Statutory Inspections · Mandatory · Construction
Skin Health Surveillance Record
A tiered health surveillance record for workers exposed to skin sensitisers or wet work. Covers cement/mortar wet work, epoxy resins, isocyanates, solvents, and rubber accelerators in gloves. Tier 1/2 can be conducted by a trained responsible person on site. Checks dryness, redness, itching, cracking, and whether symptoms worsen on workdays. OCD is reportable under RIDDOR.
Last reviewed: 2 April 2026 — This guide reflects UK law as of this date. COSHH 2002 Reg 11 remains current with no amendments enacted as of 2 April 2026. Next scheduled review: 2 April 2027.
| Document type | T8 — Skin Health Surveillance Record |
| Primary legislation | COSHH Regulations 2002, Regulation 11 (Health Surveillance) |
| Why it matters | Occupational contact dermatitis (OCD) is one of the most common occupational diseases in the UK construction industry |
| Tiered model | Tier 1 / Tier 2: trained responsible person (practical, low-cost). Tier 3: occupational health nurse. Tier 4: consultant dermatologist |
| Frequency | Baseline before first exposure, then periodic checks — typically every 1–3 months for regular exposure |
| RIDDOR reporting | Occupational dermatitis is reportable under RIDDOR Schedule 1 — must be reported within 15 days of diagnosis |
1. Why Skin Health Surveillance Matters
Occupational contact dermatitis (OCD) is one of the most common occupational diseases in the UK, and the construction industry is one of the sectors most affected. Workers are exposed to a wide range of skin hazards on a daily basis: wet cement (highly alkaline, causing cement burns and chrome sensitisation), epoxy resins (potent skin sensitisers), isocyanates (skin and respiratory sensitisers), solvents (degrease and damage the skin barrier), cutting oils, adhesives, cleaning chemicals, and prolonged wet work. Without systematic surveillance, early signs of skin disease go undetected until the condition has progressed to a stage that is painful, disabling, and in many cases irreversible.
COSHH Regulation 11 requires health surveillance for workers who are exposed to substances that cause identifiable skin diseases. This is not a discretionary measure — it is a legal requirement wherever the COSHH assessment identifies a risk of skin disease. The purpose of surveillance is early detection: identifying the first signs of dermatitis so that the worker can be treated, controls can be reviewed and improved, and the condition can be prevented from progressing to chronic, irreversible disease.
The UK skin health surveillance model uses a tiered approach designed to be practical and proportionate. Tier 1 and Tier 2 checks can be carried out by a trained responsible person — a site supervisor, health and safety advisor, or appointed colleague who has received specific training in conducting skin checks. This person does not need to be a nurse or doctor. The purpose of Tier 1/2 is to identify early signs (redness, dryness, cracking, itching) and to trigger referral to occupational health (Tier 3) or a dermatologist (Tier 4) when warranted. This tiered model makes skin surveillance accessible and affordable for construction projects of all sizes.
Skin surveillance doesn't require a nurse — a trained responsible person can do Tier 1/2
One of the most common barriers to implementing skin health surveillance on construction sites is the mistaken belief that every check requires a nurse or doctor. This is not the case. Tier 1 (a self-assessment questionnaire) and Tier 2 (a visual skin inspection by a trained person) can be carried out by any competent person who has received appropriate training. The HSE's guidance on skin surveillance (MS24) is clear on this point. Tier 1/2 checks are quick, practical, and can be integrated into routine site processes such as toolbox talks, inductions, or welfare facility visits. Only when Tier 1/2 checks identify a potential problem is referral to Tier 3 (occupational health nurse) required.
2. Key Content of the Skin Health Surveillance Record
The skin health surveillance record must capture both the worker's baseline skin condition and the results of periodic checks. The following table sets out the key content areas and the information that must be recorded.
| Section | Content required |
|---|---|
| Worker details | Full name, date of birth, employer, job title/trade, site/project assignment. Unique employee or personnel reference number for record continuity. |
| Skin hazards in role | Specific substances the worker is exposed to that are identified as skin hazards in the COSHH assessment: cement, epoxy resins, isocyanates, solvents, cutting oils, adhesives, cleaning agents, wet work. Frequency and duration of exposure. |
| Pre-placement assessment | Baseline skin condition recorded before first exposure to skin hazards. Any pre-existing skin conditions (eczema, psoriasis, dermatitis) noted. History of allergies or previous occupational skin disease. This baseline is essential for identifying work-related changes. |
| Periodic skin checks — Date | Date each skin check was conducted. Checks should be scheduled at regular intervals — typically every 1–3 months for workers with regular skin hazard exposure. |
| Periodic skin checks — Tier | Which tier of surveillance was conducted: Tier 1 (self-assessment questionnaire), Tier 2 (visual inspection by trained responsible person), Tier 3 (assessment by OH nurse), Tier 4 (assessment by dermatologist). |
| Periodic skin checks — Areas inspected | Specific body areas inspected: hands (dorsal and palmar), wrists, forearms, face, neck, and any other areas identified as at risk from the specific exposure. Both hands must be checked — dominant hand often worse. |
| Periodic skin checks — Symptoms reported | Worker-reported symptoms: itching, stinging, burning, dryness, cracking, soreness. Onset pattern: when symptoms started, whether they improve on days off or holidays. |
| Periodic skin checks — Observed findings | Visual observations by the assessor: redness, dryness, scaling, cracking, fissuring, vesicles (blisters), weeping, thickening of skin. Location and extent of any findings. |
| Periodic skin checks — Skin worse on workdays? | Critical diagnostic question. If dermatitis is worse on workdays and improves at weekends, holidays, or during sickness absence, this strongly indicates an occupational cause. This single question is one of the most important in the entire surveillance record. |
| Periodic skin checks — Outcome | Fit to continue in current role. Fit with additional controls specified. Refer to Tier 3 (OH nurse) or Tier 4 (dermatologist). Temporarily redeploy to non-exposure role pending further assessment. |
| Periodic skin checks — Gloves being used correctly? | Observation of whether the worker is using the correct type, thickness, and size of gloves as specified in the COSHH assessment. Are gloves being changed regularly? Are they intact? Is the worker using solvents to clean skin? |
| Periodic skin checks — Assessor | Name and role of the person conducting the check. For Tier 1/2: trained responsible person. For Tier 3: OH nurse name and registration. For Tier 4: dermatologist name. |
| RIDDOR required? | If occupational dermatitis is diagnosed (confirmed by a medical practitioner as caused by work), it must be reported under RIDDOR Schedule 1 within 15 days. Record whether a RIDDOR report has been submitted and the date. |
The 'worse on workdays' question is critical
Asking whether the worker's skin condition is worse on workdays and improves during weekends, holidays, or sickness absence is the single most important diagnostic indicator in occupational dermatitis. A clear pattern of work-related worsening strongly suggests an occupational cause and should trigger immediate referral to occupational health for further assessment. Do not wait for the next scheduled check — act on this finding immediately.
3. Common Mistakes
Only conducting skin checks when a worker complains
Reactive surveillance — waiting for a worker to report a skin problem before conducting any check — defeats the entire purpose of health surveillance. The point of a structured surveillance programme is to detect early, subclinical signs of dermatitis before the worker is aware of them or before they feel the condition is severe enough to report. Many workers tolerate dry, cracked, sore skin as a normal part of construction work and do not report symptoms until the condition has progressed significantly. By the time a worker complains, the dermatitis may already be established and difficult to reverse. Proactive, scheduled checks at regular intervals are essential.
Not checking whether dermatitis is worse on workdays
Failing to ask whether the skin condition improves on days off, weekends, or holidays misses the most important diagnostic indicator for occupational dermatitis. If dermatitis is consistently worse on workdays and improves during time away from work, this pattern strongly indicates that workplace exposures are causing or aggravating the condition. Without asking this question, occupational dermatitis may be misattributed to non-work causes (domestic detergents, pre-existing eczema), and the worker continues to be exposed to the causative agent without any change in controls. This question must be asked at every periodic check and the answer recorded.
5. Frequently Asked Questions
Is occupational contact dermatitis reportable under RIDDOR?▾
Yes. Occupational dermatitis is listed in RIDDOR Schedule 1 as a reportable occupational disease. When a medical practitioner diagnoses a case of dermatitis that is caused by occupational exposure to a known skin sensitiser or irritant, the employer must report it to the HSE within 15 days using the RIDDOR online reporting system. This applies to both irritant contact dermatitis and allergic contact dermatitis where the cause is workplace exposure. The RIDDOR report is in addition to — not a substitute for — the internal investigation, control review, and any changes to the COSHH assessment that must follow a confirmed case.
Who can carry out Tier 1 and Tier 2 skin checks?▾
A trained responsible person. This does not need to be a nurse, doctor, or occupational health professional. It can be a site supervisor, health and safety advisor, welfare officer, or any other competent person who has received specific training in conducting skin checks for occupational dermatitis. The training should cover: what to look for (redness, dryness, cracking, scaling, vesicles), the key questions to ask (symptoms, onset pattern, work-relatedness), when to refer to Tier 3 (OH nurse), and how to complete the surveillance record. Several accredited training providers offer half-day or one-day courses in skin surveillance for non-clinical staff.
How long must skin surveillance records be kept?▾
COSHH Regulation 11 requires that health surveillance records be kept for at least 40 years from the date of the last entry. This reflects the long latency period of some occupational skin conditions and the need to demonstrate a history of surveillance if a former worker later develops disease. Records must be kept securely and made available to the worker, their GP (with consent), the HSE, and any appointed employment medical advisor on request.
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