When Is Health Surveillance Required in the Workplace?
A practical guide for Australian employers on when health surveillance becomes a legal requirement, what triggers it, and how to set up a compliant monitoring program.
What Is Health Surveillance?
Health surveillance is the systematic monitoring of workers' health to detect early signs of ill health or disease caused by exposure to workplace hazards. It is not a general health check. Health surveillance is targeted monitoring specifically linked to identified workplace exposures that pose a risk to workers' health.
The purpose of health surveillance is to detect adverse health effects at an early stage, before they become serious or irreversible. It also provides data that the employer can use to evaluate whether existing control measures are working. If monitoring shows that workers are developing health effects despite controls being in place, the controls are inadequate and need to be improved.
Health surveillance is a legal requirement under the Work Health and Safety Act 2011 and the Work Health and Safety Regulation 2017 when specific triggers are met. It is not at the employer's discretion - when the conditions exist, surveillance must be provided.
When Health Surveillance Is Legally Required
Under Regulation 368 of the WHS Regulation 2017, health monitoring is required when a worker is carrying out work that involves a risk of exposure to a substance listed in Schedule 14, and there is a valid way of detecting the health effect associated with that exposure. The regulation specifies both the triggering substances and the type of monitoring required for each.
Beyond Schedule 14, the general duty provisions of the WHS Act can also trigger health surveillance for other hazards where monitoring is a reasonably practicable control measure. The key test is whether there is a valid method of detecting the health effect and whether early detection would benefit the worker.
Schedule 14 Hazardous Substances
Schedule 14 of the WHS Regulation 2017 lists specific substances that trigger mandatory health monitoring. These include crystalline silica (silicosis risk), lead and inorganic lead compounds, asbestos (for workers involved in asbestos removal or related work), isocyanates (used in spray painting, foam manufacturing), organophosphate pesticides, and several other substances. For each substance, the schedule specifies the type of monitoring required - for example, blood lead levels for lead exposure, lung function testing for silica exposure.
Noise Exposure
Workers exposed to noise at or above LAeq,8h of 85 dB(A) or LC,peak of 140 dB(C) require audiometric testing. This is covered under Part 4.1 of the WHS Regulation 2017. Baseline audiometry should be conducted before noise exposure begins, with monitoring every two years at minimum.
Hazardous Manual Tasks
While not specified in the same way as chemical exposures, workers performing hazardous manual tasks that create a risk of musculoskeletal disorders may benefit from health monitoring as part of an injury prevention program. This is where pre-employment screening and periodic functional assessments fit into the broader health surveillance framework.
Types of Health Monitoring
The type of health monitoring required depends on the hazard. The WHS Regulation 2017 specifies the monitoring method for each listed substance. Common types include the following.
Biological monitoring
Blood or urine tests that measure the level of a substance or its metabolites in the worker's body. Used for lead exposure (blood lead levels), organophosphate exposure (cholinesterase levels), and other substances where biological markers are available. Provides a direct measure of the worker's internal exposure.
Lung function testing (spirometry)
Measures the volume and flow rate of air that the worker can inhale and exhale. Used for workers exposed to dusts, fumes, and respiratory sensitisers including silica, asbestos, isocyanates, and wood dust. Spirometry detects early restrictive or obstructive changes in lung function before symptoms develop.
Audiometric testing
Measures hearing thresholds across frequencies to detect noise-induced hearing loss. Required for workers exposed to hazardous noise levels. Establishes baseline hearing and tracks any deterioration over time.
Skin examination
Visual inspection of the skin for dermatitis, sensitisation, or other changes. Used for workers exposed to skin sensitisers, irritants, or chromium compounds. Early detection prevents progression to chronic occupational dermatitis.
Health questionnaires and clinical examination
Structured questionnaires about symptoms combined with a clinical examination by a medical practitioner. Used as a screening tool alongside more specific tests. Can identify early symptoms that warrant further investigation.
Employer Obligations for Health Surveillance
When health surveillance is triggered, the employer has several specific obligations under the WHS Regulation 2017.
Provide at Employer's Cost
Health surveillance must be provided at no cost to the worker. The employer pays for the testing, the clinician's time, and any follow-up required. Testing should be conducted during work hours wherever practicable.
Use a Registered Medical Practitioner
Health monitoring for hazardous substances must be carried out by or under the supervision of a registered medical practitioner with experience in health monitoring. For some exposures, the practitioner needs specific expertise in occupational medicine.
Keep Records for 30 Years
Health monitoring records must be kept for at least 30 years. This long retention period reflects the latency of many occupational diseases - silicosis, mesothelioma, and noise-induced hearing loss can take decades to manifest. Records must be kept confidential and stored securely.
Act on Results
If monitoring reveals an adverse health effect, the employer must investigate the cause, review control measures, and take action to prevent further exposure. The affected worker must be informed of the results and provided with access to appropriate medical follow-up.
How Health Surveillance Fits Into Your Broader Risk Management
Health surveillance is not a standalone activity. It sits within the hierarchy of controls as a monitoring measure that checks whether higher-order controls (elimination, substitution, engineering controls, administrative controls, PPE) are effective.
A workplace risk assessment identifies the hazards present in the workplace and the workers who are exposed. The risk assessment determines which controls are needed, including whether health surveillance is required. The two are directly linked - you cannot set up a health surveillance program without first understanding what the exposures are.
For physical hazards, pre-employment screening and periodic functional assessments complement the health surveillance framework. A pre-employment assessment establishes a baseline for the worker's physical health, and ongoing monitoring tracks any changes that may be attributable to workplace exposures or demands.
Common Mistakes Employers Make
Health surveillance is one of those obligations that employers sometimes get wrong, often through incomplete implementation rather than deliberate non-compliance.
Testing without acting on results
Some employers conduct health monitoring but do not act when results show a problem. Monitoring without action is not compliance. The WHS Regulation requires the employer to investigate and respond to adverse findings, including reviewing and improving control measures.
Not covering all exposed workers
Health surveillance must cover all workers exposed to the hazard, including casual employees, labour hire workers, and contractors. Missing certain worker categories creates gaps in the monitoring program and leaves those workers unprotected.
Inadequate record keeping
Records must be maintained for 30 years. Employers who do not have a proper system for storing and managing health monitoring records will fail to meet this obligation. Electronic record management systems are recommended over paper-based systems for long-term retention.
If you need help determining whether health surveillance is required for your workplace, or setting up a monitoring program, contact us to discuss your situation.
Frequently Asked Questions
What triggers the requirement for health surveillance in the workplace?
Health surveillance is required when workers are exposed to hazards listed in Schedule 14 of the WHS Regulation 2017, such as crystalline silica, lead, asbestos, or isocyanates. It is also required for workers exposed to hazardous noise levels above 85 dB(A) LAeq,8h. The general trigger is any workplace exposure where there is a valid method of detecting the associated health effect.
How long must health surveillance records be kept?
Health surveillance records must be kept for at least 30 years after the record is made. This long retention period accounts for the latency of occupational diseases like silicosis, mesothelioma, and noise-induced hearing loss, which can take decades to develop after exposure.
Who pays for health surveillance in the workplace?
The employer pays. Health surveillance required under WHS legislation must be provided at no cost to the worker. This includes the testing, the clinician's time, and any follow-up required as a result of the monitoring.
Key Takeaways
- Required by WHS Regulation 2017
- Covers Schedule 14 substances
- Includes noise and dust exposure
- Records kept for 30 years
- Employer funded at all times
- Detects health effects early
- Links to risk assessment program
Need a Health Surveillance Program?
We help employers set up compliant health monitoring programs linked to workplace risk assessments.
Contact Usor call 0431 092 829
Related Services
Content reviewed by Jovi Villanueva, AHPRA Registered Physiotherapist, SIRA Approved Provider, Principal Physiotherapist at Wellworx Workplace Solutions.
Last updated: June 2026
Set Up a Health Surveillance Program
Compliant health monitoring linked to your workplace risk profile. On-site delivery across Sydney.