What this is
What is a health surveillance compliance review?
What is a health surveillance compliance review?
A health surveillance compliance review checks whether the assessments a surveillance plan requires are actually happening on time, for the people who are supposed to receive them. It counts what is due, what is completed, what is overdue, and who has never been assessed at all, and separates that from the medical findings themselves.
How is this different from an occupational hygiene programme review?
This review tracks individual workers against a schedule: who is due, who is overdue, who is exempt or refused. It does not evaluate whether the schedule itself, the sampling strategy, or the exposure limits behind it are scientifically sound. That evaluation belongs to the programme review, which asks whether the monitoring and control strategy is adequate, not whether people turned up.
Who is responsible for closing a compliance gap?
Occupational health owns the review and identifies the gap; the site manager owns getting the named individual to attendance, because compliance failures are usually a rostering or access problem rather than a medical one. The two signatures on the record exist because both parties are needed to close it.
Scope
When is a health surveillance compliance review required?
This review is one step in a larger programme. Using it for work that belongs to a neighbouring template produces records that are hard to report on later.
Use this template when
- The quarterly interval for this review has arrived
- A change to the surveillance schedule, workforce, or exposure group needs the compliance position re-checked
- Occupational health needs to report population-level compliance to site management without disclosing individual results
- A trend in adverse findings needs a decision on whether it should trigger an exposure review
- The programme's compliance position feeds a linked surveillance plan or a hygiene programme review
Do not use it for
- Health Surveillance Plan, which decides who needs which health checks and how often; this review only checks whether that plan is being kept to.
- Periodic Health Assessment, which is the individual worker's actual scheduled check; this review counts whether it happened, not what it found.
- Pre-Placement Health Assessment, which is a one-off fitness decision before a worker starts, not a recurring schedule.
- Occupational Hygiene Programme Review, which evaluates whether the monitoring and control strategy behind the schedule is adequate, not whether individuals attended.
- Health Referral Record, which is where an individual finding or fitness concern is actually managed and followed up.
Compliance mapping
Which OSHA requirements does this satisfy?
OSHA has no single scheduling standard. The obligation to keep workers current with surveillance sits in substance- and hazard-specific standards, alongside recordkeeping and access duties.
| Clause | Requirement | Where it lands |
|---|---|---|
| OSHA 29 CFR 1910.95(g)(1) | Annual audiometric testing for employees enrolled in a hearing conservation programme, on a defined schedule | Findings across the population |
| OSHA 29 CFR 1910.134(e)(1) | Medical evaluation before respirator assignment and at required intervals thereafter | Compliance |
| OSHA 29 CFR 1910.1025(j)(1) | Medical surveillance for lead-exposed workers, with frequency tied to blood lead level results | Compliance |
| OSHA 29 CFR 1910.1020(d)(1)(i) | Preservation of employee medical records for the duration of employment plus a specified retention period | Programme quality |
| OSHA 29 CFR 1910.1020(e)(2)(i) | Employee and representative access to their own exposure and medical records on request | Header |
| OSHA 5(a)(1) | General Duty Clause obligation to address a recognised hazard where surveillance has identified one, not merely to record it | Programme quality |
| OSHA 29 CFR 1910.95(l) | Retention and availability of audiometric test records for the duration of employment | Compliance |
What it does not cover
- Health Surveillance Plan, which sets out which workers need which checks and how often, the schedule this review checks compliance against.
- Periodic Health Assessment, the scheduled check itself, carried out and recorded per worker rather than counted in aggregate.
- Pre-Placement Health Assessment, a one-off fitness decision before a worker starts, not a recurring compliance count.
- Health Referral Record, where an individual adverse finding, fitness concern, or refusal is actually followed up to a conclusion.
- Occupational Hygiene Programme Review, which judges whether the strategy behind the schedule is scientifically adequate, not whether it was kept to.
Global
Health Surveillance Compliance Review requirements by country
The duty to run medical surveillance is set standard-by-standard in the United States rather than as a single general requirement, while other regimes treat it as one strand of a broader management system.
OSHA substance- and hazard-specific standards (1910.95, 1910.134, 1910.1025 among others); OSH Act 5(a)(1)
No general scheduling standard. Each applicable substance or hazard standard sets its own frequency and trigger.
A review has to be read against the specific standards in force at the site, since 'overdue' means something different for audiometric testing than for lead surveillance.
COSHH regulation 11; Control of Noise at Work Regulations 2005
Health surveillance is required where exposure could result in identifiable disease and valid techniques exist, with records kept for a set minimum period.
HSE inspectors ask for the surveillance record and the compliance position together; a plan with a poor attendance rate is treated as evidence the duty is not being met in practice.
ISO 45001 cl.9.1.1
Monitoring and measurement of OH&S performance, which surveillance compliance data feeds directly.
Certification auditors expect the compliance percentage to be acted on, not merely reported, with a visible link to corrective action for gaps.
How to complete it
How to complete a health surveillance compliance review, step by step
The template counts easily. The judgement calls are about what the count is allowed to hide and what it has to trigger.
Findings are aggregated across the workforce so a reader cannot work backwards to an individual's result. A finding reported in a way that could identify one worker has broken the confidentiality participation depends on, and that failure outranks any accuracy gained by being specific.
A compliance percentage can hold steady while the same workers rotate through 'overdue' every quarter. The number worth acting on is workers never assessed, because that person has been exposed with no baseline, and the percentage does not surface that on its own.
A worker who refuses surveillance may need a fitness or redeployment decision; one who simply was not released for an appointment needs a rostering fix. Recording both under one overdue count loses which lever actually closes the gap.
Agency and contractor workers sit outside the roster most schedules are built from, so a percentage calculated only against permanent staff can look healthy while this population is essentially unmonitored. Their coverage figure needs to be checked, not assumed to track the main one.
What auditors find
Most common health surveillance compliance review findings
The document these reviews produce almost always exists on schedule. The findings concern what the numbers are hiding and whether a gap ever reached the people who could close it.
| Finding | Clause | What fixes it |
|---|---|---|
| Compliance percentage improves while workers never assessed stays flat or rises. | OSHA 29 CFR 1910.1020(d)(1)(i) | Report and act on workers never assessed as a named list, separate from the aggregate. |
| Refusals and non-attendance recorded under the same overdue count. | OSHA 5(a)(1) | Record refusal and non-attendance as distinct outcomes with different owners and follow-up routes. |
| Agency or contractor workers absent from the compliance denominator entirely. | OSHA 5(a)(1) | Confirm the agency and contractor coverage figure against the actual site roster, not the schedule's default population. |
| A rising trend in adverse findings does not trigger an exposure review. | OSHA 29 CFR 1910.95(g)(1) | Route any worsening trend to an exposure review automatically rather than waiting for the next scheduled one. |
| Individual results identifiable from the way findings are reported. | OSHA 29 CFR 1910.1020(e)(2)(i) | Report findings only as counts and trends across the population; route individual results through the referral record. |
| Action closed as complete once an appointment is booked, not once attendance is confirmed. | OSHA 29 CFR 1910.1020(d)(1)(i) | Close an overdue action only on confirmed attendance and a recorded result, not on a scheduled booking. |
Case in point
Case in point: the percentage that hid the people who mattered most
A packing site ran quarterly compliance reviews for its hearing conservation programme. The percentage sat at 91 to 94 percent for six consecutive quarters, signed off each time with no action required, because it was calculated against permanent headcount only.
An external audit pulled the underlying list and found the same eleven agency workers overdue every quarter, on a rolling contract that never lined up with the site's booking cycle, two of them never baseline-tested despite two years on the noisy line. The aggregate was not dishonest, it was simply the wrong number to manage by; the fix was reporting workers never assessed and agency coverage as separate figures a stable denominator could not smooth over.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
4 sections
- Reference
- HLT-015
- Archetype
- Review
- Record ID
- HSC-2026-000
- Scoring
- Compliance percent
- Direction
- High is good
- Singleton
- No
- Basis
- OSHA
- Links
- Links Surveillance Plan
- Tags
- Health, Governance
- Sections
- 4
- Fields
- 43
- Follow up fields
- 4
- Repeating sections
- 0
- Links out
- 3
Header
10 fieldsReview ID*
Auto sequence. Format HSC-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Date and Time*
Completed By*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Period Covered*
Reviewed By*
Plan ID
Links to HLT-009 Plan ID
Anonymised Trends Only
This review reports numbers and patterns across groups. It never contains an individual result, and anybody reading it should not be able to identify a person.
Compliance
9 fieldsAssessments Due*
Assessments Completed*
Compliance Percent*
Overdue Assessments*
Workers Never Assessed*
Somebody exposed for years with no baseline is the worst position to be in.
Baselines Missing*
Refusals
Non Attendance*
Agency And Contractor Coverage Percent*
Findings across the population
9 fieldsAdverse Findings This Period*
Previous Period
Trend Direction*
- Improving3 pts
- Stable2 pts
- Worsening0 pts
Hearing Findings
Respiratory Findings
Skin Findings
Findings Concentrated In One Area*
- No3 pts
- Yes0 pts
Area Identified
Exposure Review Triggered*
- Yes3 pts
- Not needed3 pts
- No0 pts
Programme quality
15 fieldsProvider Performance Acceptable*
- Yes3 pts
- Concerns1 pt
- No0 pts
Report Turnaround Acceptable*
- Yes3 pts
- Slow1 pt
- No0 pts
Confidentiality Maintained*
- Yes3 pts
- Breach occurred0 pts
Feedback Loop To Exposure Control Working*
The test of the whole programme. Findings must change controls, not just fill a file.
- Yes3 pts
- Partly1 pt
- No0 pts
Anonymity Preserved In This Report*
- Yes3 pts
- No0 pts
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Reported To Management Review*
Next Review Due*
Occupational Health*
Signature*
Site Manager*
Second Signature*
HLT-015 · record IDs look like HSC-2026-000 · Links Surveillance Plan
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The review itself is a count. What fails around it is the handoff: the overdue name that never reaches a roster, the trend that never reaches an exposure review, and the contractor population nobody is tracking at all.
Holds the surveillance schedule against the workforce register, flags overdue and never-assessed workers by name, and routes each gap to its owner.
Reconciles the agency and contractor roster against the site's headcount so coverage is measured against who is actually exposed, not just who is on permanent payroll.
Picks up a worsening trend or findings concentrated in one area and raises the exposure review automatically rather than waiting for the next cycle.
Coordinates the crew, rolls the compliance position into one view for management review, and holds every write for approval before it touches a worker's record.
This template lives in KnowHealth — employee wellbeing. Exposure monitoring, health surveillance, case management and return to work.
Meet KnowHealth→Glossary
Health Surveillance Compliance Review definitions and key terms
- Baseline assessment
- The first surveillance result recorded for a worker against a hazard, used as the reference point every later result is compared to.
- Compliance percent
- Assessments completed as a proportion of assessments due, calculated for the review period across the population, not per worker.
- Refusal
- A worker's declination of a scheduled surveillance assessment, distinct from non-attendance and usually requiring a fitness or redeployment decision.
- Non-attendance
- A missed scheduled assessment where no refusal was made, typically a rostering, release, or logistics failure rather than a worker decision.
- Anonymised trend
- A finding reported as a count or pattern across a group, structured so that no individual result can be inferred by a reader.
FAQ
Frequently asked questions about health surveillance compliance review
Does a high compliance percentage mean the surveillance programme is working?+
No. It means the schedule was kept to. It says nothing about whether the schedule was the right one, whether limits are being compared correctly, or whether a control is failing. That evaluation sits with the hygiene programme review, not this one.
Should a refusal be treated the same as a missed appointment?+
No. A refusal usually needs a documented conversation and possibly a fitness or redeployment decision. A missed appointment is normally a scheduling problem a site manager can fix without occupational health involvement.
Why does the review report trends and not individual results?+
Because readers, site management included, should not be able to identify one worker's medical finding from it. Reporting at population level protects confidentiality and keeps participation voluntary.
How should agency and contractor workers be counted?+
Separately, at least at first. A percentage calculated only against permanent headcount can mask a contractor or agency population that is barely being monitored at all, since they sit outside the roster the schedule was built from.
What should trigger an exposure review from this record?+
A worsening trend in adverse findings, or findings concentrated in one area, should route to an exposure review rather than wait for the next one on the calendar. The compliance review's job is to notice the pattern; the exposure review's job is to explain it.
When is a compliance action actually closed?+
When the worker has been seen and a result recorded, not when an appointment has been booked. Booking and attendance are different events, and treating them as the same one is the most common way an overdue count is understated.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Used together in Occupational Health Surveillance
Similar Exposure Group Register
Groups workers who share the same tasks, agents and exposure patterns
Qualitative Exposure Assessment
Rates likely exposure using professional judgement, task knowledge and existing data, before any sampling
Personal Air Sampling Record
Records a sample taken from a worker's breathing zone over a shift
Area Monitoring Record
Records fixed point sampling in a work area rather than on a person
Noise Dosimetry Record
Records a worker's noise exposure over a full shift using a personal dosimeter
Chemical Exposure Assessment
Assesses exposure to a specific chemical across the tasks where it is used
More in Health Surveillance
Health Surveillance Plan
Sets out which workers need which health checks, how often and why
Pre-Placement Health Assessment
Assesses whether a worker can safely perform the physical demands of a role, before they start
Periodic Health Assessment
A scheduled health check for workers exposed to specific hazards
Exit Health Assessment
Records a worker's health status when they leave a role with hazardous exposure
Health Referral Record
Records a referral to occupational health, with the reason and what is being asked
Vaccination Record
Records vaccinations offered and given where a role carries biological risk
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- OSHA 29 CFR 1910.95 — Occupational noise exposure, hearing conservation amendment
- OSHA 29 CFR 1910.134 — Respiratory protection
- OSHA 29 CFR 1910.1020 — Access to employee exposure and medical records
- OSH Act Section 5(a)(1), General Duty Clause
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.