Health surveillance plays a vital role in safeguarding employee wellbeing and ensuring compliance with UK health and safety law. In a workplace context, health surveillance refers to a system of ongoing, repetitive health checks designed to detect early signs of work-related ill health. It provides employers with essential insight into whether workplace exposures, such as noise, vibration, chemicals or dust, are affecting workers’ health and whether further control measures are required.
Not every workplace requires health surveillance, but many do, particularly where hazardous substances or harmful physical agents are present and cannot be fully controlled through engineering or organisational measures. Where residual risk remains, health surveillance becomes a legal requirement.
Kingfisher Professional Services supports employers across all sectors with expert Health & Safety consultancy, comprehensive risk assessments and tailored occupational health-surveillance programmes to ensure legal compliance and protect employee health.
What Is Health Surveillance?
What Health Surveillance Means
Health surveillance refers to regular, systematic health checks carried out to monitor employees for early signs of work-related illness. These checks are directly linked to specific hazards in the workplace and are designed to identify harm at the earliest possible stage, before symptoms become severe or irreversible.
It is distinct from general health screening or wellbeing initiatives. Health surveillance is hazard‑specific and arises from formal risk assessment outcomes. Typical examples include hearing tests for noisy environments, lung-function tests for workers exposed to respiratory hazards, or skin checks for those handling sensitisers.
When UK Law Requires Health Surveillance
Under UK health and safety law, employers have a duty to provide health surveillance whenever a risk assessment shows that residual risk of harm remains, even after appropriate control measures have been implemented. This is especially relevant where exposure to hazardous agents cannot be eliminated entirely.
Several regulations impose mandatory health surveillance, including:
- Control of Substances Hazardous to Health Regulations 2002 (COSHH) – for dust, fumes, chemicals, mists, vapours and biological agents.
- Control of Noise at Work Regulations 2005 – for employees regularly exposed above upper exposure action values.
- Control of Vibration at Work Regulations 2005 – for workers using vibrating tools or machinery, or exposed to whole‑body vibration.
Health surveillance should be implemented with involvement from a competent occupational health professional, following proper medical protocols and maintaining secure, legally compliant health records.
Key Situations & Hazards That Commonly Trigger Health Surveillance
Health surveillance becomes necessary when workplace hazards pose an ongoing risk that could lead to identifiable occupational diseases or conditions. Understanding these triggers ensures employers remain compliant and proactive.
Noise Exposure
Workers exposed to noise levels regularly exceeding 85 dB(A) are at risk of noise-induced hearing loss. Where exposure cannot be reduced sufficiently, employers must implement hearing surveillance, including baseline audiometry and periodic hearing checks.
Vibration Exposure
Hand‑arm vibration syndrome (HAVS) and whole‑body vibration injuries are long-term risks associated with vibrating tools, machinery, and certain vehicles. Surveillance is required when risk assessments indicate that exposure could lead to early-stage symptoms unless monitored.
Hazardous Substances
Under COSHH, health surveillance is required wherever there is a “reasonable likelihood” that exposure to harmful substances could cause disease. This includes:
- Respiratory sensitisers
- Skin sensitisers
- Carcinogens and mutagens
- Dust, fumes and vapour exposures
- Biological agents
Workers may require lung-function tests, skin checks, blood tests or other specialist assessments depending on the specific hazard.
Other Hazard Triggers
Health surveillance may also apply in situations involving radiation, lead, asbestos, or other high‑risk agents. Additionally, health surveillance is recommended when employees start new roles, when tasks or processes change, or when new materials are introduced. Establishing baseline health data allows for accurate comparison over time and supports early detection of change.
How to Introduce Health Surveillance: Step‑by‑Step Employer Guide
Introducing health surveillance should follow a structured, compliance‑driven approach. The following steps help employers implement programmes that are both legally sound and operationally effective.
Step 1: Conduct a Comprehensive Risk Assessment
A thorough risk assessment is the foundation for deciding whether health surveillance is required. Employers must analyse all tasks, processes, equipment and substances used in the workplace. The assessment should determine whether existing controls eliminate or sufficiently reduce risk. If residual risk remains, and especially where exposure could cause identifiable ill health, health surveillance becomes necessary. This decision should be clearly documented and reviewed regularly.
Step 2: Consult with Employees and Occupational‑Health Professionals
Engagement with employees, safety representatives and managers is crucial for ensuring trust and participation. Employers should appoint a competent occupational health provider who understands the hazards involved and can recommend appropriate surveillance measures. Where in‑house capacity is unavailable, external providers can deliver compliant and tailored programmes.
Step 3: Define the Scope – Who and What to Monitor
Employers must identify which individuals or groups require monitoring based on exposure profiles. Surveillance requirements differ by hazard: lung‑function tests may be necessary for those exposed to airborne contaminants, while audiometry may be needed for noisy environments. The scope should reflect role-specific risks, vulnerable workers and potential exposure changes over time.
Step 4: Implement the Programme & Record Keeping
Once defined, the programme should be scheduled and implemented with clear timelines. Baseline assessments should be conducted prior to exposure, followed by regular periodic checks. Robust health records must be maintained for each individual, in accordance with legal retention requirements, which may span decades for certain hazards. Data protection is essential – records should be accessible only to authorised personnel.
Step 5: Act on Results – Review Controls, Adjust Work, Provide Support
Health surveillance is only effective when findings are acted upon. If early signs of ill health are detected, employers must review risk controls, improve ventilation, revise work processes, enhance PPE provision, or adjust employee duties where necessary. Surveillance outcomes should feed into continuous improvement, ensuring workplaces remain safe and legally compliant.
Best Practice & Practical Tips – Beyond Legal Minimum
Effective health surveillance should be viewed as a proactive investment in employee well-being. It strengthens safety culture, builds trust, and reduces long-term sickness absence.
Establishing baseline health data helps employers track changes and protect both employees and the organisation. Transparent communication about the purpose of surveillance – emphasising confidentiality and the value of early detection – encourages cooperation and reduces anxiety.
Health surveillance should sit within a broader health and safety system that includes risk assessments, PPE programmes, training, incident reporting and continuous improvement. Employers must also be mindful of record retention requirements, as certain hazards require long-term health record storage for regulatory or medical reasons.
By integrating surveillance with existing safety systems, organisations create a more complete and effective approach to managing occupational health risks.
How Kingfisher Professional Services Can Help
Kingfisher Professional Services provides expert support to ensure employers meet their legal obligations and protect employee health. Our consultants conduct detailed risk assessments to determine whether health surveillance is required and what form it should take.
We design and implement tailored health surveillance programmes based on your specific hazards, industry requirements and workforce profile. Where needed, we coordinate access to qualified occupational-health professionals for specialist assessments.
Our services include assistance with compliance documentation, secure record‑keeping, data protection, and preparation for regulatory inspections. We also provide training for employees and managers to ensure everyone understands the purpose and value of health surveillance.
With a proactive, structured approach, Kingfisher helps organisations embed a culture of safety, protect their people and remain compliant with UK regulations.
Conclusion
Health surveillance is a vital component of workplace health and safety, helping employers identify early signs of work-related ill health and strengthen the effectiveness of control measures. In environments involving noise, vibration, hazardous substances or other high‑risk exposures, it is a legal requirement under UK law.
By implementing a well-planned surveillance programme, employers can protect employee wellbeing, reduce risk and demonstrate a strong commitment to safety. If you are unsure whether your business requires health surveillance or need support implementing a compliant programme, Kingfisher Professional Services is ready to assist.