COVID-19: Rapid Antigen Testing in your Workplace

Coronavirus disease (COVID-19)

Covid-19 is an airborne infectious disease caused by the SARS-CoV-2 virus.

Infection can occur through droplets in the air and contaminated surfaces, but primarily spreads through aerosols in the air. Learn more about the importance of ventilation in reducing the risk of catching COVID-19.

Most persons infected with COVID-19 experience mild symptoms and recover. However, some go on to experience more serious illness and may require hospital care. There are some who can also experience ongoing health issues from COVID-19 known as ‘Long Covid.’

Generally, it takes between 2 and 10 days before people who are infected show symptoms. A person may not be showing any signs of illness, hence the ability for the infection to spread. This is not unlike the common cold or flu, but is much more infectious.

Learn more about COVID-19 and how it spreads.

Rapid antigen tests – what they are?

Rapid antigen tests (RATs) are an accessible way for workers to test themselves for COVID-19. RATs are best used if you are a close contact or have COVID-19 symptoms. RATs are done by taking swabs from the mouth or the nose and take about 20 minutes to do.

RATs are less accurate than polymerase chain reaction (PCR) tests, but are much more accessible - especially if you are testing at work. They can be done on site, during paid time, and are relatively inexpensive for the employer.

The best way to reduce COVID-19 as a hazard is to eliminate it before it starts. RATs help keep COVID out of the workplace by quickly informing workers if it’s safe for them to stay at work. Introducing a RAT program that suits your workplace is one of the best ways to reduce the risk of COVID-19 outbreaks at work.

What does a RAT program look like?

RAT programs can differ from workplace to workplace and will depend on the risk of COVID-19 outbreaks at your work. A RAT program can range from simply maintaining a stock of RATs for use when necessary to surveillance testing (see below).

Regardless of what kind of RAT program is appropriate, it should be systematic and integrated into the workplace’s health and safety system. An effective RAT program should be backed up with COVID-19 risk assessments, records of consultation, and other COVID-19 control measures.

Systematic RAT program VS. ad hoc provision of RATs

A systematic RAT program is preferred because it:

  • involves consultation with HSRs and workers
  • is documented in risk register as a control measure
  • can be reviewed periodically or on request of an HSR
  • makes sure there is a policy that workers and HSRs can refer to
  • controls the risk of COVID-19 according to the Victorian OHS Act

Surveillance Testing

Surveillance testing is a more thorough way to make sure there are no outbreaks because regular and systematic testing can pick up infections before symptoms appear. This kind of RAT program is usually only in high-risk industries such as schools, aged or disability care facilities, abattoirs, or hospitals. You might be required to regularly take a RAT at work if there is surveillance testing in place. After the employer has done a risk assessment and has consulted with HSRs, surveillance testing may be appropriate for your workplace.

If surveillance testing is mandated in your industry, workers and HSRs must still be consulted on how it is implemented.

What should be included in a RAT program?

RAT programs should be introduced after the employer has assessed the risk of COVID-19 with the input of health and safety representatives (HSRs). The following principles should apply when introducing a RAT program:

  • When waiting for the test result, interactions between people must be minimised
  • If the RAT result positive – the person must not enter the workplace until they have completed their 7 day isolation period and they have no symptoms
  • When, who, and how workers use RATs.
  • RATs provided at work should be approved by the Therapeutic Goods Administration (TGA). Click here to view the list of approved RATs.
  • Employers should not solely rely on a RAT program to prevent outbreaks and should consider introducing paid pandemic leave, improving ventilation, providing face masks, encouraging workers to be vaccinated, maintain physical distancing, and keeping on top of hygiene and cleaning processes.
  • HSRs must be consulted when deciding on what kind of RAT program is suitable

Case study: Department of Education & Training

The Victorian Department of Education & Training established a rapid antigen testing program for workers as part of a wider return to face-to-face learning for students during an unprecedented level of COVID-19 community transmission. The RAT program was a surveillance model, with workers required to test themselves using RATs at least twice a week. Workers at specialist schools were required to test 5 times a week due to the vulnerability of the student cohort. The rapid antigen testing program was delivered with the support the Australian Education Union, and subsequent changes and modifications were in consultation with HSRs and their union. The RAT program is no longer surveillance based, but is a fixture control against COVID-19 transmission in the workplace. Rapid Antigen Tests continue to be provided to workers for free, with staff recommended to use them when symptomatic. The RAT program was one control among many that was implemented in Victorian Primary and Secondary Schools. RAT programs should be implemented in conjunction with other controls, such as improved ventilation, mask wearing, physical distancing and improved hygiene and cleaning standards.

Read more:

Action Plan for HSRs

COVID-19 is a workplace hazard. HSRs have the power to introduce effective controls for COVID-19 such as a RAT program by:

  1. Checking there is a risk assessment for COVID-19
  2. Reviewing and evaluating the risk assessment and the controls for COVID-19
  3. Requesting a RAT program to be added to the controls for COVID-19
  4. Implementing the RAT program
  5. Using Provisional Improvement Notices (PIN)


Step One: Checking there is a risk assessment for COVID-19

Before you request a RAT program to be introduced, you should check that your employer has already done a risk assessment for COVID-19

If your employer has not done a risk assessment yet, then check the OHS Reps’ action plan for COVID-19.

Step two: Reviewing and evaluating the risk assessment and the controls for COVID-19

Make sure that there are adequate controls for COVID-19. Remember you should not rely on RATs as the only COVID-19 control

Double check the risk assessment for COVID-19 - is there anything the employer missed in the first risk assessment? Are they properly maintaining records and controls?

Has there been any COVID-19 cases or outbreaks at work since the risk assessment was done?

Step three: Requesting a RAT program to be added to the controls for COVID-19

As an HSR, you can have a conversation with your employer about getting a RAT program. Remind them how important it is to catch a COVID-19 case with a RAT before it becomes a workplace outbreak.

If this conversation doesn’t achieve your goal, you can also write a petition and ask for the members of your DWG to sign it. This demonstrates that it is not just you who is asking for RATs.

Step four: Implementing the RAT program

It is the responsibility of your employer to implement the RAT program and they must consult you, as an HSR, on what kind of program is most appropriate for your workplace

Ask the members of your DWG what kind of RAT program they would like to have and communicate their views to your employer

Step five: Using Provisional Improvement Notices (PIN)

If you have gone through the steps above, but your employer is not introducing a RAT program after consulting with the workers, you can issue a PIN.

A PIN will put pressure on the employer to act on implementing control measures and it is

Step six: Reviewing and evaluating the RAT program

As an HSR you need to regularly check that the RAT program is working as required. Keep talking to the members of your DWG to get their opinions and check that the records are maintained properly by the employer.

Assessing the risk within the workplace and suitability of RAT’s as a part of a COVID safe environment.

Whether a rapid antigen testing program is necessary in your workplace will depend on a number of factors. Key considerations are:

  • The availability of RATs for purchase.
  • The extent of any local community transmission.
  • The likelihood that workers are going to be exposed to COVID-19 in their workplace. RAT programs may be appropriate for workers in public facing roles, or where there is potential to come into contact with COVID positive individuals.
  • The likelihood of harm to members of the DWG if they do contract COVID-19. A workplace with workers at higher risk of serious illness may be appropriate for a RAT program.
  • Whether members of the DWG are caring for, or coming into contact with, vulnerable people at a higher risk of serious illness if they contract COVID-19.
  • Any public health directions requiring the use of RATs in the workplace.
  • All these questions should be considered in the lens of the likelihood that COVID could spread in the workplace.

Duties of the employer in relation to rapid antigen testing

Duty to provide a safe workplace - s21

Remember, it doesn’t matter whether it’s COVID-19 or an injury at work, it is your employer’s responsibility under s21 of the OHS Act to keep your workplace as safe as is reasonably practicable. It is important to remember that regardless of the current COVID-19 restrictions, the duty for your employer to prevent, as far as is reasonably practicable, transmission of COVID-19 in the workplace remains.

Duty to monitor health of workers and conditions - s22

Employers have a duty to monitor the health of workers and the conditions of the workplace under s22 of the Act. Implementing a RAT program to systematically identify those who have COVID-19 and are infectious falls would help meet this duty.

Duty to consult with workers - s35

When setting up a RAT program or introducing measures to control the risk of COVID-19 outbreaks, the employer must consult with HSRs at every step. Read more about employers’ duty to consult.

Documenting RAT programs

The employer also needs to record and document any information or measures taken to control COVID-19 outbreaks at work. This includes any policies around RAT programs. This is so HSRs are able to review the program if necessary and so they can communicate the program with other members of the DWG.

Read more about the duties of employers under the OHS Act.

Further Reading