NDIA Accountability Project

Protecting workers with disabilities from poor Indoor Air Quality and extreme heat

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13 November 2025

Attorney-General’s Department
4 National Circuit
BARTON ACT 2600

Uploaded using the consultation submission form

Dear sir/madam,

SA Unions makes a submission with respect of the Disability Discrimination Act 1992 (Cth) (DDA), as follows.

  1. SA Unions is the peak trade union council for South Australia, and our office is located on the lands of the Kaurna people.
  2. Through its twenty-six (26) Affiliated Unions, SA Unions represents approximately 160,000 union members from across a wide spectrum of industries, sectors, professions and occupations across South Australia.
  3. SA Unions is grateful for the opportunity to respond to the DDA Review Issues Paper.
  4. As the peak body representing South Australian workers, SA Unions advocates to ensure that all workers have access to safe, inclusive, accessible, and equitable workplaces. The DDA is essential in supporting these objectives and underpinning the rights of workers with disability in employment and other areas of public life.
  5. SA Unions has had the benefit of contributing to and reviewing the submission of the Australian Council of Trade Unions (ACTU) in relation to the Issues Paper, and we endorse and adopt the ACTU’s submissions.
  6. Additionally, SA Unions makes the following submissions concerning Indoor Air Quality and extreme heat to support and ensure inclusive workplaces for workers with disabilities.

Indoor Air Quality

  1. Indoor Air Quality has been increasingly recognised as a serious concern, particularly for workers who are immunocompromised and/or have chronic health conditions.
  2. The Australian Bureau of Statistic’s “Health Conditions Prevalence” data released in 2023 showed that 49.9% of Australians live with a chronic health condition.¹

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¹ Australian Bureau of Statistics. (2022). Health conditions prevalence. redacted

  1. Indoor Air Quality is negatively impacted by smoke, pollutants, and biological hazards including vector-born illnesses.

  2. Public health advice confirms that the people most at risk of serious illness and fatality from biological hazards such as influenza, respiratory syncytial virus (RSV), and COVID-19 are those who are immunocompromised and/or have a chronic health condition.² Further, in relation to “long COVID”, public health advice confirms that “Some things that can make it more likely that you’ll get long COVID are: …

    a. being older age

    b. being female…

    c. overweight or underweight …

    d. having other conditions — including anxiety, depression, asthma, chronic kidney disease, chronic obstructive pulmonary disease (COPD), diabetes or problems with your immune system

    e. having heart problems — such as high blood pressure, coronary heart disease or heart failure”.³

  3. Poor Indoor Air Quality represents a barrier to participation in employment — a barrier reasonably comparable to lack of other accessibility features including ramps, assistive audiology, visual alerts, subtitles etc.

  4. Indoor Air Quality can be improved with simple and effective measures such as the use of filtration, ventilation, circulation of outdoor air within indoor spaces, and risk mitigation strategies for biological hazards and other airborne pathogens.

  5. Consistent with proposals to introduce a positive duty under the DDA, SA Unions supports the inclusion of proactive obligations on employers, service providers and building managers to assess and address risks associated with poor Indoor Air Quality. SA Unions submits that this should include the imposition of clear obligations employers to undertake monitoring of air quality, with transparency and disclosure of testing and audit results, and prioritising clean air and air quality through filtration and ventilation. This would assist employers and service providers in understanding their obligations to make adjustments that support safe participation for workers with disabilities.

Extreme Heat

  1. Climate change is already contributing to deteriorating working conditions and increasing the risk of occupational injury, illness, and death.

  2. Extreme heat has been a long-standing concern — and one which is anticipated to worsen with climate change.

² Department of Health Victoria (2025) Increase in COVID, flu and RSV in Victoria redacted ³ Healthdirect Australia (2025) Long COVID redacted

  1. Workers with disabilities are at greater risk from the effects of heat-related illness,⁴ noting that the risks are particularly acute with respect of workers: a. suffering from heart disease or lung disease, having high blood pressure, or having diabetes b. taking certain medications c. experiencing perimenopause, menopause, or andropause.

  2. The Australian Bureau of Statistic’s “Health Conditions Prevalence” data released in 2023 showed that 49.9% of Australians live with a chronic health condition,⁵ and that: a. 5.3% of Australians live with diabetes b. 5.2% of Australians live with heart, stroke and vascular disease c. 2.5% of Australians live with Chronic Obstructive Pulmonary Disease (COPD)

  3. Heat-related illness can affect workers in all sectors, but some sectors have higher risk, such as those involving work outside or in environments which are not temperature controlled — including construction, landscaping, agriculture, retail, land management, utilities, warehousing, and some public administration services which involve working outdoors.

  4. Indoor workers are also at risk of heat-related illness from hot environments created by processes or restricted spaces, with the risks exacerbated if there is limited ventilation and/or no air conditioning - including unairconditioned factories, commercial laundries, dry cleaners, manufacturers, restaurants, catering services, take away food preparation areas, and bakeries.

  5. Extreme heat represents a barrier to participation in employment — a barrier which disproportionately impacts workers with disabilities.

  6. Consistent with proposals to introduce a positive duty under the DDA, SA Unions supports the inclusion of proactive obligations on employers, service providers and building managers to assess and address risks associated with extreme heat.

  7. SA Unions submits that the DDA must do more to help protect workers with disabilities from poor Indoor Air Quality and from the impacts of climate change such as working in extreme heat. Further, SA Unions submits that the DDA obligations can be integrated with work health and safety obligations, so that thermally appropriate workplaces and clean air are recognised as access rights and safety duties.

  8. SA Unions also submits that there are workforce benefits to addressing Indoor Air Quality and protecting workers with disabilities from extreme heat — including a reduction in sick leave use, improved retention of workers, and supporting the workforce participation for the one in two Australians living with a chronic health condition.

⁴ redacted ⁵ Australian Bureau of Statistics. (2022). Health conditions prevalence. redacted

  1. Should you require further information about the above, please contact Coordinator of Union Power and Women’s Strategy, redacted on redacted.

Yours sincerely,

redacted

Secretary, SA Unions