Health Surveillance and Exposure Monitoring

Identifying The Need for Health Surveillance and Exposure Monitoring

Potential health hazards must be identified as part of conducting the Project Risk Assessment prior to commencing construction.  This must include consideration of the following health hazards: 

• Biological (e.g. bacteria, viruses, biological waste, fungi, insects etc.) 
• Physical (e.g. noise, vibration, etc.) 
• Chemical/atmospheric contaminants (e.g. dusts, fumes, gases, etc.) 

The assessment of potential health hazards must be undertaken by a competent person.  Depending on the nature of the hazards this may include a qualified Occupational Hygienist and/or a Health Practitioner. This includes where measurement and evaluation of personal exposure to health hazards is required as part of assessing the risk. 

Subcontractor Requirements

When evaluating tenders from Subcontractors who will be performing asbestos-related work, lead-related work, or work where other hazardous chemicals such as crystalline silica poses a high risk, HY must verify that the relevant subcontractor has health monitoring processes are in place to monitor and manage workers’ health.

When a Subcontractor has been engaged to perform this work, the Subcontractor’s Health Monitoring process is to be discussed prior to the work commencing. Subcontractors’ Health Monitoring programs should ensure workers have undergone initial physical examinations by registered medical practitioners prior to being exposed to harmful health hazards and undergo continuous testing and examinations relevant to the hazards associated with their duties.

Exposure Monitoring of Airborne Contaminants

Exposure monitoring may be required to ensure that no person at the workplace is exposed to a substance or mixture in an airborne concentration that exceeds the exposure standard.  Exposure monitoring is to be done when:

• It is required by legislation (e.g. asbestos removal work)
• It is uncertain on reasonable grounds whether exposure standard is exceeded
• Determining whether there is a risk to health (e.g. assessing whether control measures are effective)

Exposure monitoring is not required in all situations as the risk of exposure to airborne contaminants can be managed by the use of well known exposure controls.

Where exposure monitoring is required, it must be planned and conducted/overseen by a qualified occupational hygienist.  Samples must be analysed at a NATA accredited laboratory.  The results must be interpreted and recommendations made by a qualified occupational hygienist.

Hazardous Chemicals Health Monitoring

Health monitoring must be provided to workers that carry out work at a workplace using, handling, generating, or storing hazardous chemicals and there is a significant health risk due to exposure to a hazardous chemical:

• listed in Schedule 14 of relevant state WHS Regulations (Schedule 9 of the VIC OHS Regulations); or
• for which valid techniques are available to detect the effect on the worker’s health; or
• for which a valid way of determining biological exposure to the hazardous chemical is available and it is uncertain, on reasonable grounds, whether the exposure to the hazardous chemical has resulted in the biological standard being exceeded.

Who Can Perform Health Monitoring?

Health monitoring must be carried out or supervised by registered medical practitioner with relevant experience in health monitoring. HY will consult with the worker receiving health monitoring about selection of the registered medical practitioner.

The following information is to be given to the registered medical practitioner carrying out or supervising the health monitoring:

• employer name and address
• the name and date of birth of the worker
• the work that the worker is, or will be, carrying out that has triggered the requirement for health monitoring
• if the worker has started that work – how long the worker has been carrying out that work

HY will take all reasonable steps to obtain the health monitoring report that it has commissioned, as soon as practicable after the monitoring is carried out.  HY will give a copy of the health monitoring report to the worker as soon as possible after HY obtains the report.

Asbestos

HY will ensure that the subcontractor provides health monitoring to its workers carrying out work for HY if the worker is:

• carrying out licenced asbestos removal work at a HY project and is at risk of exposure to asbestos when carrying out the work; or
• is carrying out other ongoing asbestos removal work or asbestos-related work and is at risk of exposure to asbestos when carrying out the work.

The health monitoring must commence before the worker carries out the licensed asbestos removal work.  Refer to HY Asbestos Management procedure.

Crystalline Silica

Where workers are exposed, suspected of being exposed or are concerned about exposure to crystalline silica, the person conducting the business or undertaking (PCBU) has a duty to arrange a health monitoring appointment for the worker(s) with the registered medical practitioner.

Health monitoring for crystalline silica may be required before the worker starts work so that a baseline can be established and any changes to the worker’s health after commencing the work can be detected.

Initial discussions about a health monitoring program should include:

• possible health effects from exposure to crystalline silica
• how to recognise and report symptoms, and
• what is involved in the health monitoring program, for example the frequency of testing and the tests that may be needed, and
• recording any previous workplace or non-occupational exposure to silica.

An initial physical examination by the registered medical practitioner should place emphasis on the respiratory system, including baseline spirometry. 

Continuous health monitoring (including type of testing and frequency) is to be determined by the medical practitioner depending on the workers’ regular duties.

Lead

In the workplace, lead may be encountered as a dust or fume in a pure, oxide or salt form.

Lead and lead compounds are found in solders, metal alloys, bronzes, and construction material, and have previously been used in paints. Lead may still be found in paint or painted products sourced from overseas. 

Lead poses particular risks to health and biological monitoring is required to determine these effects in humans.

Biological monitoring for lead is conducted by taking a blood sample and measuring the blood lead level. Blood lead levels differ for females, females of reproductive capacity, and males. After an initial blood test to determine blood lead levels, the following applies. For females not of reproductive capacity and males, biological monitoring must be conducted:

• 6 months after the last test if the last result showed a blood lead level of less than 10 µg/dL (0.48 µmol/L)
• 3 months after the last test if the last results showed a blood lead level of 10 µg/dL (0.48 µmol/L) or more but less than 20 µg/dL (0.97 µmol/L), or
• 6 weeks after the last test if the last results showed a blood lead level of 20 µg/dL (0.97 µmol/L) or more.

For females of reproductive capacity, biological monitoring must be conducted:

• 3 months after the last test if the last result showed a blood lead level of less than 5 µg/dL (0.24 µmol/L)
• 6 weeks after the last test if the last results showed a blood lead level of 5 µg/dL (0.24 µmol/L) or more but less than 10 µg/dL (0.48 µmol/L).

Audiometric Testing

Workers who are frequently required to wear hearing protection to protect them from the risk of hearing loss associated with noise that exceeds the exposure standard for noise must undergo regular audiometric testing (as provided by their employer).

Audiometric testing is conducted for HY employees within 3 months of the worker beginning work. Follow up audiometric testing is to be undertaken at least every 2 years thereafter for employees who predominantly work on site and is optional or available upon request for all staff.

Pre-Employment Medical Assessment

Prior to commencing employment at HY, employees are required to undergo a medical assessment by a qualified Medical Practitioner.  The Medical personnel performing the examination/s must be qualified to carry out the assessment/s.  The Employment Medical assesses the following as a minimum:

• Physical examination
• Audiometric testing
• Cardiovascular system
• Respiratory system
• Locomotor system (movement)
• Skin check
• Drug testing (urinary testing)
• Vision

Inspection Measuring and Test Equipment 

Inspection, measuring and test equipment related to HSE must be maintained and stored in accordance with the manufacturer’s recommendations, relevant legislation and Australian Standards.  This includes: 

• Anemometers 
• Noise Meters 
• Dust Meters 
• Gas meters & monitors 
• Breathalysers 
• Lasers 
• Light (Lux) meters 
• RCD calibration testers 
• Health monitoring equipment such as air monitors 

All HSE equipment must be calibrated in accordance with ISO 10012.  HY obtains a copy of the calibration records for registered equipment which is kept in the Project HSE files. 

Reports And Record Keeping

HEALTH MONITORING RECORDS

Health monitoring reports are to be kept as a confidential record by the employer.  They are to be kept for at least 30 years as defined by legislation.  Asbestos health monitoring reports are to be kept for at least 40 years.

Health monitoring reports and results of a worker must not be disclosed to another person without the worker’s written consent.  This does not apply if the record is being disclosed, as per legislative requirements, to:

• the regulator (as required)
• other PCBUs who have a duty to provide health monitoring to that worker

Definitions And Abbreviations

Audiometric testing – testing and measurement of the hearing threshold levels of each ear of a person by means of pure tone air conduction threshold tests

Biological monitoring – measurement and evaluation of a substance, or its metabolites, in body tissue, fluids or exhaled air of a person exposed to the substance

Exposure standard – an exposure standard in the Workplace Exposure Standard for Airborne Contaminants

Health monitoring – monitoring a person to identify changes in the person’s health status because of exposure to certain substances

Registered Medical Practitioner – person registered under the Health Practitioner Regulation National Law to practice in the medical profession (other than a student)

References

• Work Health & Safety Regulation 2011 (QLD), 2012 (SA/TAS) and 2017 (NSW)

• Part 3.2 Division 7 Managing risks from airborne contaminants
• Part 4.1 Noise
• Part 4.3 Confined spaces
• Part 4.8 Diving Work: Division 2 General diving work-fitness and competence of worker
• Part 7.1 Hazardous Chemicals: Division 6 Health monitoring
• Part 7.2 Lead: Division 4 Health monitoring
• Part 8.5 Asbestos at the workplace: Division 1 Health monitoring

• Occupational Health and Safety Regulations 2017 (Victoria)

• Part 3.2 Noise: Division 3 Audiometric tests and audiological examinations
• Part 3.4 Confined spaces
• Part 4.1 Hazardous substances: Division 3 Duties of employers and self-employed persons
• Part 4.2 Lead: Division 2 Duties of employers
• Part 4.4 Asbestos: Division 7 Removal of asbestos

• Workplace Exposure Standards for Airborne Contaminants (16 December 2019) Safe Work Australia 
• Guidance on the Interpretation of Workplace Exposure Standards for Airborne Contaminants (April 2013) Safe Work Australia 
• ISO 10012: 2003 Measurement management systems – Requirements for measurement processes and measuring equipment
• Federal Safety Commission (FSC) Audit Criteria – WH14 Health Surveillance and Exposure Monitoring

Associated Documents

• HY Fitness for Work policy
• HY Privacy Policy
• Fitness for Work procedure
• Drugs and Alcohol Management procedure