Health Surveillance

13th June 2025
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    Employers have a legal responsibility to ensure that a worker’s health is not impacted by their work activities or their working environment.

    Employers can organise/conduct “health surveillance,” a scheme of repeated health checks used to identify if ill health is being caused by work. This is a legal requirement, in specific circumstances, where a risk of exposure to health remains despite control measures being put in place. It should be used to gauge where harm may still occur.

    These specific risks are related to:

    • Noise
    • Vibration
    • Use of substances that are hazardous to health (i.e., Respirable Crystalline Silica – RCS)

    Conducting health surveillance

    Health surveillance must not be confused with medical surveillance, provided by an HSE-appointed doctor, because employees are working with Asbestos, Lead, or Ionising Radiation. Health surveillance is also not to be confused with health screening or health promotion. 

    It is recommended that the services of a competent occupational health professional be sought out when conducting health surveillance.

    It should:

    • Only be provided to those workers who need it. Blanket coverage of the whole workforce should be avoided
    • Provide feedback about actions to take to further prevent harm and protect workers
    • Allow workers to raise concerns about how their work affects them
    • Provide the opportunity to reinforce a worker’s training and education

    The risk assessment for the activity should help employers decide if health surveillance is needed. The findings will hopefully provide evidence that the controls are being effective, and if not, a more in-depth review of the risk assessment may be needed to revise control measures. Issues that indicate health surveillance might be appropriate include:

    • Cases of properly diagnosed work-related ill health are occurring in the workplace, such as
    • Chronic obstructive pulmonary disease
    • Occupational asthma
    • Dermatitis
    • Silicosis
    • There is evidence of ill health occurring in similar jobs within the same industrial sector
    • There is a heavy reliance on PPE as an exposure control measure (experience tells us that PPE use is not always managed properly or sufficiently)
    • Information has come to light due to insurance claims, manufacturers’ data and/or industry guidance

    Working with employees

    Health surveillance only works with the cooperation of employees. Conduct a consultation and provide employees with the information they need. These discussions can increase a worker’s commitment to health surveillance, which is for their benefit, and comply with and implement all control measures. 

    Employees are also the best asset an employer can have when it comes to understanding the activities conducted. They can help identify the risk of the workplace and help make sure controls are practical.

    It is up to the employer to make sure workers understand:

    • The identified risk and the controls put in place to manage them (one of them being the health surveillance scheme)
    • Why health surveillance is important and what it is for
    • What will happen if ill health is identified
    • That health surveillance appointments will occur during work time and be paid for by the employer
    • Their own duties in law (for example, they must attend appointments)
    • What action can be taken if they refuse to attend appointments

    Act on the results of health surveillance

    When the physical part of health surveillance has ended, the process is not completed until the feedback has been received from the occupational health professional who carried it out. 

    This feedback should advise on fitness for tasks with the relevant exposure(s) and when further health surveillance should be conducted. This information should be stored appropriately, with adequate safeguards for data protection, but also kept readily available for reference. 

    Results should be used to formulate the plan of action moving forward, with worker protection at the forefront, where health surveillance has shown that there is work-related ill health. If further investigation is required, this should be done in a timely manner in discussion with the occupational health professional.

    Also, review information from health surveillance to determine whether other groups of similarly exposed workers, or those involved in similar tasks, have effective controls for each source of health risk. When doing this, groups of workers should be big enough to protect individual workers’ anonymity and prevent disclosure of confidential medical information.

    To avoid accidents, causing harm and facing prosecution,  ensure your business complies with health and safety law in 2025, by:

    • Conducting risk assessments as and when required (prior to undertaking activities). 
    • Providing training regarding the risks involved and how to manage them.
    • Supervising risk management, as necessary, until competence is demonstrated.
    • Formally reviewing risk assessments and associated safe systems of work, regularly.
    • Updating training provided (toolbox talks, in-house or external formal training).
    • Keeping/updating records of all the above processes.