Summary
In short
- Surveillance is triggered by exposure. Programmes built around job grade, age or an annual medical are health screening, whatever they are called.
- The classic requirement set is respiratory, skin, hearing, hand-arm vibration and specific substance programmes, each with its own trigger and technique.
- Findings must feed back into the risk assessment. A confirmed case is evidence that controls were inadequate for that person, and it is the most direct information the system will ever get.
- Baseline matters. Surveillance without a baseline can detect that someone has a condition and cannot establish when it developed or whether work contributed.
- Clinical information stays with occupational health. Management receives fitness advice and any restrictions, not diagnoses, and the plan should say so explicitly.
- Where a case is confirmed, the response has two branches: the individual, and everyone else doing the same work.
What it is
What it is
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.
When to use it
When to use it, and when not to
The plan sets out which programmes run, for whom, and how findings are used. Clinical delivery sits with occupational health.
Use it for
- 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
Not 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
Standards
What it is built against
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.
Filling it in
Filling it in well
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.
Audit findings
Common audit 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. |
Worked case
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.
Definitions
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
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.
The agents
What the agents do with it
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→Sources
Sources
- 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