UV risk management is a duty of care obligation
Under the Australian Work Health and Safety (WHS) Act, a person conducting a business or undertaking (PCBU) has a general duty to eliminate or minimise risks to the health and safety of workers, so far as is reasonably practicable. This duty applies to all workplace hazards — including ultraviolet (UV) radiation.
UV radiation is not listed in Schedule 14 of the WHS Regulations, which covers hazardous chemicals requiring mandatory health monitoring. However, the general duty of care provisions under the WHS Act still require PCBUs to identify, assess, and control UV exposure as a workplace hazard — and to take reasonable steps to monitor whether workers’ health has been affected.
For employers with outdoor workers, skin cancer is the most significant health risk linked to UV exposure. A structured skin cancer screening program is one of the most direct ways to demonstrate proactive risk management under your general duty of care.
What the WHS Act requires for UV exposure
The WHS Act and Regulations require PCBUs to manage workplace risks through the standard hierarchy of controls. For UV exposure, this means:
- Identifying the hazard — recognising that UV radiation during outdoor work poses a risk to worker health.
- Assessing the risk — determining which workers are regularly exposed and to what degree.
- Implementing controls — applying the hierarchy from elimination through to PPE.
- Monitoring health outcomes — taking reasonable steps to determine whether workers’ health has been affected by the hazard.
- Keeping records — documenting the measures taken to manage the risk.
Health monitoring for UV is not prescribed in the same way as monitoring for lead or asbestos. But the general duty to manage risk so far as is reasonably practicable supports implementing structured health monitoring where the hazard is significant and the monitoring is practical.
Who should consider health monitoring for UV?
Any PCBU with workers who spend a significant portion of their working time outdoors should consider whether health monitoring is a reasonably practicable step. This includes sectors such as:
- Construction and civil infrastructure
- Mining and resource extraction
- Agriculture and pastoral work
- Local government (parks, roads, water, waste)
- Education (teachers, groundskeepers, sports coaches)
- Sports and recreation
The obligation extends to all workers — not just employees. Contractors, labour hire workers, and volunteers may also be within scope depending on the jurisdiction and the nature of the work.
How skin cancer screening supports your duty of care
A properly structured skin cancer screening program provides health monitoring that supports your WHS obligations in several ways:
Periodic health assessment — workers are screened at regular intervals, creating a documented history of skin health over time. This demonstrates ongoing risk management, not a one-off measure.
Clinical oversight — when screenings are assessed by registered nurse practitioners, with GP escalation for identified concerns, the process goes beyond informal self-assessment or general wellness.
Documented outcomes — each screening generates a timestamped clinical record linked to the individual worker. This creates evidence that the employer took proactive steps to monitor the health impact of UV exposure.
Referral pathways — where concerns are identified, a GP-signed referral ensures workers can access further assessment through the Medicare system at no cost to the employer.
The gap between controls and monitoring
Many employers provide sun safety training, PPE, and general health awareness campaigns. These are important controls — but they address the hazard itself, not whether workers’ health has been affected by it.
Without a structured health monitoring program, employers may find it difficult to demonstrate that they took all reasonably practicable steps to manage UV risk during an audit, investigation, or workers’ compensation claim. The question is not just whether you provided hats and sunscreen — but whether you took reasonable steps to monitor the health impact of the hazard on your workers.
Moving from controls to documented evidence
Implementing a skin cancer screening program does not need to be operationally complex. Phone-based screening solutions allow workers to complete a skin check in minutes, from any location, without site visits or roster disruption. Results are reviewed by clinicians and documented automatically.
The result is a continuous record of proactive health monitoring that your WHS team can reference with confidence — not a folder of sign-in sheets from an annual training day.