The annual health check is one of the most universal features of Japanese working life. The Industrial Safety and Health Act requires an examination when a regular employee is hired and then once a year. The items are set by ordinance: medical history, height, weight and waist, eyesight and hearing, chest X-ray, blood pressure, blood tests for anaemia, liver function, lipids and blood sugar, a urine test and an ECG, with some items that can be skipped for younger employees on a doctor's judgement. Workers on regular night shifts and certain other hazardous duties must be examined every six months.
The employer pays and the employee must attend, although they may use their own doctor and submit the results. The employer must keep the records for five years, and workplaces with 50 or more workers report the results of the annual check to the Labour Standards Inspection Office. The obligation does not end with the test. Where results are abnormal, the employer must get a doctor's opinion and take measures if needed, such as changing duties or cutting overtime. Separately, an employee whose overtime exceeds 80 hours in a month and who shows signs of fatigue can ask for an interview with a doctor.
Part-time and fixed-term staff are covered if they are expected to work for a year or more, including through renewals, and their weekly hours are at least three quarters of a full-timer's in the same kind of work.
What it means for a foreign employer
- It is a cost line, not a perk. Budget for it per head, and for the follow-up. Many companies use the health insurance society's programmes to cover part of it.
- Abnormal results create a duty. Ignoring a doctor's recommendation and keeping someone on heavy overtime is the pattern behind many overwork claims.
- Keep medical data out of the global HR system. Results are sensitive personal information. Restrict access to those who need it, usually the occupational physician and a named local HR contact.
- Pre-employment checks have limits. The check on hiring is for placement and later health care, not for choosing between candidates. Ministry guidance says employers should not test applicants for HIV, or for hepatitis unless the job genuinely requires it, and screening on health items unrelated to the job invites a discrimination complaint.
Sources
- Industrial Safety and Health Act, Articles 66, 66-4, 66-5 and 66-8.
- Ordinance on Industrial Safety and Health, Articles 43, 44, 45, 51 and 52-2 (the 80-hour threshold for the doctor interview).
- Ministry of Health, Labour and Welfare, circular of 1 October 2007 (Kihatsu No. 1001016) on health checks for part-time workers.
- Ministry of Labour, Guidelines on HIV and AIDS in the Workplace (20 February 1995).
- Ministry of Health, Labour and Welfare, points to note on hepatitis virus infection in the workplace.