Health monitoring – Legislative requirements for registered medical practitioners (RMP)

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Health monitoring is the monitoring of a person’s health for the purpose of identifying changes in the person’s health status resulting from exposure to a hazardous chemical.

Health monitoring enables the Registered Medical Practitioner (RMP) to identify any potential adverse effect on health from exposure to a hazardous chemical in the workplace. Early identification enables early intervention (e.g. hygiene and safe work practices, removal from further exposure, remedial action by the workplace) to prevent serious harm to the worker. 

Becoming an RMP who provides health monitoring

RMP should have a good understanding of the relevant Work Health and Safety Regulations 2022 (‘WHS Regulations’) as listed in Section 3.

Medical practitioners who wish to become an RMP are required to have adequate experience to conduct health monitoring in relation to the hazardous chemical in question, and are appointed by the person conducting a business or undertaking (PCBU).

Health monitoring requirements

Health monitoring requirements are specified in the following WHS regulations:

  • Regulations 368 –378 (Part 7.1 Hazardous Chemicals, Division 6 Health Monitoring),
  • Regulations 405 – 418 (Part 7.2 Lead, Division 4 Health Monitoring)
  • Regulations 435 – 444 (Part 8.5 Asbestos at the workplace, Division 1 Health Monitoring)
  • Schedule 14 Requirements for Health Monitoring

The PCBU is required to provide health monitoring at no cost to the worker, if the health of the person is at risk as a result of the person’s exposure at the workplace to a hazardous chemical.

The PCBU is required to ensure that health monitoring is supervised by an RMP.

Health monitoring includes:

  • obtaining a work history (nature of exposure, duration, work activity, work environment and controls, personal hygiene) and health screening questionnaire
  • physical examination, as required
  • biological monitoring where there are recognised tests and biological exposure indices for substances or metabolites e.g. blood or urine test
  • other relevant medical investigations (e.g. lung function tests (spirometry), chest imaging, etc).

Role of the RMP

The RMP has an important role in providing education on potential health effects, the importance of personal hygiene and correct use of personal protective equipment (PPE) for the protection of the health and safety of the workers.

The RMP should be familiar with the relevant regulations (provided in Section 3); in particular;

  • Regulation 368, requiring health monitoring for exposures to hazardous chemicals listed in Schedule 14, and for any other hazardous chemicals where there is risk to health and suitable health monitoring techniques are available;
  • Regulation 371, requiring health monitoring be supervised by a registered medical practitioner with experience in health monitoring;
  • Regulation 373, detailing information that must be provided to a registered medical practitioner;
  • Regulation 374, specifying the health monitoring report requirements including the provision of the report directly to the PCBU;
  • Regulation 376, requiring the RMP to provide the regulator a copy of the health monitoring report if the results are consistent with exposure (this includes where the work tasks involve exposure);
  • Schedule 14 - Table 14.1 lists the 15 main hazardous chemicals for which health monitoring is required on a risk basis;
  • Schedule14 Table 14.2 Lead health monitoring; and
  • Part 8.5, Division 1- Health monitoring for asbestos.

Contravention of regulation 376 may result in a penalty of $7,000 for an individual or $35,000 for body corporate.

The RMP assesses the risk to health from exposure to the hazardous chemical and provides recommendations to the PCBU on whether medical counselling is required, whether the worker may continue working with the hazardous chemical, and any relevant remedial measures.  The RMP is required to use the WorkSafe WA health monitoring report forms.

In the event of a medical removal, the RMP:

  • Notifies WorkSafe WA promptly by phone 1300 307 877 and/or email safety@dmirs.wa.gov.au; and
  • Examines the worker before making recommendations for a return to work with the hazardous chemical.

Prompt notification to WorkSafe enables early intervention from WorkSafe to protect the health and safety of workers.

The RMP should refer to WorkSafe WA guidelines for medical practitioners for specific hazardous chemicals.  In the absence of a specific WorkSafe WA guideline, reference can be made to Safe Work Australia guidelines.

The RMP may request to speak to the WorkSafe Occupational Health Nurse or the Occupational Physician to clarify relevant issues.

References

Department of Energy, Mines, Industry Regulation and Safety (DEMIRS)

 

Safe Work Australia guides are useful as an adjunct resource.

 

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