COSHH, Noise, Vibration, Asbestos and Lead, UK wide
Health Surveillance
Health surveillance exists because controls fail quietly. Where a worker stays exposed to a health risk after controls are in place, the law requires repeated checks designed to catch work caused ill health early enough to act on it. AL23 Safety scopes the programme, appoints and manages the clinical provision, interprets what comes back and turns it into action, for clients UK wide.
What is health surveillance?
A control check that happens to involve a clinician
HSE defines health surveillance as a scheme of repeated health checks used to identify ill health caused by work. It is required where workers remain exposed even after controls are in place. The named hazards are noise, vibration and substances hazardous to health. Medical surveillance is a stricter sub-set, required by law for asbestos, lead and ionising radiation among others.
Health surveillance is not health screening. HSE is explicit that it differs from health monitoring, health promotion and health screening. A wellness check covering blood pressure, cholesterol and body mass index is an employee benefit. Health surveillance is a statutory control verification tool aimed at a defined exposed group. It gives the employer a fitness statement without clinical detail and feeds back into the risk assessment. Buying one while believing you bought the other is the standard mis-sale here.
Where AL23 sits
We are not a clinical provider. We define who is in scope and why, specify the modalities, appoint and manage the occupational health provider or appointed doctor, then convert the anonymised findings into control actions. Clinical examination and diagnosis belong to the clinicians we appoint. We scope the work, appoint the right specialist, interpret the results and turn them into an action plan you can actually deliver.
Who needs one
The triggers, regulation by regulation
- Any substance and process listed in Schedule 6 to COSHH, which triggers compulsory medical surveillance
- Regular exposure to noise above the upper action value of 85 dB(A) daily or weekly or 137 dB(C) peak, plus anyone at risk through existing hearing loss or heightened sensitivity
- Regular exposure to hand-arm vibration above the daily exposure action value of 2.5 m/s² A(8), plus anyone with an existing diagnosis of HAVS or carpal tunnel syndrome
- Licensed and notifiable non-licensed asbestos work, plus lead work where exposure is significant
- Wet work, cutting fluids, solvents, cement and epoxies, which drive skin surveillance
- Exposure to asthmagens such as isocyanates, flour dust, wood dust and solder flux fume, which drive respiratory surveillance
Surveillance is appropriate where four conditions hold. There must be an identifiable disease linked to the exposure, a reasonable likelihood it may occur in your conditions of work and a valid technique for detecting it. That technique must pose low risk while being likely to further the protection of health. This four part test comes from the COSHH Approved Code of Practice L5. It decides who goes into a programme.
The regulations that apply
Your legal framework, in plain terms
The duties are spread across five regimes rather than sitting in one place. The Control of Substances Hazardous to Health Regulations 2002, the Control of Noise at Work Regulations 2005, the Control of Vibration at Work Regulations 2005, the Control of Asbestos Regulations 2012 and the Control of Lead at Work Regulations 2002 each impose their own trigger, frequency and record rules. They do not align, which is why a programme has to be designed rather than assembled.
COSHH 2002, regulation 11
Suitable health surveillance where it is appropriate for protecting health. Regulation 11(3) requires a health record per employee, kept at least 40 years from the last entry. Regulation 11(4) requires medical surveillance under a relevant doctor at intervals of not more than 12 months for Schedule 6 work. That doctor may certify in the health record that an employee should not be exposed. The employer must not then permit the work.
Control of Noise at Work Regulations 2005, regulation 9
Hearing checks for employees likely to be regularly exposed above the upper exposure action value, plus those at risk for any other reason. Records are kept per employee, made available to them and used in anonymised aggregate to review the risk assessment.
Control of Vibration at Work Regulations 2005, regulation 7
Health surveillance above the exposure action value, plus for those at particular risk. Hand-arm vibration syndrome and carpal tunnel syndrome are reportable under RIDDOR 2013 on written diagnosis where the work involves regular use of vibrating tools.
Control of Asbestos Regulations 2012, regulation 22
Medical examination by an appointed doctor, with a valid certificate required before licensed work is carried out. Licensed work is examined every 2 years and notifiable non-licensed work every 3 years. HSE reviewed those intervals and decided against changing them on 1 February 2018.
Control of Lead at Work Regulations 2002, regulation 10
Medical surveillance at least every 6 months, dropping to no more than 3 months for young persons and women of reproductive capacity, starting within 14 working days of first exposure at the latest. Blood lead action levels are 20 µg/dl for women of reproductive capacity and 35 µg/dl for other employees. Health records are kept at least 40 years.
Schedule 6 catches almost nobody
COSHH Schedule 6, the list that triggers compulsory 12 monthly medical surveillance, is short and archaic. It reaches vinyl chloride monomer, certain nitro and amino derivatives of phenol and benzene, chromate manufacture, auramine and magenta manufacture and a few indiarubber and pitch processes. Almost every employer is caught instead by regulation 11(2)(b), which carries no statutory interval. Annual surveillance with more frequent checks in the first year is convention rather than law.
What the service covers
Every modality, scoped and managed end to end
Audiometry
Pure tone air conduction testing in a sound attenuating booth or acoustically suitable room, categorised against the scale in HSE guidance L108, with warning and referral categories triggering onward review. Convention requires a period free of noise exposure beforehand, which shift planning must allow for.
Spirometry
FEV1, FVC and the FEV1 to FVC ratio against predicted values, by an operator holding the recognised spirometry certificate. Spirometry alone is a weak screening tool for occupational asthma. We pair it with a validated respiratory symptom questionnaire. Symptoms almost always precede a measurable fall in FEV1.
HAVS tiered surveillance
Tier 1 initial screening for new starters, tier 2 annual screening questionnaire by a trained responsible person, tier 3 assessment by a qualified occupational health nurse, tier 4 formal diagnosis by a doctor with HAVS training and tier 5 optional referral testing. Tiers 1 and 2 can run in-house. Tiers 3 to 5 sit with occupational health. Findings are staged on the Stockholm Workshop Scale, sensorineural and vascular components separately for each hand.
Skin surveillance
A trained responsible person carrying out regular checks, typically a monthly self-check backed by a periodic trained inspection, escalating to occupational health on a positive finding. No statutory frequency applies.
Biological monitoring
Urine or blood sampling where it adds something air sampling cannot, such as isocyanate derived diamines for spray painters. Blood lead monitoring under the lead regulations is compulsory. Most other biological monitoring is voluntary and needs informed consent.
Statutory medicals and records
Asbestos and lead medicals through an appointed doctor with certificate validity tracked, plus the employer held health record set up correctly and separated from clinical records.
Feedback into control
Anonymised aggregate results used to review the risk assessment, the controls and the exposure monitoring behind them.
Our process
Start with exposure, finish with control actions
- 01
Exposure review
We start with the assessments and the exposure data. Where nobody has measured the noise, the vibration magnitudes or the airborne concentration, the scope is guesswork and we will say so.
- 02
Scope and specification
We define the exposed groups, the modality for each, the interval, the referral pathway and the responsible person roles, then write it up.
- 03
Appointment and mobilisation
We appoint the occupational health provider or appointed doctor, agree the clinical protocol and reporting format and set the logistics around your shift patterns.
- 04
Delivery and quality check
Clinical sessions run and results come back. We check the outputs against the specification and challenge anything that arrives as a bare fitness statement.
- 05
Action and review
Aggregate findings become control actions with owners and dates. The risk assessment is reviewed and the next interval confirmed or shortened.
What you get
A programme, records and the trends that matter
- A written programme naming every exposed group, the modality, the interval and the legal basis
- Health records set up to the correct content standard, holding the worker's details, workplace, hazards and fitness to continue
- An anonymised aggregate report showing trends across each exposed group, which is the output that changes the risk assessment
- A retention schedule applying 40 years to COSHH, asbestos and lead health records, with a documented position where the noise and vibration regulations state no period
What we need from you
Exposure data, shift patterns and a responsible person
- Current noise, vibration and COSHH assessments plus any exposure monitoring results
- Any existing health records and previous results, including who holds the clinical files
- Shift patterns and a realistic view of how many people can be released per session
- A nominated responsible person who can be trained to run tier 1 and tier 2 HAVS screening and the routine skin checks
Why AL23 Safety
We manage the clinicians, then use the findings
Accountable
Where your current programme is a wellness check dressed as surveillance, we will say so before you renew.
Clear on our role
We arrange and manage the clinical provision rather than performing it. Diagnosis belongs to the clinicians we appoint, which we say up front rather than blurring the line.
The findings get used
Aggregate results feed the risk assessment and the control plan. Surveillance that produces certificates and changes nothing has failed at its only purpose.
UK wide
We design and manage surveillance programmes for clients across the UK from our Manchester base, in manufacturing, construction, food production and healthcare.
Talk to us about health surveillance
Find out what you actually need and what you do not
Most programmes we review are either missing an exposed group or testing people who never needed to be in scope. Describe the exposures on a call for a straight view.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usIt depends on which regulation triggers it. Schedule 6 work under COSHH is not more than 12 monthly. Lead is at least 6 monthly, dropping to 3 monthly for young persons and women of reproductive capacity. Licensed asbestos work is every 2 years and notifiable non-licensed work every 3 years. Ordinary COSHH surveillance under regulation 11(2)(b) has no statutory interval. For audiometry, HSE guidance rather than the regulations suggests a baseline before exposure, annually for the first two years, then every three years.
Cost is driven by headcount, the modalities involved and whether an appointed doctor is required. A tier 2 HAVS questionnaire run by your own trained responsible person costs a fraction of a nurse led tier 3 assessment. An asbestos medical sits at the other end again. Tell us the exposures and the headcount and we will scope it rather than quote per head for a package you may not need.
The health record is held by the employer and is a legal document. It carries the worker's details, where they work, the hazards they have been exposed to and their fitness to continue. It must not contain confidential clinical information without the worker's written permission. The medical record is clinical, held in medical confidence by the occupational health professional and accessible only with consent. If you change provider, you must ensure both paper and electronic medical records transfer across. That contract point is missed constantly.
Only for specific regimes. An appointed doctor is a registered medical practitioner formally appointed by HSE. The appointment is regulation specific and time limited. Appointed or relevant doctors are required for COSHH Schedule 6 work, asbestos and lead medicals and classified persons under the ionising radiations regulations. Ordinary COSHH surveillance under regulation 11(2)(b) does not. It can be delivered by a competent occupational health nurse or technician under the direction of an occupational health professional, at a materially different cost.
Not meaningfully. There is no established health surveillance technique for whole-body vibration. What is sold under that name is health monitoring for back symptoms rather than surveillance with a diagnostic basis. Control the exposure through vehicle selection, seating, ground condition and job rotation, then treat back pain reporting as a monitoring signal. Hand-arm vibration is a different matter, covered on our hand-arm vibration assessments page.
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