Phoenix Journal · LEV & Air Quality
Health surveillance is how you find out whether your controls are really working, before a worker's early symptoms become a permanent disease. Done well, it catches harm while it can still be stopped. Done as a box-ticking round of questionnaires that nobody reads, it is worse than nothing, because it looks like protection while providing none.
Health surveillance is an ongoing, planned check on some aspect of a worker's health that could be harmed by their work, such as lung function, hearing, skin condition or the circulation in their hands. It has two jobs at once. For the individual, it aims to catch the earliest signs of harm, when moving or protecting that person can still make a difference. For the workplace as a whole, the pattern of results is a read-out on whether the controls are actually holding, because a cluster of early cases is evidence that exposure is not under control however good the paperwork looks.
Crucially, it is a process, not a test. Collecting questionnaires or lung-function readings achieves nothing unless the results are interpreted by someone competent and then acted on, whether that means improving controls, redeploying an affected worker, or reviewing the whole assessment. Surveillance that generates data nobody uses is a cost with no protective value.
It is worth being clear on what surveillance is not. It is not a control measure and never replaces one; it sits after prevention and control, as a way of confirming that those upstream measures are working. Nor does it apply to everyone: the duty falls on employers, so a genuinely self-employed sole trader with no staff is outside Regulations 10 and 11, though the moment they employ others the duty applies. And where the underlying risk is a carcinogen, related monitoring records must be kept not for five years but for forty, reflecting how long the harm can take to surface.
When you must
Under Regulation 11 of COSHH, health surveillance is required where employees are exposed to a substance hazardous to health and there is a reasonable likelihood that an identifiable disease or effect will result, and valid techniques exist to detect it. In practice that captures a familiar set of exposures: isocyanates and other asthmagens for occupational asthma, hardwood dusts for nasal effects, chrome and wet work for dermatitis, and, under their own regulations, noise for hearing loss and vibration for hand-arm vibration syndrome. Where a substance and process appear in Schedule 6 to COSHH, the surveillance must include medical surveillance under a doctor at intervals of no more than twelve months.
The records carry a striking duration. Because many occupational diseases have long latency, a health record must be kept for at least forty years from the last entry, so that a pattern emerging decades later can still be traced. Workers have a right to see their own record, and if the business ceases trading the records must be offered to the HSE rather than binned.
Getting the trigger question right is half the battle. If exposure is genuinely eliminated or controlled well below the level at which harm is likely, surveillance may not be needed at all; where it is needed, skipping it is one of the failings inspectors look for around COSHH.
Build it in tiers
A workable programme is tiered, escalating only as far as the risk demands. At the base sit low-cost routine checks: a short questionnaire completed by the worker, or a simple self-check, flagging anyone with early symptoms. Those flags are reviewed by a responsible person, and anyone identified moves up to assessment by an occupational health nurse or technician, and if needed to an occupational health doctor. This tiered structure is exactly how hand-arm vibration, the slow injury sites ignore, is monitored: a yearly questionnaire that escalates to clinical assessment as symptoms or exposure rise, catching the reversible early stage before it becomes permanent.
Close the loop
The point of all this is what you do when a result comes back. A confirmed early case is not just a matter for that individual; it is a warning that the control protecting everyone doing that job may be failing, and the correct response is to look again at the exposure and the controls, not simply to log the case. Hearing checks under a noise programme work the same way, which is why understanding how to reduce noise exposure in a workshop matters as much as measuring the hearing: surveillance without action is a paper trail to a preventable injury. A good programme feeds its findings straight back into the controls, so each round of results either confirms the controls are working or tells you exactly where they are not.
Questions
Under COSHH Regulation 11 it is required where workers are exposed to a substance hazardous to health, an identifiable disease or effect is reasonably likely under the conditions of work, and there is a valid way to detect it. Common triggers include isocyanates, hardwood dust, substances causing dermatitis, and, under their own regulations, noise and vibration.
Many occupational diseases have a long latency, appearing years or decades after exposure. Keeping the health record for at least 40 years from the last entry means a pattern that emerges late can still be linked back to the work, which protects the worker and provides evidence for the employer.
It depends on the tier. Simple questionnaires and self-checks can be run in-house by a trained responsible person, but interpreting results and any clinical assessment or medical surveillance should be done by an occupational health professional, a nurse or doctor competent in occupational medicine. The employer stays responsible for acting on what the surveillance finds.
Phoenix Duct Clean · by the numbers
Surveillance tells you a control is failing; LEV testing tells you why. Phoenix examines and tests your extraction to COSHH Regulation 9 so problems are found at source. UK-wide.