Health Surveillance for Hand-Arm Vibration: An Employer's Guide

Health surveillance is the duty employers most often get wrong under the Control of Vibration at Work Regulations 2005, usually not through resistance but through vagueness: a sense that "occupational health is involved" without a clear picture of who must be under surveillance, what the process actually involves, or what to do with the results. This guide sets out the practical shape of HAV health surveillance: who it covers, how the tiered scheme works, what happens when it finds something, and the records that hold it all together.

One framing point first. Health surveillance does not protect anyone by itself. Hand-arm vibration syndrome is progressive and irreversible, so surveillance is valuable only as an early-warning system that triggers change while change can still help. An organisation that runs diligent annual questionnaires while doing nothing about exposure has bought itself evidence of harm, not protection from it. Surveillance works alongside exposure control, never instead of it.

Who Must Be Under Surveillance

Regulation 7 requires health surveillance for employees who are regularly exposed above the exposure action value, 2.5 m/s² A(8), the 100-point daily threshold in the exposure points system, and for any employee otherwise at risk, which includes workers who occasionally exceed the EAV, workers who have reported symptoms, and workers whose existing health makes them more vulnerable at any exposure level.

That last group deserves emphasis, because the standard thresholds assume a standard worker. Conditions such as Raynaud's disease, carpal tunnel syndrome, previous hand or wrist injury, circulatory disorders, or early HAVS symptoms from past employment can all mean a worker is at risk well below 100 points a day. Identifying these workers is part of the risk assessment, and it is where surveillance and exposure management meet: occupational health may advise a reduced personal exposure limit for an individual, and that advice only means something if daily monitoring can actually enforce a personal threshold rather than the generic one.

The Tiered Scheme

HAV health surveillance in Great Britain follows the tiered approach set out in the HSE's guidance (L140), delivered in practice by an occupational health provider. The structure escalates by need rather than putting every worker in front of a doctor every year.

Tier 1 is a baseline questionnaire, completed before or when a worker first starts vibration-exposed work. It establishes the starting point: existing symptoms, relevant medical history, previous exposure.

Tier 2 is a short screening questionnaire repeated annually for everyone under surveillance. It is deliberately lightweight, a check for emerging symptoms, and it is the minimum ongoing cadence: an organisation whose surveillance consists of less than an annual screen for exposed workers is below the baseline the HSE expects.

Tier 3 is an assessment by a qualified person, typically an occupational health nurse trained in HAVS, triggered when a questionnaire reports symptoms and carried out periodically, commonly every third year, even where questionnaires are clear.

Tier 4 is a formal diagnosis by an occupational physician, with staging of the condition and fitness-for-work advice: whether the worker can continue vibration work, under what reduced exposure, or not at all.

Tier 5, which is optional, covers standardised clinical tests used to support staging where more certainty is needed.

When Surveillance Finds Something

A HAVS or work-related carpal tunnel diagnosis sets several things in motion at once. The worker receives the clinical advice; the employer receives fitness-for-work advice, typically a reduced personal limit or removal from vibration work, and must act on it. Once a doctor has made the diagnosis in writing, HAVS or carpal tunnel syndrome in someone whose work involves regular use of percussive or vibrating tools is reportable to the HSE under RIDDOR, which puts the organisation's exposure records and risk assessment within reach of external scrutiny. And the case itself is evidence about the workplace: one diagnosed worker means the exposure that caused it was probably shared, so a diagnosis should always prompt a review of the risk assessment and of the exposure records of colleagues doing similar work.

This is the moment when the quality of daily exposure records is tested. An occupational physician staging a case, and later perhaps a solicitor testing a claim, will want to know what this worker was actually exposed to, tool by tool and day by day, over years. Organisations that can produce that history are in a categorically different position from those reconstructing it from rotas and memory.

Health Records, and the 40-Year Question

Two kinds of record exist here, and they must not be confused. The clinical record, questionnaire answers, examination findings, diagnoses, is confidential medical information held by the occupational health provider. The health record, which Regulation 7 requires the employer to make and maintain for each worker under surveillance, is the non-clinical output: that surveillance happened, when, and the fitness-for-work outcome, including any restrictions or adjusted limits. The employer holds the health record alongside, but separate from, general personnel files.

On retention: the Regulations require the health record to be made and maintained and kept available "in a suitable form", and that is all they say — they do not themselves fix a retention period. The widely adopted convention, and the one the HSE's guidance points towards, is to keep health records for 40 years from the last entry, borrowing the statutory retention period that regimes such as COSHH apply to exposure records. The logic is latency: vibration injury can surface and claims can arrive decades after exposure, long after a five-year retention policy would have destroyed the evidence. Alongside the health record itself, keep the exposure records, risk assessments, and records of actions taken at thresholds, which are the documents that give a health record its context.

Adjusted Limits Must Be Operational, Not Aspirational

The weakest link in most surveillance schemes is the handover: occupational health advises that a worker should be limited to, say, half the standard action value, the advice is filed, and the worker goes back to a workplace where nothing measures their exposure against it. An adjusted limit that exists only in a letter is not a control.

Making it operational means three things: the personal limit is documented in the risk assessment, daily exposure for that worker is actually tracked against their limit rather than the generic thresholds, and someone is alerted before the personal limit is reached, in time to change the day rather than record the breach.

HSE Resources

• Hand-arm vibration at work: the HSE's HAV hub, including its health surveillance guidance
• L140, Hand-arm vibration: The Control of Vibration at Work Regulations 2005, sets out the tiered surveillance scheme in full

For the wider legal framework this duty sits inside, see The Control of Vibration at Work Regulations 2005, explained.

Important Notice

This guide is intended as general guidance only and does not constitute legal, safety, or medical advice. Health surveillance decisions, diagnoses and fitness-for-work advice are clinical matters for occupational health professionals. Organisations are responsible for their own risk assessments, surveillance arrangements and compliance with the Control of Vibration at Work Regulations 2005 and related HSE guidance. Earlsmere Limited accepts no liability for any loss or damage arising from reliance on this guide.