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How to build a health surveillance programme

If your risk assessment shows workers need health surveillance, the next question is how to set it up properly. Building a health surveillance programme means working out who needs it, choosing the right checks for the risks, setting intervals, using competent people, keeping records, and - crucially - acting on the results. Here is a practical, step-by-step overview of how to build one. This is general information, not a substitute for competent occupational health advice.

Who and what
Identify who needs which checks
How and when
Competent people, right intervals
Act on results
The point of the whole thing
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The short answer

Building a health surveillance programme means turning the duty to provide surveillance into a working system, through a series of practical steps: first, identify who needs it - start from your risk assessment (COSHH and any other relevant regimes), which tells you who is exposed to a risk that triggers health surveillance (a substance linked to an identifiable disease, with a real chance of harm and a valid detection technique), and so who to include; second, choose the right checks for each risk - matched to the harm the exposure could cause (skin checks for dermatitis risks, respiratory questionnaires and lung-function tests for respiratory risks, and so on), using competent occupational health advice on what's appropriate; third, set appropriate intervals - typically a baseline check when a worker starts (or when surveillance begins) and then periodic checks at intervals suited to the risk and guidance; fourth, use competent people - some checks need an occupational health professional, others can be done by a suitably trained person, so match the person to the check; fifth, keep proper records - health records recording that surveillance was done and its outcomes, kept and retained appropriately (and respecting the confidentiality of health information); and sixth, and most important, act on the results - health surveillance is pointless if you don't act on what it finds: respond to individual results (protecting a worker showing early signs, e.g. by reviewing their exposure and getting medical follow-up) and use the results across the workforce to check whether the controls are working (if surveillance is picking up effects, the controls - including the LEV - may not be adequate, so review them); underlying it all is that health surveillance supports control, not replaces it, so the programme sits alongside good exposure control (with tested LEV), as a check and safety net; so building a programme is: identify who, choose the checks, set intervals, use competent people, record, and act - all from the risk assessment and with competent advice; so it's a system to catch harm early and check controls; this is general information, not competent occupational health advice

Once your risk assessment shows that workers need health surveillance (because they're exposed to a risk that triggers it), you have to set it up properly - a working programme, not just an intention. Here's a practical, step-by-step overview of how to build one. This is general information, not a substitute for competent occupational health advice, which you should get for your specific risks. Step 1: Identify who needs it. Start from your risk assessment. Health surveillance is required where specific criteria are met (under COSHH: exposure to a substance linked to an identifiable disease or health effect, a reasonable likelihood of harm under the work conditions, and a valid detection technique - and there are similar requirements under other regimes like noise, vibration and asbestos). So your risk assessment tells you which exposures trigger health surveillance, and therefore which workers - those exposed to those risks - need to be included. So the first step is identifying the population: who is exposed to what, and who therefore needs surveillance. Step 2: Choose the right checks. For each risk, choose the health checks appropriate to it - matched to the harm the exposure could cause. A dermatitis risk calls for skin checks; a respiratory risk (from a sensitiser or dust) calls for respiratory questionnaires and lung-function tests (spirometry); other risks have their own appropriate checks. The check has to be a valid technique for detecting early signs of that specific harm. This is where competent occupational health advice is essential - a professional advises on what checks are appropriate for your risks, and how they should be done. Step 3: Set intervals (with a baseline). Set appropriate intervals for the checks. Typically this means a baseline check when a worker first starts (or when surveillance begins) - establishing their starting health status, so later changes can be measured against it - and then periodic checks at intervals suited to the risk and the relevant guidance (often annually or as advised, sometimes more frequently for higher risks, and sometimes with more frequent early checks). The baseline matters because surveillance works by detecting change over time, so you need a starting point. Step 4: Use competent people. Health surveillance has to be carried out by people competent to do it. Some checks need an occupational health professional (a doctor or occupational health nurse) - for example, interpreting lung-function tests, or making clinical judgements. Others - simpler checks like some skin checks or questionnaires - can be done by a suitably trained 'responsible person' under occupational health guidance. So match the person to the check: don't have complex clinical checks done by the untrained, but don't necessarily need a doctor for the simplest checks. Competent occupational health support underpins the programme. Step 5: Keep proper records. Keep proper health records - recording that surveillance was carried out, when, and its outcomes. These records track each worker's health over time (so changes and early signs can be spotted across successive checks), evidence that the duty is being met, and can reveal patterns across the workforce. Records need to be kept and retained appropriately (for periods relevant to the risk, which for some exposures is many years, because some diseases develop long after exposure). And the confidentiality of health information must be respected - there's a distinction between the health record (which the employer keeps) and confidential medical information (which stays with the occupational health professional). Step 6: Act on the results. This is the most important step, and the one most easily neglected: act on what the surveillance finds. Health surveillance is pointless if the results just sit in a file. Acting means two things. Respond to individual results: if a worker shows early signs of harm, take action to protect them - review and reduce their exposure, arrange medical follow-up, and address why it happened. Catching an early effect and acting on it is the whole point (it can prevent the harm becoming serious or permanent). And use the results across the workforce to check the controls: if health surveillance is picking up health effects among workers, that's a signal the exposure controls may not be adequate - that people are being harmed despite them - so review the controls, including whether the LEV is capturing the contaminant and still working. So the results feed back into both individual protection and the control regime. The underlying principle: it supports control. Underlying the whole programme is that health surveillance supports control, it doesn't replace it. The primary protection is still controlling the exposure at source (reducing it, capturing it with LEV, RPE where needed), so harm doesn't occur. The surveillance programme sits alongside that as a check and a safety net - catching anything the controls miss, and flagging if the controls are failing. So a good health surveillance programme is built to work with the exposure controls (including well-maintained, tested LEV), not instead of them. This connects to the employer-duties-on-occupational-health-surveillance page (the duty behind the programme). The takeaway. So building a health surveillance programme means: identify who needs it (from the risk assessment); choose the right checks for each risk; set appropriate intervals with a baseline; use competent people; keep proper records; and, above all, act on the results - both to protect individuals and to check the controls. Do it with competent occupational health advice, as part of an overall approach where controlling exposure comes first and surveillance backs it up. This is general information, not a substitute for that advice. This is general information.

Key points

The short version

  • Start from the risk assessment - identify who is exposed and needs surveillance.
  • Choose the right checks for each risk (skin, respiratory, and so on).
  • Set appropriate intervals, with a baseline when workers start.
  • Use competent people and keep proper health records.
  • Act on the results - and use them to check whether controls are working.

Identify who needs it

Start from the risk assessment

The first step in building a health surveillance programme is identifying who needs it - and that starts from your risk assessment. Health surveillance is required where specific criteria are met: under COSHH, exposure to a substance linked to an identifiable disease or health effect, a reasonable likelihood of harm under the work conditions, and a valid technique to detect it (with similar requirements under other regimes like noise, vibration and asbestos). So your risk assessment tells you which exposures trigger health surveillance.

From that, you identify the population to include: which workers are exposed to those triggering risks, and therefore need to be in the programme. This might be everyone doing a particular process (all the sprayers exposed to isocyanates, say, or all those exposed to a hazardous dust), scoped by who actually has the exposure. So the programme's coverage is defined by the risk assessment, not guessed at - you surveil those whose exposure warrants it. Getting this right ensures the programme covers the people who need it (and doesn't waste effort on those who don't). So identify who needs it - start from the risk assessment - is the foundation: the assessment defines who to include. Choosing what to check them for is next. So the risk assessment defines who needs surveillance. This is general information, not competent occupational health advice. This is general information.

Choose the right checks and intervals

Matched to the risk, with a baseline

For each risk, choose the health checks appropriate to it, matched to the harm the exposure could cause. A dermatitis risk calls for skin checks; a respiratory risk (from a sensitiser or a hazardous dust) calls for respiratory questionnaires and lung-function tests (spirometry); other risks have their own appropriate checks. The check must be a valid technique for detecting early signs of that specific harm - so it's targeted, not a general health check. This is where competent occupational health advice is essential: a professional advises on what checks suit your risks and how they should be done.

Then set appropriate intervals. Typically this means a baseline check when a worker first starts (or when surveillance begins) - establishing their starting health status so later changes can be measured against it - and then periodic checks at intervals suited to the risk and the relevant guidance (often periodic, sometimes more frequent for higher risks or in early employment). The baseline matters because surveillance works by detecting change over time, so you need a starting point to compare against. So choose the right checks and intervals - matched to the risk, with a baseline - is the second step: the right checks for each hazard, at the right frequency, starting from a baseline. Who does them is next. So pick targeted checks at suitable intervals, from a baseline. This is general information, not competent occupational health advice. This is general information.

Use competent people

Match the person to the check

Health surveillance has to be carried out by people competent to do it - and the level of competence needed depends on the check. Some checks need an occupational health professional (a doctor or occupational health nurse): for example, interpreting lung-function tests, making clinical judgements, or seeing a worker with signs of harm. Others - simpler checks like some skin checks or standard questionnaires - can be done by a suitably trained 'responsible person' under occupational health guidance.

So match the person to the check: don't have complex clinical checks done by someone untrained, but you don't necessarily need a doctor for the simplest routine checks (a trained responsible person, overseen by occupational health, can do those). Competent occupational health support underpins the whole programme - advising on the checks, doing or overseeing the clinical parts, and interpreting results. So a well-built programme has the right competence at each level, with occupational health professionals involved for the parts that need them. So use competent people - match the person to the check - is the third step: the right level of competence for each check, with occupational health support behind it. Recording the results is next. So the right person does each check, backed by occupational health. This is general information, not competent occupational health advice. This is general information.

Keep proper records

Tracking health over time, confidentially

Keep proper health records - recording that surveillance was carried out, when, and its outcomes. These records serve several purposes: they track each worker's health over time (so changes and early signs can be spotted across successive checks, which a single check wouldn't reveal); they evidence that the duty is being met; and they can reveal patterns across the workforce (several workers showing effects flags a possible control failure).

Records need to be kept and retained appropriately - for periods relevant to the risk, which for some exposures is many years, because some diseases develop long after the exposure (so a record may need keeping for a long time to be useful). And the confidentiality of health information must be respected: there's an important distinction between the health record (a record that surveillance was done and its outcome/fitness conclusion, which the employer keeps) and confidential medical information (clinical details, which stay with the occupational health professional and aren't shared with the employer). So the records are kept properly and confidentially, serving the individual, the compliance duty and the control regime. So keep proper records - tracking health over time, confidentially - is the fourth step: proper, retained, confidential health records. Acting on them is the crucial last step. So record the surveillance properly and confidentially. This is general information, not competent occupational health advice. This is general information.

Act on the results

Protect individuals, and check the controls

This is the most important step, and the one most easily neglected: act on what the surveillance finds. Health surveillance is pointless if the results just sit in a file - the whole value is in acting on them. Acting means two things. Respond to individual results: if a worker shows early signs of harm, take action to protect them - review and reduce their exposure, arrange medical follow-up, and address why it happened. Catching an early effect and acting on it is the entire point, because it can prevent the harm becoming serious or permanent (the difference, sometimes, between a reversible early sign and an established disease).

And use the results across the workforce to check the controls: if health surveillance is picking up health effects among workers, that's a signal the exposure controls may not be adequate - people are being harmed despite them - so review the controls, including whether the LEV is capturing the contaminant and still working (a prompt to check and test the LEV). So the results feed back into both individual protection and the control regime. Underlying this, and the whole programme, is that health surveillance supports control, it doesn't replace it: the primary protection is still controlling exposure at source (with well-maintained, tested LEV among the controls), and surveillance is the check and safety net alongside it. So a good programme is built to work with the exposure controls, catching what they miss and flagging if they fail. So act on the results - protect individuals, and check the controls - is the crucial step and the programme's purpose: use what surveillance finds to protect people and verify the controls. So always act on the findings - that's the point. This is general information, not competent occupational health advice. This is general information.

Questions

Frequently asked questions

How do I know who to include in health surveillance?

Start from your risk assessment - it identifies who is exposed to a risk that triggers health surveillance (under COSHH: a substance linked to an identifiable disease, a real chance of harm, and a valid detection technique), so those workers are who to include; the assessment defines the coverage, not guesswork. You know who to include in health surveillance by starting from your risk assessment. Health surveillance is required where specific criteria are met - under COSHH, exposure to a substance linked to an identifiable disease or health effect, a reasonable likelihood of harm under the work conditions, and a valid technique to detect it (with similar requirements under other regimes like noise, vibration and asbestos). So your risk assessment tells you which exposures trigger health surveillance. From that, you identify the population: the workers exposed to those triggering risks are the ones who need to be in the programme. This might be everyone doing a particular process (all the sprayers exposed to isocyanates, all those exposed to a hazardous dust), scoped by who actually has the exposure. So the coverage is defined by the risk assessment, not guessed at - you surveil those whose exposure warrants it, which ensures the programme covers the right people and doesn't waste effort on those who don't need it. Competent occupational health advice helps confirm who needs what. So the risk assessment defines who to include. So your risk assessment identifies the exposed workers to include. This is general information, not competent occupational health advice. This is general information.

What checks does health surveillance involve?

Checks matched to each risk - skin checks for dermatitis risks, respiratory questionnaires and lung-function tests (spirometry) for respiratory risks, and other targeted checks appropriate to the hazard - each a valid technique for detecting early signs of that specific harm, chosen with competent occupational health advice. Health surveillance involves checks matched to each specific risk - targeted at the harm the exposure could cause, not a general health check. So a dermatitis risk calls for skin checks; a respiratory risk (from a sensitiser like isocyanates or flour dust, or a hazardous dust) calls for respiratory questionnaires and lung-function tests (spirometry); and other risks have their own appropriate checks. The key requirement is that each check is a valid technique for detecting early signs of that specific harm - so it can catch the effect early, when action can still help. The checks range from relatively simple (skin checks, questionnaires) to more formal (lung-function testing), and they're carried out at appropriate intervals (typically a baseline plus periodic checks). Choosing the right checks for your risks is where competent occupational health advice is essential - a professional advises on what's appropriate and how it should be done, rather than you guessing. So the checks are risk-specific, valid detection techniques, chosen with occupational health advice. So targeted checks matched to each risk, chosen with advice. This is general information, not competent occupational health advice. This is general information.

Who should carry out health surveillance?

People competent for the check - some checks (like interpreting lung-function tests or clinical judgements) need an occupational health professional, while simpler ones (some skin checks, questionnaires) can be done by a suitably trained responsible person under occupational health guidance; match the person to the check. Health surveillance should be carried out by people competent to do the specific check - and the level of competence needed varies. Some checks need an occupational health professional (a doctor or occupational health nurse): for example, interpreting lung-function tests, making clinical judgements, or assessing a worker showing signs of harm. Others - simpler checks like some skin checks or standard questionnaires - can be carried out by a suitably trained 'responsible person' under occupational health guidance. So the principle is to match the person to the check: don't have complex clinical checks done by someone untrained, but you don't necessarily need a doctor for the simplest routine checks (a trained responsible person, overseen by occupational health, can do those). Underpinning the whole programme is competent occupational health support - advising on the checks, doing or overseeing the clinical parts, and interpreting results. So a well-run programme has the right competence at each level, with occupational health professionals involved for the parts that genuinely need them. So it's people competent for each check, backed by occupational health. So competent people, matched to each check's demands. This is general information, not competent occupational health advice. This is general information.

Why is acting on the results the most important part?

Because surveillance is pointless if results just sit in a file - its value is in acting: protecting a worker who shows early signs (reviewing their exposure, medical follow-up) before harm becomes serious, and using results across the workforce to check whether the controls (including LEV) are working. Acting on the results is the most important part because health surveillance is pointless if the results just sit in a file - the whole value is in what you do with what it finds. Acting means two things. First, respond to individual results: if a worker shows early signs of harm, take action to protect them - review and reduce their exposure, arrange medical follow-up, and address why it happened. Catching an early effect and acting on it is the entire point, because it can prevent the harm becoming serious or permanent (sometimes the difference between a reversible early sign and an established, irreversible disease). Second, use the results across the workforce to check the controls: if surveillance is picking up health effects among workers, that's a signal the exposure controls may not be adequate - people are being harmed despite them - so review the controls, including whether the LEV is capturing the contaminant and still working. So the results protect individuals and verify the control regime. Without acting, you've detected harm but done nothing about it, defeating the purpose. So acting is where surveillance delivers its protection - which is why it's the crucial step. So because the value of surveillance is only realised by acting on it. So because detecting harm only helps if you act on it. This is general information, not competent occupational health advice. This is general information.

How does health surveillance relate to LEV testing?

They work together - health surveillance results picking up harm signal that controls may be failing, prompting a check of the LEV; but controlling exposure (with tested LEV) is the primary protection and surveillance the safety net, so a good programme is built alongside good, tested controls, not instead of them. Health surveillance and LEV testing work together as complementary parts of protecting workers' health. Controlling the exposure at source is the primary protection - and LEV (capturing the contaminant before it's breathed) is a key control, kept effective by regular thorough examination and testing. Health surveillance sits alongside this as a check and safety net: it catches anything the controls miss, and it provides feedback on whether the controls are working. If surveillance starts picking up health effects among workers, that's a signal the exposure controls may not be adequate - a prompt to review them, including whether the LEV is still capturing the contaminant (which its testing confirms). So surveillance can flag a failing LEV, and LEV testing then verifies and fixes it. But surveillance detects harm rather than preventing exposure, so it doesn't replace controlling the exposure - a good programme is built to work with well-maintained, tested LEV and the other controls, not instead of them. So the two reinforce each other: tested LEV prevents harm, surveillance catches and flags anything that gets through. So they're complementary - surveillance flags control failures, LEV testing proves the control. So they work together, control first and surveillance as backup. This is general information. This is general information.

Does health surveillance replace controlling the exposure?

No - controlling the exposure at source (reducing it, capturing it with LEV, RPE where needed) is the primary protection; health surveillance detects harm rather than preventing it, so it's a check and safety net alongside control, not a substitute - a worker whose surveillance detects early disease has still been exposed. No - health surveillance does not replace controlling the exposure, and a programme should never be built as if it did. The primary protection is controlling the exposure at source: through the hierarchy of control (reducing the hazard, capturing it with LEV, using RPE where needed), so that harm doesn't occur in the first place. Health surveillance works differently - it detects harm, or its early signs, rather than preventing exposure. So it's a check and a safety net that sits alongside the controls, not a substitute for them. Relying on surveillance instead of proper control would be backwards: it would mean waiting to detect harm rather than stopping it happening, and a worker whose surveillance detects early disease has still been exposed and harmed. So a health surveillance programme should be built alongside good exposure control (including well-maintained, tested LEV), as the backstop that catches anything the controls miss and flags if the controls are failing - not as the main line of defence. The right order is: control the exposure to prevent harm, and use surveillance to catch and flag anything that gets through. So no - it supports control, it doesn't replace it. So no; control prevents harm, surveillance only detects it. This is general information, not competent occupational health advice. This is general information.

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Prove the controls behind your surveillance

Health surveillance results that pick up harm are a signal to check whether the controls are working - so a surveillance programme and LEV testing work together; we thoroughly examine and test the LEV that controls the exposure, so the primary protection is proven, with surveillance as the safety net behind it. Ask us to test your LEV. This is general information.