Landmark HSE Action Highlights Importance of Competent Occupational Health Surveillance
The Health and Safety Executive (HSE) has taken landmark enforcement action against an occupational health provider after inspectors identified serious concerns about the quality of its health surveillance services.
The regulator served its first-ever prohibition notice against an occupational health service provider after finding that Cheshire-based Health Surveillance Services may have placed workers at risk.
What prompted the enforcement action?
The company had been providing health surveillance for employees exposed to workplace hazards, including wood dust and excessive noise.
According to the HSE prohibition notice, targeted health assessments requiring clinical interpretation were being conducted without sufficient training, experience or knowledge.
Inspectors also found that some services were delivered by personnel who were inadequately trained, unqualified or insufficiently supervised.
These shortcomings could have allowed the early symptoms of serious occupational conditions to go unnoticed, including:
- Occupational asthma
- Work-related dermatitis
- Noise-induced hearing loss
The HSE consequently prohibited the company from continuing the affected activities. A separate HSE improvement notice was issued after inspectors identified inadequate clinical governance, insufficient competent oversight and a lack of quality-assurance procedures.
Further details of the case can be found in the HSE’s official enforcement announcement.
Why effective health surveillance matters
Health surveillance is more than a routine medical check. It is a structured process designed to identify early signs of work-related ill health among employees exposed to particular workplace hazards.
When conducted properly, health surveillance can help employers:
- Detect occupational illness at an early stage
- Assess whether existing control measures are effective
- Identify employees requiring further medical assessment
- Review workplace risks and working practices
- Prevent health conditions from becoming more serious
Poorly managed surveillance can create a false sense of security. Employers may believe their arrangements are protecting workers when, in reality, important warning signs are being missed.
A warning for occupational health providers and employers
The case sends a clear message that occupational health providers must be able to demonstrate genuine competence, appropriate qualifications, effective clinical governance and robust procedures for responding to adverse findings.
However, employers cannot simply appoint an external provider and assume their responsibilities have been discharged. Businesses should take reasonable steps to confirm that their chosen provider is competent and that the surveillance programme is appropriate for the risks involved.
Employers should also ensure that:
- Health surveillance is based on a suitable workplace risk assessment
- The correct employees are included
- Results are reviewed and acted upon
- Workplace controls are reassessed when concerns arise
- Appropriate health records are maintained
- Services comply with relevant legislation, including COSHH and the Control of Noise at Work Regulations
Health Surveillance Services told IOSH Magazine that it had taken the HSE’s findings seriously and introduced a signed clinical protocol, additional staff qualifications, clinical supervision and quality-assurance auditing.
The key lesson
Health surveillance must be clinically appropriate, competently delivered and connected to practical workplace action. Simply carrying out screening exercises is not enough.
Both employers and occupational health providers should regularly review their arrangements to ensure they genuinely protect workers—not merely demonstrate apparent compliance.
This blog post is based on reporting originally published by IOSH Magazine.
