Health Surveillance FAQs

What Is Health Surveillance?

Health surveillance is a system of ongoing health checks. These health checks may be required by law for employees who are exposed to noise or vibration, ionising radiation, solvents, fumes, dusts, biological agents, and other substances hazardous to health, or work in compressed air. Health Surveillance is not a substitute for undertaking a suitable and sufficient risk assessment and does not reduce the need to eliminate or manage health risks. All other control measures to protect workers’ health must be robust and put in place first.

What Is The Purpose Of Health Surveillance?

The purpose of health surveillance is to maintain and protect the health and safety of your employees. This is by early detection of adverse changes to health, because of workplace exposures to health hazards.

Health Surveillance is a legal requirement and should not be confused with:

  • Workplace wellbeing checks, such as promoting healthy living

  • Fitness to work assessments such as fitness to drive forklift trucks or health assessments requested by night workers

Health surveillance is important to:

  • Detect ill-health effects at an early stage, so you can introduce better controls to prevent them getting worse

  • Provide data to help you evaluate health risks within your business

  • Enable employees to raise concerns about how work affects their health

  • Highlight lapses in workplace control measures, therefore providing invaluable feedback to your risk assessment

  • Provide an opportunity to reinforce training and education of employees (e.g., on the impact of health effects, the importance of adhering to the controls in place, including the correct use of personal protective equipment)

Your Health Risk Assessments (HRAs) should be used to identify any need for, and type of health surveillance required. You should not use health surveillance as a substitute for undertaking a risk assessment or using effective controls.

Is Health Surveillance A Legal Requirement?

Health surveillance may be required by law for employees who are exposed to:

  • Noise or vibration

  • Ionising radiation

  • Asbestos, lead, or work in compressed air

  • Solvents, fumes, dusts, biological agents, and other substances hazardous to health

Workers involved with asbestos, lead, compressed air, or ionising radiation require statutory medical surveillance under specific regulations, conducted by an HSE appointed doctor. The nature and frequency of these medicals are specific to the defined hazard.

Do I Need A Health Surveillance Programme?

The starting point in identifying the requirement for health surveillance is to conduct a risk assessment.

This will help you to identify:

  • The health hazards in the workplace

  • Who is at risk

  • The control measures in place

  • What type and level of health surveillance is required

The decision to carry out health surveillance is informed by the Business’ HRAs. Once robust controls are in place, but where some risk remains and there is likely to be harm caused to your employees, health surveillance should be implemented.

If your risk assessment is suitable and sufficient it will have identified all of the hazards in your workplace, who is at risk and the measures you can take to control the risks. You should not take a “blanket approach” to health surveillance. Health surveillance must be risk based and the risk assessment reviewed regularly to make sure it remains current and up to date.

You should strongly consider health surveillance if your employees are at risk from:

  • Noise or vibration

  • Ionising radiation

  • Asbestos, lead, or work in compressed air

  • Solvents, fumes, dusts, biological agents, and other substances hazardous to health

In the case of these particular hazards, control measures may not always be reliable, despite appropriate checking and maintenance. It, therefore makes sense to introduce health surveillance in order that any ill health is detected early.

Health surveillance is required if all the following HSE criteria are met:

  • There is an identifiable disease/adverse health effect and evidence of a link with workplace exposure

  • It is likely the disease/health effect may occur

  • There are valid techniques for detecting early signs of the disease/health effect

  • These techniques do not pose a risk to employees

What Sort Of Health Surveillance Do I Need?

Where your risk assessment has identified the requirement to implement a health surveillance programme, you will need to put into place a programme that adequately addresses the risks and potential ill-health effects your employees may be exposed to.

The HSE provides a range of industry-specific guidance and much of this includes advice on which jobs may require health surveillance and what you need to do in response. There are also a number of high hazard substances or agents where the law requires that the health surveillance programme includes statutory medical surveillance.

Statutory medical surveillance involves a medical examination, and possibly tests, by a doctor with appropriate training and experience. The doctor must have been appointed by HSE to undertake the statutory health surveillance required.

Medical surveillance is a legal requirement for the following workplace exposures:

  • Particular types of work with asbestos

  • Work with lead

  • Work with those substances hazardous to health that are subject to Schedule 6 of the Control of Substances Hazardous to Health Regulations 2002

  • Work with ionising radiation

  • Work in compressed air

What Are Occupational Health Surveillance Tests?

The occupational health surveillance tests used in the assessments depend on the risks identified, and the type and duration of an employee’s exposure to the risk. In some instances, the completion of a symptom questionnaire that is then assessed by an occupational health clinician may be considered sufficient.

Audiometric (Hearing) Testing

Audiometry is a technique used to detect early damage to hearing, from exposure to noise. Identifying any damage allows appropriate action to be taken, as well as a referral of the individual. Audio health surveillance may also find changes in hearing due to other causes outside of work. The test involves identifying a sequence of tones and volumes in a controlled environment.

Spirometry (Lung Function) Testing

Spirometry Tests (Lung Function Tests) aim to detect early damage to lung function from exposure to respiratory sensitisers and other substances that have the potential to cause serious ill health.

Spirometry screening measures:

  • Vital Capacity: how much air the individual can inhale and exhale

  • Forced Vital Capacity: the amount of air the individual can forcibly exhale from their lungs after fully inhaling

Hand Arm Vibration Health Surveillance

HAVS screening is used to detect whether working with vibrating tools is affecting the individual’s hands, arms or circulation or aggravating any underlying medical condition they may have.

Health surveillance should be provided for vibration-exposed employees who:

  • Are likely to be regularly exposed above the action value of 2.5 m/s2 A(8)

  • Are likely to be exposed occasionally above the action value and where the risk assessment identifies that the frequency and severity of exposure may pose a risk to health; or

  • Have a diagnosis of HAVS (even when exposed below the action value)

The health surveillance programme is based on the Health and Safety Executive tiered system, as advised by the HSE, in the Guidance to the Control of Vibration at Work Regulations.

Skin Surveillance

Employers are required to arrange suitable health surveillance (COSHH Reg. 11) where:

  • There is exposure to ‘wet work’ and/or substances known to cause dermatitis. and

  • There is a reasonable likelihood that the working procedures in place would lead to dermatitis. In other words, hands are in direct contact with ‘wet work’ and/or chemicals and there is evidence that the exposure is taking place regularly.

Skin surveillance is usually in the form of a symptom questionnaire and skin inspection.

What Do I Do With The Results Of The Health Surveillance Programme?

You will need to:

  • Keep records of the health surveillance advice provided for each employee (the confidential medical records from the health surveillance are securely stored by your occupational health provider). An HSE Inspector is entitled to ask to see your employees’ health surveillance records as part of their occupational health inspection, to ensure that you are complying with the regulations

  • Act upon any recommendations made by the occupational health provider about employees

  • Use the results to review and, if necessary, revise your risk assessment and your plans to control risks

Analysing the results of your health surveillance for groups of workers can give you an insight into how well your risk control arrangements are working.

As a rule, keep individual health records for those employees for as long as they are under health surveillance. Some regulations, for example, the Control of Substances Hazardous to Health (COSHH) and those for lead, asbestos, ionising radiation, and compressed air, require that records should be retained for much longer (up to 50 years) as ill health effects might not become apparent until a long time after exposure.

Please see link to HSE’s health Surveillance website for further information.