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The AIOH welcomes the opportunity to respond to Safe Work Australia’s consultation paper, Review of health and air monitoring requirements for hazardous chemicals. This review builds on the December 2024 issues paper to which we responded in February 20251. Our positions remain substantially consistent with that submission and are restated here, supported by evidence published since.
That evidence has strengthened the case for well-designed health monitoring programs. An evaluation of the Building Trades National Medical Screening Program in the United States, covering examinations from 1997 to 2021, found that construction workers who completed periodic medical examinations experienced a 28% reduction in all-cause mortality compared with workers who completed a work history interview alone, with greater reductions for those completing more examinations. The program was estimated to have prevented approximately 2,911 premature deaths and added more than 35,000 years of life, at a cost of US$2,757 per year of life saved.2 An accompanying commentary identified the credibility of an occupationally focused program and the comprehensive written communication of results to workers as key elements of that effectiveness.3 Longer-term evidence from the same program shows that the greatest improvements in construction worker health outcomes over recent decades occurred for hazards subject to strong regulatory and legal incentives to reduce exposure.4 The lessons for this review are that health monitoring programs save lives when done well, and that clear, enforceable regulation drives improvement. Where occupational hygiene monitoring data are unavailable, or the extent of exposure is uncertain, a precautionary approach should also apply, with health monitoring provided where a risk is anticipated. Recent Australian experience in the stone benchtop industry reinforces both lessons and is discussed in our responses below.