It is not uncommon for employers to believe that asking employees to complete an annual health questionnaire means they have carried out health surveillance.
Unfortunately, this is a common misunderstanding.
A general health questionnaire may provide useful information, but on its own it is rarely health surveillance in the sense intended by the Health and Safety Executive (HSE). More importantly, it may fail to detect the early signs of work-related disease the very reason health surveillance exists.
Why do we carry out health surveillance?
The purpose of health surveillance is simple: to identify ill health caused by work at the earliest possible stage.
Many occupational diseases develop gradually. Noise-induced hearing loss, occupational asthma, dermatitis and Hand-Arm Vibration Syndrome (HAVS), for example, often begin with subtle symptoms that employees may not recognise or report. If identified early, action can be taken to prevent permanent damage. If missed, the consequences can be lifelong.
Health surveillance is therefore not simply about monitoring an individual’s health. It is also a way of assessing whether the employer’s control measures are working.
If several employees begin developing early symptoms, this may indicate that workplace controls, personal protective equipment or working practices need reviewing. In this way, health surveillance protects both current and future employees.
Health surveillance starts with the risk assessment
One of the most important principles is that health surveillance is driven by risk not by a standard questionnaire.
The employer’s risk assessments and COSHH assessments determine whether health surveillance is required and, crucially, what type of health surveillance is appropriate.
Different hazards require different approaches.
For example:
- Exposure to hazardous noise may require regular audiometry.
- Exposure to respiratory sensitisers may require respiratory questionnaires combined with lung function testing.
- Employees exposed to substances capable of causing occupational dermatitis require skin surveillance.
- Workers using vibrating tools may require HAVS assessments.
- Certain substances, such as lead or asbestos, require statutory medical surveillance under specific legislation.
No single questionnaire can adequately monitor all of these hazards.
A questionnaire is only one possible component
Health questionnaires can be valuable.
When designed specifically for a particular hazard and interpreted by someone competent to do so, they are often an important part of a health surveillance programme. They can identify early symptoms that warrant further investigation and help determine whether an employee should be referred for clinical assessment.
However, a generic annual questionnaire that asks broad questions about general health cannot replace hazard-specific surveillance.
Without understanding the workplace hazards, the questionnaire cannot determine what should be monitored, how often it should be reviewed or what action should follow if concerns are identified.
Health surveillance is a structured programme not simply a form to complete once a year.
Who should oversee health surveillance?
The HSE is clear that health surveillance should be designed and overseen by someone with appropriate occupational health competence.
Some elements may be undertaken by a suitably trained responsible person within the organisation, but only where this is appropriate for the specific hazard and where they have access to occupational health support.
Clinical findings, abnormal results and decisions about fitness for work require interpretation by appropriately qualified occupational health professionals.
This distinction is important.
Collecting health information is not the same as understanding what it means, whether it is related to work and what action should be taken to protect both the individual and the wider workforce.
Protecting people not simply demonstrating compliance
Health surveillance should never be viewed as a paperwork exercise carried out to satisfy a legal requirement.
When undertaken properly, it provides early warning of work-related ill health, helps employers evaluate whether their control measures are effective and prevents employees developing irreversible occupational disease.
The most effective health surveillance programmes are those designed around the actual risks in the workplace, supported by competent occupational health professionals and integrated with the organisation’s wider health and safety management.
Ultimately, the aim is not to collect questionnaires.
It is to protect people’s health throughout their working lives.
