Health surveillance scheme for NSW coal mine workers
The Coal Services Health Monitoring Requirements for Coal Mine Workers Order No. 43 (Order 43) plays a critical role in ensuring that NSW coal mine workers are adequately screened for any health effects due to occupational exposures to dust, noise, chemicals, and other workplace hazards. Coal Services is responsible for administering the Order under the Coal Industry Act 2001 (NSW).
The health assessments detailed in the Order can also identify other health and lifestyle-related conditions that may impact a coal mine worker’s ability to work safely and effectively. Regular screening provides an opportunity to identify occupational and non-occupational diseases early, often before symptoms manifest. This provides greater scope for effective treatments and preventative measures to keep coal mine workers safe.
The health surveillance scheme also helps NSW coal industry employers to fulfil their health and safety obligations to protect the health and wellbeing of their workforce.
Preparing for the replacement Order
A revised Order has been drafted based on the outcomes of industry consultation and workshops and includes the recommendations from the Mine Safety Advisory Council (MSAC) Review. The revised Order will replace the current Order 43 as the health surveillance scheme evolves to a more contemporary and relevant model suited to industry’s needs. It will also provide greater clarity and direction as to requirements and responsibilities.
Frequently asked questions
Learn about risk categories
Review of Order 43 and industry consultation
In 2023, CS Health commenced stakeholder consultation with the NSW coal industry to revise Order 43. This consultation continued throughout 2024 and the first half of 2025.
Consultation included engagement with representatives from the NSW Minerals Council (NSWMC), the Mining and Energy Union (MEU), NSW coal industry contractor employers (NSW Contractors), and the External Doctor Network (EDN). The consultation phases included a series of workshops, face-to-face meetings, online surveys, an independent impact analysis, and formal and informal feedback.
An overview of each phase of consultation is below.
Phase One consultation commenced in August 2023 with ideation sessions conducted by an independent facilitator. These sessions highlighted the need for transparent engagement and tailored health guidelines for the coal industry. Furthermore, our stakeholders highlighted the need for a unified digital platform to enhance efficiency and communication.
Following the success of the initial ideation sessions, CS Health held workshops focusing on 10 key areas of change identified to revise the Order. The key stakeholders who participated in these workshops included MEU, NSWMC, NSW Contractors and the EDN representatives.
CS Health’s stakeholders agreed that rushed or poorly planned changes to the Order could exacerbate current issues or introduce new ones. A comprehensive evaluation and continued stakeholder feedback were deemed essential to ensure that revisions to the Order were evidence-based and served the industry’s best interests.
This phase invited stakeholder feedback on a proposed draft Order (Draft 1). Feedback was received via an online survey, formal submissions from the NSWMC and MEU, individual stakeholder meetings, and an independent impact analysis to inform the changes to the draft Order.
The feedback received during Phase Two showed strong stakeholder engagement and provided valuable insights. Additionally, our stakeholders appreciated the opportunity to provide input on the draft Order and contribute to the NSW health surveillance scheme.
During Phase Two, our stakeholders requested additional consultation on any updates to the draft Order before finalisation.
This phase invited the NSWMC and MEU to provide feedback on the revised draft Order (Draft 2) following the review of input received during Phase Two.
In addition, the consultant who conducted the Impact Analysis during Phase Two completed a mapping exercise against the impacts and considerations of the revised draft Order (Draft 2) to help CS Health make decisions on any discordant areas of the Order.
After reviewing and collating the feedback from Phase Three, the draft Order (Draft 3) was further revised.
CS Health engaged in individual consultations with the NSWMC and MEU representatives to discuss the revised draft Order (Draft 3) and outline any significant changes made since the previous consultation.
Our stakeholders valued the opportunity to discuss the proposed revisions and contribute their input on unresolved concerns.
Both stakeholders agreed in principle with the proposed draft (Draft 3), noting that outstanding action items must be addressed and supporting documents reviewed before finalising the draft Order.
Our stakeholders stressed the need for robust communication and a change management plans to ensure a seamless transition after the new Order is approved.
During Phase Five, the NSWMC and MEU were invited to provide feedback on two documents introduced to support the implementation of the revised Order:
- Coal Services Risk Category Guidelines (Risk Category Guidelines)
- Coal Services Clinical and Service Standard (Clinical and Service Standard)
The EDN were also invited to provide feedback on the Clinical and Service Standard.
Additionally, CS Health, the NSWMC, and MEU met with SafeWork NSW to discuss the class exemption (No. 010/23) issued under the Work Health and Safety Regulation 2011, relating to audiometric testing requirements in the NSW coal industry. This exemption applies to any PCBU subject to Order 43, exempting them from compliance with clause 58(2) of the Work Health and Safety Regulation 2017.
The purpose of the engagement with SafeWork NSW was to ensure they were informed of any revisions to Order 43 that may affect the current class exemption and to explore options for maintaining the exemption under a new Order.
During Phase Six, CS Health has conducted a series of change-readiness focus group workshops. These workshops engage NSW coal industry stakeholders, including the NSWMC, MEU, NSW Contractors, and EDN representatives, to identify potential challenges, clarify information needs, and co-design supporting documents to enable a clear and consistent message of the new Order across the industry.
Additionally, CS Health participated in the 2025 Coal Services Airborne Contaminants and Health Surveillance forums to provide education and updates to Industry regarding the expected changes with the replacement Order.
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