COSHH guide · Health surveillance

Health surveillance under COSHH

When regulation 11 requires repeated health checks for workers exposed to hazardous substances, what a scheme involves and the records to keep. Checked against legislation.gov.uk and HSE guidance.

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Published 5 October 2026 · Checked against legislation.gov.uk and HSE on 5 October 2026

A young man in safety glasses and a dark work jacket concentrating at a lathe, with two colleagues talking in the workshop behind him

What is health surveillance?

Health surveillance is a scheme of repeated health checks that picks up early signs of ill health caused by work. Under COSHH regulation 11 it is required where a disease linked to a hazardous substance is reasonably likely and can be detected.

In law, the employer must put employees under suitable health surveillance where it is appropriate. It is appropriate where an identifiable disease or adverse health effect may be related to the exposure and is reasonably likely in the conditions of the work. There must also be a valid technique to detect it that is of low risk to the employee.

For trades the usual cases are occupational asthma, dermatitis and silica lung disease. HSE guidance describes asthma questionnaires and lung function tests for isocyanate paints and wood dust. It describes skin checks for cement, epoxy resins and cleaning products, and lung function tests and chest X-rays for silica dust.

Health surveillance does not replace control. It checks that the controls chosen in your COSHH assessment are working. Health records are kept for at least 40 years. The wider duties are set out in the COSHH Regulations explained.

When COSHH requires health surveillance

Regulation 11

The law sets a test, not a list of trades. Your COSHH risk assessment shows whether the test is met. Each citation links to the source.

The general test

Health surveillance is appropriate where three conditions are met. An identifiable disease or adverse health effect may be related to the exposure. There is a reasonable likelihood it may occur in the particular conditions of the work. And there are valid techniques to detect indications of it, of low risk to the employee.

Regulation 11(1) and (2)(b)

What counts as a valid technique

HSE describes valid techniques as those precise enough to detect something wrong that could be caused by the exposure, and safe and practicable to carry out. L5 adds that procedures should be reproducible, reliable and preferably non-invasive.

HSE, types of health surveillance

Signs that the test is met

HSE’s L5 gives examples. Previous cases of work-related ill health in the workforce. Reliance on PPE such as gloves or respirators, as with paint sprayers wearing respirators for two-pack paints. Evidence of ill health in the same jobs across the industry. L5 says the list is not exhaustive.

HSE L5, paragraphs 233 to 238

Schedule 6 processes

Schedule 6 lists substances and processes that always call for medical surveillance where disease is reasonably likely. They are mostly in chemical, explosives and rubber manufacture. The list covers vinyl chloride monomer, nitro or amino derivatives of phenol and benzene, and chromate manufacture. It also covers certain dyes and dye intermediates, certain chemicals used in making indiarubber goods, and pitch fuel blocks. Few trades meet them.

Regulation 11(2)(a) and Schedule 6

Carcinogens

HSE’s L5 says that, as a minimum, suitable health surveillance can involve keeping an individual health record. Its example is known or suspected carcinogens other than those in Schedule 6. COSHH Schedule 1 lists hardwood dusts and used engine oils among its carcinogens. L5 adds that surveillance may continue after exposure stops, at least while the person remains your employee, where an effect may appear after a latent period.

HSE L5, paragraphs 239 and 249; COSHH Schedule 1

Who it is owed to

Unlike most COSHH duties, health surveillance is owed only to your own employees, not to other people your work affects. COSHH treats a self-employed person in scope as both employer and employee, except that regulations 10 and 11 do not apply to them. Anyone who employs others owes it to those employees. HSE’s EH40 warns that someone working under your control and direction may be self-employed for tax and National Insurance but an employee for health and safety.

Regulation 3(1)(a) and (2); EH40, paragraph 9

Noise and hand-arm vibration have their own health surveillance duties under separate regulations. Lead and asbestos work have their own medical surveillance duties, under the Control of Lead at Work Regulations 2002 and the Control of Asbestos Regulations 2012. This page covers COSHH only.

Health surveillance for the conditions trades meet

HSE G402, G403, G404

HSE’s COSHH essentials sheets say health surveillance should be considered where people work with the main causes or with products carrying certain hazard statements. Reliance on PPE, or a confirmed case in your workforce, are triggers too. This is HSE guidance, not a list in the law.

Health surveillance for occupational asthma, dermatitis and silica lung disease, from HSE guidance
Condition	Common causes in trades work	Label and other signs	What the checks involve
Occupational asthma	Isocyanates such as two-pack spray paints, wood dust, glues and resins, cleaning products, stainless-steel welding and rosin-based solder flux fume.	H334, “May cause allergy or asthma symptoms or breathing difficulties if inhaled”, or Sen in EH40. EH40 says health surveillance is appropriate for everyone exposed or liable to be exposed to a substance that may cause occupational asthma.	A baseline before exposure, or soon after it starts, such as within six weeks. Then a questionnaire and spirometry, a lung function test, usually once a year and more often for new workers.
Occupational dermatitis	Cement, epoxy resins, solvents, soaps and cleaning products, wood, “wet work” with frequent hand washing, and prolonged glove use.	H315, “Causes skin irritation”, and H317, “May cause an allergic skin reaction”.	A baseline, then a questionnaire and a skin inspection, for example once a year. The check covers the hands, forearms and face, and the lower legs if they can be contaminated.
Silicosis and COPD from silica dust	Cutting or breaking stone, concrete or brick, and making or fitting stone worktops, especially engineered stone.	Regular exposure to respirable crystalline silica dust. HSE guidance says surveillance must be provided where workers are regularly exposed and silicosis is reasonably likely to develop.	A baseline, then a respiratory questionnaire and lung function test each year. HSE’s guidance for occupational health professionals adds a chest X-ray after 15 years’ total exposure, then every three years.

Sources: HSE G402, G403 and G404, HSE’s silica supplement for occupational health professionals and EH40, paragraph 55. The law fixes no interval for these checks, and your occupational health professional may advise a different one. For asthma or dermatitis, HSE says an annual questionnaire and a health record may be adequate in some cases. That covers only occasional exposure, or adequate control with no problems found over a representative period.

Who carries out health surveillance

The law requires medical surveillance by a relevant doctor only for Schedule 6 work. For other health surveillance, HSE guidance and L5 describe who can run it: an occupational health professional or a trained responsible person.

Medical surveillance by a relevant doctor

For Schedule 6 work, surveillance includes medical surveillance supervised by a relevant doctor, at least every 12 months or more often if the doctor requires. A relevant doctor is a doctor appointed in writing by HSE, or an employment medical adviser. Appointed doctors are not HSE staff: the employer agrees terms and pays.

Regulations 2 and 11(5)

What a relevant doctor can decide

Under medical surveillance, the doctor can record in the health record that the employee must not do the exposed work, or only under stated conditions. You must follow that entry until a relevant doctor cancels it. The doctor can also record that surveillance continues after exposure ends, while the person still works for you. You must let a relevant doctor inspect the workplace and COSHH records when their duties require it. Either side may apply in writing to HSE within 28 days for a review of a suspension or conditions.

Regulation 11(6), (7), (10) and (11)

An occupational health professional

For most COSHH surveillance HSE says to involve an occupational health doctor or nurse with the right competence for your risks. If a GP offers the service, HSE says to be sure they are competent in occupational medicine. L5 says the employer must make sure whoever conducts it is competent.

HSE, COSHH health surveillance

A responsible person

A responsible person is a worker you appoint, trained and supported by an occupational health professional. HSE says they can carry out simple checks, such as skin checks or giving out an asthma questionnaire, and report the conclusions to you. Consult your occupational health professional before using one.

HSE L5, paragraphs 240 and 245; HSE G402

The employer

You decide who needs surveillance, arrange and pay for it, and act on the results. HSE says surveillance is not complete until you have feedback from the professional who carried it out. That feedback covers fitness for the task and when the next check is due.

HSE, act on the results

Setting up a health surveillance scheme

How HSE and L5 describe a scheme, from the risk assessment to acting on the results. Agree the detail with your occupational health professional.

Start from the risk assessment

Use the COSHH assessment, and any exposure monitoring, to decide which hazards need surveillance and which workers are exposed to each. Include people who are hard to reach, such as remote and shift workers.

NoteHSE’s L5, paragraph 233, and HSE, setting up a scheme.

Consult the workforce

Explain what the checks are for, what happens if ill health is found, and that appointments are in work time at your cost. Tell workers they must attend, and what you will do if they refuse.

NoteHSE says you must consult workers and their representatives.

Decide the actions first

Before the first check, agree what results trigger action and what the options are. Options include reassessing the risk, improving controls, referral for diagnosis and moving someone to other work. Decide how records are kept and results analysed.

NoteHSE’s L5, paragraph 231.

Take a baseline

Check each worker before exposure starts or, failing that, as soon as possible after, such as within six weeks. Later results are compared against it.

NoteHSE G402, G403 and G404.

Run the routine checks

Repeat the checks at the frequency your occupational health professional advises. Give workers a way to report symptoms between checks, to a responsible person or the professional.

NoteFrequency is advice, not law, outside Schedule 6.

Act on the results

Get the feedback, enter it in each health record and review the assessment and controls. Look at results for groups doing similar work, in groups large enough to keep individuals anonymous.

NoteRegulation 12(2)(e) requires employees to be told the collective results in an anonymised form.

Health records and how long to keep them

At least 40 years

A record for every employee under surveillance

The employer must make and keep a health record, with particulars approved by HSE, for each employee under surveillance. It, or a copy, is kept in a suitable form for at least 40 years from the date of the last entry.

Regulation 11(3)

What the record holds

L5 lists the contents. Identifying details, including name, gender, date of birth, address, National Insurance number and start date. A history of jobs in this employment involving exposure to substances requiring surveillance. The results of surveillance, when and by whom it was done, and decisions on fitness for continued exposure.

HSE L5, paragraph 251

Health records are not medical records

The health record holds outcomes and fitness for work. L5 says it should not include confidential clinical data. HSE says confidential medical information goes in only with the worker’s written consent. Medical records, with clinical notes and test results, stay in confidence with the occupational health professional. HSE says you can only see them with the worker’s written consent. If you change provider, they should move to the new one.

HSE, record keeping; HSE L5, paragraph 252

Access, copies and back-ups

An employee may see their own health record on reasonable notice. With the employee’s consent, L5 says their representatives may see it too. HSE can require copies. Records may be on paper or electronic, and L5 says electronic records need a back-up. HSE calls it good practice to offer workers a copy when they leave, or if you stop trading. EH40 notes that data protection law also applies to these records.

Regulation 11(4)(a) and (b); HSE L5, paragraphs 252 and 254

If the business stops trading

An employer who ceases to trade must notify HSE in writing straight away and make all the health records available to it. L5 says this applies when the employer, or an administrator, receiver or liquidator, decides the business will stop trading.

Regulation 11(4)(c) and HSE L5, paragraph 253

What to do when surveillance finds a case

Regulation 11(9) applies when a relevant doctor or other occupational health professional links a disease or adverse effect to the exposure. It sets out what the employer must do.

Tell the employee

Make sure a suitably qualified person tells the employee and gives information and advice about further health surveillance.

Regulation 11(9)(a)

Review the assessment and controls

Review the risk assessment, and the regulation 7 controls, taking account of advice from the doctor, the occupational health professional or HSE.

Regulation 11(9)(b) and (c)

Consider other work

Consider moving the employee to work with no risk of further exposure to that substance, taking account of advice from the relevant doctor or occupational health professional. L5 says the employee or their representative should be involved before decisions on alternative work.

Regulation 11(9)(d) and HSE L5, paragraph 248

Check others doing the same work

Provide for a review of the health of any other employee similarly exposed. That includes a medical examination where a relevant doctor, occupational health professional or HSE recommends one.

Regulation 11(9)(e)

Report a diagnosis under RIDDOR

Occupational dermatitis and occupational asthma are reportable on a doctor’s diagnosis. That applies where the work involves significant or regular exposure to a known skin sensitiser or irritant, or a known respiratory sensitiser. For an employee the employer reports. A self-employed person reports their own only where their work is of a prescribed description, such as work on a construction site. The report goes without delay, in the approved manner. In practice that is HSE’s online report of a case of disease form. HSE’s phone line takes only fatal and specified injuries.

RIDDOR 2013, regulation 8 and Schedule 1

Cancer and biological agents

A cancer attributed to occupational exposure to a known human carcinogen or mutagen, and any disease attributed to occupational exposure to a biological agent, must also be reported. The employer keeps a record of each reportable diagnosis for at least three years.

RIDDOR 2013, regulations 9 and 12

Under RIDDOR a diagnosis means a registered medical practitioner’s identification of new or significantly worse symptoms, in writing for an employee. HSE says asthma is not reportable where the person already had it and work did not trigger or worsen it. Silicosis is not on the regulation 8 list, but the regulation 11(9) duties above still apply.

The COSHH register in Unibuild

Every data sheet to hand,
tied to the job that uses it.

In Unibuild, each hazardous substance holds its safety data sheet and its supplier, linked to the jobs, materials and purchase orders that use it. Review dates are tracked, every version is kept, and the current one is the one out on site.

When an auditor or a principal contractor asks for the COSHH register, it is a search by name or supplier, not a spreadsheet somebody else kept.

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A data sheet for every substance held with its supplier
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Review dates tracked and every version kept
Searched by product name or supplier

Free COSHH templates

Free to use and reuse, no sign-up

Free downloadCOSHH assessment templateOne substance per assessment: the hazards from the safety data sheet, who is exposed and how, the controls, PPE, storage, spills and first aid. Free downloadCOSHH register templateEvery hazardous substance on site or in the van, with its data sheet date, assessment reference, location and review date. Free downloadCOSHH risk assessment, pre-filledA risk assessment and method statement for work with cement, solvents, resins, dusts and fume on site, filled in and editable. Free downloadCOSHH symbols posterThe nine hazard pictograms and what each one means, for the store, the van or the welfare cabin. A4 or A3.

Asked most often

Health surveillance: common questions

What is health surveillance under COSHH?

A scheme of repeated health checks for employees exposed to hazardous substances, to pick up early signs of work-related ill health. COSHH defines it as assessing an employee’s state of health as related to the exposure, including biological monitoring. Its purpose is to protect the individual and to show whether controls are working. HSE says it is not the same as general health screening or health promotion.

When is health surveillance required?

Under COSHH regulation 11, where an identifiable disease or adverse effect may be related to the exposure and is reasonably likely in the conditions of the work. There must also be a valid, low-risk way to detect it. HSE’s L5 says reliance on PPE, previous cases and known ill health in the industry all point towards it.

Is health surveillance a legal requirement in construction?

The law sets a test, not a list of industries, but construction work can meet it. HSE says health surveillance must be provided where workers are regularly exposed to silica dust and silicosis is reasonably likely. HSE also lists construction work among the high-risk groups for occupational dermatitis, with cement and epoxy resins among the main causes.

How often is health surveillance needed?

The law fixes an interval only for Schedule 6 medical surveillance: at least every 12 months. Otherwise HSE guidance applies. It describes a baseline before exposure or soon after, for example within six weeks. Asthma checks follow usually once a year, more often for new workers, and skin checks, for example, yearly. For silica, HSE gives a yearly questionnaire and lung function test, with chest X-rays from 15 years’ exposure. Your occupational health professional advises the frequency.

Who can carry out health surveillance?

Medical surveillance for Schedule 6 work needs a relevant doctor: one appointed by HSE, or an employment medical adviser. Other surveillance is usually run by a competent occupational health doctor or nurse. A trained responsible person, such as a supervisor, can carry out simple checks like skin inspections under their guidance.

Can an employee refuse health surveillance?

Regulation 11(8) says an employee must attend health surveillance when the employer requires it. It takes place in working hours and at the employer’s cost. HSE advises explaining to workers, when consulting them, what action you may take if they refuse to attend.

How long must health surveillance records be kept?

At least 40 years from the date of the last entry. The health record holds identifying details, the jobs involving exposure, the results and decisions on fitness for work. It should not hold confidential clinical data. Medical records stay with the occupational health professional.

Can my employer see my health surveillance results?

Your employer sees the health record: the outcome, your fitness for the work and when the next check is due. Clinical notes and detailed clinical results stay confidential with the occupational health professional. HSE says the employer can only see those with your written consent. You have a legal right to see your own health record on reasonable notice.

Do self-employed workers need health surveillance?

Regulation 3(2) treats a self-employed person in scope as both employer and employee, but regulations 10 and 11 do not apply to them. If you employ anyone, you owe them health surveillance where the test is met. HSE warns that someone under your control and direction may be self-employed for tax but your employee for health and safety. It is not owed to another firm’s workers on the same site.

Is occupational dermatitis or asthma reportable under RIDDOR?

Yes, once a doctor diagnoses it and the work involves significant or regular exposure to a known cause. For dermatitis that is a skin sensitiser or irritant; for asthma, a respiratory sensitiser. The employer reports without delay and keeps a record for at least three years.

The COSHH guide

Read in any order

GuideWhat is COSHHWhat COSHH means, who it applies to, and how a substance is assessed and controlled at work. GuideThe COSHH Regulations 2002Each regulation in plain words: assessment, control, exposure limits, monitoring, health surveillance and training. GuideCOSHH symbolsThe nine hazard pictograms, what each one means, and how they replaced the old orange squares. GuideSafety data sheetsThe sixteen sections of a safety data sheet, and which of them feed the COSHH assessment. GuideWorkplace exposure limitsEH40 and the workplace exposure limits: what the numbers mean, how they are averaged, and what the law asks. GuideLocal exhaust ventilationLEV for dust, fume and vapour: how it works, who checks it, and the thorough examination every 14 months. GuideFace fit testingWhy tight-fitting masks need a face fit test, who can do it, and when to test again. You are hereHealth surveillanceWhen COSHH requires health surveillance, what it involves, and the 40-year health record. GuideCOSHH storageStoring hazardous substances safely: COSHH cabinets, the store, the van and incompatible products. GuideCOSHH trainingWhat the law says COSHH training must cover, who needs it, and how to show it was given.

Sources

Great Britain law and HSE guidance, read on the dates above. Northern Ireland has its own COSHH Regulations.

Next step

The COSHH register,
tied to the job.

Unibuild keeps each substance’s data sheet and supplier against the jobs, materials and purchase orders that use it, with review dates tracked and every version kept.

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