Medical surveillance starts with exposure, not a medical package

A common compliance mistake is to send every employee for the same “occupational medical”.

That reverses the correct process.

The technical sequence should be:

1. 01Hazard
2. 02Exposure assessment
3. 03Exposed person or group
4. 04Applicable regulatory trigger
5. 05Medical-surveillance protocol
6. 06Fitness or health outcome
7. 07Exposure and control response

Different hazards require different examinations.

For example, a noise-exposed employee may require audiometric surveillance. An employee exposed to a particular hazardous chemical agent may require a clinical examination and, where indicated, biological monitoring. An asbestos worker requires an asbestos-specific system. A person exposed to ergonomic risk factors may require surveillance targeted at the relevant adverse health effect.

The medical is therefore not the starting point. The risk and exposure profile is.

Which regulations can trigger medical surveillance?

Medical surveillance requirements appear across several regulations under the Occupational Health and Safety Act.

Important current examples include:

• Regulations for Hazardous Chemical Agents, 2021;
• Regulations for Hazardous Biological Agents, 2022;
• Ergonomics Regulations, 2019;
• Asbestos Abatement Regulations, 2020;
• Construction Regulations, 2014 — medical certificates of fitness for construction employees under Regulation 7;
• Lead Regulations;
• Noise Exposure Regulations, 2024;
• Physical Agents Regulations, 2024.

The regulatory triggers and examination frequencies are not identical.

Do not take the frequency from one regulation and apply it to every hazard.

Hazardous chemical agents

Under Regulation 7 of the Regulations for Hazardous Chemical Agents, medical surveillance is required where, among other triggers:

• the employee may be exposed to an HCA listed in the relevant Table 4;
• exposure is such that an identifiable occupational disease or adverse health effect may be related to the exposure, there is a reasonable likelihood of that effect under the particular working conditions and suitable diagnostic techniques exist; or
• an occupational health practitioner recommends surveillance.

Where surveillance applies, the timing and content of the examinations are not one fixed schedule. They depend on the chemical agent concerned, how and how much employees are exposed, and the programme the occupational medicine practitioner sets for that agent.

The regulation sets the framework: an initial health evaluation performed, as far as reasonably practicable, immediately before or within 14 days after employment commences where relevant exposure exists or may exist, and periodic examinations at intervals not exceeding two years, or at intervals specified by an occupational medicine practitioner.

Within that framework, the actual programme should be determined by:

• the specific agent and the adverse health effects it is known to cause;
• which trigger applies — a Table 4 listing, a reasonably likely exposure-related effect, or a practitioner’s recommendation;
• the route of exposure — inhalation, skin contact or ingestion;
• the measured or expected exposure level from the risk assessment and monitoring;
• whether biological monitoring is indicated, and against which biological exposure index;
• the practitioner’s protocol for the examinations, tests and frequency;
• any client, site or contract requirement that is stricter.

Two employees handling different agents — or the same agent at very different exposure levels — can legitimately be on different examination schedules.

This illustrates why an SDS register alone is not enough.

The employer must know:

• what chemical agent is present;
• which employees are exposed;
• the route and level of exposure;
• the adverse effects of concern;
• whether a surveillance trigger applies.

Noise Exposure Regulations, 2024

As at September 2026, the Noise Exposure Regulations, 2024 have replaced the former Noise-Induced Hearing Loss Regulations following expiry of the transition period.

The new framework contains an 82 dBA noise action level in addition to the 85 dBA noise-rating limit and specifically recognises combined exposure involving ototoxic chemical agents and whole-body vibration.

Regulation 9 requires a documented medical-screening programme where an employee may be exposed:

• at or above the noise-rating limit; or
• at or above the noise action level where there is concomitant exposure to ototoxic chemical agents and/or whole-body vibration;

and also contains provisions for vulnerable employees.

The incorporated Code of Practice for Audiometry distinguishes several audiometric stages, including initial, entry, baseline, periodic and exit audiometry according to the applicable circumstances.

This means a noise-medical programme should not be disconnected from the noise risk assessment, monitoring results, chemical exposure data and vibration exposure.

Physical Agents Regulations, 2024

The Physical Agents Regulations cover physical-agent exposures such as heat, cold, vibration, illumination and occupational non-ionising radiation.

They were amended on 20 February 2026, including changes to certain tables and training requirements.

Regulation 8 requires documented medical screening where the physical-agent exposure risk assessment or its review indicates that screening is needed. Vulnerable employees require specific consideration by the occupational medicine practitioner.

Where medical screening is required:

• it is carried out by an occupational health practitioner;
• an initial screening must, as far as reasonably practicable, occur immediately before employment commences;
• periodic screening follows at intervals recommended by the occupational medicine practitioner but not exceeding 24 months;
• an exit medical screening is required on termination, unless a screening within the previous six months qualifies under the regulation;
• the system of medical surveillance must be overseen by an occupational medicine practitioner;
• written informed consent is required.

These are materially more specific requirements than simply sending a worker for an “annual medical”.

Asbestos has its own surveillance system

The Asbestos Abatement Regulations, 2020 contain a separate medical-surveillance regime.

An employer must establish and maintain surveillance where, among other circumstances:

• the employer is a registered asbestos contractor;
• an occupational medicine practitioner considers, after reviewing the asbestos risk assessment, that an asbestos-related disease is reasonably likely under the employee’s work conditions; or
• an occupational medicine practitioner recommends surveillance.

The appointed occupational medicine practitioner documents the surveillance system.

The initial health evaluation must occur before commencement of asbestos work and includes consideration of medical, occupational, exposure and social history, an appropriate physical examination, a chest radiograph and additional testing considered necessary. Periodic evaluations then follow at risk-determined intervals.

Asbestos records also demonstrate why retention rules must be checked hazard by hazard: Regulation 23 requires specified asbestos records, including medical surveillance reports, to be retained for a minimum of 50 years.

Baseline, periodic and exit medicals are not universal labels

These terms are useful, but they should not be applied mechanically.

A baseline or initial evaluation establishes a relevant health status before or near the beginning of exposure.

A periodic examination looks for changes over time according to the hazard-specific programme.

An exit examination creates information at the end of the relevant exposure or employment where required by the applicable regulation.

But not every OHS regulation uses the same terminology, timing or exit requirement.

For example:

• HCA surveillance specifies initial and periodic evaluations;
• Physical Agents Regulation 8 expressly provides for an exit screening;
• the Noise framework contains its own audiometry requirements;
• asbestos has its own initial and periodic system.

The employer should therefore build a medical-surveillance matrix by hazard, not a blanket company rule such as “everyone gets an annual medical and exit medical”.

Who performs medical surveillance?

The legislation distinguishes between an occupational health practitioner and an occupational medicine practitioner.

The exact allocation of functions depends on the regulation.

Typically, the occupational medicine practitioner has responsibility for designing, overseeing or making specified clinical/fitness decisions within the programme, while occupational health practitioners may perform examinations or screening within that framework.

This distinction becomes important when an employer purchases a package from a medical service provider.

What should a certificate of fitness tell the employer?

A supervisor needs sufficient information to allocate work safely.

They generally do not need the employee’s diagnosis, clinical notes or unrelated medical history.

For example, the Physical Agents Regulations require a medical certificate of fitness to address matters including:

• recommendations relevant to fitness for the inherent requirements of the job;
• the presence of an occupational disease without disclosing confidential medical information;
• restrictions or conditions on specified duties;
• the period for which those restrictions or conditions apply.

The Asbestos Abatement Regulations similarly limit information provided to the employer to the presence of occupational disease and the employee’s fitness to perform the inherent requirements of the job, without confidential medical information.

A useful operational outcome might therefore say:

It should not give a supervisor the employee’s complete clinical record.

Fitness restrictions must reach the work-allocation system

Medical surveillance fails if the clinic issues a restriction but nobody controlling the work sees or acts on it.

A functioning system should link:

• employee;
• position;
• exposure group;
• relevant surveillance programme;
• certificate status;
• restriction;
• restriction expiry/review;
• person responsible for work allocation.

Under the Physical Agents Regulations, an employer must as far as reasonably practicable accommodate recommended restrictions and may only return an employee from restricted to normal duties after the required occupational-medicine fitness decision.

Records and confidentiality

Retention periods differ by regulation.

Two current examples are particularly clear:

• Noise Exposure Regulations: specified training, assessment, monitoring, medical-screening/surveillance and control-maintenance records — 40 years;
• Physical Agents Regulations: specified records including medical screening and surveillance reports — 40 years.

Asbestos uses a 50-year minimum for the records specified in Regulation 23.

Confidentiality must also be designed into the system.

Medical records and employer-facing fitness information are not the same thing.

Access to personal medical information must follow the applicable regulation, informed-consent provisions and broader privacy/professional requirements.

How to build the programme correctly

Start with the legal and exposure logic.

For each hazard:

1. identify the applicable regulation;
2. confirm the exposure source;
3. identify the employees or similar-exposure group;
4. complete the required risk/exposure assessment;
5. determine whether surveillance is triggered;
6. have the appropriate occupational-health professionals define the protocol;
7. perform baseline/initial, periodic and exit examinations where that regulation requires them;
8. issue usable fitness outcomes;
9. implement restrictions;
10. analyse surveillance trends;
11. review workplace controls where adverse effects appear;
12. retain the correct records for the correct statutory period.

Medical surveillance should produce prevention information.

If ten people show a deteriorating exposure-related health trend, the correct response is not merely ten updated certificates. The exposure and controls need to be investigated.

Frequently asked questions

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AuthorJean DuvenageManaging Director Reviewed byArthur PaddockSenior Safety Consultant