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Question and answerEXC-OQA-0584

Are pre-employment and periodic medical examinations required for workers in Belgium?

excodex editorial teamBelgium

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

Short answer

Only for workers in safety posts, vigilance posts or activities with a defined risk. They need a pre-employment health assessment before starting and periodic surveillance, usually every 24 months with interim checks, and 12 months for carcinogens or noise of 87 dB(A) or more.

Not for every worker. In Belgium, health surveillance is compulsory for workers who occupy a safety post, a vigilance post or an activity with a defined risk identified by the risk analysis. These workers need a pre-employment health assessment before they start and periodic surveillance at the frequency set in annex I.4-5 of the Code of well-being at work, carried out by the prevention adviser-occupational physician.

Short answer

  • Who: workers in a safety post, a vigilance post or an activity with a defined risk (chemical, physical or biological exposure, ergonomic strain, or high psychosocial risk). Surveillance is not required where the risk analysis, made with the occupational physician and submitted to the Committee, shows it is unnecessary.
  • Pre-employment: a prior health assessment before the worker starts the post, or before a transfer into such a post; it can be the last step of recruitment.
  • First periodic check: in every case after 12 months, then at the risk-based frequency.
  • Typical frequencies: 24 months for safety and vigilance posts and many exposures, with additional acts 12 months after each assessment; 12 months for carcinogens and for daily noise exposure of 87 dB(A) or more; 36 months for noise of 85 dB(A) or more; 60 months for 80 dB(A) or more.
  • Return to work: compulsory after an absence of at least four weeks for these workers, within ten working days of return.
  • Cost and time: in working time, paid, travel costs borne by the employer, no cost to the worker.

The categories that trigger surveillance

The Code defines three categories:

  1. Safety post: using work equipment, driving motor vehicles, cranes, overhead cranes or lifting equipment, operating dangerous installations or carrying weapons, where this can endanger other workers.
  2. Vigilance post: permanent monitoring of an installation where a lapse of attention can endanger other workers.
  3. Activity with a defined risk: an identifiable health risk from exposure to a physical, biological or chemical agent, from ergonomic or monotonous repetitive strain, or from high psychosocial risk.

The employer draws up the lists of these posts and activities from the risk analysis, gives them to the occupational physician and keeps them available. The physician links the examination results to the risk analysis of the post when deciding on fitness.

Periodic surveillance since the 2019 reform

Since a royal decree of 14 May 2019, periodic surveillance combines a health assessment by the physician with additional medical acts, such as questionnaires, vision tests or audiograms, carried out by the physician or nursing staff, sometimes between two assessments.

Risk (examples from annex I.4-5)Health assessment by the physicianMinimum additional medical acts
Safety post or vigilance post24 months (physician may set 12 months from age 50)Questionnaires or tests chosen by the physician (vision, hearing, ECG), before the assessment and again 12 months after it
Carcinogens, mutagens, reprotoxic and endocrine-disrupting agents, including asbestos12 monthsAs set in annex VI.1-4, before and between assessments
Noise: daily exposure 87 dB(A) or more, or peak 140 dB(C)12 monthsAppropriate audiogram before each assessment
Noise: 85 dB(A) or more, or peak 137 dB(C)36 monthsAppropriate audiogram before each assessment
Noise: 80 dB(A) or more, or peak 135 dB(C)60 monthsAppropriate audiogram before each assessment
Night or shift work without particular risks36 monthsNone listed

The physician may set a higher frequency for individuals or groups, for example after accidents or when action values are exceeded, and the medical inspector of the inspectorate may impose one. If a worker is exposed to several risks, the shortest interval applies.

Example: A chemical operator works in a control room (vigilance post) and also handles a carcinogenic substance during sampling. The carcinogen sets the frequency: an annual health assessment. When the operator moves to this job from an office post, a pre-employment health assessment is needed first, and a periodic assessment 12 months later in any case.

Other examinations and worker rights

Any worker, under surveillance or not, may request a spontaneous consultation for work-related health complaints; the physician assesses within ten working days. Employers may not perform other medical tests during recruitment or employment for other purposes, and may not keep at work someone who avoids compulsory examinations. Workers may use a consultation procedure and an appeal to the social medical inspector against a decision restricting their fitness (the appeal is lodged by registered letter within 21 calendar days), but these routes do not apply to the pre-employment health assessment.

How Belgium compares

Belgium ties examinations to defined post categories and a risk-based table. Türkiye requires examinations for workers in general under Article 15 of Law No. 6331: at recruitment, on a change of job, on return after a work accident, an occupational disease or repeated health-related absences if the worker asks, and periodically at intervals set by the Ministry according to the worker, the work and the hazard class. Within the EU, Directive 89/391/EEC leaves health surveillance arrangements to national law.

Related on excodex

Standards and further reading

  • Code of well-being at work, book I, title 4 (articles I.4-1 to I.4-37) and annex I.4-5, consolidated 13 June 2026: FPS Employment PDF
  • Royal decree of 14 May 2019 amending the Code as regards periodic health surveillance (Moniteur belge 11 June 2019)

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 Belgium: law, authorities and employer duties

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