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Indicator 3.4.5
by Contact on 8 October 2026
Requirement
The UoC shall only require medical tests during employment if justified by a healthy and safety or food safety risk assessment.
How Do I Interpret This Requirement?
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There are occasional situations where the UoC, or the agency involved in recruitment may need to perform medical tests. For example:
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it is required by law
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if the function of the job requires it
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for health and safety reasons.
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Determining whether a medical test is necessary happens through a health and safety risk assessment (Indicator 3.5.4).
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Examples of when medical tests may or may not be allowed are:
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An example of when the function of a job might require a medical test is the recruitment of divers, a diver may have to undergo a chest x-ray to demonstrate that they are fit enough to dive regularly.
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An example of when a medical test might be necessary is if an employee is asked to test for Covid-19 before coming into the workplace, to avoid the spread of the disease.
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An example of when a medical test is not allowed is an STI test, which could lead to discrimination about someone’s sexual practices and / or ability to work.
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An example of when a test may be required by national law is the existence of laws in 25 countries that have a law that makes HIV testing mandatory to obtain a work or residence permit: <https://lawsandpolicies.unaids.org/topicresult?i=25&lan=en>. Outside of these 25 countries, an HIV test is not necessary and would not be conducted as it is not relevant for the function of any jobs in aquaculture.
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Evidence of Implementation
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terms of service between recruitment agencies and the UoC
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documents from recruitment processes
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health and safety and food safety risk assessments that require medical testing
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information about which medical tests are required.
Auditors Should Confirm
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where medical tests are required, the decision for these tests has been based on the outcome of a risk assessment;
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employees understand the reasons for the medical tests.
