An occupational health record (OHR) is the confidential file kept on a worker’s health in relation to their work: the jobs they have held, the hazards they were exposed to, the results of health assessments and surveillance, and the conclusions on their fitness for work. The International Labour Organization’s Occupational Health Services Recommendation, 1985 (No. 171) recommends that occupational health services record workers’ health data in “personal confidential health files”, which should also contain information on jobs held, exposure to occupational hazards and the results of any assessments of that exposure (paragraph 14(1)).

“Occupational health record” is a general term, not a legal definition. Related terms include employee health record and, in US federal rules, employee medical record. Each country’s law gives the file its own name and rules, and some, such as Great Britain, keep the employer’s health record separate from the confidential medical record.

What an occupational health record contains

Recommendation No. 171 lists the health assessments that surveillance of workers’ health may include, in the cases and under the conditions set by the competent authority (paragraph 11(1)):

  • An assessment before assignment to tasks that may involve a danger to the worker’s health or that of others
  • Periodic assessments during employment involving exposure to a particular hazard
  • An assessment on return to work after a prolonged absence for health reasons
  • Assessments on and after the end of assignments involving hazards that might cause or contribute to future health impairment

Where workers are exposed to specific hazards, surveillance should also include, where appropriate, examinations and investigations to detect exposure levels and early biological effects and responses (paragraph 12(1)). After a prescribed examination for work involving a particular hazard, the physician should give the conclusions in writing to both the worker and the employer, and those conclusions should contain no information of a medical nature: they might indicate fitness for the proposed assignment or specify the jobs and working conditions that are medically contraindicated, temporarily or permanently (paragraph 16).

Names and rules by country

  • United States. The federal OSHA standard on access to records uses the term employee medical record (29 CFR 1910.1020(c)(6)). Covered employers, those who make, maintain or have access to records on employees exposed to toxic substances or harmful physical agents, keep it for at least the duration of employment plus 30 years, unless a specific OSHA standard sets another period (§1910.1020(d)(1)). Narrow exceptions apply, such as first-aid records of one-time treatment and the records of workers employed for less than a year who are given their records when they leave.
  • Great Britain. The Health and Safety Executive (HSE) separates two records. The health record is “a legal record of the outcome of health surveillance”: it holds the worker’s details, where they work, the hazards they have been exposed to and their fitness to continue to be exposed, and it should not contain confidential medical information without the worker’s written consent. Under COSHH it is kept for at least 40 years from the date of the last entry (see COSHH health record). Medical records, which may include clinical notes and test results, are kept in medical confidence by the occupational health professional, and the employer can see them only with the worker’s written consent.
  • France. The Labor Code calls it the dossier médical en santé au travail (article L4624-8). The occupational physician or, where applicable, another health professional involved in the worker’s follow-up, such as a corresponding practitioner or a nurse working under the physician’s authority, compiles it under medical secrecy, with the worker’s health status, exposures and the physician’s opinions and proposals. The worker can request it, exposure information is confidential and cannot be passed to an employer the worker applies to, and when a worker is followed by several occupational health services or leaves one, the record is available to the service responsible for continuing the follow-up, unless the worker refuses.

Confidentiality and access

Recommendation No. 171 is not binding, but it sets out international principles for these files:

  • Need to know. Occupational health staff should access personal health files only to the extent relevant to their duties, and information covered by medical confidentiality should be restricted to medical personnel (paragraph 14(2)).
  • Consent. Personal data from health assessments may be communicated to others only with the worker’s informed consent (paragraph 14(3)).
  • National rules. How long files are kept, when they may be communicated or transferred, and how they are kept confidential, “in particular when the information they contain is placed on computer”, should be set by national law, the competent authority or recognized ethical guidelines (paragraph 15).
  • Correction. Each worker should have the right to have erroneous or misleading data corrected (paragraph 22(2)).

In practice an occupational health record therefore has two layers: the clinical detail, seen by health professionals, and the fitness outcome and work restrictions, which the employer may receive. Keeping that separation in the filing system is covered in employee health records vs personnel files, and retention by country in how long to keep occupational health records.

Electronic occupational health records

The American College of Occupational and Environmental Medicine (ACOEM) published guidance in 2024 stating that occupational and environmental medicine clinicians need specialized electronic health records “to address the privacy, data governance, interoperability, and medical surveillance concerns that are specific to occupational health”, and set out 10 recommendations for these systems. How general EMR and EHR systems compare for this work is covered in EMR vs EHR in occupational health.

MyC is one employee health record for occupational health: one record per worker across sites, with access by role for medical, HSE and HR teams.

  • Employee medical record: Employee medical record, under OSHA 29 CFR 1910.1020, means a record of an employee's health status made or kept by a physician, nurse or health care staff.
  • COSHH health record: A COSHH health record is the record COSHH requires in Great Britain for each worker under health surveillance, kept at least 40 years from the last entry.
  • Health surveillance: Health surveillance is a program of repeated health assessments for workers still exposed to a hazard after controls, to identify ill health caused by work.
  • Fitness-to-work: Fitness-to-work is an assessment of whether a worker's health lets them do a specific job safely, without danger to their own health or that of others.

Go further

Sources

  1. Occupational Health Services Recommendation, 1985 (No. 171), paragraphs 11 to 16 and 22 (ILO NORMLEX)
  2. 29 CFR 1910.1020: Access to employee exposure and medical records (OSHA)
  3. Health surveillance: record keeping (HSE)
  4. Code du travail, article L4624-8: dossier médical en santé au travail (Légifrance)
  5. Occupational Electronic Health Records: Recommendations for the Design and Implementation of Information Systems in Occupational and Environmental Medicine Practice (ACOEM, 2024)

Written by Lisa Bardet, VP Marketing at MyC. Every factual claim in this entry is checked against the primary sources listed above before publication.

This entry is general information for employers and occupational health teams. It is not legal or medical advice for a specific situation.