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Ask an Expert: When is Health Surveillance Legally Required

17th July 20267th May 2025 by Kelly Mayne

Published: March 2025

Reading time: 5 minutes

Suitable for: Business Owners, Managers and Supervisors

Topics: Health Surveillance | Noise at Work | Risk Assessment | Occupational Health


Ask Harwood

One of the questions we hear most often is:

“Do all of my employees need to undergo health surveillance?”

Here’s a recent example.


Question

Hi Harwood,

I was wondering whether there is a legal requirement for us to carry out medical screening for our employees. Some of our team work in noisy areas and are exposed to other workplace hazards.

We offered health screening last year and those who wanted it attended, but I’m unsure where we stand legally.

— Business Owner


Our Answer

That’s a great question—and one that many small businesses ask.

The short answer is not every employee automatically requires health surveillance.

Whether health surveillance is legally required depends on the findings of your risk assessment.

What does the law require?

Employers have a legal duty to protect employees from risks to their health, including exposure to excessive workplace noise.

Noise exposure can cause harm in two main ways:

  • Long-term exposure to moderate levels of noise over time.
  • Sudden exposure to very loud noises that may cause immediate damage.

Your risk assessment should identify whether employees are exposed to harmful levels of noise and whether further action is required.

When is health surveillance required?

Health surveillance becomes necessary when your risk assessment identifies a risk to employees’ health.

For example, where employees are regularly exposed to harmful noise levels, you may need to provide:

  • Hearing protection such as ear defenders or ear plugs
  • Information and training
  • Ongoing hearing tests where appropriate

Health surveillance helps identify early signs of hearing damage so action can be taken before permanent harm occurs.

If your assessment shows there is no significant health risk, routine health surveillance may not be necessary.

What should you do next?

If you’re unsure whether health surveillance is required:

  1. Review your current noise risk assessment
  2. Check previous health surveillance results (if available)
  3. Consider whether workplace conditions have changed
  4. Ensure suitable control measures, including hearing protection, are in place
  5. Seek competent advice if you’re still unsure

Remember, preventing exposure is always better than monitoring the effects afterwards.

Related resources

E-learning

  • Noise Awareness (Employees)
  • Noise Management (Managers)
  • Understanding Risk Assessment

Have a question?

If you’ve got a health and safety question you’re unsure about, there’s a good chance someone else is wondering the same thing.

The Health & Safety Portal contains practical guidance, editable templates and e-learning courses to help you understand your legal responsibilities and apply them confidently within your own business.

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