Quick answer
COSHH health surveillance is required in relevant risk-based circumstances, not automatically for everyone using a labelled product. Assess whether a work-related health effect is identifiable, likely under the conditions and detectable through a suitable safe technique. Use competent occupational-health support and act on findings; surveillance does not replace preventing exposure.
Assess the need using competent evidence
HSE health-surveillance guidance explains the conditions and distinction from general health screening. The substance, task, residual risk and suitable detection method matter.
HSENI COSHH guidance gives the NI framework. Use the relevant legal criteria and qualified advice rather than assuming a questionnaire or yearly medical is appropriate for every exposure.
Distinguish surveillance from other checks
| Activity | Main question |
|---|---|
| Exposure monitoring | What is the relevant workplace exposure? |
| Health surveillance | Are work-related health effects emerging under a suitable repeated scheme? |
| Clinical assessment | What individual medical diagnosis/advice is appropriate? |
| Control inspection | Are preventive measures available, effective and used? |
These can inform one another, but they are not substitutes. A worker reporting no symptoms does not establish that exposure controls are adequate.
Set up a suitable scheme
HSE setup guidance recommends identifying exposed workers, relevant hazards, leadership, communication and occupational-health input. Include shift, remote and temporary-work arrangements as appropriate.
Define who conducts each activity, who receives relevant outcomes and how concerns trigger action. Some surveillance activities may be performed by appropriately instructed responsible people within a competent scheme; clinical decisions require qualified roles.
Act on findings and examine controls
Illustrative example: a scheme identifies a possible work-related skin concern. Arrange appropriate professional assessment and review the actual exposure and controls. Do not diagnose it at a supervisor meeting or wait for the next scheduled check before responding.
Consider whether other workers or tasks are affected. Implement qualified recommendations and necessary control improvements. Surveillance is an opportunity to detect harm early, not permission to leave avoidable exposure uncontrolled.
Maintain appropriate records and confidentiality
HSE record guidance separates employer health-surveillance records from confidential medical information held by the occupational-health professional. Set access and retention according to the applicable requirements.
Explain the process to workers, provide appropriate access to their records and review the scheme after changes or findings. Do not put clinical test results into the general chemical inventory or claim that an agent-written article creates a completed surveillance programme.
Next steps
- Assess the legal/risk-based need with competent support.
- Define suitable repeated checks and qualified roles.
- Act promptly on concerns and review exposure controls.
- Keep appropriate employer records and medical confidentiality.
Read the official practical guidance — Use the current source alongside the procedures for your own business.