Motor trade | Employer guide | Last updated: September 2026

Health Surveillance for Garages, MOT Centres and Body-shops: A Practical Guide for Employers (2026)

Reviewed by David Barber, Specialist Practitioner in Occupational Health. Last updated: September 2026. This guide explains what HSE is checking in the motor vehicle repair sector, which health surveillance garages and body-shops may need, and how isocyanate biological monitoring works.

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Did you know?

In September 2025, HSE launched 1,000 targeted inspections of motor vehicle repair businesses across Great Britain, focusing on workplaces using isocyanate-containing paints. During 2026, HSE has served Improvement Notices on vehicle body repair businesses for failing to place employees exposed to isocyanates under suitable health surveillance.

The key points

In short

HSE is inspecting the motor vehicle repair sector

A programme of 1,000 targeted inspections was launched in September 2025, focusing on businesses using isocyanate-containing paints.

The law has not changed

Inspectors are checking long-standing requirements under COSHH and the noise and vibration regulations.

Health surveillance depends on your risk assessment

Not every garage needs every test. It is required where employees are exposed to hazards at levels that put their health at risk.

Body-shops need particular care

Paint sprayers exposed to isocyanates need respiratory health surveillance and skin checks, and HSE recommends an annual urine test (biological monitoring).

Records matter

COSHH health surveillance records must be kept for at least 40 years.

What is HSE inspecting in the motor vehicle repair sector?

In September 2025, HSE launched 1,000 targeted inspections of motor vehicle repair businesses across Great Britain. The campaign focuses on workplaces using isocyanate-containing paints and coatings, which HSE identifies as the leading cause of occupational asthma in the UK. Many skilled paint sprayers develop the condition each year and have to leave the trade permanently.

Inspectors are assessing compliance with COSHH. They want to see that exposure to isocyanates is being prevented or adequately controlled, that controls such as spray booths and air-fed breathing apparatus are working, and that this is being checked through health surveillance and biological monitoring.

Enforcement is already taking place. During 2026, HSE has served Improvement Notices on vehicle body repair businesses for failing to place employees exposed to isocyanates under suitable health surveillance.

Has the law changed for garages and body-shops?

No. There is no new legislation. The duties HSE is checking have applied for many years under:

  • ✓the Control of Substances Hazardous to Health Regulations 2002 (COSHH), including regulation 11 on health surveillance
  • ✓the Control of Noise at Work Regulations 2005
  • ✓the Control of Vibration at Work Regulations 2005
  • ✓the Management of Health and Safety at Work Regulations 1999

What has changed is the level of scrutiny. A business that has not reviewed its health surveillance for some time may find gaps that were always there but are now far more likely to be noticed.

What is health surveillance?

Health surveillance is a programme of regular health checks for employees exposed to specific workplace hazards. Its purpose is to detect early signs of work-related ill health, such as hearing loss, HAVS, dermatitis or occupational asthma, so action can be taken before the condition becomes serious or permanent.

It also tells you whether your controls are working. If a worker's hearing, lung function or skin starts to change, that is a signal to look again at how exposure is being managed. Health surveillance supports your controls. It never replaces them.

Does every garage legally need health surveillance?

No. Health surveillance is required where your risk assessment shows that employees are exposed to a hazard at a level that creates a risk to their health, and where there is a valid way of detecting the effect. In practice, many garages will need some surveillance, but the type and scope depend on the work being done.

A small MOT centre with occasional air tool use has very different needs from an accident repair centre spraying 2K paints every day. The right starting point is always an accurate risk assessment.

Health surveillance for the motor trade

Which garage hazards can require health surveillance?

Garage and bodyshop health risks, and the surveillance that may apply.

A guide, not a checklist. What your business needs depends on your risk assessment and the exposures your employees actually have.

Noise

Impact wrenches, compressors, grinders, panel beating

May need

Audiometry (hearing checks)

Hand-arm vibration

Impact guns, sanders, grinders, air chisels

May need

Tiered HAVS surveillance

Isocyanates

2K paints, clearcoats and hardeners in bodyshops

May need

Respiratory surveillance, skin checks and annual urine testing

Dusts and fumes

Sanding, welding and cutting, brake work, exhaust

May need

Spirometry (lung function) where indicated

Skin irritants

Used engine oil, fuels, solvents, degreasers

May need

Skin surveillance

Driving and safety-critical

Road tests, vehicle movement, recovery, HGV work

May need

Vision tests, driver and safety-critical medicals

Isocyanates: what body-shops and paint sprayers need to know

Why are isocyanates such a concern?

Isocyanates are respiratory sensitisers. Breathing in isocyanate paint mist can cause occupational asthma, and skin contact can cause dermatitis and may contribute to sensitisation. Once someone is sensitised, even tiny exposures can trigger a severe asthma attack, which usually means they can no longer work with these products.

Where does exposure happen?

  • ✓Spraying 2K paints and lacquers, especially outside a properly working booth or without suitable air-fed breathing apparatus
  • ✓Mixing paints and hardeners and cleaning spray guns
  • ✓Entering a booth or spray room before the clearance time has passed
  • ✓Removing breathing apparatus straight after spraying to check the finish
  • ✓Sanding freshly cured coatings

What health surveillance do sprayers need?

HSE expects workers exposed to isocyanates to receive a baseline assessment before they start, followed by a health questionnaire and lung function test (spirometry) carried out by a competent person at least once a year. Regular skin checks should look for signs of dermatitis. HSE's guidance on surveillance for occupational asthma also advises closer checks in the early period of exposure, when sensitisation is more likely to develop.

What is isocyanate biological monitoring?

Biological monitoring for isocyanates is a urine test that measures breakdown products of isocyanate in the body. HSE describes it as the most practical and cost-effective way to measure a paint sprayer's exposure. It shows whether isocyanate is getting past your controls, whether through the lungs or the skin.

  • ✓Frequency: HSE recommends testing typically once a year for vehicle spray painters, and more frequently where half-mask respirators are used in spray rooms.
  • ✓Timing: samples need to be given shortly after a spraying session, ideally within about an hour.
  • ✓Interpreting results: HSE sets a biological monitoring guidance value of 1 µmol urinary diamine per mol creatinine. Results at or below this level are associated with adequate control. Any evidence of exposure should prompt a check of controls and training.
  • ✓Consent: employees must give informed consent before samples are taken.

Biological monitoring does not tell you anything about a person's health. It tells you about exposure. That is why HSE expects health surveillance and biological monitoring to work alongside each other.

Hearing checks (audiometry) in garages

Audiometry is required where employees are regularly exposed above the upper exposure action values (a daily or weekly exposure of 85 dB(A), or a peak of 137 dB(C)), or where they are otherwise at risk, for example because they already have hearing damage. It normally involves a baseline test followed by regular checks, typically annually for the first two years and then every three years, unless results suggest more frequent testing is needed.

HAVS surveillance for workshop tool users

HAVS surveillance is required where employees are likely to be regularly exposed above the exposure action value of 2.5 m/s² A(8), or are considered at risk for another reason. HSE recommends a tiered approach: an initial questionnaire, then an annual questionnaire, with referral to a qualified occupational health professional and, if needed, a doctor where symptoms are reported. Early detection means work can be adjusted before the condition progresses.

Skin surveillance

Mechanics are frequently in contact with used engine oil, fuels, solvents and degreasers, as well as wet work and repeated hand washing. Where there is a reasonable likelihood of dermatitis, skin surveillance should be in place. This usually combines regular self-checks by trained employees with periodic checks by a responsible or qualified person.

Face-fit testing for respiratory protective equipment

Where employees rely on tight-fitting respiratory protective equipment (RPE), such as disposable masks, half masks or full-face masks, each wearer should have a face-fit test to confirm the mask seals properly. This includes some sanding and mixing tasks in body-shops. Loose-fitting air-fed hoods do not need a face-fit test, but must still be suitable, maintained and worn correctly.

Driver medicals, vision testing and drug and alcohol testing

Technicians who road test vehicles, move customer cars or work on HGVs may carry out safety-critical tasks. Vision testing, driver medicals (including HGV medicals for those who need a vocational licence) and drug and alcohol testing help employers manage these risks. Drug and alcohol testing is not usually a legal requirement for garages, but many businesses include it in a clear, fairly applied policy.

What will an HSE inspector ask to see?

Every inspection is different, but garages should be ready to show:

  • 1An up-to-date risk assessment and COSHH assessments identifying which employees are exposed to which hazards
  • 2The controls in place, such as spray booth and LEV examination records, air-fed breathing apparatus maintenance and tool vibration data
  • 3Health surveillance records for exposed employees, with evidence that results have been acted on
  • 4Biological monitoring results for paint sprayers exposed to isocyanates
  • 5Face-fit test records for tight-fitting RPE wearers
  • 6Evidence of information, instruction and training, including awareness of early symptoms

How to choose a competent occupational health provider

Health surveillance only protects your workforce, and your business, if it is done properly. In July 2026, HSE took enforcement action for the first time against an occupational health service provider, after finding that health surveillance was being delivered by personnel who were inadequately trained and unsupervised.

When choosing a provider, check that:

  • ✓assessments are carried out or overseen by qualified occupational health professionals
  • ✓technicians are properly trained and clinically supervised
  • ✓the provider holds recognised accreditation, such as SEQOHS
  • ✓you receive clear results, recommendations and recall dates, not just test figures
  • ✓records are stored securely and can be produced when needed

How David Barber (OH) Ltd can help

David Barber (OH) Ltd is a SEQOHS-accredited occupational health provider based in Shardlow, Derby. We work with garages, MOT centres, dealerships, body-shops and commercial vehicle workshops across Derby and Derbyshire to:

  • ✓help you understand what health surveillance is appropriate for your workforce
  • ✓review your risk and COSHH assessments for surveillance gaps
  • ✓deliver audiometry, spirometry, skin checks, HAVS surveillance, isocyanate biological monitoring, vision testing, driver medicals, wellbeing checks, drug and alcohol testing and face-fit testing
  • ✓carry out testing on site, so your technicians stay in the workshop
  • ✓keep records and recall dates organised and ready for inspection
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Find out more about occupational health for garages and body-shops in Derby.

Support

Frequently asked questions

Has the law on health surveillance for garages changed?

No. HSE's inspection programme checks existing requirements under COSHH 2002, the Control of Noise at Work Regulations 2005 and the Control of Vibration at Work Regulations 2005. What has changed is the level of attention HSE is giving the motor vehicle repair sector.

What health surveillance do vehicle paint sprayers need?

Paint sprayers exposed to isocyanates need respiratory health surveillance, normally a health questionnaire and lung function test at least annually by a competent person, plus regular skin checks. HSE also recommends biological monitoring (a urine test) at least once a year.

How often should isocyanate urine testing be done?

HSE recommends biological monitoring for vehicle spray painters typically once a year, and more frequently where half-mask respirators are used in spray rooms. Samples should be given shortly after a spraying session, ideally within about an hour.

When do garage workers need hearing tests?

Hearing checks (audiometry) are required where the risk assessment shows employees are regularly exposed above the upper exposure action values of 85 dB(A) daily or 137 dB(C) peak, or are otherwise at risk, for example because of existing hearing damage.

Does RPE need face-fit testing?

Tight-fitting respiratory protective equipment, such as half masks and full-face masks, should be face-fit tested for each wearer. Loose-fitting air-fed hoods and visors, commonly used for spraying, do not need a face-fit test but must still be suitable and maintained.

How long do health surveillance records need to be kept?

Health records for employees under health surveillance for hazardous substances under COSHH must be kept for at least 40 years from the date of the last entry. Keeping clear, accessible records is also the easiest way to show an inspector what is in place.

Is health surveillance a legal requirement for mechanics?

It can be. Health surveillance is legally required where a risk assessment shows mechanics are exposed to hazards such as noise, hand-arm vibration or hazardous substances at levels that create a risk to health. It is not automatically required for every mechanic in every garage.

What is the difference between health surveillance and biological monitoring?

Health surveillance looks for early signs of ill health, such as changes in lung function or skin condition. Biological monitoring measures whether a substance, such as isocyanate, is getting into the body, which shows whether exposure controls are working before health is affected.

Do water-based paints contain isocyanates?

Often, yes. HSE points out that water-based does not mean isocyanate-free. Many water-based basecoats are paired with clearcoats and hardeners that contain isocyanates, so check section 3 of each product's safety data sheet.

When is HAVS surveillance needed in a garage?

HAVS surveillance is required where employees are likely to be regularly exposed above the daily exposure action value of 2.5 m/s² A(8), or are considered at risk for another reason. HSE uses a tiered approach, starting with questionnaires and escalating to clinical assessment where needed.

Can health surveillance be carried out at our garage?

Yes. Most health surveillance for garages, including audiometry, spirometry, skin checks, HAVS assessment and urine sample collection, can be carried out on site. David Barber (OH) Ltd provides on-site testing across Derby and Derbyshire.

How do I choose a competent occupational health provider?

Look for a provider using qualified occupational health professionals, with properly trained and supervised technicians, and independent quality accreditation such as SEQOHS. In 2026 HSE took enforcement action against an occupational health provider for inadequate health surveillance, so competence genuinely matters.

What our clients say

“
Quick turnaround, excellent communication and a brilliant team that work really well together to deliver a prompt and professional service. Would highly recommend to anyone and small businesses in particular, as they are competitively priced whilst maintaining a quality professional standard.
AA Labels
Client
“
DB Occupational Health has been a valuable partner to I Holland for several years now, supporting us with our employee occupational health surveillance programme, along with HAVS surveillance and the administration of annual flu vaccinations. Lisa and the team are always prompt and professional when on-site and are fast to respond to any queries at all times. I would recommend DB Occupational Health to any business considering their services.
I Holland
Dan Dixon, HSE & CI Manager
“
David Barber (OH) Ltd responded to an urgent job. Health surveillance was carried out with reports uploaded in real time, with an easy to read spreadsheet also sent. Thanks for your prompt work. Timescales were good and good service.
McPhee Mixers
Client

Not sure what health surveillance your garage needs?

Book a free, no-obligation 30-minute review. We will talk through the work your team does, look at your risk and COSHH assessments, and help you put a proportionate programme in place, on site, across Derby and Derbyshire. Prefer to talk? Call 01332 318978.

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