Health Surveillance at Work: When It's Required and Who Needs It

Your RAMS says hearing protection is mandatory and the breaker has a trigger time. Then a client's pre-qualification form asks a different question: what health surveillance do you provide? For plenty of small contractors, that's where things go quiet. Is it a legal requirement? Who needs it? Does it mean sending the whole team for medicals every year?

Health surveillance is narrower than most people assume, but where it applies it's a legal duty, and it belongs in your risk assessments rather than in a drawer.

Key takeaway: health surveillance is required where your risk assessment shows people remain exposed to certain health risks, such as noise, vibration, hazardous dust and fumes, or asbestos, after your controls are in place. Every worker under it needs a health record, and the results feed back into your controls.

What is health surveillance?

HSE defines health surveillance as "a scheme of repeated health checks which are used to identify ill health caused by work" (HSE health surveillance overview). It picks up early signs of work-related ill health and shows whether you need to review your risk assessment and controls. If several people on the same task show early signs, the controls on that task aren't working.

HSE is clear that it's not the same as health monitoring, health promotion or health screening. A wellbeing day doesn't count, and nor does face fit testing, which checks that a mask seals rather than checking the wearer's health.

When is health surveillance required by law?

The starting point is regulation 6 of the Management of Health and Safety at Work Regulations 1999. It requires employers to provide "such health surveillance as is appropriate" having regard to the risks identified by the risk assessment. The duty flows straight from your assessment.

Specific regulations then set out when it's needed for particular hazards. HSE's summary is that the law requires health surveillance when workers remain exposed to health risks, because control measures may not always be reliable. On construction, FM and maintenance work, that usually means noise, vibration, hazardous substances and asbestos.

The three-part test for dust, fumes and chemicals

For hazardous substances, HSE's COSHH guidance says health surveillance is necessary when all three of these apply:

1. There is a disease associated with the substance in use.
2. It's possible to detect the disease or an early adverse change and reduce the risk of further harm.
3. The conditions in the workplace make it likely that the disease will appear.

Someone cutting timber or blocks most of the day is in a very different position from someone who opens a tin of paint once a month. The legal source is regulation 11 of the Control of Substances Hazardous to Health Regulations 2002. Our COSHH risk assessment guide covers assessing the exposure, and our silica dust COSHH guide works through a common construction example.

Reference table: health surveillance by hazard

• Noise. When: HSE says hearing checks are needed for employees likely to be regularly exposed above the upper exposure action values (85 dB(A) daily or weekly, or a 137 dB(C) peak), and for anyone at particular risk, such as people with existing hearing loss. What: regular hearing checks, with a baseline before exposure where possible, then usually annually for two years and three-yearly after that. Law: Control of Noise at Work Regulations 2005, regulation 9.
• Hand-arm vibration. When: employees likely to be exposed at or above the exposure action value of 2.5 m/s² A(8), or at risk for another reason. What: a tiered scheme starting with symptom questionnaires, with anyone reporting symptoms referred to occupational health. Law: Control of Vibration at Work Regulations 2005, regulation 7.
• Hazardous substances. When: the three-part test above is met. What: checks matched to the disease, for example occupational asthma, dermatitis or silicosis. Records: at least 40 years. Law: COSHH 2002, regulation 11.
• Asbestos. When: licensed work, and notifiable non-licensed work. What: medical examinations by a doctor before the work starts, then at least every two years (licensed) or three years (notifiable non-licensed). Law: Control of Asbestos Regulations 2012, regulation 22. Our asbestos RAMS guide covers the planning side.
• Lead and ionising radiation. What: medical surveillance by a doctor appointed by HSE. Less common on general construction and FM work.

What does it mean for a small contractor day to day?

Usually far less of a production than people fear:

• It's only for the people who are exposed. The site manager in the cabin doesn't need hearing checks because the groundworkers do. Your risk assessments set the scope.
• Some of it can be done in-house. For vibration, HSE describes basic health surveillance as regularly asking workers about early symptoms with a questionnaire and referring anyone who reports them to an occupational health provider.
• It needs professional input. HSE says schemes should usually be set up with a competent occupational health professional. Hearing checks must be done by someone with appropriate training, under the control of an occupational health professional such as a doctor or suitably trained nurse.
• It's on the clock and at your cost. Under the noise and vibration regulations, employees attend during working hours, at the employer's expense.
• It follows the person, not the site. Run the scheme and keep records centrally, not project by project.

It's also on HSE's radar: its noise and vibration campaign, launched in October 2026, tells employers to arrange health surveillance where required once other controls are in place.

How to set up health surveillance in six steps

1. Start from your risk assessments. List every task where people remain exposed after your controls.
2. Name the people. Who does those tasks regularly? Make sure new starters are picked up.
3. Get occupational health advice. Agree which checks, how often, and who carries them out.
4. Take a baseline. Check people before exposure starts where you can. HSE recommends this for hearing checks.
5. Keep a health record for each person. See below.
6. Act on the results. Feed them back into your risk assessments and controls.

What health surveillance records do you need to keep?

HSE's record keeping guidance separates two kinds of record:

• Health records are the legal record of the outcome: the worker's details, where they work, the hazards they're exposed to and their fitness to carry on with that exposure. You keep these.
• Medical records hold clinical notes and test results. The occupational health professional keeps them in confidence, and you can only see them with the worker's written consent.

Keep health records for at least as long as the regulations say: 40 years from the last entry under COSHH, and the same for licensed asbestos work. Where no period is set, HSE says keep them at least while you employ the worker, and offer a copy when they leave or if you stop trading.

What should you do when health surveillance finds a problem?

HSE says you must act on the results, and that surveillance isn't complete until you've had feedback from your occupational health provider. The regulations and HSE's guidance on acting on results point to the same steps:

• Tell the worker what was found.
• Review your risk assessment and control measures.
• Consider alternative work without further exposure, where occupational health advises it.
• Review the health of others doing similar tasks.

Some conditions are also reportable under RIDDOR once diagnosed by a doctor and linked to specified hazards at work. HSE's list includes hand-arm vibration syndrome, occupational dermatitis, occupational asthma and carpal tunnel syndrome. Our RIDDOR reporting guide explains how to report.

How to write health surveillance into your RAMS and COSHH assessments

Health surveillance sits at the end of a chain: hazard, risk assessment, controls, then checks on the people still exposed. So record it in the documents your team already works from. For each task that needs it, say:

• who is in scope (the role or task, not just "all operatives");
• which checks they need and who provides them;
• how often the checks happen;
• where the health records are kept.

swiftRMS builds this in. COSHH assessments flag, substance by substance, whether health surveillance is required and what it involves. The HAVS assessment works out daily exposure points for each tool and recommends a surveillance tier and frequency (our HAVS assessment guide explains the points). The construction phase plan has its own section for health surveillance arrangements.

These documents are AI-generated drafts that a competent person must review before use on site, and the checks themselves still need the right occupational health input. As HSE puts it, findings from health surveillance must contribute to your risk assessment and to effective controls. A record nobody acts on protects no one.

If your assessments don't yet say who needs health surveillance and how often, try swiftRMS free on your next job. You can also see how AI RAMS works, browse example documents or compare plans.

Frequently asked questions

Is health surveillance a legal requirement?

Yes, where your risk assessment shows it's appropriate. Regulation 6 of the Management of Health and Safety at Work Regulations 1999 sets the general duty, and specific regulations require it for noise, vibration, hazardous substances and asbestos when workers remain exposed after controls. It isn't required for everyone in every job.

Who can carry out health surveillance?

It depends on the hazard. Simple checks, such as vibration symptom questionnaires, can be run in-house by a trained person. HSE says schemes should usually be set up with a competent occupational health professional, and medical surveillance for asbestos, lead and ionising radiation must be done by a doctor, usually one appointed by HSE.

How often is health surveillance needed?

It varies by hazard and by what earlier checks found. For noise, HSE suggests a baseline check, then usually annual checks for the first two years and three-yearly after that. Asbestos medicals are needed at least every two years for licensed work and every three years for notifiable non-licensed work. Your occupational health provider sets the rest.

Is health surveillance the same as a medical?

Not usually. HSE says health surveillance is not the same as health monitoring, health promotion or health screening. It's a scheme of repeated checks aimed at specific work hazards, such as hearing checks for noise. A medical examination by a doctor is required for certain hazards, such as asbestos, lead and ionising radiation.

Official resources

• HSE: Health surveillance overview
• HSE: Health surveillance for noise
• HSE: Hand-arm vibration health surveillance
• HSE: COSHH health surveillance
• HSE: Health surveillance record keeping
• Management of Health and Safety at Work Regulations 1999, regulation 6
• Control of Substances Hazardous to Health Regulations 2002, regulation 11
• Control of Noise at Work Regulations 2005, regulation 9
• Control of Vibration at Work Regulations 2005, regulation 7
• Control of Asbestos Regulations 2012, regulation 22