Recent Changes to Health Surveillance Requirements
Updated: Jul 7
The requirement for undertaking health surveillance for workers in mineral mines and quarries has recently changed in the latest update to QGL02. Version 4 of QGL02 released in April 2021 has broadened the requirement for health surveillance by stipulating all workers are required to undertake respiratory health surveillance ‘unless the workers current or previous exposure to respiratory hazards is shown to be so minimal that risks can be managed without respiratory health surveillance’1. In practice, health surveillance now takes into account the past exposure history of the worker where previously it did not, as a consequence almost all workers at mineral mines and quarry sites will require health surveillance.
Groundwork Plus understands this change set by the Mines Inspectorate is to ensure any respiratory illnesses are diagnosed at an early stage and steps taken to slow progression of disease by ensuring further exposure to a respiratory hazard is prevented. Many respiratory diseases have latency periods in the decades, with most diseases irreversible and/or degenerative. Chronic obstructive pulmonary disease (COPD) is one such example where respiratory hazards cause permanent obstructions to the airways and tubes within the lungs; the Lung Foundation Australia estimates one in seven persons over 40 years have COPD though 50% of these people are unaware of their condition. Exposure to respirable dusts increases the risk of developing COPD and as such historically mining and quarrying as an industry is likely over-represented in respiratory disease statistics.
Health risk assessments undertaken by an occupational hygienist for airborne hazards in accordance with the requirements of QGL02 can be used to determine if a workers current exposure risk is minimal enough to remove the health monitoring requirement for current exposure. However, if in the past, the worker has had exposure to a respiratory hazard that carries an associated increase in risk of developing a respiratory disease, health surveillance requirements still apply.
Whilst QGL02 refers to the management of respirable dust, the health requirement refers to respiratory hazards which can extend past the subset of respirable dust to include other respiratory hazards where long-term exposures could amount to a respiratory illness (examples include diesel particulate matter, asbestos, wood dust, welding fumes etc.). The requirement also extends to other sectors outside of the mineral and mines and quarries industry to include other industries which contain long-term respiratory hazards such as manufacturing, demolition, building and construction.
As an example, if a worker is employed at a quarry in an indoor administrative position, health surveillance may still be required despite the role being recognised as an acceptable risk to respiratory hazards. Where the employee work history indicates previous exposures to respiratory hazards (occupations such as mining, asbestos work, timber miller, quarry worker etc), the health surveillance requirement is triggered.
Estimating a person's current exposure to airborne contaminants has improved over the years both through compulsory exposure monitoring programs and improved detection limits on analytical instrumentation. Assessing a person's historical exposure to a respiratory hazard may be a more complex task and as such a conservative approach should be taken when deciding health surveillance requirement based on previous work history. It is understood if a worker has previously been subject to respiratory health surveillance, the surveillance should be continued.
It should be noted that the health surveillance requirement applies of all persons who perform work at a mine and/or quarry. Under schedule 2 of the MQSH Act this includes all employees, contractors, labour hire workers and service providers onsite.
One practicable solution to help identify the health monitoring requirement for historical exposures could be as simple as a pre-employment or checklist undertaken approved by the SSE for any workers prior to undertaking works onsite.
Further detailed information on the health surveillance requirements including exemptions, frequency, authorised medical practitioners and approved tests can be found within the QLD mines inspectorate guideline QGL04 published in April 2021.
Health surveillance is an important tool used in combination with site dust exposure controls to minimise the health impacts to workers. Contact or call us on 1800 GW PLUS (1800 497 587) to better understand your health surveillance obligations and ensure everyone can breathe easier.
1 In previous editions of QGL02, health surveillance was only required for workers in similar exposure groups (SEGs) identified as having an estimated average exposures of greater than 50% of the shift adjusted exposure standard, it did not take into account a workers historical exposure.