Health surveillance guidance

The following information provides guidance relating to health surveillance. It outlines the categories of hazards where health surveillance may be appropriate and provides practical guidance on when exposure levels in the workplace fulfil the legislative criteria for requiring health surveillance. Guidance is also provided on what exposure information is required by the University Occupational Health Service (UOHS) to allow them to establish the appropriate level of health surveillance.

This risk-based approach, consistent with legislative requirements, aims to ensure those at highest risk (and therefore in most need of health surveillance) are under the appropriate level of health surveillance, and those whose exposure does not meet the criteria are not subject to health surveillance where this is unnecessary. This is pursuant to the appropriate use of clinical resources.

What is Health Surveillance?

Health surveillance is a system of ongoing health checks. These health checks may be required by law for employees who are exposed to noise or vibration, ionising radiation, solvents, fumes, dusts, biological agents and other substances hazardous to health, or work in compressed air.

Health surveillance is important for:

detecting ill-health effects at an early stage, so employers can introduce better controls to prevent them getting worse
providing data to help employers evaluate health risks
enabling employees to raise concerns about how work affects their health
highlighting lapses in workplace control measures, therefore providing invaluable feedback to the risk assessment
providing an opportunity to reinforce training and education of employees (e.g. on the impact of health effects and the use of protective equipment)

Individual risk assessments should be used to identify any need for health surveillance. You should not use health surveillance as a substitute for undertaking a risk assessment or using effective controls.

Health surveillance can sometimes be used to help identify where more needs to be done to control risks and where early signs of work-related ill health are detected, employers should take action to prevent further harm and protect employees.

Why do we need Health Surveillance?

Health surveillance is required by law where certain criteria are met. It is not required simply because there is work involving a hazard - working with something is not the same as being exposed to it, or meeting the criteria of health surveillance
Health surveillance is not a control measure and does not remove the need for appropriate risk assessments, including the identification of hazards, suitable controls measures, maintenance of those control measures, and instruction, training and supervision of those using them. Exposure should always be adequately controlled
The need for health surveillance comes out of the risk assessment process in accordance with the criteria set out in the relevant legislation. This should be done prior to starting the work activity
The health surveillance requirements outlined apply to staff (in accordance with relevant legislation), except where indicated otherwise, e.g. LAA where HSE guidance and the current University policy statement indicates that students (and visitors) should be registered for health surveillance
Visitors (including contractors) should follow departmental procedures and control measures. There should be a risk assessment covering their activities (shared with their employer). Their employer is responsible for their health surveillance arrangements and individual risk assessments. Departments may wish to confirm these arrangements are in place when authorising access
Where health surveillance is required, the supervisor must complete a ‘Health Surveillance HS1 form’ with the required level of information. It remains the responsibility of the head of department, and individual supervisors, for ensuring registration to the health surveillance programme, as well as attendance by individuals where required

What is not covered by Health Surveillance?

Common myths about health surveillance:

Health surveillance is not a substitute for undertaking a risk assessment
Health surveillance does not reduce the need to eliminate or manage health risks

Health surveillance is a legal requirement, but should not be confused with:

activities to monitor health where the effects from work are strongly suspected but cannot be established
workplace wellbeing checks, such as promoting healthy living
fitness to work assessments, such as fitness to drive forklift trucks or health assessments requested by night workers
health assessments, including vaccinations, such as working with specific pathogens

These may require a separate registration with Occupational Health.