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December 28, 2025
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What is Health Monitoring?
Health monitoring is a proactive approach to assess whether workers exposed to hazardous chemicals are developing health issues from workplace exposure. It involves a registered medical practitioner examining and monitoring workers to detect changes in health status before serious harm occurs.
Organisations must never use health monitoring as a substitute for effective control measures. Rather, it complements and validates whether your existing controls are working effectively.
When Must You Provide Health Monitoring?
As a person conducting a business or undertaking (PCBU), you must arrange safework health monitoring if workers are exposed to:
Scheduled hazardous chemicals (listed in Table 14.1 of Schedule 14, WHS Regulations) including:
* Lead
* Asbestos
* Cadmium, chromium, mercury, nickel, beryllium
* Benzene, toluene, styrene
* Crystalline silica
* Isocyanates, creosote, organophosphate pesticides
* PAH, vinyl chloride, and others
Exposure triggers requiring action:
* Workers using, handling, generating or storing hazardous chemicals
* Risk of exposure exceeding biological exposure standards
* Work involving lead processes likely to exceed control thresholds
* Licensed asbestos removal or ongoing asbestos work
Additional scenarios for consideration:
* One-off incidents (spills, leaks, loss of containment)
* Worker reports of relevant symptoms
* Changes in exposure levels or work processes
* When workers cease work with hazardous chemicals
Risk Assessment Framework
Before implementing safework health monitoring, conduct a comprehensive risk assessment considering:
Hazard classification
* How is the chemical classified under the Globally Harmonised System?
* Is it an irritant, sensitiser, carcinogen, or acute toxicant?
* Physical form (solid, dust, mist, fume)?
* Route of entry (inhalation, ingestion, skin contact, absorption)?
Exposure assessment
* Workplace location and quantity of chemicals used
* Frequency and duration of worker exposure
* Concentration levels (pure or diluted)
* Effectiveness of current control measures
* Individual work practices and behaviours
* Worker characteristics affecting absorption (respiratory rate, smoking, fitness)
Information sources
* Safety Data Sheet (SDS) for each chemical
* Hazardous Chemicals Information System (HCIS)
* Air monitoring and surface wipe test results
* Occupational hygiene assessments
* Manufacturer guidance for generated chemicals
Consider seeking specialist advice from an occupational hygienist, occupational physician, or the regulator if uncertainty exists about exposure risk or available testing methods.
The Safework Health Monitoring Process
1. Consult with Workers
Before workers start:
* Inform workers of safework health monitoring requirements
* Explain why monitoring is necessary
* Describe what to expect in the program
Consultation must cover:
* Types and frequency of tests required
* Schedule for medical appointments
* Qualifications of the registered medical practitioner
* Cost responsibility (employer funded)
* How results may affect work duties
* Confidentiality and record handling practices
* Potential health effects from exposure
Addressing resistance:
Workers have a legal duty to participate in reasonable health monitoring. If a worker refuses, discuss concerns with the registered medical practitioner or health and safety representative. If refusal continues, you may need to restrict their work with hazardous chemicals to meet your PCBU duties.
2. Engage a Registered Medical Practitioner
The medical practitioner must have demonstrable experience in health monitoring. They can be based in:
* Private practice
* Occupational health organisations
* Corporate health services
* Specialist testing facilities
Your responsibilities:
* Genuinely consult workers on practitioner selection
* Provide comprehensive workplace information
* Ensure the practitioner designs a suitable program
* Confirm they supervise any delegated testing (e.g., to occupational nurses)
Practitioner should:
* Visit your workplace to understand control measures and exposure scenarios
* Develop a tailored health monitoring program
* Seek specialist advice when necessary
* Have overall clinical responsibility for the program
3. Provide Essential Information to the Practitioner
Mandatory information:
* Business name and address
* Worker’s name and date of birth
* Description of work involving hazardous chemicals
* Duration of exposure (if started)
Additional information to provide:
* Risk assessment reports and air monitoring data
* List of all hazardous chemicals worker may encounter
* Safety Data Sheets for each chemical
* Workplace exposure standards
* Details of control measures implemented
* Previous health monitoring results (if any)
* Workplace air monitoring outcomes
This information enables the practitioner to design an effective program and identify cumulative or combined effects from multiple chemical exposures.
4. Organise Health Monitoring Appointments
Timing considerations:
Baseline monitoring (before work starts)
* Establishes baseline health status
* Captures demographic, medical and occupational history
* May include physical examination, respiratory testing, blood/urine collection
Routine monitoring (during employment)
* Frequency depends on the chemical, exposure level and work processes
* May increase if workers report relevant symptoms
* Should review if control measures change
* One-off monitoring after spills or containment loss
Final monitoring (upon cessation)
* Arrange when worker stops working with the hazardous chemical
* Establishes final health status upon leaving role
Practical arrangements:
* Schedule appointments during normal working hours
* Ensure minimal workplace disruption
* Maintain confidentiality of appointments and results
* Provide paid time for workers to attend
5. Cost Responsibility
As the PCBU, you must fund:
* Medical appointment fees
* Testing and pathology analysis
* Worker’s time attending appointments and undergoing tests
* Travel expenses
If multiple PCBUs share responsibility for a worker, costs should be split equally unless agreement specifies otherwise.
6. Health Monitoring Methods
The registered medical practitioner selects appropriate monitoring techniques based on:
* Regulatory requirements (Schedule 14)
* Type of chemical involved
* Exposure pathway and level
* Effectiveness of control measures
* Availability of proactive testing options
Scheduled Chemical Monitoring Requirements
Lead Risk Work
Lead risk work is any process likely to cause blood lead levels exceeding:
* Females of reproductive capacity: 5 μg/dL
* Other workers: 20 μg/dL
Mandatory monitoring:
* Before work starts
* One month after commencing lead work
* Ongoing biological monitoring based on blood lead levels:
| Blood Lead Level | Monitoring Frequency |
|—|—|
| Less than 10 μg/dL (females non-reproductive and males) | Every 6 months |
| 10 to less than 20 μg/dL (females non-reproductive and males) | Every 3 months |
| 20 μg/dL or higher (females non-reproductive and males) | Every 6 weeks |
| Less than 5 μg/dL (females of reproductive capacity) | Every 3 months |
| 5 to less than 10 μg/dL (females of reproductive capacity) | Every 6 weeks |
| 10 μg/dL or higher (females of reproductive capacity) | Mandatory removal from lead work |
Removal thresholds:
* Females of reproductive capacity: 10 μg/dL
* Other workers: 30 μg/dL
Workers removed from lead work must undergo reassessment before returning. They can only resume when blood levels fall below safe limits and the practitioner confirms fitness to return.
Asbestos Work
Workers conducting licensed asbestos removal or ongoing asbestos work require baseline health monitoring including:
* Demographic, medical and occupational history
* Assessment of previous personal exposure
* Physical examination emphasising the respiratory system
Refer to the Code of Practice: How to Safely Remove Asbestos for detailed requirements.
Given the serious consequences of silicosis, https://www.safework.nsw.gov.au/notify-safework/silica-worker-register-notificationmonitoring typically includes:
* Respiratory questionnaire
* Respiratory function testing (spirometry)
* Low-dose high-resolution CT chest imaging (1.5 mm or less slice thickness, less than 1 mSv exposure)
Health Monitoring Reports
Report Requirements
The registered medical practitioner must provide you with a report containing:
Essential information:
* Worker’s name and date of birth
* Practitioner’s name, registration number and signature
* Business name and address
* Monitoring dates
* Any advice regarding injury, illness or disease from work
* Recommendations for remedial action
* Whether worker can continue the work
* Need for medical counselling or specialist referral
* Test results (whether positive for exposure)
* Blood lead level results
* Whether removal thresholds reached or exceeded
* Date of blood sampling
* Pathology service details
For asbestos and scheduled chemicals:
* Biological monitoring results
* Test dates and methodology
* Interpretation of findings
Your copy should only include:
* Information necessary to monitor worker health
* Relevant test results and interpretation
* Recommendations for workplace action
* NOT unrelated medical information or pre-existing conditions (unless worker consents and relevant to exposure effects)
Acting on Reports
Possible recommendations from the practitioner:
Timing and Distribution
You must provide a copy of the health monitoring report to:
* The worker (as soon as practicable)
* Any other PCBU responsible for monitoring that worker
The registered medical practitioner will provide a copy to the regulator if results indicate exposure to the hazardous chemical.
Record Keeping and Confidentiality
Storage and Confidentiality
Health monitoring records are confidential and must be:
* Stored separately from routine HR or payroll records
* Kept secure to prevent unauthorised access
* Not used for purposes other than monitoring worker health
* Not shared with other parties without written consent
Authorised disclosure (without consent):
* The regulator
* Other PCBUs with monitoring duties for the worker
* Professionals bound by confidentiality (other doctors)
* When required by law
Retention Periods
* Hazardous chemicals and lead: minimum 30 years after record creation
* Asbestos: minimum 40 years after record creation
Records must be retained even if the worker no longer works for you, due to latency periods for occupational disease.
FAQs: Answering Common Questions
Who is covered by health monitoring requirements?
Health monitoring applies to all workers as defined under the WHS Act, including employees, contractors, subcontractors, apprentices, and any person working for you.
Can workers refuse health monitoring?
Workers have a legal duty to participate in reasonable health monitoring. If they refuse, you must take steps to ensure compliance with your PCBU duties, which may include removing them from work with hazardous chemicals. Discuss concerns with the worker, the registered medical practitioner, or a health and safety representative.
What if we can’t identify a suitable medical practitioner?
Seek recommendations from occupational health organisations, occupational physicians, or contact the regulator for guidance. Ensure any practitioner has demonstrated experience in health monitoring for your industry.
How do we handle monitoring results that show exposure?
If results show biological exposure levels or early health effects:
1. Provide results to the worker
2. Review existing control measures with an occupational hygienist
3. Implement revised or additional controls
4. Increase monitoring frequency if recommended
5. For lead, follow mandatory removal procedures if thresholds exceeded
Can health monitoring replace control measures?
No. Health monitoring is a complementary tool to assess effectiveness of controls, not a substitute. You must implement engineering controls, administrative controls and PPE first, then use health monitoring to validate their effectiveness.
What happens if a worker’s health monitoring shows they need removal from work?
You must remove them from work with that specific hazardous chemical and provide alternative work or location without exposure. Arrange continued health monitoring at intervals recommended by the practitioner to determine when they’re fit to return. Workers can only resume when medically cleared and when you’ve confirmed control measures are effective.
Do we need to inform workers about control measure changes?
Yes. Significant changes to work processes, control measures, or chemical exposure should be communicated to workers and their health and safety representative. The practitioner may recommend adjusting monitoring frequency if exposures change.
How long do we keep health monitoring records?
Minimum 30 years for hazardous chemicals and lead exposure. Minimum 40 years for asbestos exposure. Records must be retained even after the worker leaves employment.
What’s the difference between baseline, routine and final monitoring?
* Baseline: Initial assessment before work starts, establishing health status for future comparison
* Routine: Regular periodic checks during employment, frequency depends on chemical and exposure level
* Final: Assessment when worker ceases work with the hazardous chemical, documenting final health status
Who pays for health monitoring costs?
The PCBU (you) pays all costs including medical fees, testing, pathology analysis, worker’s time and travel expenses. If multiple PCBUs share responsibility, costs are split equally unless agreed otherwise.
Must the practitioner visit our workplace?
Whilst not mandatory, it is strongly recommended that the registered medical practitioner visit to understand your:
* Work processes and exposure scenarios
* Control measures in place
* Workplace environment
* Actual exposure levels
This enables them to design a more appropriate and effective monitoring program.
What if we use hazardous chemicals generated at our site (e.g., dust from cutting)?
Request safety information from the manufacturer or supplier of the product or equipment generating the chemical. Use this to conduct your risk assessment. If health monitoring is required, consult with the registered medical practitioner on suitable testing methods, as no standard SDS may be available.
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Industry Guidance
HSE Direct recommends developing a comprehensive health monitoring policy integrating health monitoring within your broader WHS management system. This should include:
* Clear procedures for identifying chemicals requiring monitoring
* Consultation framework with workers
* Process for engaging and liaising with medical practitioners
* Documentation and record-keeping systems
* Response procedures for abnormal results
* Regular review of control measures based on monitoring outcomes
Regular review ensures your health monitoring program remains effective and compliant with evolving legislative requirements and best practice standards.