseline spirometry. For vibration, it is a Tier 1 questionnaire.

  4. 4

    4. Set up a surveillance schedule

    Create a calendar of when each worker needs their next check. Frequency depends on the hazard -- blood lead tests every 3 months, audiometry annually then every 3 years, lung function tests annually, skin checks as frequently as monthly during initial exposure. Use occupational health software or a simple spreadsheet to track due dates and send reminders.

  5. 5

    5. Act on results

    When health surveillance detects a problem, you must act. Review and improve your exposure controls. Consider moving the affected worker to alternative duties. Investigate whether other workers have similar exposure and may be at risk. An appointed doctor may recommend restrictions on a worker's duties or removal from exposure entirely.

  6. 6

    6. Maintain records for 40 years

    You must keep individual health surveillance records for 40 years from the date of the last entry. Records must include the worker's name, date of surveillance, the outcome, and any restrictions recommended. Employees are entitled to see their own records. If your business ceases trading, offer records to HSE for safekeeping.

  7. 7

    7. Inform employees about their results

    Give each employee access to their individual health record. Explain what the results mean and what action, if any, is required. Workers must understand that health surveillance protects them -- it is not a test they can pass or fail.

Common mistakes to avoid

Confusing health surveillance with sickness absence management: Health surveillance is a proactive, statutory requirement to detect early signs of specific work-related conditions. It is not about managing absence or assessing general fitness for work.

Not acting on results: The most common failing is carrying out surveillance but not acting when results show a problem. If a worker's lung function is declining, you must investigate and improve controls -- not simply record the result.

Stopping surveillance when a worker leaves: Offer departing workers a copy of their health records. Some health effects such as noise-induced hearing loss or occupational cancer may not become apparent for years after exposure ends.

Relying on health surveillance instead of controls: Health surveillance detects harm that has already begun. It does not prevent exposure. Your primary duty is to eliminate or control the hazard. Health surveillance is a safety net, not a substitute for proper risk management.

What to do next

Review your workplace risk assessments to determine whether any of your employees require health surveillance. If they do, contact an occupational health provider to arrange a programme. The Society of Occupational Medicine and the Faculty of Occupational Health Nursing can help you find qualified professionals in your area.

If you are already running health surveillance, check that your records are complete, that you are acting on abnormal results, and that your 40-year retention arrangements are in place.

Official guidance on health surveillance