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Health Surveillance: Under and Over Health Surveillance

Updated: Jul 26, 2023

Health surveillance (HS) involves regular medical checks being undertaken on employees, by occupational health clinicians, on behalf of the employer, to ensure their health and wellbeing where they are exposed to potential hazards within the workplace.


HS is a legislative requirement which MUST be implemented by employers if employees are exposed to specific hazards, furthermore employees have a duty to engage with the HS assessment process in order that their employers can ensure that they do not suffer harm because of their work. Employers may decide to withdraw an individual from undertaking hazardous tasks if they cannot ensure their occupational health and safety.


The most common forms of HS undertaken by employers relate to the exposure to noise, vibration and/or exposure to respiratory and/or skin irritants, although additional specific guidance also exist for those exposed to lead, asbestos, and radiation in the workplace.


All HS programmes should be undertaken based upon up to date and accurate risk assessments, in deciding what assessments may need to be undertaken employers should consider any known cases of work-related ill health in the workplace, the extent to which personal protective equipment (PPE) is used and compliance with its use, industry guidance or evidence of work-related ill health in the sector and wider information from insurance claims, manufacturer’s data and industry guidance


Regarding additional support for employees, employers may also consider alongside statutory HS assessments to help monitor the health and wellbeing of employee’s and enable suitable adjustments to be put in place relating to other risks including manual handling and shift/night work.


On the subject of HS the Health and Safety Executive (HSE) provides clear guidance for employers, stating it:

  • should only be used for workers who need it

  • provides feedback about actions you may need to take to prevent further harm and protect workers

  • allows workers to raise concerns about how work affects their health

  • provides the opportunity to reinforce workers’ training and education

Insight Workplace Health (IWH) regularly come across two specific scenarios relating to HS, these are a lack of (under) health surveillance or blanket (over) health surveillance. Under Health Surveillance Failing to implement a robust HS programme for employee’s is one of the greatest risks an employer can take. The HSE list all cases and breaches geographically on their enforcement database which gives an indication of the level of fines and HSE costs which employers have become liable for following conviction in court.


The sums of money can be eyewatering, especially when the cost to obtain professional occupational health advice and implement appropriate HS programmes to demonstrate that a business is fulfilling its legislative duty towards to employee’s are a fraction of the cost.


IWH are often called upon by companies requesting urgent support following impromptu inspections of their premises by HSE inspectors.


If you are unsure of your duties as an employer with respect to managing your employee’s health, consider contacting us and arranging for a Discovery Audit to be undertaken LINKS This process will assess the current level of occupational health provision and provide the business with clear guidance on actions to take, to improve the health and wellbeing of employees.

Over Health Surveillance

Some employers choose to undertake the blanket (over) health surveillance assessments on all staff regardless of the individual risks to the employee. Although this blanket approach may feel easier to implement it has significant drawbacks:

  • blanket health surveillance in all cases will be more expensive than using a tailored approach, and as such may use up an often-limited occupational health budget more rapidly, without necessarily addressing the key occupational health and safety issues within the workplace

  • clinicians have a duty of care to follow the relevant protocols when potential symptoms are identified, this may lead to individuals being referred for further assessment by the occupational health advisor (OHA - nurse) or occupational health physician (OHP – doctor) unnecessarily but at additional cost to the company e.g. if an employee exposed to noise has category 3 hearing loss this would necessitate a follow up audiometry assessment and then once confirmed, a referral to the OHP, however an individual who is not exposed to noise in the workplace who has hearing loss caused by other means, maybe they have a noisy hobby or due to underlying conditions, does not need either of the above appointments.

IWH advise that you DO NOT use a blanket health surveillance approach, if concerned about the potential challenges of tailoring a HS programme to the risks individual employees are exposed to contact us to discuss working smarter and spending available budgets more effectively.

We currently manage health surveillance programmes for customers with more than 10,000 staff, and are equipped to tailor HS services for our customers regardless of their size from startup’s to well established national and international business.


Testimonies and customer feedback relating to our service provision are visible here

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