Australia’s work health and safety landscape is undergoing one of its most significant regulatory shifts in recent years. From 1 December 2026, the current Workplace Exposure Standard (WES) framework will be replaced by Workplace Exposure Limits (WEL). This is a change that carries real implications for how organisations monitor, manage and document worker exposure to airborne contaminants, and strengthens expectations around exposure control.
For employers, WHS leaders and HR and People & Culture teams, the transition is more than a terminology update. It signals a tightening of scrutiny on air monitoring practices, control measures and worker health surveillance, particularly in high-risk roles across manufacturing, mining, construction, logistics and allied industries. Across the board, the time to prepare is now.
WES: Understanding the Current Framework
Before exploring what’s ahead, it’s important to understand the framework currently in place.
Under the model Work Health and Safety (WHS) Regulations, persons conducting a business or undertaking (PCBUs) are legally required to ensure that no worker is exposed to airborne contaminants at concentrations exceeding the Workplace Exposure Standards for Airborne Contaminants (the WES list). These standards are expressed in three forms:
- 8-hour Time Weighted Average (TWA): The average airborne concentration of a substance over a standard working day that is unlikely to cause an adverse health effect.
- Short-Term Exposure Limit (STEL): A 15-minute average concentration that must not be exceeded at any point during the working day.
- Peak Limitation: An instantaneous maximum concentration applicable where no TWA or STEL is set.
Employer Duties Under WES
PCBUs must currently:
- Identify hazardous airborne contaminants in the workplace
- Ensure exposures do not exceed the prescribed standard
- Conduct air monitoring where risk is uncertain or where exceedance is possible
- Implement control measures using the hierarchy of controls
Compliance with WES remains legally mandatory until 30 November 2026. Organisations should not delay action on the assumption that changes only apply later. This transition period is designed to run alongside (not instead of) existing duties.
WEL: What is Changing
From 1 December 2026, the WES list will be officially replaced by the Workplace Exposure Limits for Airborne Contaminants (the WEL list), following agreement by WHS ministers across all Australian jurisdictions. While many values remain similar, the new terminology deliberately reinforces these figures as enforceable exposure thresholds rather than advisory standards.
In practical terms, the WEL list introduces several substance-level changes, including:
- Reduced limits for some hazardous substances to reflect updated health evidence
- Increased limits in cases where data supports adjustment
- Newly listed substances now subject to defined exposure limits for the first time
- 33 airborne contaminants have been removed from the list entirely, in the absence of any safe level of exposure
- New notations have been introduced including DSEN (dermal sensitiser), RSEN (respiratory sensitiser) and OTO for chemicals that may increase hearing-damage risk under certain conditions
To see what’s changed, visit Safe Work Australia’s comparison table.
The Transition Period (Now – December 2026)
Regulators expect organisations with workers in high-exposure roles to use the transition period to compare their current airborne contaminant inventory against the WEL list. SafeWork Australia is also developing guidance resources throughout this period to assist PCBUs in preparing.
State and Territory Implementation:
WEL will be adopted across jurisdictions through amendments to WHS regulations, maintaining national consistency while enforcement remains state-based. Regulators including WorkSafe Victoria, SafeWork NSW and SafeWork SA are working to align regulatory instruments with the model WHS framework used across most of Australia.
For national employers, this means:
- Enforcement remains jurisdictional, but expectations are harmonised
- Compliance obligations are effectively consistent regardless of location
- Organisations operating across multiple states should adopt a unified national response rather than a site-by-site approach
Regardless of jurisdiction, the core compliance expectations are the same: understand your exposure risks, implement effective controls and monitor worker health where required.
Why Health Surveillance Will Matter More Under WEL
Health surveillance (or health monitoring) is required where workers are exposed to hazardous chemicals or agents that post a significant risk to health. It services three critical purposes:
- Early detection of harm, for intervention before irreversible injury occurs.
- Verification of control effectiveness, to prompt regular review and improvement.
- Evidence base for risk management, since surveillance data informs decisions about exposure controls, work practice and future monitoring frequency.
It’s important to remember that health monitoring is an additional layer of protection, not a substitute for eliminating or minimising exposure at the source. Monitoring workers without controlling exposure does not meet obligations.
Core Health Surveillance Programs Organisations Should Review
As exposure limits tighten, many businesses will need to formalise or expand surveillance programs aligned with their risk profile.
| Hazard / Exposure Type | Typical Health Surveillance | Purpose |
| Noise Exposure | Baseline and periodic audiometry | Detect early noise-induced hearing loss and validate noise controls |
| Respiratory Hazards (dusts, fumes, silica) | Spirometry and respiratory assessment | Identify decline in lung function linked to airborne exposure |
| Vision Risks | Task-specific vision screening | Ensure fitness for visually demanding or splash-risk roles |
| Hazardous Chemicals | Monitoring aligned with WHS Schedule 14 | Required for substances such as lead, benzene, mercury and organophosphates |
| Biological Monitoring | Blood or urine testing (where mandated) | Measure absorbed dose rather than airborne concentration alone |
| Skin / Dermatitis Risks | Periodic skin assessments | Detect early irritation or sensitisation from chemical exposure |
Bodycare can assist with delivery of effective programs which are risk-based, medically directed and integrated into broader safety systems, as opposed to being delivered as stand-alone testing.
Governance Requirements Employers Must Meet
Under WHS legislation, health surveillance must be:
- Conducted or supervised by a suitably qualified medical practitioner
- Arranged and funded by the PCBU
- Managed confidentially, with results provided appropriately to the worker
- Recorded and retained for extended periods (often 30 years or more)
These obligations carry significant administrative and legal weight, particularly for organisations with long-latency exposure risks.
What Regulators Will Be Looking For
As the 2026 implementation date approaches, regulators are expected to focus on whether organisations and PCBUs can demonstrate:
- A clear understanding of their airborne contaminant risks
- Evidence-based reassessment against updated WEL values
- Validated control measures (not assumptions)
- Appropriate air monitoring and exposure data
- Structured, risk-aligned health surveillance programs
- Inclusion of contractors and labour-hire workers in protection systems
Ultimately, documentation is key. Organisations that cannot demonstrate a systematic approach to managing airborne contaminant risks will face exposure, both in the regulatory sense and the reputational one.
What Employers Should Be Doing Now
Organisations that begin preparing and transitioning early will be far better positioned to manage both compliance and work health outcomes.
Recommended actions include:
- Review airborne contaminant risks against upcoming WEL values
- Identify gaps between current controls and future requirements
- Engage occupational hygienists and occupational health providers early
- Plan budgets and timelines for monitoring, surveillance and control upgrades
- Update SOPs, risk registers and Safety Data Sheet reviews
- Educate leaders and workers on exposure risks and monitoring programs
- Ensure contractor and labour-hire workforces are included in compliance planning
Preparing for a Strong Preventative Model
The move from WES to WEL reflects a broader national shift toward earlier intervention, stronger evidence and measurable prevention in workplace health. For Australian workplaces, this is an opportunity to extend beyond minimum compliance and build mature exposure management systems that protect workers for the foreseeable future.
As the WEL transition approaches, Bodycare is ready to bring its 25 years’ experience in occupational health and injury prevention services in guiding your organisation through the change.
Speak with us today to get started on assessing current surveillance gaps, design fit-for-purpose monitoring programs and ensure your workforce is protected and your business is compliant, ready for 1 December 2026.

