What this is
What is health surveillance?
What is health surveillance?
Systematic, ongoing health checks required where workers are exposed to a hazard capable of causing an identifiable disease, where valid techniques exist to detect it, and where detection at an early stage would benefit the individual. It is a control-verification activity, not a wellbeing offering.
How does it differ from a general health check?
By trigger and purpose. Surveillance is required because of a specific exposure, uses techniques targeted at the effect that exposure causes, and produces findings that feed back into whether controls are adequate. A general health screening is offered to a population and reports to the individual, with no route back into the risk assessment.
Scope
When is a health surveillance plan required?
The plan sets out which programmes run, for whom, and how findings are used. Clinical delivery sits with occupational health.
Use this template when
- Determining which surveillance programmes are required from the risk assessments
- Defining who is in scope for each programme, by exposure rather than by role title
- Setting baseline and periodic intervals per programme
- Establishing how findings feed back into risk assessment and control review
- Governance: who holds records, who receives what, and for how long records are kept
Do not use it for
- The individual health record, which is confidential and held by occupational health
- Exposure monitoring, which measures the environment rather than the person
- Fitness for work assessment for a specific role, which is a different question
- Wellbeing and general health screening, which has no regulatory trigger and different governance
- The exposure control plan for a specific substance, which this plan may reference
Compliance mapping
Which ISO 45001 cl.8.1 requirements does this satisfy?
Surveillance obligations are specific in some jurisdictions and embedded within substance standards in others.
| Clause | Requirement | Where it lands |
|---|---|---|
| COSHH reg.11 | Health surveillance where exposure may cause an identifiable disease and valid detection techniques exist (GB) | Programmes |
| Noise Regulations 2005 | Hearing health surveillance where exposure exceeds the upper action value (GB) | Programmes |
| Vibration Regulations 2005 | Health surveillance where exposure exceeds the action value or a diagnosis exists (GB) | Programmes |
| 29 CFR 1910.95(g) | Audiometric testing programme including baseline and annual audiograms | Programmes |
| 29 CFR 1910.134(e) | Medical evaluation before respirator fit testing and use | Programmes |
| Substance-specific standards | Medical surveillance triggered by exposure at or above defined levels or durations | Programmes |
| 29 CFR 1910.1020 | Access to and retention of employee medical and exposure records | Governance |
| ISO 45001 cl.9.1 | Monitoring and measurement, into which surveillance findings feed | Governance |
What it does not cover
- Individual health records, confidential and held by occupational health.
- Exposure monitoring, measuring the environment rather than the person.
- Fitness for work assessment, addressing capability for a specific role.
- Wellbeing and general screening, which has no regulatory trigger and different governance.
- Substance-specific exposure control plans, which this references rather than contains.
How to complete it
How to complete a health surveillance plan, step by step
Derive the programmes from exposure, establish baselines, and define what happens when something is found.
Who is exposed, to what, at what level and for how long. Job titles are a poor proxy: a maintenance technician may have higher noise and vibration exposure than a production operator with the same title on a different line, and agency staff performing the same task are in scope on the same basis.
A baseline audiogram, skin assessment or lung function test taken before or shortly after starting is what makes later results interpretable. Without it, a finding establishes that a condition exists and cannot establish when it developed, which affects both the individual's care and any question of attribution.
For the individual: assessment, advice, restriction or removal from exposure. For the system: check everyone else doing the same work, revisit the risk assessment, and review the controls. Writing both branches into the plan means the second one happens, because in the moment the clinical branch absorbs all the attention.
Occupational health holds clinical detail. Management receives fitness advice and functional restrictions. The plan should state this, because the alternative is a manager asking a reasonable-sounding question and receiving information they should not have, which damages participation in the programme permanently.
What auditors find
Most common health surveillance plan findings
Surveillance findings concentrate on scope, baselines and feedback.
| Finding | Clause | What fixes it |
|---|---|---|
| Programme scope defined by job title rather than by exposure. | COSHH reg.11 | Derive from the assessments; exposure varies within titles and across shifts. |
| No baseline established before exposure began. | 1910.95(g)(5) | Baseline is what makes later results interpretable. |
| Confirmed cases not fed back into risk assessment. | COSHH reg.11 | A case is direct evidence controls were inadequate; revisit the assessment. |
| Others doing the same work not checked after a confirmed case. | ISO 45001 cl.10.2 | Same exposure, same risk; the population check is the preventive step. |
| Clinical information reaching managers. | 1910.1020 / GDPR | Fitness and restrictions only; the boundary protects participation as well as privacy. |
| Agency and contractor staff excluded from programmes. | COSHH reg.11 | Exposure determines scope, not employment status. |
| Records not retained for the required period. | 1910.1020(d) | Medical records commonly require employment plus thirty years. |
| Surveillance offered but participation not tracked. | ISO 45001 cl.9.1 | Non-participation concentrates in the exposed groups least likely to report symptoms. |
| Wellbeing screening presented as health surveillance. | COSHH reg.11 | Different trigger, technique and governance; one does not satisfy the other. |
| Programme not reviewed after a process or substance change. | COSHH reg.11 | New exposures create new scope; change should trigger review. |
Case in point
Case in point: the first confirmed case
A site running skin surveillance identified a confirmed case of occupational contact dermatitis in a sanitation operative. Occupational health assessed him, advised removal from the specific exposure, and arranged follow-up. The case was handled well and closed.
Nobody checked the other seven people on the same crew, performing the same task with the same chemicals and the same glove regime. Three of them had symptoms they had not reported, on the reasonable basis that dry cracked hands in winter did not seem like a work matter.
The risk assessment for the task was not revisited either. It had been written before the crew moved to a longer shift pattern that increased continuous glove wear, which was the change that mattered.
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.
3 sections
- Reference
- HLT-009
- Archetype
- Plan
- Record ID
- HSP-2026-000
- Scoring
- Not scored
- Direction
- n/a
- Singleton
- No
- Basis
- ISO 45001 cl.8.1, OSHA
- Links
- Links SEG, Worker
- Tags
- Health, Plan
- Sections
- 3
- Fields
- 41
- Follow up fields
- 3
- Repeating sections
- 1
- Links out
- 5
Header
11 fieldsPlan ID*
Auto sequence. Format HSP-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
Version*
Issue Date*
Next Review Due*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Plan Owner*
Occupational Health Provider
Approved By*
Surveillance Detects, It Does Not Protect
Health surveillance finds early harm so you can act. It is never a substitute for controlling exposure, and finding a case means a control has already failed.
Programmes
Repeats12 fieldsHazard*
Surveillance Type*
Audiometry, spirometry, skin inspection, biological monitoring, vision or questionnaire.
Legal Requirement*
SEG Reference
Links to HLT-001 Group Reference
Workers In Scope*
Frequency*
Baseline Required Before Exposure*
Without a baseline you cannot prove whether damage happened here or before they arrived.
- Yes3 pts
- No0 pts
Exit Assessment Required*
- Yes3 pts
- No0 pts
Provider
Referral Trigger Defined*
- Yes3 pts
- No0 pts
Action On Adverse Finding Defined*
- Yes3 pts
- No0 pts
Feedback To Exposure Control Defined*
An adverse finding must trigger a review of the control, not just a medical follow up.
- Yes3 pts
- No0 pts
Governance
18 fieldsQualified Practitioner Appointed*
- Yes3 pts
- No0 pts
Confidentiality Arrangements Documented*
- Yes3 pts
- No0 pts
Consent Process Documented*
- Yes3 pts
- No0 pts
Record Retention Period Set*
- Yes3 pts
- No0 pts
Retention Years
Worker Right Of Access Explained*
- Yes3 pts
- No0 pts
Group Anonymised Reporting Defined*
Management sees trends across a group, never individual results.
- Yes3 pts
- No0 pts
Refusal Process Defined*
- Yes3 pts
- No0 pts
Plan Document
Document ID
Format DOC-0000.
Links to FDN-008 Document ID
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
Occupational Health*
Signature*
Site Manager*
Second Signature*
HLT-009 · record IDs look like HSP-2026-000 · Links SEG, Worker
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The plan defines who is surveilled and why. What fails is scope by job title and the population nobody checked after a case.
Derives programme scope from exposure in the risk assessments, schedules baselines and intervals, and keeps clinical detail behind the information boundary.
Triggers the population check when a case is confirmed, so the system branch of the response happens alongside the clinical one.
Feeds confirmed cases back into the relevant risk assessment as evidence that controls were inadequate for that exposure.
Brings agency and contractor staff into scope where they share the exposure, which employment-based scoping omits.
This template lives in KnowHealth — employee wellbeing. Exposure monitoring, health surveillance, case management and return to work.
Meet KnowHealth→Glossary
Health Surveillance Plan definitions and key terms
- Health surveillance
- Systematic checks triggered by exposure to detect early signs of work-related ill health while removal from exposure still protects.
- Baseline
- The initial measurement against which later results are compared, without which findings cannot be interpreted.
- Identifiable disease
- A condition linked to the exposure with valid detection techniques, which is part of the test for whether surveillance is required.
- Fitness advice
- What occupational health communicates to management: capability and restrictions, without clinical detail.
- Audiometry
- Hearing testing, with baseline and periodic audiograms required where noise exposure crosses defined levels.
- Tiered surveillance
- Programmes structured in levels, from questionnaire through to clinical assessment, escalating on findings.
- Population check
- Examining everyone with the same exposure after a confirmed case, the preventive branch of the response.
- Record retention
- The extended periods required for medical and exposure records, commonly employment plus thirty years.
FAQ
Frequently asked questions about health surveillance plan
What makes surveillance different from a health check?+
The trigger and the purpose. Surveillance is required because of a specific exposure, uses techniques targeted at the effect that exposure causes, and produces findings that feed back into whether controls are adequate. A general health check is offered to a population, reports to the individual, and has no route back into the risk assessment.
Who should be in scope?+
Everyone with the exposure, determined from the risk assessments rather than from job titles. Exposure varies substantially within the same title depending on line, shift and task, and agency and contractor staff performing the same work are in scope on the same basis. Scoping by title reliably includes people who are not exposed and excludes people who are.
Why does baseline matter so much?+
Because without it a later finding establishes that a condition exists and cannot establish when it developed or whether work contributed. That affects the individual's care, any question of attribution, and the organisation's ability to tell whether its controls are working. A baseline taken before or shortly after exposure begins is what makes everything afterwards interpretable.
What should happen when a case is confirmed?+
Two things. The individual is assessed, advised, and restricted or removed from the exposure. And everyone else doing the same work is checked, the risk assessment is revisited, and the controls are reviewed. The second branch is the one that prevents the next case, and it is the one that gets omitted because the clinical response absorbs the attention.
What can managers be told?+
Fitness for work and any functional restrictions. Not diagnoses, test results or clinical detail, which stay with occupational health. The plan should state this boundary explicitly, because a manager asking a reasonable question and receiving more than they should damages participation in the programme in a way that is very difficult to recover.
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
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
Health Surveillance Compliance Review
Checks that scheduled health assessments are actually happening on time
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:
- Control of Substances Hazardous to Health Regulations 2002, regulation 11 (GB)
- Control of Noise at Work Regulations 2005 and Control of Vibration at Work Regulations 2005 (GB)
- 29 CFR 1910.95(g), audiometric testing programme, OSHA
- 29 CFR 1910.1020, access to employee exposure and medical records, OSHA
- 29 CFR 1910.134(e), medical evaluation for respirator use, OSHA
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.