Published 3 September 2026

Guidance note: Changes to Airborne Contaminants Legislation — Implications for the National Aquatic Industry

Background / context

Australia is transitioning its work health and safety regulatory scheme relating to airborne contaminants from the Workplace Exposure Standards (WES) to Workplace Exposure Limits (WEL), with new limits applying from 1 December 2026. While most limits have been finalised and many have been lowered, nine chemicals — including chlorine — remain under ministerial review and will carry over unchanged for now (see Legislative context, below). Relevant to aquatic facilities is hydrogen chloride, whose Peak limitation falls from 5 ppm to 2 ppm under the WEL — the one aquatic-relevant figure that actually changes on 1 December 2026, and, because Victoria adopts the WEL list on its own timeline, the one place Victorian and interstate numbers can genuinely diverge for a period (see the Victorian jurisdictional note in Legislative context, below). However, the underlying legal duty for pool owners and operators has not changed: workers, contractors or patrons must not be exposed above any applicable (ceiling) limit, and all exposure must be kept as low as reasonably practicable.

Aquatic facilities present unique exposure scenarios. Aquatic staff may be exposed to certain airborne contaminants depending on the chemicals and substances used at the facility, the level of ventilation, safe chemical handling processes and safe management of substances, including dusts. Plant room operators and maintenance staff may experience intermittent but higher-risk exposures during chemical handling, dosing, routine maintenance (such as shock doses), spills or system faults. Construction and refurbishment activities introduce additional risks, including concrete and crystalline silica dust, which require the same level of control as routine operations.

Members of the National Aquatic Industry Committee have researched the scheme and the implications for the aquatic industry and put together this document to help aquatic facility owners and operators make informed decisions about risk management. Please note this document does not replace the need for local due diligence, analysis and appropriate mitigations. We should note none of the authors are chemistry experts, however, there are several aquatic technical operations experts in management of water quality and chemical safety at public aquatic venues.

Purpose

This paper explains Australia's updated workplace exposure requirements and what they mean for aquatic facilities, including indoor pools, plant rooms, and construction or maintenance activities. It outlines what reasonable due diligence looks like for aquatic facility owners and operators and how to manage uncertainty.

Legislative context

Under Australian Work Health and Safety laws, aquatic facility owners and operators have a primary legal duty to ensure a safe workplace free from harm to staff (whether paid or voluntary), contractors and patrons.[1],[2] Regulations are in place relating to managing risk and exposure to airborne contaminants. This scheme is being transitioned from the current Workplace Exposure Standards scheme to a newly named Workplace Exposure Limits scheme.

The current exposure standards scheme applies until 30 November 2026. The new exposure limits scheme will apply from 1 December 2026.[3] Some limits remain unchanged, while others have been lowered.[4],[5] The core legal duty remains the same: workers, contractors and patrons must not be exposed above the limit, and exposure must be kept as low as reasonably practicable.

Exposure limits do not represent a boundary between safe and unsafe. Irritation or harm may occur below a published limit, and meeting a limit does not remove the need for effective controls.

Understanding exposure limits

Exposure limits describe how much of a substance a worker, contractor or patron can be exposed to in the air. Safe Work Australia defines three distinct limit types:[13]

• Time-weighted average (TWA): the average amount of a substance a person may be exposed to over a normal working day, usually eight hours. Intended to protect against repeated, day-to-day exposure. TWA figures can be adjusted for longer or shorter working days.
• Short-term exposure limit (STEL): a short-period average, typically 15 minutes, designed to prevent acute irritation or injury from brief but higher concentrations.
• Peak limitation: a hard ceiling — “the maximum or peak concentration of an airborne contaminant measured over the shortest analytically practicable period of time, and not exceeding 15 minutes.”[14] A peak limitation cannot be adjusted for longer or shorter working days, and exposure above it is not allowed at any time, however brief.

Operators should understand whether their activities could reasonably result in exposure above exposure limits.

Due diligence in an aquatic facility

Due diligence requires owners and operators to be informed, proactive and systematic in managing airborne risks.[16] In an aquatic facility this typically includes:

• identifying where airborne exposure could occur
• understanding which chemicals and dusts are relevant
• implementing controls that prevent or minimise exposure
• monitoring air quality where uncertainty exists
• reviewing controls when conditions change or issues arise

Identifying realistic airborne risks

Plant rooms and chemical handling areas

Higher-risk tasks include chemical container changeovers, manual handling of liquids and powders, maintenance on dosing systems, spill response, and entry to poorly ventilated spaces. Exposure may be intermittent but can be significant.

Gases and vapours that can be encountered include chlorine gas (from dedicated gas disinfection systems, or as an incompatibility reaction), hydrochloric acid vapours, carbon dioxide used for pH control, and ozone where secondary disinfection systems are installed.

Powders and solids commonly handled include calcium hypochlorite, sodium bisulphate, sodium bicarbonate, sodium thiosulphate, perlite (and other) filter media, and construction-related dusts such as concrete and other dusts that could contain crystalline silica.

Construction, maintenance and refurbishment

Common airborne risks include concrete and cement dust, crystalline silica from tiles or grout, ultra-fine filter media replacement, welding fumes, paints and solvents. These risks apply even when work is temporary or undertaken by contractors.

Substance risk management

Some substances have published Australian exposure limits, while others do not. Where no limit exists, the duty to manage risk still applies.

The table below reflects what is currently published in the Safe Work Australia WES/WEL lists and how it applies to aquatic facilities.[21] Rows shaded amber carry a Peak limitation only — a ceiling that must never be exceeded, not an averaged exposure.

Disclaimer: the substances listed below are those most commonly encountered in aquatic facility operations. This is not an exhaustive list of hazardous chemicals that may be present on site, and operators retain a duty to identify and manage the risks of all hazardous chemicals they use, store or generate, whether or not those chemicals appear here. The indicative risk rating reflects the potential severity of harm from exposure to each substance itself — based on its toxicity, corrosivity and reactivity — and is not a reflection of whether the substance carries a workplace exposure limit. A substance can present a real risk of harm even where no WES/WEL figure is published for it.

Typical risk controls in aquatic facilities

Pool halls

Commonly expected controls include ventilation systems that move air effectively at deck level, balanced air supply and exhaust to prevent stagnant air above the water, effective water chemistry, circulation and secondary disinfection — or in the alternative sufficient freshwater and fresh air intakes — to minimise chloramine formation, investigation of repeated eye or respiratory irritation complaints, and operational controls during peak usage periods.

Routine personal air monitoring for lifeguards and other staff is not generally recommended unless there are reasonable or founded complaints, incidents or system failures.

Plant rooms and chemical storage areas

Commonly expected controls include automated and enclosed dosing systems, segregation of incompatible chemicals, bunding and spill containment, natural and/or mechanical ventilation appropriate to the space and tasks, clear procedures for chemical handling and changeovers, trained personnel with restricted access, appropriate and fitted personal protective equipment including respiratory protection where appropriate, spill containment equipment and procedures, and emergency response equipment and training.

Air monitoring is often justified where ventilation is limited, after incidents, or where chemical vapours could reasonably accumulate.

Powder handling

Expected controls include minimising manual handling of powders, enclosed transfer or wet methods where appropriate and practicable, local exhaust or general ventilation, appropriate respiratory protection where higher-order controls are not practicable, and good housekeeping to prevent secondary dust exposure. Good housekeeping includes appropriate separation of chemicals, use of raised platforms and/or sealed containers, and ensuring any spills are quickly cleaned and disposed of appropriately.

Construction and maintenance activities

Expected controls include risk assessments that address airborne dust, silica management measures where concrete, tiles or grout are disturbed, sealing and separating construction areas from operating pool spaces, scheduling dusty work outside operating hours where possible, wet cutting and on-tool extraction, contractor induction and supervision, and air monitoring where silica exposure is reasonably possible.

Temporary work does not remove the obligation to manage exposure.

Personal Protective Equipment (PPE)

Personal protective equipment is a supplementary control and does not replace higher-order controls such as elimination, substitution, engineering or administrative measures. PPE is required where residual risk remains after those controls have been applied, or where short-duration or non-routine tasks introduce foreseeable exposure.

Personal protective equipment is issued to individuals and should not be treated as shared communal equipment unless specifically designed for that purpose (for example, emergency spill kits with disposable components). Sharing of gloves, respirators, goggles or clothing between staff is not appropriate where the equipment is reusable, as this may compromise hygiene, fit, integrity and performance.

Expected controls include:

• A documented PPE risk assessment aligned to specific tasks (chemical handling, media changeover, spill response, confined plant room work, construction interface).
• Selection of PPE based on Safety Data Sheets (SDS), exposure pathways and ventilation conditions.
• Provision of correctly sized and fitted equipment.
• Training in correct use, limitations, cleaning, maintenance and storage.
• Replacement schedules and inspection regimes.
• Clear supervision to ensure PPE is worn where required.

PPE must be compatible (for example, respiratory protection that does not interfere with eye protection) and suitable for wet and corrosive environments typical of aquatic facilities.

Health monitoring

Health monitoring is not automatically required simply because chemicals are used in the workplace.

It is required only where a chemical listed in WHS regulations is used and there is a significant risk to health from ongoing exposure.

In most aquatic facilities, health monitoring for chemical exposure is not expected as a routine activity. It may become necessary where controls are ineffective or exposure is ongoing and significant. Health monitoring does not replace the need to reduce underlying risk to as low as reasonably practicable.

Managing uncertainty

Where exposure limits are unclear or not listed, owners and operators should acknowledge the uncertainty, assess who may be exposed and under what conditions, strengthen engineering and system controls, use air monitoring where uncertainty cannot be resolved by design alone, document decisions, and review outcomes.

Taking reasonable, documented steps to manage uncertainty is a key element of due diligence.

Conclusion / Summary

The transition from Workplace Exposure Standards to Workplace Exposure Limits does not change the fundamental obligations of aquatic facility owners and operators. The duty to ensure that workers, contractors and patrons are not exposed to harmful airborne contaminants, and that exposure is kept as low as reasonably practicable, remains unchanged.

For chlorine specifically, the operative limit — now and after 1 December 2026 — is a Peak limitation of 1 ppm (3 mg/m³): a ceiling that must never be exceeded, at any moment.

Most airborne risks in aquatic facilities are well understood and can be effectively managed through good facility design, robust systems of work and appropriate supervision. Effective ventilation, automated and enclosed chemical systems, sound chemical storage and handling practices, and well-managed construction and maintenance activities remain the primary means of controlling risk.

Health monitoring is not automatically required because chemicals are used. It is only required in specific circumstances where there is a significant risk to health and regulatory requirements apply. In most aquatic facilities, prevention and control remain the appropriate focus.

Where exposure limits are unclear or not listed, owners and operators are expected to take a measured, evidence-based approach. This includes recognising uncertainty, strengthening controls, using air monitoring where appropriate, and documenting decisions. Demonstrating informed and proportionate risk management is central to reasonable due diligence under work health and safety laws.