Chemical Exposure Limits Are Changing: Why Workplaces Should Act Before the Rules Catch Up

Australian workplaces are once again being reminded that hazardous chemical exposure is not always immediate, visible or obvious.

A recent ABC News report highlighted calls from leading lung doctors and public health organisations for stronger protection for workers exposed to nine hazardous workplace chemicals, including benzene, formaldehyde, respirable crystalline silica, chlorine, copper, hydrogen cyanide, hydrogen sulphide, nitrogen dioxide and titanium dioxide. The report noted that workers in construction, demolition, tunnelling, healthcare, laboratories and other industrial settings may be among those most exposed.  

The issue is not just whether a business is currently meeting today’s legal exposure standard. It is whether the organisation has a reliable, evidence-based system for identifying chemical hazards, assessing exposure risk, implementing controls, monitoring effectiveness and acting when conditions change.

Exposure standards are not a “safe/unsafe” line

Safe Work Australia is transitioning from Workplace Exposure Standards to Workplace Exposure Limits for airborne contaminants from 1 December 2026. Until then, PCBUs must continue to comply with the current WES list, while preparing for the WEL transition.  

Safe Work Australia also makes an important point: exposure limits are not a simple dividing line between a healthy and unhealthy workplace. Individual workers may still experience adverse effects below a stated limit, so PCBUs must continue to eliminate or minimise exposure so far as is reasonably practicable.  

This matters because many airborne contaminants may not be visible or detectable by smell. Dusts, fumes, gases, vapours and mists can be generated by routine work processes, meaning exposure can occur even when the workplace appears clean or well controlled.  

The nine chemicals under review

Safe Work Australia has identified nine chemicals for further consideration by WHS ministers:

• benzene  

• chlorine  

• copper fumes, dusts and mists  

• formaldehyde  

• hydrogen cyanide  

• hydrogen sulphide  

• nitrogen dioxide  

• respirable crystalline silica  

• titanium dioxide  

Safe Work Australia has developed a Decision Regulation Impact Statement for these chemicals, which has been provided to WHS ministers for consideration. Until a decision is made on each proposed limit, the current workplace exposure standards for these nine chemicals continue to apply.  

For many organisations, the practical lesson is clear: don’t wait for regulatory changes before reviewing chemical risk controls. If a substance is hazardous, difficult to detect, frequently used or generated through high-risk work, it should already be subject to robust controls and regular review.

Silica shows why recordkeeping and controls matter

Respirable crystalline silica remains one of the most visible examples of long-latency occupational disease risk. Safe Work Australia states that crystalline silica is found in sand, stone, concrete and mortar, and that respirable crystalline silica can be generated by processes such as crushing, cutting, drilling, grinding, sawing or polishing materials that contain silica. It can penetrate deep into the lungs and cause irreversible lung damage.  

Australia has already taken major steps on silica, including the engineered stone ban from 1 July 2024 and stronger regulation of work with materials containing at least 1% crystalline silica from 1 September 2024. These changes require stronger controls for crystalline silica substances, including risk assessment and, for certain high-risk engineered stone work, silica risk control plans.  

But silica is only one part of the broader chemical exposure challenge. Similar principles apply to other hazardous substances: know where they are used or generated, understand who may be exposed, verify that controls are working, and maintain evidence that risks are being managed.

What PCBUs should be doing now

For organisations managing hazardous chemicals, now is a good time to review whether the following information is current, complete and easy to access:

1. Chemical registers and Safety Data Sheets
   Every hazardous chemical should be identified, with current Safety Data Sheets available to workers and supervisors.  

2. Task-based risk assessments
   Chemical risk should be assessed in the context of the actual work being performed, not just the product being used. Cutting, heating, spraying, mixing, grinding or cleaning can change the exposure profile.  

3. Exposure controls
   Higher-order controls should be prioritised wherever possible, including elimination, substitution, isolation, engineering controls and process redesign. PPE should not be the only control relied on.  

4. Air monitoring
   Safe Work Australia says air monitoring is required where a PCBU is not certain on reasonable grounds whether airborne concentrations exceed the exposure standard, or where monitoring is necessary to determine whether there is a risk to health. Air monitoring can help identify exposure levels, sources of exposure and whether controls are working.  

5. Health monitoring
   Where required, health monitoring should be planned, documented and reviewed, especially for workers exposed to hazardous chemicals with long-term health risks.  

6. Actions and corrective controls
   Findings from inspections, monitoring, incidents, audits and worker reports should trigger actions that are assigned, tracked and closed out.  

7. Training and consultation
   Workers should understand the chemicals they work with, the health risks, the controls in place, how to use those controls and how to report concerns.  

8. Review and assurance
   Chemical risk controls should be reviewed after changes to work methods, substances, equipment, exposure limits, monitoring results, incidents or health monitoring outcomes.  

Why digital systems make chemical risk easier to manage

Chemical safety often fails when information is scattered across spreadsheets, folders, emails and paper-based forms. A chemical register may exist, but it may not be connected to inspections, risk assessments, corrective actions, training records, exposure monitoring or dashboards.

A modern HSEQ system can help organisations bring these elements together. For example, myosh can support chemical risk management by helping organisations maintain chemical registers, attach SDS documentation, record risk assessments, assign corrective actions, schedule inspections, track training and provide dashboard visibility over outstanding controls.

This is particularly important for larger or multi-site organisations where chemical exposure risks vary by site, contractor group, work activity or asset. Centralised data helps safety teams identify trends, verify control effectiveness and maintain a clear audit trail.

Chemical exposure risk should not be managed reactively. Whether or not a specific exposure limit changes, PCBUs still have a duty to eliminate or minimise risks so far as is reasonably practicable.

The current national discussion around hazardous chemicals is a timely reminder to check whether your organisation can answer some simple but critical questions:

Do we know which hazardous chemicals are used or generated across our operations?
Do we know who may be exposed, and during which tasks?
Are controls documented, implemented and verified?
Can we prove that monitoring, training, inspections and corrective actions are happening?
Are we ready if exposure limits become more stringent?

For many businesses, the safest time to improve chemical risk management is before the next regulatory deadline arrives.