As the person conducting a business or undertaking (PCBU), you must:
- use a health monitoring doctor, and
- arrange health monitoring appointments for your workers where there is a significant risk to their health because of exposure to a hazardous chemical, they are at risk of exposure to asbestos, or they are conducting lead risk work.
You can make one-off health monitoring appointments if a worker has concerns about potential exposure. For example if there was a leak or spill, or if your worker’s personal situation changes and their risk of harm from exposure has changed.
The Health monitoring for PCBU's: Checklist can be used with this guide.
As the PCBU, you must pay for your worker’s health monitoring including:
- health monitoring appointment fees
- testing and analysis costs
- time to attend appointments and testing procedures, and
- travel costs.
If you and other PCBUs are jointly responsible for monitoring a worker’s health and one of you has arranged the health monitoring, you must share the costs equally, unless you agree otherwise. For example, you may agree one of you will pay more of the costs.
Testing for exposure or health effects
If your workers use the chemicals listed in table 14.1 of Schedule 14 to the model WHS Regulations, the health monitoring doctor must use specific health monitoring tests for those chemicals. The chemicals and their tests have also been provided for you at Appendix A.
A health monitoring doctor can only use other tests if they can detect health effects or biological changes and are equal to or better than the tests in Schedule 14. It is important to closely consult with your worker and the health monitoring doctor if other tests are to be used. The health monitoring doctor must recommend the alternative method before it is used. More information about this can be found in the Guide for registered medical practitioners and in the individual Health monitoring guides for hazardous chemicals.
If there is a significant risk to workers from exposure to other hazardous chemicals that are not listed in table 14.1 of Schedule 14, you should discuss what tests can be used with your health monitoring doctor and consult with your workers before you arrange health monitoring. The health monitoring doctor should use health monitoring that measures exposure or detects harmful effects early on, so you can take action as soon as possible. The tests should be practical, accurate and safe, and should be appropriate for your worker and their circumstances. Some examples of other hazardous chemicals not listed in Schedule 14 and their tests are also provided for you at Appendix A.
Examples of health monitoring test methods
Biological exposure monitoring
Where exposure causes that chemical or a metabolite to appear in urine, blood or exhaled air
Test method: Assess exposure from routes like ingestion, inhalation or absorption through the skin, by analysing urine, blood or exhaled air for levels of the chemical or metabolite or breakdown products.
Biological effect monitoring
For a chemical that causes respiratory irritation or reduced respiratory function
Test method: A respiratory questionnaire or spirometry, or lung function test, or both to assess the effects of inhaling a chemical.
For a chemical that causes specific observable health effects including skin or eye irritation or a rash
Test method: Simple observation of your worker’s eyes and skin by a competent person, for example an occupational nurse, or the health monitoring doctor may train your worker to observe and report themselves.
Where a valid health monitoring test is not available or the link between work and illness is unclear, the health monitoring doctor may review your records of worker absences.
You should make sure health monitoring has minimal impact on your worker and make sure activities like medical appointments are during your worker’s normal work hours.
When you should monitor health
The timing of health monitoring should be organised depending on the chemical being used, handled, generated or stored and the way a chemical is being used. This may include monitoring worker’s health:
- before they start work
- this is known as baseline monitoring
- if they are excessively exposed
- for example, after spills or loss of containment
- where your worker has concerns about exposure
- for example, where they notice relevant symptoms, and
- when your worker finishes working with the hazardous chemical.
Health monitoring before starting work
Baseline monitoring is provided to workers before they start work with certain chemicals and varies for each chemical:
- sometimes it involves collecting workers’ demographic data, previous work history and medical history, or
- it may be a physical examination, checking of respiratory function or skin checks and testing of urine, saliva, mucus, hair or blood.
Health monitoring during work
The health monitoring doctor will include regular checks and tests in a worker’s routine health monitoring program.
How often your worker’s health is monitored will depend on the hazardous chemical they work with, how much they may be exposed and their work processes. It may also depend on:
- frequency of use
- for example, daily, weekly or seasonal use of certain chemicals
- previous health monitoring, air monitoring or surface wipe testing results, and
- if workers report symptoms of exposure or signs of injury, illness or disease linked with their use of hazardous chemicals.
If your workers report symptoms this may indicate that your control measures may not be working effectively and you should review these and take remedial action. Read the individual Health monitoring guides for hazardous chemicals for more information on the exposure symptoms your workers may report.
You may also organise one-off health monitoring checks if there is a spill, leak or loss of containment at work.
Health monitoring when work finishes
A final health monitoring appointment should be organised when your worker stops working with a hazardous chemical, for example when they finish employment or change their job role.
Health monitoring for inorganic lead
There are extra health monitoring requirements for workers involved in lead risk work, under the model WHS Regulations. These include:
- how often biological monitoring must be done
- when the amount of monitoring must increase
- when workers must be removed from lead risk work
- when a worker can return to lead risk work, and
- arranging a medical examination for your worker within seven days after they stop lead risk work.
If you have identified lead risk work, worker health must be monitored:
- before your worker first starts lead risk work, and
- one month after your worker first starts lead risk work.
If you identify work as lead risk work after a worker starts, their health must be monitored:
- as soon as you can after you have identified the lead risk, and
- one month after the first health monitoring.
Biological monitoring for lead involves monitoring blood lead levels. How often biological monitoring must be done is specified in the WHS Regulations (regulation 407) and is dependent on:
- blood lead levels detected at the last biological monitoring appointment
- if your worker’s potential exposure changes, or
- any requirements set by the regulator about the frequency of monitoring.
The types of health monitoring required for lead include demographic, medical and occupational history, physical examination and biological monitoring.
Blood lead levels at the last health monitoring appointment
You must arrange biological monitoring for each worker who does lead risk work at the following times:
- for females not of reproductive capacity and males:
- six months after the last biological monitoring of your worker if the last monitoring shows a blood lead level of less than 10 µg/dL (0.48 μmol/L)
- three months after the last biological monitoring of your worker if the last monitoring shows a blood lead level greater than or equal to 10 µg/dL (0.48 μmol/L) but less than 20 µg/dL (0.97 µmol/L), or
- six weeks after the last biological monitoring of your worker if the last monitoring shows a blood lead level of greater than or equal to 20 µg/dL (0.97 µmol/L)
- for females of reproductive capacity:
- three months after the last biological monitoring of your worker if the last monitoring shows a blood lead level of less than 5 µg/dL (0.24 µmol/L), or
- six weeks after the last biological monitoring of your worker if the last monitoring shows a blood lead level of greater than 5 µg/dL (0.24 µmol/L) but less than 10 µg/dL (0.48 μmol/L) (blood lead levels higher than this requires your worker to be removed from lead risk work).
If exposure changes
You must increase how often biological monitoring is done if your worker does work that may expose them to more lead, or expose them for longer periods or expose them more often.
How often the WHS regulator recommends monitoring
The WHS regulator may decide to change how often you must do biological monitoring after considering:
- what the work is and how long and how often workers are exposed to lead, and
- how likely it is that your workers’ blood lead levels will significantly increase.
If this happens, the WHS regulator must give you written notice within 14 days after making this determination. You must then arrange biological monitoring for workers as determined by the WHS regulator.
For more information, see Part 7.2 and Table 14.2 of Schedule 14 to the WHS Regulations or the section on inorganic lead in Health monitoring guides for hazardous chemicals or contact your local WHS regulator in your state or territory.
Health monitoring for asbestos
There are specific health monitoring requirements for workers who work with asbestos.
You must monitor the health of a worker if they are at risk of asbestos exposure and carrying out:
- licensed asbestos removal work, or
- other on-going asbestos removal work or asbestos-related work.
Asbestos health monitoring includes a baseline medical assessment that records:
- your worker’s demographic, medical and occupational history
- previous personal exposure, and
- a physical examination with emphasis on the respiratory system.
Please read Health monitoring guides for hazardous chemicals for more details about how often workers should be tested when they are exposed to specific chemicals.