COSHH Health Surveillance: When It's Required (UK Guide)

Do I Need COSHH Health Surveillance? (Short Answer)

You must put workers under health surveillance when they are exposed to certain hazardous substances and there is a real chance they could develop a recognised disease that can be detected early. Under the Control of Substances Hazardous to Health Regulations 2002, this is a legal duty in defined situations — not an optional extra.

Health surveillance means ongoing health checks (skin checks, lung function tests, or specific medical tests) to spot early signs of harm before they become serious. Regulation 11 of COSHH sets out when it is required, and it applies to small businesses just as much as large factories — a salon, a joinery, or a bakery can all have triggers. The rest of this guide explains the two ways the duty is triggered, what surveillance involves, and the record-keeping you must do.

What COSHH Regulation 11 Says

The duty comes from Regulation 11. It requires health surveillance "where it is appropriate for the protection of the health of his employees who are, or are liable to be, exposed to a substance hazardous to health."

That "appropriate" test is made concrete in two ways.

Trigger 1 — Schedule 6 substances and processes

Regulation 11(2)(a) says surveillance is appropriate where "the employee is exposed to one of the substances specified in Column 1 of Schedule 6 and is engaged in a process specified in Column 2 of that Schedule." Schedule 6 is a specific list — substances like vinyl chloride monomer and certain others, paired with the processes they are used in. If your work matches an entry on that list, surveillance is required, full stop.

Trigger 2 — the general appropriateness test

Even outside Schedule 6, surveillance is appropriate where exposure is such that an identifiable disease or adverse health effect may be related to the exposure, there is a reasonable likelihood the disease or effect may occur under the conditions of work, and valid techniques exist to detect it. In plain terms: there is a known disease linked to the substance, it can be detected early, and your working conditions make it a real possibility.

This second trigger is the one that catches most small businesses. The common examples are:

Respiratory sensitisers — isocyanates (vehicle paint spraying), flour dust (bakeries), wood dust (joinery), certain adhesives. These can cause occupational asthma, so lung function checks are appropriate.
Skin sensitisers and irritants — PPD in hair dye, epoxy resins, cement, wet work over long periods. These can cause occupational dermatitis, so skin checks are appropriate.

What Health Surveillance Involves

The level of surveillance scales with the risk. It can range from a trained supervisor carrying out regular skin inspections and asking about symptoms, up to lung function testing or specific medical tests carried out by an occupational health professional.

For many SME triggers — skin checks for dermatitis risk, for example — surveillance can start as a structured, recorded skin-check routine led by a trained person, escalating to occupational health input where needed. For respiratory risks like occupational asthma, lung function testing by a qualified provider is usually appropriate.

Whatever the level, the point is the same: catch early signs so you can act — improve controls, move the worker, or get medical input — before the harm becomes permanent.

How Long to Keep Health Records

This is where COSHH is unusually demanding. Regulation 11(3) requires that the health record "or a copy thereof is kept available in a suitable form for at least 40 years from the date of the last entry made in it."

Forty years. That is far longer than the five-year retention for most other COSHH records, and it reflects the long latency of occupational diseases — some only show up decades after exposure. You need a system that will not lose these records when staff leave, computers are replaced, or the business changes hands.

Note that the health record (a record that surveillance happened and the outcome) is different from confidential clinical records held by the occupational health professional — but the duty to keep the health record for 40 years sits with the employer.

How This Fits Your COSHH Assessment

Health surveillance is not a standalone task — it flows out of your COSHH assessment. When you assess a substance and find it is a respiratory or skin sensitiser, or it appears on Schedule 6 for your process, that assessment should record that surveillance is required and what form it takes. Section 11 of the Safety Data Sheet (toxicological information) is where the sensitisation warnings usually appear.

Health Surveillance Checklist

Check each substance against Schedule 6 (substance + process match = required)
For other substances, apply the general test: known disease, detectable early, realistic under your conditions
Identify respiratory sensitisers (asthma risk → lung function checks)
Identify skin sensitisers/irritants (dermatitis risk → skin checks)
Set up surveillance at the appropriate level (trained supervisor up to occupational health)
Act on results — improve controls, not just record findings
Keep health records for at least 40 years
Record the surveillance requirement in the relevant COSHH assessment

Keeping 40-Year Records Safe

A 40-year retention duty is impossible to meet reliably with a folder in a cupboard or a spreadsheet on one person's laptop. Records get lost long before the 40 years are up.

COSHHmate is being built to flag which substances trigger health surveillance from your COSHH assessments, so the requirement is surfaced rather than missed. Pricing will be a flat monthly fee with no per-user charges. To get your COSHH compliance organised, join the waitlist.

Sources

This is general guidance based on the COSHH Regulations 2002 and published HSE guidance. Whether health surveillance applies to your workers, and at what level, depends on your specific substances and processes — verify against HSE guidance and seek occupational health advice where needed. Not legal, medical, or safety advice.