AIOH Submission – Review of health monitoring and air monitoring requirements for hazardous chemicals in the model WHS laws

Description

We appreciate the opportunity to respond to Safe Work Australia’s issues paper regarding the review of health monitoring and air monitoring requirements for hazardous chemicals in the model WHS laws (December 2024). We recognise that Safe Work Australia have been stewarding the most comprehensive review of workplace exposure standards, WHS regulation and guidance on chemical hazards in many decades.

We believe that a comprehensive risk assessment is a crucial element of both exposure and health monitoring for hazardous chemicals. When a Person Conducting a Business or Undertaking (PCBU) is uncertain about the nature or extent of a risk (such as their level of compliance with exposure limits), they often consult with an occupational hygienist. The occupational hygienist determines whether overexposure to a hazard has or could occur, for instance, due to non-compliance with exposure limits. They identify which workgroups may be at risk of overexposure and recommend appropriate control measures as necessary. They also may recommend health monitoring for individuals or workgroups, based on the nature of the risk to the hazardous chemical. If exposure through other routes (beyond inhalation) is relevant, the occupational hygienist may recommend biological or biological effect monitoring. Conversely, an occupational physician may identify signs of ill health in an individual worker and recommend enhanced control measures for that worker (and co-workers), in addition to recommending exposure monitoring.

Association number: A0017462L
ABN: 50 423 289 752
Approved by Council: 20 February 2025
Prepared by: AIOH External Affairs Committee
Date: 20 February 2025

Acknowledgements
The AIOH Council acknowledges the work of members who contributed to this submission from the External Affairs Committee in addition to input from the Workplace Exposure Assessment Committee and external member representatives.