Service line one

Statutory health surveillance, programme by programme

Health surveillance is not a wellbeing benefit. It is a legal duty that attaches to specific exposures, on specific cadences, with record retention measured in decades. These are the six programmes Polarisk runs, the regulation behind each one, and who is owed it.

Fig. 1 How roles map to programmes. The list of who is owed an assessment is derived from exposure rather than remembered, and the workers who correctly need nothing are evidenced as such. Roles shown are illustrative.

Nobody fails at the clinical part. Coverage and cadence are what break, and what an inspector actually asks about.

Cadences above are the common pattern in HSE guidance, not a substitute for it. The interval that applies to you depends on your exposures, your risk assessment and the clinical findings in your own workforce. Where guidance recommends rather than requires, the individual programme page says so.

Where we stop. Asbestos, lead, ionising radiation, compressed air and certain other streams require an HSE Appointed Doctor by law. Polarisk does not run those and will tell you so rather than quoting for them. HSE guidance on Appointed Doctors

The register

Six programmes, each tied to its regulation

Every one has its own trigger, cadence and clinical protocol. Most exposure-heavy employers run three or four at once. Open any card for the detail.

PROGRAMME 01

Audiometry and hearing surveillance

Control of Noise at Work Regulations 2005

Noise-induced hearing loss is permanent, gradual and almost always silent until it is advanced. Surveillance exists to catch the shift before the worker notices it.

Key facts

Triggered by: Regular exposure at or above the upper action values, 85 dB(A) daily or weekly and 137 dB(C) peak, or being at risk for another reason.
Cadence: Baseline on entry, annually for the first two years of exposure, then commonly around every three years.
May be led by: An occupational health nurse or other qualified OH professional, with referral to a doctor on adverse findings.
Reportable: Noise-induced hearing loss diagnosed by a doctor is RIDDOR-reportable where the criteria are met.

The full programme

PROGRAMME 02

Hand-arm vibration (HAVS)

Control of Vibration at Work Regulations 2005

Tiered surveillance for anyone regularly using vibrating tools. Catches blanching, numbness and grip loss before they become permanent.

Key facts

Triggered by: Likely regular exposure at or above the exposure action value of 2.5 m/s² A(8), or being at particular risk.
Cadence: Baseline questionnaire on entry, then an annual screening questionnaire for everyone in scope.
May be led by: Tier 1 and 2 by a trained responsible person; Tier 3 by a qualified person; Tier 4 diagnosis by a doctor.
Reportable: HAVS and vibration-related carpal tunnel syndrome are both RIDDOR-reportable.

The full programme

PROGRAMME 03

Respiratory surveillance

Control of Substances Hazardous to Health 2002

For welding fume, flour dust, isocyanates, wood dust and other sensitisers. Occupational asthma is preventable, and surveillance is how it is prevented.

Key facts

Triggered by: Exposure to a respiratory sensitiser or another agent linked to lung disease, where the risk criteria under COSHH are met.
Cadence: Baseline with lung function testing, then an annual symptom questionnaire, with spirometry at intervals set by the programme.
May be led by: An occupational health nurse or other qualified OH professional. Spirometry must be performed by a trained operator.
Reportable: Occupational asthma diagnosed by a doctor is RIDDOR-reportable where there is significant exposure to a known sensitiser.

The full programme

PROGRAMME 04

Skin surveillance and dermatitis

Control of Substances Hazardous to Health 2002

Wet work, metalworking fluids, solvents, cement and epoxies. Among the most under-reported occupational diseases, and among the easiest to catch early.

Key facts

Triggered by: Wet work, or contact with irritants and skin sensitisers. Extended use of occlusive gloves counts, because sweat damages skin much as water does.
Cadence: Baseline assessment, then regular structured checks at intervals set by the risk. More frequent than most other programmes.
May be led by: Routine checks by a trained responsible person, with referral to an occupational health professional on any finding.
Reportable: Occupational dermatitis diagnosed by a doctor is RIDDOR-reportable where the criteria are met.

The full programme

PROGRAMME 05

Night-worker health assessment

Working Time Regulations 1998

Owed on the pattern of work alone, with no exposure threshold to argue about. The duty is to offer the assessment, so the offer itself has to be evidenced.

Key facts

Triggered by: Meeting the night worker definition: normally at least three hours of daily working time during night time, on the majority of days worked.
Cadence: Before assignment to night work, then at regular intervals afterwards. Annual is common practice and generally defensible.
May be led by: Questionnaire-led with review by a qualified OH professional. The duty to transfer to day work is triggered by a registered medical practitioner's advice.
Reportable: Not a RIDDOR matter, but a declined offer must be recorded, because an unrecorded offer evidences nothing.

The full programme

PROGRAMME 06

Safety-critical medicals

General duties and sector guidance

Forklift and plant operators, work at height, confined space, driving for work. Fitness assessed against the task rather than a generic standard.

Key facts

Triggered by: Duties where a sudden loss of consciousness or attention would endanger the worker or others. No single regulation names them, so a written policy is the defensible position.
Cadence: On appointment to the role, then typically every three to five years, shortening with age or a relevant condition.
May be led by: An occupational health physician or a suitably qualified OH professional, depending on the task and the standard applied.
Reportable: Not routinely reportable in itself. Reassess after illness, a new diagnosis, a medication change or any incident raising a fitness question.

The full programme

Fig. 2 One year at a single site running all six programmes. There is no surveillance day: something falls due in eleven months of twelve. That cadence, not the clinical work, is what a spreadsheet loses track of. Pattern is illustrative.

In our experience of how these programmes break down, the clinical assessment is almost never the problem. What fails is everything around it: knowing exactly who is in scope this year, getting those people to attend or respond, noticing that eleven of them did not, and being able to prove any of it eighteen months later when the person who ran the spreadsheet has left.

That is the work Polarisk takes over. The clinical judgment stays with a registered clinician, because it has to. The scheduling, chasing, record-keeping and evidence production stop being a person's job.

Coverage, not activityThe measure that matters at audit is the proportion of the in-scope population that is in date, by programme and by site. Not how many appointments were booked.
Lapse is visible before it happensAssessments approaching expiry surface while there is still time to act, with the names attached.
The record outlives the staffRetention for several of these streams runs to forty years. The record has to survive turnover, restructures and system changes, which is precisely what a spreadsheet does not do.

Questions

Common questions

How do I know which programmes apply to us?

It follows from your risk assessment and your actual exposures rather than from your industry. The quickest route is the surveillance check: four questions about your workforce and its exposures, and an estimate of the assessments owed per year by programme. It takes about two minutes, needs no sign-up, and collects no personal data.

Is health surveillance the same as a health check or a wellbeing screening?

No, and conflating them is a common and expensive mistake. A wellbeing screening is discretionary and looks at general health. Statutory health surveillance is a legal duty tied to a specific workplace exposure, uses a defined clinical protocol for that exposure, and produces a fitness outcome and a record the employer must keep. A general health check does not discharge the duty.

Can an occupational health nurse sign these, or do we need a doctor?

For noise, vibration, respiratory and skin surveillance, the programme can lawfully be led by an occupational health nurse or another suitably qualified OH professional, with referral to a doctor when findings require it. That matters commercially, because the pool of qualified nurses is much larger than the pool of OH physicians. Streams that legally require an HSE Appointed Doctor, including asbestos, lead, ionising radiation and compressed air, are out of scope for Polarisk.

What happens if someone is found not fit?

The clinician issues the fitness outcome and any recommended workplace adjustment, and your organisation receives that outcome and the adjustment. You do not receive the clinical findings behind it. In several programmes an adverse finding also triggers duties on you: reviewing the control measures for that person and often for everyone doing the same job, and in some cases a RIDDOR report. Those obligations are flagged with the outcome rather than left for you to discover.

How long do we have to keep the records?

It depends on the stream. Health records under COSHH must generally be kept for forty years from the date of the last entry, and records must be retained when a worker leaves rather than disposed of with the rest of their personnel file. Retention is set per programme on the platform, and records are not deleted on a worker's departure.

Start here

Find out which programmes you owe

Four questions about your workforce and its exposures. You will get an estimate of the assessments owed each year, by programme, and where your current arrangement leaves a gap. No sign-up, no personal data.

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