Health monitoring requirements for workers exposed to hazardous chemicals, lead risk work, Silica or asbestos-related work.

Legal and ethical obligations of a PCBU:   

The PCBU should assess significant risks and decide whether a health monitoring program is necessary, particularly for hazardous substances with severe known health effects.   

Legal and ethical obligations of a PCBU to assess risks associated with hazardous substances:  

  • consult with medical professionals  
  • implement health monitoring programs to protect workers from severe health effects.   

The main focus is on preventing harm through early detection and proactive measures.   

Responsibilities might vary based on the specific regulations and laws in each jurisdiction.  

Duty to Determine Significant Risk:   

The PCBU (employer or organization) has the responsibility to identify and determine what constitutes a “significant risk” to workers in relation to hazardous substances. This involves considering both the likelihood of exposure to the hazardous chemical and the known health effects associated with that chemical.  

Consultation with Health Monitoring Doctor:   

To make decisions about significant risk, the PCBU may need to consult with a health monitoring doctor. Employees Health medical professional can provide expertise in evaluating the potential health effects of chemical exposure and whether health monitoring is required.  

Factors Influencing Decision:   

The decision to implement a health monitoring program is based on several factors, including:  

  • Regulatory requirements under the model Work Health and Safety (WHS) laws.  
  • Type of chemical being used and its known health effects.  
  • Method and level of exposure to the chemical.  
  • Presence of control methods or equipment to minimize exposure.  

Hazardous substances with Severe Health Effects:   

The PCBU, in consultation with our health monitoring doctor, should particularly consider implementing health monitoring programs for substances that have severe known health effects. This includes substances that are carcinogenic (cancer-causing), mutagenic (causing genetic mutations), toxic to human reproduction, respiratory or skin sensitizers that have other severe toxic effects.  

Lead Risk Work: 

Health monitoring is mandated when a worker starts or is performing lead risk work. This is likely due to the potential health risks associated with lead exposure.  

Asbestos-Related Work: 

Health monitoring is required for workers engaged in licensed asbestos removal or other asbestos-related work. Asbestos exposure can have serious long-term health implications, so health monitoring is crucial.  

Methods of Health Monitoring:   

The health monitoring doctor will determine the best approach to monitor workers’ health. This might involve using various methods and may include proactive health monitoring, which means assessing workers’ health before they show symptoms. This could involve testing the level of a chemical or substance in a worker’s blood or urine.  

Preferential Proactive Monitoring:   

Proactive monitoring is preferred over monitoring symptoms after they have developed. This proactive approach allows for early detection of potential health issues related to chemical exposure and enables preventive measures to be taken.  


Medical examination:  

This involves the use of standard clinical and medical assessments, tests, and techniques to assess the presence of early or long-term health effects, often at set intervals.  

It could include a clinical examination, and tests like spirometry (lung function) and radiography, for example chest X-ray.  

Biological effect monitoring:  

This is the measurement and assessment of early biological effects before health  

impairment occurs in exposed workers. For example, hematological (blood) profiling,  

monitoring of the liver or kidney markers or measurement of the reduction of cholinesterase activity levels.  

Biological exposure monitoring:  

This involves measurement and evaluation of the levels of a hazardous chemical or its metabolites in:  

− body fluids including urine or blood  

− body tissues such as a build-up of a hazardous chemical in the lungs, or exhaled breath.  

In many cases, more than one monitoring method is used and choosing the most appropriate health monitoring method will depend on:  

  • the regulatory requirements for the chemical under the WHS laws  
  • the type of chemical involved  
  • the way the worker is exposed  
  • the level of exposure, and  
  • if it is possible to use a proactive method, like biological exposure monitoring, rather than a reactive method, like a medical examination will be required.  

 Examinations and sampling procedures used in a health monitoring program should be safe, easy to perform, acceptable to workers and, where possible, non-invasive.  

However, when planning a health monitoring program and when interpreting results, it is important to understand the limitations of the test method and results.  

It is also important to remember the level of a hazardous chemical or its metabolites in the body may not necessarily correlate with workplace exposure to the hazardous chemicals  

(e.g., lifestyle behaviors may confound results), symptoms or adverse effects to health.  

Experience needed to carry out health monitoring:  

The model WHS Regulations provide that health monitoring must be carried out by or under the supervision of a registered medical practitioner with experience in health monitoring.  

Before agreeing to supervise or carry out health monitoring program you should ensure you have the necessary skills, qualifications, and experience for this work.  

Registered medical practitioners should be able to carry out the key requirements of a health monitoring program including:  

  • planning a health monitoring program specific for exposures to the relevant hazardous chemical that requires health monitoring  
  • implementing, monitoring, and managing a health monitoring program  
  • recognizing and harnessing specialist assistance when required  
  • sourcing, interpreting, and applying best practice, medical, toxicological and epidemiological literature and integrate this knowledge into health monitoring programs. 
  • advising and supervising other registered medical practitioners carrying out health monitoring.  

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