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When to monitor the health of your workers

Your duty to provide health monitoring

You should carefully consider the hazardous chemicals your workers will or could be exposed to and how much they will be exposed. For lead and asbestos you should consider how they could be exposed. This will assist you to work out if you must monitor their health.

You must monitor the health of your workers for four types of chemicals:

  • hazardous chemicals listed in table 14.1 of Schedule 14
  • other hazardous chemicals (not listed in Schedule 14)
  • lead, and
  • asbestos.

You must monitor the health of a worker if they:

Hazardous chemicals listed in table 14.1 of Schedule 14

are using, handling, generating or storing hazardous chemicals and are at significant health risk from exposure to the hazardous chemicals listed in table 14.1 of Schedule 14 to the model WHS Regulations

  • the type of health monitoring you must do for each chemical is also outlined in table 14.1 and provided at Appendix A.

Other hazardous chemicals (not listed in Schedule 14)

are using, handling, generating or storing hazardous chemicals, and are at significant health risk from exposure to these hazardous chemicals, which are not listed in Schedule 14 and for which either:

  • valid techniques or tests are available to detect an effect on your worker’s health, or
  • valid way is available to determine biological exposure and you are not sure whether the exposure to your workers is more than the biological exposure standard

Examples of chemicals and the type of health monitoring are provided at Appendix A.

Lead

start or do lead risk work

  • you must follow the model WHS Regulations for the frequency and nature of health monitoring for lead risk work. For example you must begin health monitoring before your worker first starts lead risk work, or as soon as possible after the lead risk work is identified, and one month after your worker first starts lead risk work.
  • the type of health monitoring you must do for lead is outlined in table 14.2 and provided at Appendix A.

Asbestos

are at risk of asbestos exposure when carrying out licensed asbestos removal at a workplace, or doing other ongoing asbestos work. 

  • you must start monitoring a worker’s health before your worker carries out licensed asbestos removal work.

What ‘significant risk’ means

This part does not apply to you if your workers work with asbestos or perform lead risk work. If your workers are at any risk of exposure to asbestos or perform lead risk work, you must provide health monitoring regardless of the level of risk.

For hazardous chemicals, you must provide health monitoring to your workers if there is a significant risk to your worker’s health because of exposure to a table 14.1 hazardous chemical, or significant risk of exposure to another hazardous chemical and there are suitable testing methods available.

As the PCBU, it is your responsibility to determine if there is a ‘significant risk’ of either of these things, to inform whether you need to monitor the health of your workers. 

The level of risk depends on the hazards of the chemicals (what type of harm they might cause) and the frequency, duration and amount of exposure (also known as dose or how much your worker might be exposed).

You should consider a health monitoring program for all ongoing use, handling, generating or storage of hazardous chemicals by your workers. You should also consider a health monitoring program for the chemicals that are created as by-products or in work waste and have severe known health effects. This includes chemicals:

  • known, or thought to be, carcinogenic, mutagenic or toxic to human reproduction
  • that are respiratory or skin sensitisers, or
  • with other known severe toxic effects.

You should also consider health monitoring for hazardous chemicals where you regularly use administrative controls or personal protective equipment (PPE) to control risks.

If you are not sure if a hazardous chemical is a significant risk to your worker’s health or if your workers are at a significant risk of exposure, you can seek specialist advice from an occupational hygienist, health monitoring doctor, occupational physician or a WHS regulator. For hazardous chemicals not listed in Schedule 14, you should also consult your health monitoring doctor to see if suitable testing methods for the chemical are readily available.

What to consider when you conduct a risk assessment

Conducting a risk assessment involves collecting information about:

  • the hazardous chemicals that are used, handled, stored or generated at your workplace
  • what measures you use to control the risk of these hazardous chemicals
  • where and how much workers can be exposed, and
  • how often workers can be exposed.

You should consider:

  • what, and how high, are the risks of each chemical:
    • how the chemical is classified in the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)?
      • Is it an irritant, a sensitiser, a carcinogen, or an acute toxicant?
    • what form of the chemical is used or generated at the workplace?
      • Is it solid, granulated, dust, mist, or fume?
    • how the chemical enters the body to affect worker health? Is it by inhalation, ingestion, skin contact or absorption?
  • how much your workers are exposed, thinking about:
    • where in the workplace the chemicals are used, handled, stored or generated?
    • who could be exposed?
    • how strong is the chemical when workers are exposed or what is the strength of the chemical that workers come in contact with?
    • what are the quantities and concentrations (pure or dilute) of chemicals being used, handled, stored or generated?
    • what are the standard work practices and procedures?
    • what are the ways individual workers carry out their daily tasks?
    • whether the way you currently control exposure is effective?

You are looking for information about how the chemical affects human health and how the chemical may be absorbed into the body. You should read the safety data sheet (SDS), label, or look in the Hazardous Chemicals Information System (HCIS) to find information on the hazardous chemical’s nature and hazard severity. It is important for you to investigate and understand the physical properties of the chemicals because some gases or liquid chemicals can become more concentrated in the air.

Sometimes hazardous chemicals are generated at your workplace, for example your workers could make dust through cutting a product, or equipment workers use might generate fumes. These hazardous chemicals won’t have a SDS or label available. In these instances you can ask the manufacturer or importer of the chemical, equipment or product for safety information.

It is important to consider how your workers might be exposed to a chemical, because the way your workers do their work could increase how much of the chemical they absorb and in turn increase the level of risk. For example, workers who are exposed during strenuous activity breathe more heavily and can inhale more of the chemical. The worker’s individual characteristics can also increase the risk of health effects, for example their heart rate, respiration rate, diet, whether they are a smoker or have been previously exposed.

You can also do air monitoring or surface wipe testing to see how much workers are exposed and whether your current control methods are able to control the exposure.

How to work out the level of risk

In health monitoring, we generally describe the level of risk as ‘not significant’ or ‘significant’.
‘Not significant’ may include circumstances where it is unlikely your worker will be exposed at all to a hazardous chemical, or that they will be exposed to an amount of a hazardous chemical that is not expected to harm their health.
As the PCBU, you should decide significance based on the acute (short term) and chronic (long term) exposure levels and the possible health effects.

A significant risk includes circumstances where workers are likely to be exposed to an amount of a hazardous chemical that could harm their health. For example, there may be a ‘significant risk to a worker’s health’:

  • if exposure is high, where:
    • the chemical’s airborne concentration is more than 50 percent of the workplace exposure standard
    • workers are exposed to a pure form of the chemical, or
    • workers can easily absorb the chemical through their skin
  • if the chemical is highly toxic, where the chemical is classified according to the GHS as:
    • acute toxicant category 1 or 2
    • carcinogen, mutagen or reproductive toxicant
    • a respiratory or skin sensitiser, or
    • a specific target organ toxicant single or repeat exposure category 1.

It is important to consider the health effects to decide if a risk is significant, because individuals may react to hazardous chemical exposure in different ways. For example, they may be sensitive to certain chemicals or have past exposure that may change how they react. You should also consider routine health monitoring for workers exposed regularly to lower levels of hazardous chemicals because this may also be a significant risk to health.

Guide for when a significant risk may be present

Possibility: The risks are significant, but the possibility of exposure is eliminated through effective controls 

Description

The hazardous chemical poses significant risk to your worker’s health. However, the overall risk is not significant because you have eliminated the risks from hazardous chemicals by eliminating the risk of exposure in line with known, effective control measures, like those included on the chemical’s SDS.

For example, risks are low because the process is completely enclosed or workers are isolated from possible exposure. 

Action

You do not have to monitor health.

Possibility: The risks are significant and despite control measures, exposure is possible

Description

You think the risks are significant but your controls are not effective to eliminate exposure, resulting in possible exposure to your workers.

For example, there is a risk of exposure that poses a significant risk to health because you think that the PPE is not being used properly. You must monitor the health of your workers.

Action

You must monitor the health of your workers.

You must review and revise the way you control the risks to eliminate or minimise the risks as much as possible.

Possibility: There is uncertainty about the risks, not enough information about the hazards, or uncertainty about the amount of exposure

Description

You are uncertain about the level of risks posed by the hazardous chemical or the amount of exposure to the hazardous chemical your workers are experiencing.

For example, you don’t know if exposure might have been more than the biological exposure standard.

Action

You must monitor the health of your workers.

Read the  Model Code of Practice: Managing risks of hazardous chemicals in the workplace for more guidance on controlling exposure to hazardous chemicals.

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