The registered medical practitioner or other qualified person (such as an occupational nurse) can interview your worker and ask questions about:

• symptoms related to exposure
• previous occupational history
• medical history or lifestyle, for example dietary, smoking and drinking habits.

An interview may include your worker answering simple questions about their work, their personal hygiene at work or where they eat and drink at the workplace.

The registered medical practitioner will use the answers to assess your worker’s current or previous exposure to hazardous chemicals. The registered medical practitioner may obtain further information from your worker after they complete the questionnaire.

Counselling is where the registered medical practitioner educates your worker about the effect of their lifestyle on symptoms of workplace exposure, for example lead workers who smoke or bite their nails should be counselled on the risk of lead ingestion.

The registered medical practitioner might also discuss how exposure to certain chemicals can have an effect on reproduction, pregnancy and breastfed children.

The registered medical practitioner may use standard techniques to measure early or long term health effects, and they may do this regularly. They might check your worker’s skin, eyes or hearing and collect baseline information to measure any future changes against.

The registered medical practitioner may check the levels of a hazardous chemical or its metabolites (breakdown products) in:

• body tissues
• body fluids like urine or blood
• the exhaled breath of an exposed worker.

The registered medical practitioner may look at early biological effects, before your worker’s health is harmed, for example by:

• blood tests
• monitoring your worker’s liver or kidney function
• measuring the reduction of cholinesterase activity levels.

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
• asbestos.

You must monitor the health of a worker if they: 

The WHS Regulations provide the regulator with the power to direct a PCBU to arrange for a medical examination of a worker (rr. 55E-55K).

As the PCBU, it is your responsibility to determine if there is a risk to your worker’s health because of exposure to a table 14.1 hazardous chemical, or risk of exposure to another hazardous chemical and there are suitable testing methods available.

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
• 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 risk to your worker’s health or if your workers are at risk of exposure, you can seek specialist advice from an occupational hygienist, registered medical practitioner, occupational physician or the regulator. For hazardous chemicals not listed in Schedule 14, you should also consult your registered medical practitioner to see if suitable testing methods for the chemical are readily available.

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
• 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.

As a PCBU, it is your primary duty to ensure, so far as is reasonably practicable, the health of your workers. You also have a duty to monitor their health and your workplace conditions to prevent injury, illness and disease.

Workers also have a duty to comply with any reasonable instruction given by you to enable you to comply with WHS laws, including participating in health monitoring and wearing PPE when working with certain chemicals.

You should encourage your workers to talk to you about concerns they have with their health monitoring program. You can also refer them to your registered medical practitioner to talk about the clinical aspects of health monitoring, or to their health and safety representative, if your workplace has one, or their personal general practitioner (GP).

If your worker still does not want to do health monitoring, you must comply with your duties under WHS laws, which may include stopping them working with the hazardous chemical.

As the PCBU, you must provide your registered medical practitioner with the following information.

About the business and your worker

• name and address of your business or undertaking.
• the name and date of birth of your worker. (You may need to gain your worker’s consent before supplying any extra information.)

About the work

• the work that your worker is, or will be, carrying out that has made you to seek health monitoring.
• if your worker has already started, how long they have been carrying out the work.

You should provide extra information to your registered medical practitioner, including:

• relevant risk assessment reports, details of workplace exposure standards and results of workplace air monitoring
• a list of the hazardous chemicals your worker is or will be exposed to and the dates your worker last used the chemicals
• the SDS for the chemical(s).

It is important to provide this information to the registered medical practitioner so they can design an effective health monitoring program for your worker. This information will help the registered medical practitioner to understand the situations and potential exposure levels that a worker could be exposed to. If you provide information about other hazardous chemicals your worker may be exposed to, the registered medical practitioner may be able to identify other or more severe effects. You should include information about likely workplace exposures in your risk assessment reports including control measures to reduce exposure and your investigations where workplace exposure standards have been reached or exceeded.

Health monitoring notification forms for WA are available on the DMIRS website and may help you prepare information on work practices and workplace controls to provide to the registered medical practitioner.

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
• 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.

If your workers use the chemicals listed in table 14.1 of Schedule 14 to the WHS Regulations, the registered medical practitioner must use specific health monitoring tests for those chemicals. The chemicals and their tests have also been provided for you at Appendix 1.

A registered medical practitioner 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 registered medical practitioner if other tests are to be used. The registered medical practitioner must recommend the alternative method before it is used. More information about this can be found in the in the individual WorkSafe WA health monitoring guides for hazardous chemicals.

If there is a 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 registered medical practitioner and consult with your workers before you arrange health monitoring. The registered medical practitioner 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 1.

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
• 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 registered medical practitioner 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
• 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.

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.

There are extra health monitoring requirements for workers involved in lead risk work, under the 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
• 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
• 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
• 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 regulation 407 of the WHS Regulations 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
• 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 the health monitoring guides for hazardous chemicals or contact WorkSafe WA.

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
• a physical examination with emphasis on the respiratory system.

You will find more information about health monitoring for asbestos in Chapter 8 of the WHS Regulations and the Code of practice: How to safely remove asbestos.

The registered medical practitioner must put certain information in the health monitoring report. To ensure you are meeting your duties, you must check it contains:

• the name and date of birth of your worker
• the name, registration number and signature of the registered medical practitioner
• name and address of the business or undertaking
• the date(s) of health monitoring
• any advice that your worker may have contracted an injury, illness or disease as a result of carrying out work that requires health monitoring
• any recommendation that you take remedial measures including whether your worker can continue to do the type of work, and
• whether your worker requires medical counselling or specialty medical advice about the injury, illness or disease.
• for health monitoring for hazardous chemicals specifically:
  • test results that show whether or not your worker has been exposed to a hazardous chemical
• for health monitoring for lead specifically:
  • the results of biological monitoring that indicate blood lead levels in your worker’s body
  • test results that show your worker has reached or exceeded the relevant blood lead level for your worker under regulation 415 of the WHS Regulations
  • the date of the blood sampling
  • details of the pathology service used
• the date of sampling if blood, urine or other samples are taken
• results of biological monitoring and other tests carried out.

Your copy should only report information about the health monitoring program. It should not report health information other than what you need to know to help monitor your worker’s health. The report should not contain details of medical conditions provided to or diagnosed by the registered medical practitioner if these are not relevant to your worker’s job. If your worker has a pre-existing medical condition that may worsen the health effects of exposure to the hazardous chemicals at your workplace, the registered medical practitioner should bring this to your attention so you can put in place effective control measures. However, the registered medical practitioner will only share the details of pre-existing medical conditions if the worker gives written permission to do so.

The registered medical practitioner should include a recommendation based on the results, for example biological exposure testing that shows early indication or diagnosis of injury, illness or disease related to the work that requires health monitoring, or other interpretation of X-ray, low dose CT, or spirometry readings that lead to recommending you review workplace controls. If they include detailed health information about your worker that is not required to be in the report, or information on your worker’s pre-existing medical conditions without permission, you should return the report marked as confidential to the registered medical practitioner, informing them of the error.

Once the registered medical practitioner gives you the health monitoring report, you should consider the results, recommendations and advice provided.

As soon as practicable, you must provide a copy of the report to:

• your worker
• all other PCBUs who have a duty to provide health monitoring for your worker

The registered medical practitioner will provide recommendations in the health monitoring report about the health monitoring program for your worker that could include:

• whether it is a final health monitoring report
• details for a repeat appointment, for example:
  • a follow up assessment to confirm results
  • the next routine health monitoring appointment
• any counselling required
• an extra medical examination
• that your worker has been referred to a medical specialist.

The registered medical practitioner will also provide specific recommendations to you based on your worker’s health monitoring results that may include:

• your worker is fit for work with the hazardous chemical
• your worker is fit to resume work with the hazardous chemical
• biological monitoring results show unacceptably high exposure levels
• if you should review workplace control measures
• that your worker should be removed from work with the hazardous chemical.

Recommendations about a health monitoring program

You must consult with your worker and explain any recommended remedial measures you must take, for example removing them from work where they have been exposed. You should also consult your worker if you need to further monitor their health. Only your worker and the registered medical practitioner should discuss treatment. Recommendations a doctor may give you

Removal of your worker from work with a hazardous chemical

If the registered medical practitioner recommends that you remove your worker from work, you should remove them from work with the hazardous chemical that triggered the need for health monitoring. For example, you should give your worker other work or another location where they will not be exposed to the hazardous chemical. You should do this after consulting with your worker and the registered medical practitioner and ensure that your worker is not returned to work with the hazardous chemical until cleared to do so by the registered medical practitioner.

You should continue to provide workers who have been removed from work or transferred to other work with information about their health monitoring.

Lead

The registered medical practitioner will make recommendations in the health monitoring report if you should remove a worker from lead risk work.

You must remove a worker from lead risk work if recommended by the registered medical practitioner if:

• the biological monitoring of your worker shows your worker’s blood lead level is at or more than the blood lead removal level for that person:
  • for females not of reproductive capacity and males – 30 µg/dL (1.45 µmol/L)
  • for females of reproductive capacity – 10 µg/dL (0.48 µmol/L)

or

• there is an indication a risk control measure has failed and, as a result, your worker’s blood lead level is likely to reach the relevant level for removal, as per the levels noted above.

A registered medical practitioner may also recommend you remove the worker from lead risk work if their blood lead level is still below the mandatory level but there is an indication your worker has health effects from exposure. If this recommendation is made you should remove your worker from lead risk work. You must notify the WHS regulator as soon as possible if you remove a worker from carrying out lead risk work.

You must arrange for your worker to be medically examined by a registered medical practitioner within seven days after the day your worker is removed. 

If you expect your worker to return to carrying out lead risk work, you must monitor their health as often as the registered medical practitioner recommends. This will determine whether your worker’s blood lead level is low enough for your worker to return to carrying out lead risk work.

You must ensure your worker does not return to carrying out lead risk work until:

• your worker’s blood lead level is less than:
  • for females not of reproductive capacity and males – 20 µg/dL (0.97 µmol/L)
  • for females of reproductive capacity – 5 µg/dL (0.24 µmol/L)

and

• the registered medical practitioner is satisfied your worker is fit to return to carrying out lead risk work.

Review control measures in the workplace

You should, and in some cases must review, and revise if necessary, the control measures in the workplace. The registered medical practitioner will make this recommendation:

• if test results show your worker has been exposed and has elevated levels of metabolites or break-down products, of a hazardous chemical in their body
• in the case of lead, if test results show your worker has reached or exceeded the relevant blood lead removal level, or if they have otherwise been removed from carrying out lead risk work, or
• if test results show your worker may have contracted a disease, injury or illness as a result of working with the chemical that triggered health monitoring.

The registered medical practitioner may also recommend you take other actions including if your worker can continue to work with hazardous chemicals.

You should examine your work practices and procedures to see if tasks are being done correctly and if controls are not effective or being bypassed. If necessary, you should review and revise worker training programs.

You must regularly review and revise the control measures you have in place for hazardous chemicals. You will find more information on review of control measures in Code of Practice: Managing risks of hazardous chemicals in the workplace.

Provide a copy of the health monitoring report to the WHS regulator

The registered medical practitioner must provide a copy of the health monitoring report to the regulator. You must provide a copy to the worker.

Role of the regulator

The regulator may assign an inspector to conduct an inspection or make enquiries if there are concerns about worker exposure to hazardous chemicals. The regulator may also assign an inspector to conduct a proactive inspection of any workplace to check work health and safety compliance.

You must keep health monitoring reports as confidential records and must not disclose them to another person without your worker’s written consent, except where you must provide the records under a law. For example, the WHS Regulations require disclosure to any of the following:

• the WHS regulator
• another PCBU who has a duty to monitor the health of your worker
• a person who must keep the record confidential under a duty of professional confidentiality, for example another doctor.

You must keep health monitoring reports separate from normal workers’ records like payroll or human resources data, to prevent unauthorised people from seeing them.

To ensure you meet your confidentiality obligations, you must not use the health monitoring report for any purpose other than monitoring the health of your worker. Similarly, you must not use blood or tissue samples, X-rays, questionnaires or other materials taken for health monitoring for any other purpose.

You must keep workers’ health monitoring records for hazardous chemicals and lead for at least 30 years after the record is made, even if the worker no longer works at your workplace.

You must keep asbestos health monitoring records for at least 40 years, even if the worker no longer works at your workplace, due to the long period of time it can take for asbestos-related disorders to develop.

The information in this appendix is taken from regulation 436 (asbestos) and Schedule 14 to the WHS Regulations. 

You may wish to consider the following examples of hazardous chemicals and their testing methods, which are not listed in Schedule 14 to the WHS Regulations, when implementing a health monitoring program for your workers.