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Health monitoring requirements

Submitted by sat on 28 August 2019

Answer reviewed 02 February 2023

The hazardous chemicals used in schools that are included in our List of Recommended Chemicals are generally used infrequently, in small quantities and for a short exposure time. Control measures determined by a risk management approach in consultation with the information found in the chemical’s Safety Data Sheet should be in place such as engineering controls (e.g. fume cupboard) and Personal Protective Equipment (PPE) to further limit the exposure.

By following Science ASSIST recommendations and jurisdictional policies for working with hazardous chemicals, there should be no situation that warrants health monitoring in school science.1

The model WHS Regulations:

The model WHS Regulations set out instructions regarding the requirement for health monitoring in regulations 368, 405 and 435. Health monitoring, such as testing body fluids or function, is required ‘if the worker is carrying out ongoing work using, handling, generating or storing hazardous chemicals and there is a significant risk to the worker’s health because of exposure to a hazardous chemical referred to in Schedule 14, table 14.1, column 2(Reg 368)’ where there are valid tests available; and for lead risk work (Reg 405) and asbestos (Reg 435).2

There are only two chemicals from schedule 14, chromium and mercury, that are included in the list of recommended chemicals:

Schedule 10 in the Regulations sets out prohibited carcinogens in table 10.1, and restricted carcinogens in table 10.2. There are no chemicals from either of these lists in the list of recommended chemicals.

Schedule 10 in the Regulations lists restricted hazardous chemicals with restricted use in Table 10.3. These chemicals are not permitted to be used in certain concentrations for abrasive blasting or spray painting processes. Some chemicals from this list included in the list of recommended chemicals are

These chemicals should not be used in ways to create dust, fumes or aerosols that would contribute to exposure in the workplace.

While chemicals other than those listed in Schedules 10 and 14 can also be the focus for health monitoring,3 chemicals used in schools should not be used in a manner that would pose a significant risk to staff or students.

It is the responsibility of a person conducting a business or undertaking (PCBU) to determine if health monitoring is required. The Work Safe Australia web page, Health Monitoring4 provides access to specific factors to consider in making such a determination.

A note about sensitisers:

It is important to be aware that amongst hazardous chemicals, there are a number of chemicals used in schools which may be classified as sensitisers. These may be respiratory and/or skin sensitisers and the GHS classification may carry the exclamation or health hazard pictogram and relevant hazard statement.

Where a staff member or student has existing chemical sensitivities, e.g. latex allergies,5 precautions should be taken to avoid contact, similar to how a school would manage in cases where allergies are noted.

References and further reading

1 Safe Work Australia. (2020). Guide to the Model Work Health and Safety Regulations’ Retrieved from the Safe Work Australia website:

2 Safe Work Australia. (2013). Safe Work Australia website. Health Monitoring, Retrieved from the Safe Work Australia website.

3 The European Agency for Safety and Health at Work. (2003, June 18). ‘Factsheet 39 – Respiratory sensitisers’, Retrieved from the European Agency for Safety and Health at Work website:

4 The European Agency for Safety and Health at Work. (2003, June 18). ‘Factsheet 40 – Skin sensitisers’, Retrieved from the European Agency for Safety and Health at Work website,

5 Science ASSIST. (2017). AIS: Latex allergies in schools, Retrieved from the Science ASSIST website,

Safe Work Australia. (2021). ‘Model code of practice: Managing risks of hazardous chemicals in the workplace’ Retrieved from the Safe Work Australia website