Australian employers are considering whether to utilise rapid antigen testing (referred to endearingly as “RAT”) as a cost-effective and comparatively efficient means of screening workers for COVID-19 in the workplace.

What is RAT?

RAT is usually administered by swabbing the inside of the mouth or nose and works by identifying protein fragments on the surface of the coronavirus where the pathogen is present.

It is proving popular with employers in some industries as tests can be performed onsite and the process is, as the name implies, comparatively straightforward with results usually available within 15 to 20 minutes of testing.

Can your organisation access RAT and how is RAT implemented?

Most employers will be able to utilise RAT in their workplaces but must use a health practitioner to conduct or at least oversee the testing process and interpretation of results.

Only RAT testing devices registered by the Therapeutic Goods Administration (“TGA”) can be used for COVID-19 testing in Australia and screening must be conducted in accordance with conditions and instructions set by the TGA.

NSW Health has published a framework and standard operating procedure for RAT which can be accessed here.

What happens in the event of a positive test result?

Where an individual receives a positive RAT result, the site manager must immediately notify the Public Health Unit so that arrangements can be made to have the individual transported to a local COVID-19 testing facility where the person will undergo a priority PCR test and that individual must remain in isolation until a definitive result is available.

By contrast, where a person receives a negative result, they must have the test result registered with a testing supervisor onsite and the worker can then commence their work.

Potential issues for employers to consider if implementing RAT

Rapid Antigen Testing, in combination with a mandatory vaccination program and other COVID safeguards, may form part of a robust system to assist an employer meet their work health and safety obligations and to minimise the risk of material business impacts caused by a COVID outbreak at their workplace. However, the use of RAT gives rise to number issues that employers need to take into consideration, including those that relate to the efficacy of the testing method, practicalities and cost of testing a large workforce and in relation to any workers that are unwilling to undergo this type of testing. We outline these issues below:

• A limitation of RAT is that it is less sensitive than current PCR diagnostic testing procedures, with the result that it will likely miss a greater number of COVID-19 cases than standard testing procedures. RAT programs are imperfect, and shouldn’t take the place of other COVID safe workplace arrangements and contingency planning.
• As part of the introduction of a RAT program at the workplace, it’s important that the employer consults with its employees and any representatives as required under WHS legislation and any applicable industrial instruments. It’s important that employers clearly document the arrangements, including the consequences for an employee who refuses to undertake a RAT. In almost all situations, it is likely to be lawful and reasonable for an employer to require a RAT as a condition of entry, but employers will need to consider an employee’s specific circumstances.
• Employers will be responsible for procuring their own test kits (either directly or through a third party RAT service), in line with the TGA requirements, and will bear the costs of implementing RAT.
• RAT will present potential logistical challenges for larger organisations. Given the need for workers to be tested before starting work, larger organisations may need to consider the logistics and time requirements for significant numbers of employees to complete a RAT prior to the start of their work day.

People + Culture Strategies