HAVS Health Surveillance: When to Refer Workers and What Records to Keep
When Health Surveillance Becomes Mandatory
Health surveillance for HAVS isn't optional once workers are exposed above certain levels. Under the Control of Vibration at Work Regulations 2005, you must provide health surveillance when:
- A worker's daily exposure regularly reaches or exceeds the EAV (2.5 m/s² A(8) / 100 points)
- A worker is otherwise at risk — for example, they have a pre-existing condition that makes them more susceptible to vibration damage
- A worker reports symptoms consistent with HAVS, regardless of their calculated exposure level
The purpose is early detection. HAVS damage is irreversible — health surveillance catches it before a worker loses significant hand function.
The Tier System: What Happens at Each Level
Tier 1: Initial baseline screening
When: Before a worker starts using vibrating tools.
What: A short self-assessment questionnaire covering:
- Previous exposure to vibrating tools (prior jobs, duration)
- Any existing symptoms (tingling, numbness, white finger, loss of grip)
- Relevant medical history (circulatory conditions, previous hand injuries)
Who administers it: The worker completes it themselves. A trained supervisor or H&S coordinator reviews the answers.
Outcome: If the worker reports existing symptoms or significant prior exposure, escalate directly to Tier 3 before they start work.
Tier 2: Annual screening
When: Every 12 months for workers exposed at or above the EAV.
What: An annual questionnaire asking:
- Have you experienced any new symptoms since the last screening? (tingling, numbness, white finger, reduced grip)
- Has your vibration exposure changed? (new tools, different work patterns)
- Any concerns about your hand health?
Who administers it: A trained person — typically the site supervisor or H&S coordinator. They don't need medical qualifications for Tier 2, but they do need training to recognise when answers indicate a referral is needed.
Outcome: If symptoms are reported, refer to Tier 3.
Tier 3: Clinical assessment
When: When Tier 1 or Tier 2 identifies possible symptoms.
What: A standardised clinical assessment by an occupational health professional:
- Detailed symptom history
- Grip strength measurement
- Manual dexterity tests
- Sensory perception tests (monofilament testing, thermal threshold)
- Assessment for Raynaud's phenomenon
Who does it: An occupational health nurse, technician, or physiotherapist with HAVS training. This is not a GP appointment — it requires someone familiar with occupational vibration exposure.
Outcome: If the assessment confirms HAVS symptoms, escalate to Tier 4 for formal diagnosis.
Tier 4: Formal diagnosis
When: When Tier 3 confirms HAVS symptoms.
What: A full clinical assessment by a doctor with expertise in occupational medicine, including formal staging of the condition using the Stockholm Workshop Scale:
| Vascular staging | Description |
|---|---|
| 0V | No blanching attacks |
| 1V | Blanching of fingertips only |
| 2V | Blanching of fingers, with numbness |
| 3V | Extensive blanching, frequent episodes |
| 4V | Extensive blanching of all fingers, skin changes |
| Sensorineural staging | Description |
|---|---|
| 0SN | Exposed, no symptoms |
| 1SN | Intermittent numbness/tingling |
| 2SN | Intermittent or persistent numbness, reduced sensory perception |
| 3SN | Persistent numbness, reduced tactile discrimination and grip |
Outcome: Formal diagnosis with staging, fitness-for-work assessment, and recommendations for ongoing management.
When to Refer: Decision Points
Don't wait for the annual Tier 2 screening if a worker reports symptoms mid-year. (If you're not sure what the early signs look like, our guide to HAVS symptoms and vibration white finger covers what supervisors should watch for.) The referral triggers:
- Worker reports new or worsening tingling/numbness in fingers
- Worker reports white finger episodes (any frequency)
- Worker reports difficulty with fine motor tasks (buttons, coins, small objects)
- Worker reports reduced grip strength
- Supervisor observes a worker dropping tools or struggling with fine work
- Worker requests a health check due to concerns
Speed matters. Early HAVS is harder to detect clinically but easier to manage by reducing exposure. Late HAVS is obvious but the damage is permanent.
What to Record and For How Long
Records you should keep
Under Regulation 7, you must make and maintain a health record for each worker under health surveillance and keep it available in a suitable form. The Regulations do not set a retention period; HSE's health surveillance record-keeping guidance states that where the regulations do not specify how long records should be kept, "the health record should be kept at least while you employ the worker." In practice, because HAVS symptoms can develop or progress years after exposure ends, many employers and occupational health providers retain these records far longer — applying the 40-year benchmark that HSE sets under the COSHH Regulations.
For each worker under health surveillance, keep:
| Record | Typical retention |
|---|---|
| Tier 1 baseline questionnaire | At least while employed; commonly retained 40 years (COSHH benchmark) |
| All Tier 2 annual questionnaires | At least while employed; commonly retained 40 years |
| Tier 3/4/5 assessment reports (non-confidential summary) | At least while employed; commonly retained 40 years |
| Fitness-for-work recommendations | At least while employed; commonly retained 40 years |
| Referral letters and dates | At least while employed; commonly retained 40 years |
| Actions taken in response to findings | At least while employed; commonly retained 40 years |
Long retention is good practice because HAVS symptoms can develop or progress years after exposure ends. These records may be needed for:
- Ongoing medical management
- Workers' compensation claims
- HSE investigations
- Civil litigation
Confidentiality
The detailed clinical records (Tier 3-5) are confidential medical records held by the occupational health provider. You, as the employer, receive only:
- Whether the worker is fit for continued vibration exposure
- Any restrictions on exposure
- When the next review is due
You do not receive the clinical details, diagnosis staging, or medical history. Keep the fitness-for-work summary in your HAVS register alongside the exposure records.
If you close the business
HSE's health surveillance record-keeping guidance states that "it is good practice to offer workers a copy of their health record when they leave your employment or if you cease trading." If your business closes while you hold these records, the practical step is to offer each worker a copy of their own record before you wind down — they may need it for ongoing medical management or a future claim.
Making It Work for Small Firms
Health surveillance sounds bureaucratic. For a 6-person crew, it's actually straightforward:
- Tier 1: Give each worker the baseline questionnaire when they join. File it.
- Tier 2: Set a calendar date — same time every year. Run through the annual questionnaire with each exposed worker. 10 minutes per person.
- Tier 3+: If anyone flags symptoms, book an occupational health assessment. Your local OH provider can arrange this — costs typically £80-150 per assessment.
- Filing: Keep all questionnaires and summaries in your HAVS register. Digital is better than paper for 40-year retention.
The cost of annual Tier 2 screening for a small crew is negligible. The cost of an HSE enforcement notice for not having it is significant. The cost to a worker who develops preventable HAVS is permanent.
Health surveillance sits alongside — not in place of — your information and training obligations under Regulation 8. Workers must be told about their entitlement to health surveillance and how it works.
Sources
This guide is for general information only. It is not a substitute for professional health and safety advice.