Managing the risks from air pollution: Advice for PCBUs

Your duty to manage risks from air pollution 

The model WHS laws require you to manage WHS risks at your workplace, including from air pollution. The model WHS Act requires you to ensure, so far as is reasonably practicable, the health and safety of your workers and others at your workplace. This includes providing and maintaining a work environment that is without risks to health and safety. 

To meet your WHS duty, you must identify hazards at your workplace, and the associated risks. Air pollution is a hazard. You can identify when this hazard may be present at your workplace, and the level of risk it might pose to workers, by monitoring your jurisdiction’s air quality index, considering advice and guidance from experts (for example, public health officials), and talking to your workers. You could also undertake air quality testing at your workplace to monitor the ongoing risk. 

You must first aim to eliminate WHS risks. If elimination is not reasonably practicable, you must minimise the risks so far as is reasonably practicable. You should follow the hierarchy of control measures, which ranks the ways of controlling risks from the highest level of protection and reliability (eliminating the risk) to the lowest (PPE). 

How the hierarchy of control measures can be applied to manage the risks from air pollution is set out below. 

More information on the hierarchy of control measures can be found in the model Code of Practice: How to manage work health and safety risks. 

Start from the top of the hierarchy of control measures and do what is reasonably practicable 

Whether a control measure is reasonably practicable for you to implement involves consideration of what is able to be done to manage a risk and whether it is reasonable in the circumstances for you to do so. 

  • The state of knowledge about a risk and ways of eliminating or minimising the risk is a key consideration in determining what can be done to manage a risk. This guidance can assist you with that consideration. 

  • The likelihood of the risk occurring, the degree of harm that might result and the availability and suitability of a control measure are key considerations in determining whether that measure is reasonable to implement in your circumstances. 

Some of your workers may have a pre-existing condition that makes them more sensitive to air pollution (for example, asthma or other respiratory conditions). 

Special consideration may also need to be given to older workers and pregnant women. You may or may not know who these workers are. If you know a worker has a condition that might make them more vulnerable, you should confidentially talk to them about their needs. 

You should also consider what you can do to manage risks to workers who may be more sensitive to air pollution, but who you don’t know about (for example, look out for signs of workers who might be more sensitive and/or invite workers to talk to you about relevant health conditions and needs). 

More information on determining what is reasonable practicable can be found in the Guide: How to determine what is reasonably practicable to meet a health and safety duty. 

Talk to your workers throughout this process 

You must talk to your workers and their elected Health and Safety Representatives (HSRs) and take their views into account when deciding on control measures to eliminate or minimise WHS risks at your workplace, including measures to eliminate or minimise risks from air pollution. 

Hearing the experience of your workers allows you to make more informed decisions and helps build worker awareness, understanding and commitment to the decisions made. 

More information on your duty to consult with workers and HSRs can be found in the model Code of Practice: Work health and safety consultation, cooperation and coordination. 

Applying the hierarchy of control measures to manage risks from air pollution 

Eliminate the risk by eliminating the hazard 

Eliminate risks to health and safety 

You must always eliminate the risk unless it is not reasonably practicable to do so. Eliminating exposure to air pollution is the best protection. 

Examples 

  • Relocate work to areas with good air quality (for example, employees working from home or alternative sites) 

  • If air pollution is limited to outdoors, postpone outdoor work 

Substitute the hazard, isolate the hazard, or reduce the risk with engineering control measures 

Minimise risks by substituting the hazard with a safer alternative (less risk) 

Find alternative work or work processes with better air quality. 

Examples 

  • Work inside where possible 

  • Reduce the physical intensity of work to reduce how much air pollution is inhaled 

Minimise risks by isolating the hazard from people 

Protect workers from exposure by isolating them from air pollution. 

Examples 

  • Ensure doors and windows are well sealed 

  • Minimise door and/or window opening to the outdoors (for example, shop doors and sliding service windows should be kept closed whenever possible) 

  • Switch air conditioning or ventilation systems to recycle or recirculate, to avoid bringing poor quality outdoor air inside 

  • Use closed-cab vehicles with ventilation set to recycle the air inside the cab 

  • Avoid using evaporative air conditioners that pull air in from outside with no or little filtering 

Note: domestic evaporative air conditioners are more likely to bring air pollution inside. Commercial evaporative air conditioners may filter out some larger particles, but not all. Check the specification with the manufacturer. 

Minimise risks by implementing engineering control measures 

Engineering control measures are physical or mechanical measures that can improve the air quality for workers. 

Examples 

  • Use air purifiers 

  • Use air locks or air curtains to create an air barrier with the outside environment 

Reduce exposure with administrative control measures and personal protective equipment (PPE) 

Note: These measures are the least effective at minimising risk. They should only be used to supplement higher level measures, as short-term interim measures, or as a last resort. 

Minimise the remaining risk using administrative control measures 

Administrative control measures are measures that rely on human assessment and intervention to work effectively, and includes methods of work, processes or procedures designed to minimise risk. 

Examples 

  • Increase frequency and length of rest times, and provide an indoor area for rest times, where possible 

  • Rotate staff who work outside through an indoor environment to limit prolonged exposure 

  • Vacuum indoor areas regularly with a vacuum cleaner that has a HEPA filter to reduce the build-up of settled particulates 

  • Provide workers with water, eye drops and saline nasal sprays to reduce irritation of eyes, nose and throat 

  • Air out buildings on days with better air quality 

  • Request that workers and others at your workplace only use one entrance to a building to limit flow of poor quality air into a building 

  • Implement a policy on when and how you will monitor air quality and what you will do to manage risks from air pollution 

  • Provide training and information to workers 

  • Know the physical effects of air pollution, such as difficulty breathing, coughing, blurred vision and irritability, and provide information on the effects to your workers 

  • Make allowances for workers suffering physical effects of air pollution (for example, by providing modified duties) 
    Note: Eligible workers would also be entitled to personal leave if they are not fit for work due to the physical effects of air pollution. 

  • Ensure plant is functioning correctly and has not been affected by dust or debris 

  • Once conditions improve, clean any dust and debris off outdoor surfaces by wet wiping or using a HEPA filtered vacuum cleaner 

  • Ensure workers  have an effective means of communication if working alone, remotely or in an isolated place 

Minimise the remaining risk by providing and using personal protective equipment 

Personal protective equipment (PPE) limits exposure to the harmful effects of a hazard, but only if it is worn and used correctly. 

PPE must be suitable, maintained properly and workers must be instructed on how to use it properly. 

Examples 

  • Use P2 or N95 masks for respiratory protection. However, it is essential that they are fitted properly. 

  • For information about how to properly fit a mask, refer to the manufacturer’s instructions 

  • If the mask is damaged, dirty or wet, replace it 

  • Be aware that P2 masks may make it more difficult to breathe and can increase the risk of a heat-related illness 
    Note: Paper dust masks, bandanas or handkerchiefs are not a substitute as they do not filter out fine particles, eg from bushfire smoke 

  • Use eye protection to help avoid eye irritation caused by air pollution, which can result in blurry vision. 
    Note: It is important to consider what eye protection is appropriate for the worker and their task. 

  • For more information on the requirements for PPE, visit our Personal Protective Equipment web page 

Further considerations 

You should also be mindful that the level of other WHS risks might also increase in circumstances when workers are facing WHS risks from air pollution. For example, air pollution due to bushfire smoke will generally occur during the Australian summer, when WHS risks for outdoor workers from heat and sun (ultraviolet) exposure are also increased. 

There may also be increased risks from fatigue for workers balancing volunteer emergency management activities with work commitments during the bushfire season. Workers may also face increased risks to their mental health during and after disaster and emergency situations.

 

Find out more: