When is health surveillance required?
A common misconception is that health surveillance is a blanket requirement. It isn't — it is risk-based, and the specific trigger depends on the hazard. Here is the general framework, and how the specific rules differ for common workplace hazards.
The general framework
As a general, risk-based principle, health surveillance is appropriate where all of these apply: there is an identifiable disease or adverse health effect linked to the exposure; there is a valid technique for detecting it; there is a reasonable likelihood that the effect will occur under the particular conditions of the work; and surveillance is likely to further the protection of the workers concerned. That is the general framework — but the precise trigger is set by the specific regulation, so check the one that applies (below).
The common triggers
Noise. Audiometric surveillance is required for workers regularly exposed at or above the upper exposure action value (85 dB), or otherwise at particular risk, under the Control of Noise at Work Regulations 2005. See noise action values.
Hand-arm vibration. For workers likely to be regularly exposed above the exposure action value, or otherwise at risk, under the Control of Vibration at Work Regulations 2005 — see HAVS.
Substances hazardous to health. Under the criteria in regulation 11 of COSHH (and any specific Schedule requirements) — for exposures such as respiratory sensitisers, certain skin irritants and some carcinogens. Asbestos and lead have their own separate regimes.
In Northern Ireland the equivalent regulations apply (for example the Control of Noise at Work Regulations (Northern Ireland) 2006 and the Control of Vibration at Work Regulations (Northern Ireland) 2005).
Where clinical judgement sits
The surveillance itself — and any fitness or clinical decision — is carried out by occupational-health professionals or other competent people, not by an employer or by software. The employer identifies who needs surveillance, arranges it, acts on the outcomes, and keeps the records (separately from confidential clinical detail).
Run health surveillance as a programme
Complys records which workers need health surveillance and for what hazard, tracks recall and review dates, and holds the outcomes and evidence — while clinical assessment stays with occupational-health professionals.
Health surveillance software →FAQs
Is health surveillance always required?
No — it is risk-based and selective, not universal. The general principle is that it is appropriate where there is a known adverse health effect linked to the exposure, a valid technique to detect it, a reasonable likelihood of harm, and surveillance would help protect workers. The exact trigger, though, is set by the specific regulation — for example the upper exposure action value for noise, regular exposure above the action value for vibration, and the regulation-11 criteria for COSHH — so check the one that applies rather than assuming any exposure requires it.
What are the common triggers?
Noise (audiometry where workers are at risk, typically at or above the upper exposure action value under the Control of Noise at Work Regulations 2005), hand-arm vibration (Control of Vibration at Work Regulations 2005), and substances hazardous to health under COSHH — for example respiratory sensitisers, some skin irritants, and certain carcinogens. Other regimes (such as asbestos and lead) have their own requirements.
Who carries out health surveillance?
The health surveillance itself and any clinical judgement are carried out by occupational-health professionals or other competent people — not by software. An employer's job is to identify who needs it, arrange it, act on the outcomes, and keep the records.
Related: what is HAVS, noise at work action values, and health surveillance software. General information, not legal or medical advice.