WHS Regulation 2025, Part 7.2

Regulation

Schedule 14 substances + significant risk

Trigger

Paid by the PCBU

Cost

Registered medical practitioner

Performed By

30 years minimum

Record Retention

Before commencing + regular intervals

Frequency

You need health monitoring when your workers are exposed to any substance listed in Schedule 14 of the WHS Regulation 2025 and there is a significant risk to their health from that exposure. Schedule 14 substances include crystalline silica, lead, asbestos, isocyanates, organophosphate pesticides, polycyclic aromatic hydrocarbons, mercury, cadmium, chromium, arsenic, thallium, platinum salts, 4,4-methylenebis (2-chloroaniline), pentachlorophenol, vinyl chloride, acrylonitrile, benzene, and noise exposure. Health monitoring is triggered when the worker is exposed to these substances during routine work activities, not only when exposure exceeds the workplace exposure limit. The purpose of health monitoring is to detect early signs of health effects before they become irreversible. If your workers handle, process, or are exposed to any Schedule 14 substance as part of their work, you must assess whether there is a significant risk and, if so, arrange health monitoring.

You do not need health monitoring when your workers are not exposed to any Schedule 14 substance, or when the exposure is so low that there is no significant risk to health. For example, a worker in an office environment who has no contact with hazardous chemicals does not require health monitoring. A worker who occasionally uses a small quantity of a cleaning product that contains a Schedule 14 substance may not require health monitoring if the exposure is assessed as not posing a significant risk. The assessment of whether there is a significant risk must consider the nature of the substance, the duration and frequency of exposure, the quantity used, the controls in place, and the route of exposure. This assessment must be documented. If the assessment concludes that there is no significant risk, health monitoring is not required but the assessment must be reviewed whenever work practices, processes, or controls change.

The PCBU must pay all costs associated with health monitoring including medical consultations, tests, and any follow-up investigations. The PCBU must ensure that health monitoring is carried out by or under the supervision of a registered medical practitioner with experience in health monitoring for the relevant substances. The PCBU must provide the medical practitioner with information about the substance, the type of work, the exposure conditions, and the results of any workplace exposure monitoring. Health monitoring must be offered before the worker commences the relevant work and at regular intervals thereafter, typically annually unless a shorter interval is specified for the substance. Workers have the right to choose their own medical practitioner from the options provided by the PCBU. Health monitoring records must be kept for at least 30 years after the last entry. If a health monitoring report contains an adverse finding, the PCBU must take action to prevent further exposure and review the effectiveness of current controls.

Health monitoring obligations are most commonly triggered in construction where workers are exposed to crystalline silica from cutting, grinding, and drilling concrete, stone, and engineered stone. Metal fabrication and welding operations may trigger health monitoring for chromium, manganese, and welding fume constituents. Spray painting operations may trigger health monitoring for isocyanates and organic solvents. Mining operations commonly require health monitoring for silica, diesel particulate, noise, and various metals. Agricultural operations may require health monitoring for organophosphate pesticides. Laboratory and healthcare settings may require health monitoring for formaldehyde, glutaraldehyde, and cytotoxic drugs. The WEL transition commencing 1 December 2026 may expand the population of workers requiring health monitoring as the lower exposure limits mean that more workers will be assessed as having a significant risk of exposure to Schedule 14 substances.