Introduction: Three States, One Framework

South Australia, Tasmania, and the Australian Capital Territory may be geographically dispersed and economically distinct, but they share a common regulatory approach to occupational noise management: all three have adopted the national Model Work Health and Safety Regulations, including the audiometric testing requirements analogous to Regulation 58.

For employers operating in these three jurisdictions, this creates an opportunity. A single, well-designed audiometric testing program can satisfy the requirements of all three states simultaneously. However, each state’s regulator interprets and enforces these requirements with nuanced differences, and each jurisdiction has unique industrial profiles and compliance cultures.

This guide explains what each state requires, how they are similar, where they differ, and how to build a compliance program that works across all three.

The Common Foundation: Adopted Model WHS Law

All three states have adopted the Model Work Health and Safety Act and Model Regulations (with state-specific modifications).

South Australia: Work Health and Safety Regulations 2012

SA has integrated the Model WHS law into its Work Health and Safety Act 2004 (as amended). The Work Health and Safety Regulations 2012 incorporate audiometric testing requirements consistent with the national model. SafeWork SA is the regulator.

Tasmania: Work Health and Safety Regulations 2022

Tasmania adopted the Model WHS Act more recently than some other states. The Work Health and Safety Regulations 2022 represent a comprehensive adoption of the model with Tasmania-specific provisions. WorkSafe Tasmania is the regulator.

ACT: Work Health and Safety Regulation 2011

The ACT has integrated the Model WHS regulations into its Work Health and Safety Regulation 2011 (as amended). WorkSafe ACT is the regulator, though there is close coordination with other Australian WHS regulators through the various councils and committees.

What This Means for Audiometric Testing

Because all three states have adopted the Model WHS framework, their fundamental audiometric testing requirements are equivalent:

• 85 dB(A) exposure standard is the trigger
• Baseline testing within 3 months of employment commencement (or regulation commencement)
• Monitoring testing at least every 2 years
• Worker notification of results
• 30-year record retention
• Compliance with AS/NZS 1269.4:2014

An employer complying with one state’s requirements is typically compliant with all three.

South Australia: SafeWork SA and Local Compliance

Regulatory Framework

SafeWork SA administers WHS law in South Australia. The regulator has published guidance consistent with the national Safe Work Australia position on audiometric testing.

Key aspects of SafeWork SA’s approach:

• Emphasis on hazard assessment: SafeWork SA expects employers to conduct documented noise assessments before determining whether Regulation 58 applies.
• Flexible interpretation of “frequently required”: SafeWork SA guidance is somewhat less prescriptive than some other state regulators, allowing employers some discretion in determining which workers meet the threshold. However, this should not be interpreted as permission to be restrictive; SafeWork SA expects conservative interpretation.
• Proportionate enforcement: SafeWork SA generally takes a cooperative approach with employers demonstrating good faith effort toward compliance, but enforcement is firm for deliberate non-compliance.

SA-Specific Industries and Compliance Concerns

• Whyalla steelworks: The Whyalla steelworks is Australia’s largest integrated steelworks. Workers in steelmaking are exposed to substantial noise. Compliance here is typically mature, with comprehensive audiometric programs in place.
• Adelaide manufacturing: Adelaide has a diverse manufacturing base, from vehicle assembly (historically) to machinery manufacturing. Manufacturing workers with noise exposure require audiometric testing. Compliance is variable; larger operators tend to comply, while smaller shops are more inconsistent.
• Mount Gambier timber processing: Timber processing, particularly in the Mount Gambier region, generates significant noise. Workers in this sector require testing. Compliance is emerging as an issue as SafeWork SA increases focus on the sector.
• Adelaide construction: Construction activity in Adelaide, particularly in the CBD and suburban development, creates noise-exposed worker populations. Compliance is moderate; some major builders comply well, but smaller contractors often lag.

Tasmania: WorkSafe Tasmania and Emerging Compliance

Regulatory Framework

WorkSafe Tasmania administers WHS law. Tasmania adopted the Model WHS law relatively recently (compared to NSW and Queensland), with the Work Health and Safety Regulations 2022 representing a comprehensive update.

WorkSafe Tasmania’s approach:

• Active engagement with industry: WorkSafe Tasmania has been proactive in educating employers about the new regulatory framework, including audiometric testing requirements.
• Technical guidance: WorkSafe Tasmania has published detailed guidance on noise management and audiometric testing, reducing interpretive uncertainty.
• Risk-based enforcement: Enforcement priorities focus on high-risk sectors first. Mining and construction are primary focus areas.

TAS-Specific Industries and Compliance Concerns

• Hobart maritime and manufacturing: Hobart’s maritime industry and associated manufacturing generate noise exposure. Workers in these sectors require audiometric testing. Compliance is developing as awareness increases.
• Launceston food processing: Launceston is a food processing hub. Meat processing, grain milling, and beverage manufacturing are significant employers with noise-exposed workforces. Compliance is emerging as a regulatory focus area for WorkSafe Tasmania.
• Mining services and operations: Tasmania has some ongoing mining activity and significant mining services. Compliance in mining is generally good due to industry maturity and insurance requirements.
• Forestry and timber: Tasmania’s forest industry involves significant noise exposure. Harvesting operations, timber processing, and related activities require audiometric testing. Compliance is variable in this dispersed sector.

Transitional Considerations for Tasmania

Because Tasmania adopted the model regulations more recently (2022), some employers are still in the early stages of implementation. If your organization is in Tasmania and has not yet established an audiometric testing program, prioritize this immediately. WorkSafe Tasmania is likely to increase focus on baseline compliance over the next 12–18 months.

Australian Capital Territory: WorkSafe ACT and Government-Focused Compliance

Regulatory Framework

WorkSafe ACT administers WHS law in the territory. The ACT has adopted the Model WHS regulations and has published guidance consistent with national best practices.

WorkSafe ACT’s approach:

• Government sector focus: The ACT government is a major employer in the territory. WorkSafe ACT has emphasized WHS compliance in government agencies, including audiometric testing for noise-exposed public sector workers.
• Construction site compliance: With significant construction activity (Commonwealth infrastructure, university expansion, residential development), WorkSafe ACT focuses on construction site WHS compliance.
• Clear guidance: WorkSafe ACT has published clear, practical guidance on audiometric testing requirements.

ACT-Specific Industries and Compliance Concerns

• Government contractors and agencies: The ACT government and its numerous contractors employ many workers with noise exposure (maintenance, logistics, facilities management). Compliance is generally good due to government sector emphasis on WHS.
• Construction (Canberra CBD, ANU, infrastructure): Canberra’s construction sector is driven largely by government and government-linked projects. Compliance in major construction projects is typically mature; compliance in smaller projects is more variable.
• Defence-related operations: The ACT hosts significant defence-related infrastructure and contractors. Defence organizations are typically highly compliant with WHS requirements, including audiometric testing.
• Manufacturing and logistics: ACT’s manufacturing and logistics sector (warehousing, freight handling) involves noise exposure. Compliance is moderate and improving.

Consistency Across SA, TAS, and ACT: What’s the Same?

Despite geographic and economic differences, all three states’ audiometric testing requirements are consistent in these key areas:

The Trigger

Noise exposure at or above 85 dB(A) (eight-hour TWA) for workers “frequently required to use HPE” triggers the obligation in all three states.

Baseline and Monitoring Timelines

All three require baseline testing within 3 months of employment commencement (or within 3 months of the regulation’s commencement in the state if the employee was already employed). Monitoring occurs at least every 2 years in all three states.

Tester and Equipment Requirements

All three require compliance with AS/NZS 1269.4:2014. Testers must be qualified audiometrists. Equipment must be properly calibrated.

Record-Keeping

All three expect records to be retained for at least 30 years.

Worker Notification

All three require workers to be notified of test results.

Enforcement Priorities and Local Regulatory Differences

While the requirements are consistent, how each regulator prioritizes and enforces can vary:

SafeWork SA

• Emphasis on documented hazard assessment
• Focus on major industries (steelworks, mining, manufacturing)
• Proportionate enforcement for good-faith efforts

WorkSafe Tasmania

• Active educational outreach about new regulations
• Risk-based focus on high-risk sectors
• Likely to increase enforcement intensity over next 12–18 months

WorkSafe ACT

• Strong emphasis on government sector compliance
• Construction site audits and enforcement
• Generally cooperative approach with emphasis on capability-building

Practical Compliance Checklist for All Three States

Use this checklist to ensure your audiometric testing program complies with SA, TAS, and ACT requirements:

Foundation: Noise Assessment and Worker Identification

• ☐ Have you conducted a documented noise assessment of your workplace(s)?
• ☐ Are exposure levels measured and recorded (frequency, location, role)?
• ☐ Have you identified all workers exposed to 85 dB(A) or above?
• ☐ Is your worker identification process documented and defensible?
• ☐ Are worker lists reviewed and updated annually?

Program Structure: Baseline Testing

• ☐ Have all identified workers received a baseline audiometric test?
• ☐ Were baseline tests conducted within 3 months of employment commencement?
• ☐ If workers were already employed, was the 3-month regulation commencement window observed?
• ☐ Were tests conducted by qualified audiometrists in compliant sound booths?
• ☐ Was the 14-hour quiet period observed before each baseline test?

Program Structure: Monitoring Testing

• ☐ Have you established a monitoring schedule (at least every 2 years)?
• ☐ Are workers scheduled for monitoring based on their baseline date?
• ☐ Do you have a system to identify workers due for testing?
• ☐ Are monitoring results compared against baseline thresholds?

Tester and Equipment Compliance

• ☐ Do your testing providers comply with AS/NZS 1269.4:2014?
• ☐ Are testers qualified audiometrists?
• ☐ Is equipment properly calibrated (biological check daily, electroacoustic 6-monthly, full calibration annually)?
• ☐ Are calibration records retained?

Results and Notification

• ☐ Are workers notified of test results in writing?
• ☐ Do notifications explain what results mean and any implications?
• ☐ If significant threshold shift is detected, are workers referred for assessment?
• ☐ Are control measures reviewed when deterioration is detected?

Record-Keeping and Documentation

• ☐ Are all audiometric test records retained for at least 30 years?
• ☐ Are records stored securely (physical security, digital backup)?
• ☐ Are records easily retrievable for inspection or by workers?
• ☐ Do records include worker identification, test date, tester credentials, equipment details, and test conditions?
• ☐ Is your noise assessment documentation retained and available for inspection?

Due Diligence and Management

• ☐ Can your PCBU demonstrate the decision-making process about worker identification?
• ☐ Do you have written policies or procedures for the audiometric testing program?
• ☐ Have workers been informed about the program and its purpose?
• ☐ Is the program reviewed and updated periodically (at least annually)?
• ☐ If multi-state compliance required, is there clear documentation of how each state’s requirements are addressed?

Multi-State Compliance: Practical Approach

If you operate in more than one of these three states (or in other states with Model WHS adoption), a single, comprehensive program can satisfy all requirements:

Design the Program Once, Apply It Everywhere

• Use a centralized noise assessment and worker identification process
• Select a testing provider who operates across all your jurisdictions and complies with AS/NZS 1269.4:2014
• Establish baseline and monitoring timelines that satisfy the most stringent requirement (which is identical across all Model WHS adopters)
• Implement a record-keeping system that stores all necessary documentation for 30 years

Document Your Multi-State Approach

• Create a compliance matrix showing how your program addresses each state’s specific requirements
• Document any state-specific nuances (e.g., enforcement priorities) and how your program addresses them
• Maintain documentation of your PCBU’s decision-making process for multi-state compliance

Leverage Differences Strategically

• If one state’s regulator is more active or aggressive (e.g., increased enforcement in one state), design your program to exceed that state’s baseline requirements. This provides a buffer for other states.
• If one state has published particularly clear guidance, use it as your primary reference and adapt as necessary for other states.

Internal Links: Regional Resources

• WHS requirements across all Australian states
• Audiometric testing in Adelaide — South Australia
• Audiometric testing in Hobart — Tasmania
• Audiometric testing in Canberra — Australian Capital Territory

Conclusion

South Australia, Tasmania, and the Australian Capital Territory have adopted the national Model WHS law and its audiometric testing requirements. For employers in these states, this creates regulatory consistency and the opportunity for streamlined multi-state compliance.

Implement a comprehensive audiometric testing program that includes documented noise assessment, baseline testing within 3 months, monitoring every 2 years, and secure 30-year record retention. This program will satisfy the requirements of all three states and demonstrate due diligence to any regulator.

Each state’s regulator has different enforcement priorities and guidance nuances. Familiarize yourself with your specific state regulator’s guidance, but do not let regulatory differences delay implementation. The core requirements are identical, and compliance is non-negotiable.