| 📋 Article Summary — Occupational Hygiene Programme Audit | |
|---|---|
| Entity | Anitech Group — Occupational Hygiene |
| Article Type | Programme Assessment Guide |
| Target Audience | WHS managers, EHS directors, internal auditors, organisations seeking ISO 45001 or external WHS certification |
| Key Entities | Safe Work Australia, ISO 45001:2018 (OHS Management Systems), AIOH, model WHS Act |
| Regulations & Standards | ISO 45001:2018 Occupational health and safety management systems; model WHS Act s.19 primary duty; How to Manage WHS Risks Code of Practice — regulatory basis for audit findings |
| Key Fact 1 | A 2022 SafeWork NSW inspection campaign found that 60% of construction sites audited had no evidence of RCS monitoring records for dust-exposed workers — making monitoring gap audits a high-value activity before regulatory inspections. |
| Key Fact 2 | Regulatory audits are unannounced and may require immediate production of monitoring records — if records cannot be located and produced quickly, regulators may assume they do not exist. |
| Key Fact 3 | An occupational hygiene audit is not the same as a safety observation tour — it systematically reviews documentation, records, programme design, and compares findings against legislative requirements, not just best practice. |
| What This Covers | Audit scope and planning, document review checklist, field verification activities, gap analysis against regulatory requirements, corrective action prioritisation, audit reporting |
| What This Does Not Cover | OH audit in specific sectors (mining, construction, manufacturing) — sector-specific requirements beyond the model WHS framework |
| Primary CTA | Contact Anitech for an independent occupational hygiene programme audit and gap analysis |
| Read Time | 9 min read |
Occupational Hygiene Audit: How to Assess Your Monitoring Programme
An occupational hygiene programme audit is a systematic, documented examination of whether your workplace monitoring, health surveillance and control verification activities meet legal requirements, professional standards, and your own internal policies. It is distinct from a routine WHS inspection — it specifically evaluates the design and performance of the hygiene programme over time, not just current conditions on the day of inspection.
Organisations conduct OH programme audits for several reasons: internal quality assurance, preparation for regulatory inspection, ISO 45001 certification, post-incident review, or as part of a broader WHS management system review. An external audit conducted by an independent qualified hygienist adds credibility and identifies blind spots that internal teams may have normalised.
Audit Scope Planning
Before conducting the audit, define its scope clearly:
- Which sites, operations or business units are included
- Which hazard categories are covered (chemical, dust, noise, biological, or all)
- The audit period under review (typically the preceding 12–24 months of programme activity)
- The standard against which findings will be evaluated (model WHS regulations, specific codes of practice, internal policy, ISO 45001)
Document Review Checklist
The document review phase examines the paperwork trail of the hygiene programme. Key documents to request and review:
- Chemical register and SDS library: Is it current? Does it include all chemicals in use? Are high-hazard substances identified?
- Hazard identification records: Is there a documented process for hazard identification and has it been applied recently?
- Exposure monitoring records: Are there records for all monitored hazards? Do they include: sampling date, SEG, worker details, pump calibration records, laboratory reports, and WES comparison? Are records retained for the required period (minimum 30 years for carcinogens and silica)?
- Health surveillance records: Is there a register of workers enrolled in health surveillance? Are individual records complete? Have results been communicated to workers? Are regulatory notifications documented for any positive findings?
- Control verification records: Are LEV inspection and maintenance records available? Are RPE fit test records current? Are engineering control effectiveness reviews documented?
- Training records: Evidence of worker training on hazardous substance SDS, control use, RPE, and health surveillance obligations
- Corrective action register: Documented response to past monitoring exceedances, health surveillance findings, and previous audit recommendations
Field Verification
Document review must be supplemented by field verification — physically checking that what the documents claim is occurring is actually happening:
- Observe actual work practices during dust or chemical-generating tasks — do workers actually use the controls specified in procedures?
- Check LEV system condition — are hoods positioned correctly? Are extraction ports unblocked? Is the system operating (measure face velocity with an anemometer)?
- Check RPE storage — are respirators stored clean and undamaged? Are there unexpired replacement filters?
- Interview workers: Do they know what they are exposed to? Do they know how to use controls? Have they participated in health surveillance?
- Check chemical storage areas — are incompatible chemicals separated? Are SDS accessible to workers in storage areas?
Gap Analysis and Findings Classification
Findings from document review and field verification are classified by severity:
- Major non-conformance: A systemic failure or absence of a required programme element — no monitoring records for a high-hazard substance, health surveillance not conducted for mandatory surveillance workers, no corrective action for past WES exceedances. These require immediate attention and a documented response within days to weeks
- Minor non-conformance: A requirement is being met but with gaps, inconsistencies or lapses — monitoring records exist but are missing pump calibration documentation, health surveillance is conducted but records are not well organised. These require correction within a defined timeframe
- Observations (improvement opportunities): Programme meets minimum requirements but could be improved — monitoring frequency could be increased for borderline-compliant SEGs, health surveillance forms could be standardised
Corrective Action Prioritisation
Not all findings can be remediated simultaneously. Prioritise based on:
- Regulatory risk (major non-conformances for legally mandatory elements first)
- Health risk (hazards with highest disease severity — carcinogens, respiratory sensitisers — before nuisance dusts)
- Number of workers affected
- Feasibility (quick wins that can be completed immediately without significant resources)
A corrective action register with assigned owners, due dates and status tracking should be established from audit findings. The register is reviewed at the next management WHS review meeting to confirm progress.
