Occupational health surveillance

Occupational Health Surveillance

Posted By Kerry Budworth on 2016-01-25 19:04

Do You Need Health Surveillance in Your Workplace?

Occupational Health Surveillance as a legal requirement

In some cases that question is easily answered, if your employees work with certain substances or in certain situations then occupational health surveillance is 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

The Control of Substances Hazardous to Health Regulations 2002

Before we move on, let's look at the regulations. Under the regulations, medical surveillance is ruled appropriate for the following substances and work. If your employees work in this manner with these substances by law you need to supply occupational health surveillance.

Vinyl chloride monomer (VCM)

In manufacture, production, reclamation, storage, discharge, transport, use or polymerisation.

Nitro or amino derivatives of phenol and of benzene or its homologues

In the manufacture of nitro or amino derivatives of phenol and of benzene or its homologues and the making of explosives with the use of any of these substances.

Potassium or sodium chromate or dichromate

In manufacture. Ortho-tolidine and its salts. Dianisidine and its salts. Dichlorobenzidine and its salts. In manufacture, formation or use of these substances.

Auramine. Magenta

In manufacture. Carbon disulphide. Disulphur dichloride. Benzene, including benzol. Carbon tetrachloride. Trichlorethylene. Processes in which these substances are used, or given off as vapour, in the manufacture of indiarubber or of articles or goods made wholly or partially of indiarubber.


In manufacture of blocks of fuel consisting of coal, coal dust, coke or slurry with pitch as a binding substance.

Outside of Those Industries and Those Substances

What about outside of those industries and specific substances, is there a case for occupational health surveillance? The short answer is maybe, the health & safety regulations are all encompassing and you have a duty to take steps to protect the health of your employees and any visitors to your workplace. This is a pretty far reaching requirement and ignorance is not a defence, in fact ignorance is bound to be seen as negligence. With the recent changes in sentencing guidelines negligence would be disastrous for any business. 

You can answer the question about occupational health surveillance with your health & safety risk assessment. A thorough risk assessment should have found out the hazards in your workplace, identified who is at risk and identified the measures you can take to control the risks. Where some risk remains (this can be unavoidable) and there is likely to be harm caused to your employees, you will need to take further steps. Occupational health surveillance could be one of those further steps, you should consider health surveillance if your employees are at any risk from:

  • noise or vibration
  • solvents, dusts, fumes, biological agents and other substances hazardous to health

In the case of these risks, control measures may not always be fully reliable. Even though you have instituted appropriate checking and maintenance. Occupational health surveillance can help make sure that any ill health effects or health issues in your employees are detected as early as possible.

Do you need health surveillance?

The simple answer to that question is that if there is still a risk to health after the implementation of all reasonable precautions, you should consider a health surveillance programme. The HSE says that occupational health surveillance is required if all the following 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

Industries that should consider health surveillance

The HSE provides a range of industry-specific guidance and advice on which jobs and industries may require health surveillance, they include;

  • Agriculture

  • Motor Vehicle Repair

  • Foundries

  • Metal Working

  • Ceramics

  • Electroplating

  • Timber treatment / wood working

  • Food industry

  • Beauty industry

  • Printing industry

  • Welding, hot work and allied processes

  • General dust exposure

  • Borehole sites and operation

  • Construction industry

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. If you are unsure about occupational health surveillance, or if you would like to discuss occupational health surveillance services, don't hesitate to call us on 01455 234 600 or contact us online.