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Health surveillance and safety critical medicals during the coronavirus (COVID-19) pandemic

Guidance for occupational health providers and appointed doctors

HSE issued updated guidance on 4 January 2021. This advice (issued on 5 March 2021) further updates that guidance. It continues to balance the need to protect the health, safety and welfare of workers and practitioners with the current constraints due to the pandemic.

For all health surveillance, an adequate assessment of the worker should continue to take place (including specialist referral where required), with provision of appropriate advice to the worker and employer. This guidance sets out options for conducting health surveillance using remote assessment and, as appropriate, face to face assessment. The latter should be subject to a suitable and sufficient risk assessment to provide a COVID-secure environment, taking into account public health advice on coronavirus. The general principles set out in the guidance apply to both new workers and those undergoing periodic medicals.

Where local or national restrictions are implemented due to the pandemic, occupational health providers should discuss the delivery of health surveillance with an affected employer to establish an appropriate course of action.

HSE will continue to review this guidance as appropriate.

Health surveillance using questionnaires

Where health surveillance is performed using questionnaires, they can be administered remotely. For questionnaires requiring follow up, this can be by telephone, video or where appropriate, face to face assessment in a COVID-secure environment.

Respiratory health surveillance

Providing a current respiratory health questionnaire does not raise any concerns and previous lung function tests were normal (where available), occupational health providers can defer spirometry for up to 18 months (including any previous deferral periods).

Spirometry can be performed where considered necessary. For example, as part of a safety critical medical, where there is a clinical concern or known lung function abnormality, or after a maximum 18-month deferral period. Where spirometry is considered necessary in these types of circumstances, the potential for aerosols containing coronavirus should be taken into account. It should be subject to a suitable and sufficient risk assessment and appropriate controls put in place, including the provision of suitable personal protective equipment (PPE).

Control of Substances Hazardous to Health Regulations 2002 (COSHH)

For health surveillance under COSHH regulation 11 and medical surveillance under Schedule 6, occupational health professionals, occupational health technicians, responsible persons and appointed doctors can perform assessments following relevant guidance in the sections on health questionnaires and respiratory health surveillance.

Control of Asbestos Regulations 2012 (CAR)

For medical surveillance under CAR, appointed doctors can perform assessments remotely using a respiratory symptom questionnaire or face to face in a COVID-secure environment.    

For remote assessments, where no problems are identified, they can issue a certificate for up to 18 months (including any previous deferral periods), ensuring it clearly states for how long it is valid. Where remote assessments require follow up, this can be by telephone, video or where appropriate, face to face assessment in a COVID-secure environment.

Where the appointed doctor conducts a full face to face medical with spirometry, if there are no problems, they can issue a certificate for two years.

Doctors can follow the same approach for assessing workers who are carrying out non-licensed work with asbestos. However, where they conduct a full face to face medical with spirometry, if there are no problems, they can issue a certificate for three years.

Ionising Radiations Regulations 2017 (IRR)

For medical surveillance of classified persons, appointed doctors can perform assessments remotely or, where appropriate, face to face in a COVID-secure environment (eg for high risk radiation workers such as industrial radiographers or for an overexposure). For remote assessments, where no problems are identified, they can schedule the next medical in 12 months. Where a remote assessment requires follow up, this can be by telephone, video or where appropriate, face to face assessment in a COVID-secure environment.

Control of Lead at Work Regulations 2002 (CLAW)

For medical surveillance under CLAW, appointed doctors can obtain blood lead levels and perform assessments in accordance with the Approved Code of Practice and guidance (L132).

Face to face contacts (eg blood taking) should be carried out in a COVID-secure environment.

Control of Noise at Work Regulations 2005

Occupational health providers and audiologists can carry out audiometry, subject to a suitable and sufficient risk assessment to provide a COVID-secure environment.

Control of Vibration at Work Regulations 2005

Health surveillance for hand arm vibration syndrome (HAVS) can continue using initial and screening health questionnaires administered remotely. Where a remote assessment requires face to face follow up, it should be subject to a suitable and sufficient risk assessment to provide a COVID-secure environment.

Safety critical medicals

Occupational health providers can carry out safety critical medicals subject to a suitable and sufficient risk assessment to provide a COVID-secure environment.

Contacting us if you have questions

If you have any questions, please contact [email protected].

This page is reviewed regularly and updated to reflect any changes in the guidance.

Page last reviewed: 28 May 2021

Next review due: 30 June 2021

2021-05-28