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Question and answerEXC-OQA-0414

Are pre-employment and periodic medical examinations required for workers in the United Kingdom?

excodex editorial teamUnited Kingdom

Part of: Occupational safety and health in United Kingdom: law, authorities and employer duties

Short answer

Not as a general rule. UK law requires health surveillance where the risk assessment shows a residual health risk (noise, vibration, hazardous substances) and doctor examinations only for set hazards such as asbestos, lead and radiation. Night workers must be offered free checks.

Not as a general rule. UK law has no blanket requirement for pre-employment or periodic medical examinations. Employers must provide health surveillance where their risk assessment shows that workers remain exposed to a health risk after controls (Management of Health and Safety at Work Regulations 1999, regulation 6), and specific regulations require medical examinations by a doctor for certain hazards such as licensable asbestos work, lead and ionising radiation.

Short answer

  • General rule: health surveillance "as is appropriate having regard to the risks" identified by the risk assessment (MHSWR regulation 6); no routine check-ups for all workers.
  • Specific health surveillance: noise (including hearing tests), hand-arm and whole-body vibration, and substances hazardous to health under COSHH 2002, regulation 11.
  • Medical surveillance by a doctor: for example asbestos, lead and ionising radiation, and the substances and processes in COSHH Schedule 6 (at intervals of not more than 12 months).
  • Night workers: must be offered a free health assessment before starting night work and at regular intervals (Working Time Regulations 1998, regulation 7).
  • Pre-employment health questions: in Great Britain, the Equality Act 2010, section 60, restricts asking about an applicant's health before a job offer, except for listed purposes such as checking whether the person can carry out a function intrinsic to the job.
  • Records: COSHH health records must be kept for at least 40 years from the last entry.

When health surveillance is legally required

HSE describes health surveillance as a scheme of repeated health checks used to detect ill health caused by work, needed when workers stay exposed to health risks even after controls are in place. Under COSHH regulation 11, surveillance is appropriate where an identifiable disease or adverse health effect may be linked to the exposure, is reasonably likely under the conditions of work, and can be detected by a valid, low-risk technique. Typical examples are lung function testing for respiratory sensitisers, skin checks for dermatitis risks and audiometry for noise.

HazardWhat the law requiresSource
Noise, where the risk assessment shows a risk to healthHealth surveillance including hearing tests; doctor referral if damage is foundControl of Noise at Work Regulations 2005, reg. 9
Hazardous substances where the COSHH tests are metSuitable health surveillance; health records kept 40 yearsCOSHH 2002, reg. 11
COSHH Schedule 6 substances and processesMedical surveillance under a relevant doctor, at least every 12 monthsCOSHH 2002, reg. 11(5)
Licensable asbestos workMedical examination by a relevant doctor within 2 years before exposure and at least every 2 years; health records kept 40 yearsControl of Asbestos Regulations 2012, reg. 22(1) and (2)
Notifiable non-licensed asbestos workMedical examination within 3 years before exposure and at least every 3 years, which any fully registered doctor holding a licence to practise may carry outControl of Asbestos Regulations 2012, reg. 22(3)
Lead, ionising radiationMedical surveillance by a relevant doctor (HSE appointed doctor or employment medical adviser) where the regulations require itControl of Lead at Work Regulations 2002; Ionising Radiations Regulations 2017; HSE health surveillance guidance

Where medical surveillance is required, HSE states that employers must use an appointed doctor (a competent occupational health doctor appointed by HSE), with one exception for some lower-risk asbestos work (the notifiable non-licensed work in the table). The decision on a worker's fitness under these schemes belongs to the doctor.

Fitness for work and pre-employment checks

Outside these duties, employers may still check that workers are medically fit for safety-critical roles, often using industry fitness standards, and must review the risk assessment when a worker returns after sickness absence or declares a health condition (HSE occupational health guidance). In Great Britain, health questions before a job offer are restricted by the Equality Act 2010; after an offer, a health assessment can be made a condition, provided the employer then considers reasonable adjustments and does not discriminate.

Example: A metal fabrication company has welders exposed to noise and welding fume. Its risk assessment shows that, even with extraction and hearing protection, some exposure remains. It sets up a health surveillance programme with an occupational health provider: baseline and periodic audiometry and a respiratory questionnaire with lung function testing. It does not need routine general medicals for its office staff, and it does not ask applicants about their health before making a job offer.

How the UK compares with Türkiye

The UK model is risk-based. In Türkiye, Law No. 6331, Article 15, requires examinations on hiring, on change of job, on return after repeated absences when requested, and at regular intervals set by the Ministry, and workers in hazardous and very hazardous classes may not start work without a fitness report. Employers moving staff between the two countries should plan for this difference.

Common mistakes

  • Running general "annual medicals" instead of targeted surveillance linked to the actual exposures.
  • Asking health questions at application stage in Great Britain without a lawful reason under section 60.
  • Not keeping COSHH health records for 40 years, or not giving workers access to their own records.

Related on excodex

Standards and further reading

This article is general occupational safety and health information prepared by the excodex editorial team. It does not replace the applicable legislation, standards, manufacturers' instructions or the assessment of a competent OSH professional or occupational physician.

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Part of: Occupational safety and health in United Kingdom: law, authorities and employer duties

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