Occupational health procedure (Issue 1 – June 2018)


This procedure sets out how Hampshire County Council (HCC) manages occupational health (OH) in relation to health and safety.  The aim is to reduce the risk of work-related ill health and secure compliance with health and safety legislation including the Health and Safety at Work etc., Act 1974 and the Management of Health and Safety at Work Regulations 1999, as amended.


This procedure provides an overview of the occupational health arrangements within HCC.  It covers conditions that are either caused or made worse by work, e.g. noise-induced hearing loss (NIHL) and contact dermatitis.  It does not cover the management of health problems that an employee brings to work, e.g. diabetes.  This is covered by the general Occupational Health and Wellbeing procedures and policies.

HCC’s arrangements for managing risks from hazardous substances and complying with the Control of Substances Hazardous to Health Regulations 2002 (COSHH) are detailed in the COSHH Corporate Procedure.

HCC’s arrangements for managing risks from noise and vibration and complying with the Control of Noise at Work Regulations 2005 and the Control of Vibration at Work Regulations 2005 are detailed in the Noise and Vibration Corporate Procedure.

HCC’s arrangements for undertaking risk assessments are detailed in the Risk Assessment Corporate Procedure.

This procedure replaces all previous corporate policies and procedures on occupational health.


Health surveillance – a system of ongoing health checks that may be required by law if employees are exposed to hazardous substances or activities that could cause them harm. It can detect ill health effects at an early stage and highlight failures in workplace control measures.

Health records – records relating to individuals under health surveillance that must be held by the employer; they do not contain confidential medical information. They contain information on the employee, their work, the hazards they’ve been exposed to and the dates in relation to this. They also state the outcome of the health surveillance and the employee's fitness to continue working with exposure to certain hazards.

Medical records – records containing confidential medical information held by a health professional. Medical records related to health surveillance will be held by the occupational health service provider.


Occupational Health and Wellbeing Services

Hampshire County Council has an in-house provider of Occupational Health and Wellbeing Services. The service employs qualified occupational health professionals and retains registered medical practitioners. It provides advice to managers on occupational health matters and regulatory requirements. It also undertakes health surveillance, including lung function testing, audiometry and Hand Arm Vibration Syndrome (HAVS) surveillance.

Occupational health risk management

Hampshire County Council follows the "plan, do, check, act" approach to managing work-related health risks:

  • Plan – identifying health risks as part of the risk assessment process
  • Do – implementing appropriate control measures
  • Check – monitoring the effectiveness of control measures
  • Act – taking appropriate remedial action when necessary

When assessing health risks, those that can cause chronic effects, such as lung disease, need to be considered as well as those causing acute reactions such as contact dermatitis.

Control measures for health risks should normally follow the following hierarchy:

  1. elimination
  2. substitution
  3. engineering solutions
  4. safe working practices
  5. personal protective equipment

More information on the hierarchy of controls can be found in the corporate procedures covering COSHH, noise and vibration.

Health surveillance

Where a risk assessment identifies that health risks remain after all reasonable control measures have been implemented, a health surveillance programme is needed. Health surveillance should be considered for those at risk from noise, vibration, solvents, dusts and other substances hazardous to health.

Health surveillance will be required if all the following criteria are met:

  • there is an identifiable disease/adverse health effect and evidence of a link with workplace exposure
  • it is likely the disease/health effect may occur
  • there are valid techniques for detecting early signs of the disease/health effect
  • these techniques do not pose a risk to employees

In its simplest form, health surveillance could involve employees exposed to cleaning materials undertaking simple skin checks, following training to identify and report cases of dermatitis. More complicated checks, such as lung function testing, will be undertaken by occupational health professionals. Occupational Health and Wellbeing Services can provide advice on this subject and will undertake health surveillance programmes where required.

Occupational Health and Wellbeing can only provide advice if they are in possession of the risk assessments associated with the hazard. The responsibility for conducting this risk assessment and requesting health surveillance lies with the manager.

Occupational Health and Wellbeing runs a recall system, however ultimately the responsibility for attending health surveillance lies with the employee and their manager.

The results of any health surveillance should be used by managers when reviewing the relevant risk assessments and workplace control measures.

To request a new health surveillance programme you must complete an application form (Appendix 1) and return it to Occupational Health with the appropriate risk assessments attached.

It is the responsibility of management to ensure that Occupational Health and Well being staff are informed of any new employees likely to be exposed to occupational health hazards or employees newly exposed to these hazards immediately on commencement and before exposure to the hazard to ensure that baseline health surveillance can be undertaken.

Health records

HCC will hold health records for all employees under health surveillance. These records will be kept for at least 40 years from the date of the last entry.

Managers are responsible for keeping copies of health records securely and in accordance with General Data Protection Regulations. Employees are entitled to see their own health records and can also give consent for their health and safety representatives to see them.

Medical records

Medical records relating to a health surveillance programme will be held by the occupational health provider. For HCC employees, this will normally be Occupational Health and Wellbeing Services. The information in these records is confidential and cannot be disclosed to third parties, such as HCC, without the employee’s consent.

Occupational Health and Wellbeing staff use a computerised system called Cohort (a system supplied by Cority group, formerly Medgate) and is cloud-based with all data retained and stored on their secure servers. They are compliant with General Data Protection Regulations and have been accredited to ISO27001 standards.

Guidance on health surveillance

Health and Safety Executive guidance on health surveillance


Download the Application for health surveillance programme

Printable version of procedure

Download the Corporate health & safety procedure - Occupational Health - Issue 1