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Queensland Government Submission to the National Dust Disease Taskforce

November 2019

Executive Summary

The risks to health associated with worker exposure to occupational dust have been researched and

publicised since the early twentieth century. The findings of the 2017 Queensland Inquiry into the re‐

identification of Coal Workers' Pneumoconiosis1 (the CWP Inquiry), the August 2017 New South Wales

(NSW) Parliamentary First Review of the Dust Diseases Scheme, and the recent outbreak of diagnoses

of accelerated silicosis amongst stone benchtop fabricators represents an alarming trend and

reinforces the need for immediate action to protect workers from exposure to occupational dust.

The lack of a coordinated national response to the ongoing risks posed by occupational dust,

particularly in relation to the increase in silica‐related disease across the nation, has meant that

jurisdictions have had to take their own actions. This has resulted in duplication of efforts and multiple

approaches across jurisdictions from new regulations2 through to recommendations to develop a

mandatory silica syllabus for trade certificate training3.

In the absence of a coordinated national approach to occupational dust, the Queensland Government

has been undertaking planned and deliberate actions to address the risk of workers developing illness

due to occupational dust exposure.

In Queensland, the existing work health and safety legislative framework already prohibits the dry

cutting of engineered stone containing high levels of respirable crystalline silica. Under section 49 of

the Work Health and Safety Regulation 2011, a person conducting a business or undertaking at a

workplace must ensure that no person at the workplace is exposed to a substance or mixture

(including respirable crystalline silica) in an airborne concentration that exceeds the exposure

standard for the substance or mixture.

In relation to respirable crystalline silica exposure to stone benchtop workers, Queensland has been

leading the charge with actions and research that is shaping the response to crystalline silica globally.

These actions include:

an industry wide audit campaign of all known stone benchtop fabrication businesses in Queensland (relating to consultation questions 1, 2 and 3);

development of the Managing respirable crystalline silica dust exposure in the stone benchtop industry Code of Practice 2019, which sets enforceable minimum standards stone benchtop fabrication businesses must met to ensure the risks of exposure to respirable crystalline silica are minimised for workers (relating to consultation questions 4, 6 and 7);

development of a Guideline for assessing engineered stone workers exposed to silica to support medical practitioners assessing workers with significant exposure to respirable crystalline silica (relating to consultation questions 4, 6 and 7);

1 See https://www.parliament.qld.gov.au/Documents/TableOffice/TabledPapers/2017/5517T815.pdf 2 See https://www.worksafe.vic.gov.au/changes‐protect‐victorians‐working‐engineered‐stone 3 See https://www.safework.nsw.gov.au/news/safework‐media‐releases/safety‐taskforce‐to‐protect‐stone‐industry‐workers

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commencement of work to develop a code of practice for the management of respirable crystalline silica in the broader construction industry (relating to consultation questions 4, 6 and 7);

support for an immediate reduction in the workplace exposure standard for respirable crystalline silica from 0.1 milligrams per cubic metre (mg/m3) to 0.05mg/m3, with the clear expectation that consideration of a further reduction of the exposure standard should occur within three years of the date of decision of work health and safety (WHS) Ministers to reduce the exposure standard (relating to consultation questions 4, 6 and 7);

funding of free initial health screenings for current or former workers in Queensland who have been exposed to dust from engineered stone in their workplaces (relating to consultation questions 4, 6 and 7);

provision of support to workers affected by exposure to respirable crystalline silica through WorkCover Queensland, including by providing assistance with the workers’ compensation process and high‐quality medical treatment and rehabilitation (relating to consultation questions 4, 6 and 7);

amending the Workers’ Compensation and Rehabilitation Act 2003 to remove the two‐year time period from the definition of ‘terminal condition’. This will ensure workers, including those diagnosed with silicosis, who are given a life expectancy of greater than two years (for example 3 or 5 years) are able to access latent onset terminal benefits (a lump sum of up to $714,455) when they need it most;

commissioning of an international research project to examine support for workers diagnosed with silicosis (to be published in 2020) (relating to consultation questions 4, 6 and 7);

engagement with suppliers and importers of engineered stone in Queensland and advocacy of an investigation by the Australian Competition and Consumer Commission (ACCC) into product safety of imported engineered stone (relating to consultation questions 3, 4,6 and 7); and

cross jurisdictional collaboration and information sharing, including with public health executives from WorkSafe New Zealand and senior officials from the Californian Department of Public Health and the Occupational Safety and Health Administration in the United States (relating to consultation questions 4, 6 and 7).

For occupational dust more generally, Queensland’s actions include:

the establishment of the Queensland Notifiable Dust Lung Disease Register4 (relating to consultation questions 4, 6 and 7);

introduction of additional legislative reforms and standards that relate to the monitoring and control of respirable crystalline silica for Queensland mine workers (relating to consultation questions 3, 4, 6 and 7); and

as for respirable crystalline silica, provision of support to workers affected by exposure occupational dust through WorkCover Queensland, including assistance with the workers’ compensation process (relating to consultation questions 4, 6 and 7).

In developing a national approach to the prevention, early identification, control and management of

occupational dust diseases in Australia, the Queensland Government recommends the Taskforce

4 See https://www.health.qld.gov.au/public‐health/industry‐environment/dust‐lung‐disease‐register

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consider the following actions to ensure Queensland’s achievements in this space are rolled out

nationally:

development of a national code of practice for managing respirable crystalline silica dust exposure and a suite of national WHS regulations concerning respirable crystalline silica (relating to questions 3, 4, 6‐8)5;

a further review of the workplace exposure standard for respirable crystalline silica and coal dust within three years of the date of decision of work health and safety (WHS) Ministers to reduce the exposure standard (relating to consultation questions 4, 6‐8);

development of a national guideline for health practitioners to undertake medical assessments of workers exposed to respirable crystalline silica (relating to consultation questions 4, 6‐8);

consideration of ways to increase the strength of WHS duties of suppliers and importers of engineered stone into Australia, as well as support for an investigation by the ACCC of the product safety of imported engineered stone (relating to consultation questions 3‐4, 6‐8);

consideration of health monitoring requirements with a view to increasing positive incentives for the reporting of adverse health monitoring findings, and ways to ensure techniques used for health monitoring are current and reflect the latest medical and technological advances (relating to consultation questions 4, 6‐8);

consideration of ways to improve the knowledge and expertise of medical professionals undertaking the health monitoring of workers, including the development of a trained pool of doctors with formal, specialised occupational dust disease training and experience to ensure they reach a suitable standard of competency (relating to consultation questions 3‐, 6‐8);

establishment and maintenance of a national dust disease register (relating to consultation questions 4, 6‐8); and

consideration of funding for strategic research in a number of areas including effective treatment options for sufferers of diseases related to respirable crystalline silica.

The following submission outlines Queensland’s approach to ensuring workers are protected from

exposure to occupational dust (both for respirable crystalline silica and occupational dust more

broadly in the mining industry), as well as providing further detail on the actions Queensland proposes

for consideration by the Taskforce.

5 Queensland notes that Safe Work Australia is currently developing the Health Monitoring – Guide for crystalline silica. However, this guide does not align with the minimum standards set out in Queensland’s own Managing respirable crystalline silica dust exposure in the stone benchtop industry Code of Practice 2019: https://www.worksafe.qld.gov.au/__data/assets/pdf_file/0005/181940/Managing‐respirable‐crystalline‐silica‐dust‐exposure‐in‐the‐stone‐benchtop‐industry‐Code‐of‐Practice‐2019.pdf

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Queensland’s approach to occupational dust disease regulation

In Queensland, regulatory oversight in relation to preventing exposure to occupational dusts differ for particular industries. Work‐related exposure to respirable crystalline silica and respirable dust generally sits within the scope of the Office of Industrial Relations (OIR). OIR is responsible for administering the Work Health and Safety Act 2011 (WHS Act). Under the WHS Act, the responsible Minister has the power to make regulations prescribing standards relating to exposure to any hazard. The Work Health and Safety Regulation 2011 (WHS Regulation) outlines that a person conducting a business or undertaking must ensure that no person at the workplace is exposed to a substance or mixture in an airborne concentration that exceeds the exposure standard for the substance or mixture (section 49). The WHS Regulation also requires air monitoring of airborne contaminant levels (section 50). However, the WHS Act does not apply to all workplaces in Queensland, and excludes, for example, coal mines under legislation administered by the Department of Natural Resources, Mines and Energy (DNRME).

In Queensland, DNRME administers the coal and metalliferous mining and quarrying safety and health legislation through the Coal Mining Safety and Health Act 1999 and the Mining and Quarrying Safety and Health Act 1999. The legislation is risk‐based, requiring mine operators to manage risk through a documented safety and health management system.

Queensland’s response to respirable crystalline silica dust

The emergence of disease related to exposure to respirable crystalline silica among engineered stone benchtop workers is a matter the Queensland Government has taken very seriously. The Government has pursued a broad ranging strategy to minimise the exposure of workers to respirable crystalline silica in the stone benchtop industry and to lead positive change within the industry’s safety culture.

Campaign of audits of stone benchtop fabricators across Queensland

In terms of consultation question 1 (issues underlying increasing rates of silicosis), OIR’s decision to undertake an industry‐wide audit of stone benchtop fabrication businesses was made in response to findings of the CWP Inquiry, the August 2017 NSW Parliamentary First Review of the Dust Diseases Scheme, and the concerns of medical experts relating to the increase in silicosis diagnoses among workers in the industry.

On 18 September 2018 Minister Grace Grace MP, Minister for Education and Minister for Industrial Relations, made a Parliamentary announcement6 alerting the community to safety concerns around worker exposure to respirable crystalline silica in the stone benchtop industry and announcing the development of a new code of practice to support industry to meet the minimum standard required to manage worker exposure to respirable crystalline silica (the proposed code).

The Minister made this announcement immediately after becoming aware of the work health and safety implications revealed by the Phase 1 compliance audits undertaken by OIR across ten stone benchtop fabrication businesses in South East Queensland.

Phase 1 audits included an initial walk through to identify and assess any respirable crystalline silica generating processes and collection of personal air‐monitoring samples to quantify exposures (3 full days of sampling at each workplace to capture a representative number of workers – 30 days of sampling in total).

A report on the findings of the Phase 1 audits is at Attachment 1. The Phase 1 audits revealed widespread non‐compliance with WHS laws within the industry and found that:

dry cutting, grinding or polishing exposed workers to excessive amounts of dust;

6 See https://www.parliament.qld.gov.au/documents/hansard/2018/2018_09_18_WEEKLY.pdf

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water suppression was being used as the primary dust control;

the results of air monitoring indicated that water suppression alone was not always sufficient to ensure the safety of workers, especially when using grinders to cut stone;

respiratory protective equipment was not used by workers when using water suppressed tools;

housekeeping required improvement across all sites, as evidenced by a build‐up of dust on floors, walls and other surfaces;

personal exposure monitoring was not previously conducted at any of the sites visited; and

health monitoring was not conducted at any of the sites visited.

As part of Phase 1, personal air‐monitoring was undertaking for a range of similar exposed groups of workers (SEGs) (shapers, saw operators, finishers, Computer Numerical Control (CNC) Router/Water Jet Operators, polishers and labourer/supervisors). Across these groups, 88% of samples were found to contain respirable crystalline silica, and the SEG for shapers exceeded the workplace exposure standard for respirable crystalline silica.

In terms of consultation questions 2, 3 and 5 (ways to collect information to understand the problem; gaps in current protections for workers; and poor practice and barriers to good practice), the Phase 1 audits revealed a lack of maturity in health and safety across the industry, uncovering high rates of worker exposure to respirable crystalline silica occurring as a result of wide spread non‐compliance across the industry with Queensland’s existing work health and safety requirements.

Poor industry practices uncovered during Phase 1 included:

uncontrolled dry processing (cutting, grinding or polishing);

water suppression as the primary dust control on both hand tools and machinery;

insufficient housekeeping practices, evidenced by a build‐up of dust on floors, walls and other surfaces;

poor fitting respiratory protective equipment was in use, or respiratory protective equipment was not worn by workers engaged in wet cutting; and

neither personal exposure monitoring nor health monitoring had been conducted at any sites.

The Phase 1 audits also revealed:

poor understanding of the risks of respirable crystalline silica by both employers and workers;

uncontrolled dry processing was commonplace in the recent past (i.e. workplaces had only transitioned to wet cutting in the last 1‐5 years);

alterations during installation of benchtops was commonly conducted using uncontrolled dry processing; and

there was a misconception that respiratory protection and health monitoring was not required where wet processing was utilised.

The findings of Phase 1 were subsequently replicated in Phase 2 compliance audits undertaken across all known remaining stone benchtop workplaces in Queensland, which provided stronger evidence of wide‐spread non‐compliance (a total of 138 workplaces were audited).

To illustrate the extent of non‐compliance, almost 600 statutory notices were issued for respirable crystalline silica related contraventions identified during Phase 1 and Phase 2 audits of these workplaces carried out between October 2017 – July 2018, and September 2018 – December 2018 respectively. This included:

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57 prohibition notices, including for uncontrolled dry cutting of engineered stone and

inadequate workplace cleaning practices; and

541 improvement notices, including for not providing health monitoring, inadequate dust control, and issues with use and fit testing of respiratory protective equipment.

As at 22 October 2019, 17 infringement notices have been issued with fines totally $58,000.

Phase 3 of the audit campaign commenced on 29 March 2019 and involved the re‐auditing and re‐sampling of the ten stone benchtop workplaces targeted in Phase 1. The results of these audits found that industry has been proactively responding to advice from OIR inspectors by implementing recommended controls prior to inspectors attending the workplace. Overall:

employers and workers had better awareness concerning the risks posed by respirable crystalline silica;

improvements were evident in relation to water suppression systems to prevent water spray (i.e. through the addition of barriers, brush guards or welding screens to machinery or workstations);

general housekeeping and cleaning had improved, with workers ensuring that floors remained wet through the day to prevent dust from drying;

respiratory protection programs were implemented in all ten workplaces, and issues around ensuring workers were fit tested and clean shaven were overcome through training, instruction and supervision; and

all fabrication and installation workers had undergone at least their first health screen.

In May 2020, OIR inspectors will re‐audit a sample of those workplaces audited in Phase 2 to verify compliance with Queensland’s Managing respirable crystalline silica dust exposure in the stone benchtop industry Code of Practice 2019, and assist in industry’s safety journey.

The new Managing respirable crystalline silica dust exposure in the stone benchtop industry Code of Practice 2019

The information gathered during these audits provided an evidence base upon which a new code of

practice was developed and approved on 18 September 2019. This new code, the Managing respirable

crystalline silica dust exposure in the stone benchtop industry Code of Practice 2019 (the Queensland

Stone Benchtop Code) (Attachment 2), commenced on 31 October 2019 as an approved Code of

Practice under section 274 of the WHS Act. The development of the Queensland Stone Benchtop Code

relates to consultation questions 4, 6 and 7 (good practice and its causes; people impacted and those

to be involved in solutions; and examples of current work, projects or research).

Under section 26A of the WHS Act, a person conducting a business or undertaking must comply with

an approved code of practice or manage hazards and risks arising from the work carried out as part of

the conduct of the business or undertaking in a way that is different to the code but provides a

standard of health and safety that is equivalent to or higher than the standard required under the

code.

OIR worked closely with stakeholders in the formulation and development of the Queensland Stone Benchtop Code. OIR established and chaired a Stone Benchtop Industry Working Group (the Working Group) consisting of representatives of unions (i.e. Construction, Forestry, Maritime, Mining and Energy Union, the Electrical Trades Union and the Australian Manufacturing Workers’ Union), industry associations (i.e. Master Builders Queensland, the Housing Industry Association, the Chamber of Commerce and Industry Queensland, and Ai Group) and medical experts (i.e. Royal Australasian College of Physicians, the Australasian Faculty of Occupational and Environmental Medicine and the

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Thoracic Society of Australia and New Zealand). The Working Group also included technical experts (i.e. from the Australian Institute of Occupational Hygienists), representatives from stone benchtop fabrication businesses of different sizes, as well as manufacturers and importers (i.e. Caesarstone, Silestone, Laminex and the Australian Stone Advisory Association). Other government agencies were also involved, including Queensland Health, WorkCover Queensland and DNRME.

The Working Group met four times and deliberated over a period of twelve months to finalise the code.

OIR’s consultation on the code’s development also included significant targeted consultation outside of the Working Group meetings, as well as ongoing collaboration with key employer and worker representatives, technical experts, medical experts and fabrication businesses.

The Queensland Stone Benchtop Code:

sets standards to prevent worker exposure to respirable crystalline silica dust in the stone benchtop fabrication industry that can lead to the development of lung dust diseases such as silicosis (including progressive massive fibrosis), particularly in those workers cutting, grinding, polishing or shaping stone slabs;

provides clarity and certainty as to the minimum standard industry must meet to identify and manage respirable crystalline silica dust hazards at stone benchtop fabrication businesses with a focus on primary and secondary prevention approaches; and

achieves consistent standards of work health and safety across the stone benchtop fabrication industry.

The Queensland Stone Benchtop Code applies to all fabrication or processing, including processing

during installation, maintenance and removal, of engineered and natural stone benchtops, and

associated activities such as clean‐up or maintenance of equipment as it relates to respirable

crystalline silica.

The Queensland Stone Benchtop Code provides a systematic approach to controlling the risks

associated with respirable crystalline silica, including continuous monitoring, review and revision in

relation to dust and exposure controls. This includes (but is not limited to):

specific dust suppression and minimisation controls that must be used;

minimum requirements for respiratory protective equipment to be used by stone benchtop fabricators, and those undertaking associated activities (i.e. cleaning and maintenance);

requirements for air monitoring to be undertaken at specified intervals to check the effectiveness of the controls (with air monitoring reports to be made available to an inspector);

investigation of any exceedances of the workplace exposure standard (and documentation detailing any corrective measures); and

requirements for health monitoring at set points and intervals, with adverse reports requiring review and revision of controls and notification to the WHS regulator.

The Queensland Stone Benchtop Code also summarises the duties that exist in relation to information,

training, instruction and supervision, and in relation to consultation with workers, and other duty

holders where a shared duty exists (i.e. labour hire).

The commencement of the Queensland Stone Benchtop Code has been supported by information

sessions held by OIR across Queensland. These sessions have been undertaken in conjunction with

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the Australian Institute of Occupational Hygienists’ roll out of the Breathe Freely Program, designed

to educate workers and employers about the dangers of occupational dust.

Consideration of duties of suppliers and importers of engineered stone

As part of its response to respirable crystalline silica, OIR has engaged directly with suppliers and

importers of engineered stone products to ensure they understand the risks associated with their

products and to determine if they have discharged their legal health and safety duties in the past and

their ongoing compliance into the future. Specifically, OIR requested suppliers and importers provide

the WHS regulator with information as to how they have been ensuring that silica‐containing

engineered stone is without risks to workers fabricating the stone, and details of the information they

have been providing to every person supplied with engineered stone to ensure the substance is

without risks in relation to respirable crystalline silica.

OIR also sourced client data from importers and suppliers as part of Phase 2 of compliance audits to

identify the location of stone benchtop fabrication workplaces to ensure appropriate targeting for the

audit campaign. This relates to consultation questions 6 and 7 (people impacted and those to be

involved in solutions; and examples of current work, projects or research).

Queensland advocacy for national action

On a number of occasions since September 2018, the Minister for Education and Minister for Industrial

Relations wrote to the Honourable Kelly O’Dwyer MP, then federal Minister for Jobs, Industrial

Relations and Women, advocating a national response to the threat posed by respirable crystalline

silica, including the development of a national code of practice. In July 2019, the Minister for Education

and Minister for Industrial Relations also wrote to the Honourable Christian Porter MP, Attorney‐

General and Minister for Industrial Relations, again highlighting the need for a national response to

silicosis.

The Minister for Education and Minister for Industrial Relations is also writing to the Honourable Michael Sukkar MP, Assistant Treasurer and Minister for Housing, requesting that the Australian Competition and Consumer Commission (ACCC) investigate the matter of imported engineered stone and the related silicosis risks. It is Queensland’s view that examination of the product safety of engineered stone by the ACCC would assist the Taskforce by providing advice on suitable approaches for the future prevention of silicosis‐related disease, and potentially deal with risks to other persons not covered by work health and safety laws such as home renovators.

Both of these activities relate to consultation questions 3 and 6 (gaps in current protections for workers; people impacted and those to be involved in solutions).

Collaboration and information sharing with the Californian Department of Public Health

Officials from the Californian Department of Public Health and the Occupational Safety and Health

Administration in the United States, and public health executives from WorkSafe New Zealand, are

engaging with the Queensland Government to learn about the work undertaken in Queensland to

address risks associated with exposure to respirable crystalline silica. OIR and WorkCover Queensland

are continuing to engage with interested parties to share learnings where possible. This relates to

consultation questions 6 and 7 (people impacted and those to be involved in solutions; and examples

of current work, projects or research).

Health screening and WorkCover Queensland support for workers diagnosed with silicosis

WorkCover Queensland is continuing to support workers affected by exposure to silica by assisting

them through the workers’ compensation process and providing high quality treatment and

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rehabilitation, as well as funding free initial health screenings for current or former workers in

Queensland who have been exposed to dust from engineered stone in their workplaces.

As at 30 October 2019, WorkCover Queensland has screened 1,000 workers with 26 workers yet to

complete the process, and has accepted 176 workers’ compensation claims for silicosis from current

and former stonemasons within the stone benchtop industry (25 with progressive massive fibrosis,

the severest form of the disease).

A further 10 claims have been accepted relating to other respiratory conditions due to respirable

crystalline silica, such as bronchitis and emphysema. It should be noted that not all claims were

diagnosed through the free health screening, as some workers lodged a claim directly with WorkCover

Queensland. Claims data has been made publicly available on the WorkSafe website7.

Workers’ compensation entitlements for workers diagnosed with dust diseases include lump sums,

compensation for lost time earnings, and all reasonable medical expenses, including hospitalisation,

surgery, rehabilitation, medication and medical aids, plus an additional lump sum for workers with

pneumoconiosis of up to $127,440. An overview of entitlements under the Queensland workers’

compensation scheme is provided in Attachment 4. The current number of claims demonstrate the

risk associated with the high silica content of engineered and some natural stone and the need for

stringent implementation and enforcement of effective dust control and health monitoring measures.

These activities relate to consultation questions 4, 6 and 7 (good practice and its causes; people

impacted and those to be involved in solutions; and examples of current work, projects or research).

Clinical guidelines concerning diagnoses related to respirable crystalline silica

The Queensland Government also identified the need to provide clear guidance for health

practitioners for the assessment and diagnosis of diseases related to respirable crystalline silica

exposure. To develop the Guideline, OIR established a Practitioner Guidance for Silicosis Reference

Group (the Reference Group), including key health specialists from:

the Thoracic Society of Australia and New Zealand;

the Australasian Faculty of Occupational and Environmental Medicine;

the Australian and New Zealand Society of Occupational Medicine;

the Royal Australian and New Zealand College of Radiologists; and

the Australian College of Rural and Remote Medicine.

The Reference Group was also supported by the Australian Institute of Occupational Hygienists,

Queensland Health, WorkCover Queensland, and DNRME.

The Guideline for assessing engineered stone workers exposed to silica (the Guideline) sets out the

process for assessing the respiratory health of a worker with exposure to respirable crystalline silica

from engineered stone for silica‐related diseases, including referrals for additional testing or

investigations which may be required depending on the individual worker’s circumstances (see

Attachment 5).

The Guideline advocates that medical practitioners should use their clinical judgement to determine

the most appropriate testing for the worker, including for example, if a potentially high‐risk worker

should be referred directly for a High Resolution CT scan (HRCT) and respiratory function testing in the

first instance or referred directly to a respiratory physician for evaluation. The pathway chosen by the

7 See https://www.worksafe.qld.gov.au/silicosis/background‐to‐silicosis

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clinician should consider the worker’s history, presentation, accessibility to testing, and their unique

circumstances.

The Guideline does not cover the treatment of workers diagnosed with silica‐related diseases. Treating

practitioners should make clinical decisions about treatment based on the individual worker’s

circumstances.

It is expected that the Guideline will be publicly available shortly on the Worksafe Queensland website.

The development of the Guideline relates to consultation questions 4, 6 and 7 (good practice and its

causes; people impacted and those to be involved in solutions; and examples of current work, projects

or research).

Future actions to address the work health and safety risks of occupational dust exposure

Future actions planned by OIR and WorkCover Queensland also relate to consultation questions 4, 6

and 7 (good practice and its causes; people impacted and those to be involved in solutions; and

examples of current work, projects or research).

Best Practice Review Recommendation 11 – identifying current and emerging risks

The Best Practice Review of Workplace Health and Safety Queensland (WHSQ) within OIR followed the tragic deaths of patrons at Dreamworld, and workers at an Eagle Farm workplace in 2016. On 3 July 2017 the Independent Reviewer, Mr Tim Lyons, handed down a report of the Best Practice Review8 containing 58 recommendations, which were largely adopted by the Queensland Government. Recommendation 11 recommended that ‘WHSQ and the Work Health and Safety Board consider establishing a specific strategy to address key occupational health risks, including examining international approaches that ensure longitudinal data on current and emerging risks are utilised as part of a health surveillance framework’.

In response to this recommendation, OIR has a formed a dedicated working group to establish a specific strategy to address key occupational health risks (both current and emerging) including work‐related cancers and respiratory disease (such as silicosis). This strategy will include the examining of international approaches involving health surveillance frameworks that systematically collect and analyse longitudinal health and other data from a range of sources to monitor change about current and emerging risks. Current and emerging risks that OIR is aware of include hazards relating to lead, wood dust, nanotechnology and diesel particulate.

Additional audits of stone benchtop workplaces

As outlined above, in May 2020 OIR inspectors will re‐audit some of the workplaces audited in Phase

2 to check compliance with Queensland’s Managing respirable crystalline silica dust exposure in the

stone benchtop industry Code of Practice 2019, which commences on 31 October 2019.

Queensland Silica in Construction Code

Work has now commenced on scoping the development of a code of practice for managing respirable

crystalline silica dust exposure in the construction industry (the Queensland Silica in Construction

Code). This code was announced by the Minister for Education and Minister for Industrial Relations in

Parliament on 18 September 2019.

The development of the Queensland Silica in Construction Code is expected to be a highly complex

undertaking due to the size and trade diversity of the industry, as well as the large range of products

8 See https://www.worksafe.qld.gov.au/__data/assets/pdf_file/0016/143521/best‐practice‐review‐of‐whsq‐final‐report.pdf

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used across the industry containing respirable crystalline silica (i.e. asphalt, clay, adhesives, concrete,

mortar, cement renders and other materials).

Consideration of regulatory changes

A suite of regulatory changes is being considered in relation to respirable crystalline silica, including

further reinforcement of the existing prohibition on dry cutting along with specific requirements for

health monitoring, provision of training and limiting the use of particular equipment. Queensland is

looking at a range of approaches, including those taken internationally (in particular British Columbia),

to inform the scope of the regulatory changes, and will be consulting with industry on these changes

in due course.

Jurisdictional access to importation data

Queensland acknowledges that the Chair of the National Dust Disease Taskforce has written to seek

the advice of Heads of Workplace Safety Authorities (HWSA) members on the value of specific

important data to state and territory WHS regulators. Queensland is supportive of access to data,

filtered by the Australian Border Force, relating to the import of engineered stone. Access to this data

would assist Queensland to corroborate the information it has sourced directly from suppliers and

importers, as well as to identify potential unknown workplaces for targeting with further compliance

efforts.

International research project to examine support for workers diagnosed with silicosis

Through an open tender process, WorkCover Queensland has engaged two leading universities to

undertake important research on how to best support workers who have been diagnosed with

silicosis. Professor Malcolm Sim from Monash University and Professor Bob Cohen from the University

of Illinois are leading expert teams to address important issues including:

the treatment, rehabilitation and retraining options that are available to improve workers’ capacity to work;

the mental health impact and issues preventing return to work; and

ensuring the return to work environment is safe to protect workers’ long‐term health.

The research is expected to be published in 2020 and will assist schemes across Australia and

internationally to improve how workers with dust diseases are supported in their recovery.

Queensland actions concerning occupational dust more generally

The following actions concerning occupational dust more generally relate to consultation questions 4,

6 and 7 (good practice and its causes; people impacted and those to be involved in solutions; and

examples of current work, projects or research).

Queensland Notifiable Dust Lung Disease Register

The Queensland Notifiable Dust Lung Disease Register (the NDLD Register) was established on 1 July

2019 after amendments to the Public Health Act 2005 (Qld) and Public Health Regulation 2018 (Qld)

came into effect.

The purposes of the NDLD Register are to monitor and analyse the incidence of notifiable dust lung disease, and enable information about notifiable dust lung diseases to be exchanged with an entity of the State. Occupational and respiratory medicine specialists are required to notify the NDLD Register if they make a diagnosis of a notifiable dust lung disease when caused by occupational exposure to inorganic dust, including cancer (i.e. mesothelioma), chronic obtrusive pulmonary disease (including bronchitis and emphysema), and pneumoconiosis, including asbestosis, coal workers’

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pneumoconiosis, mixed‐dust pneumoconiosis, and silicosis. Examples of inorganic dust include dust from silica, coal, asbestos, natural stone, tungsten, cobalt, aluminium and beryllium.

Information collection requires clinical notifications by appropriately qualified medical practitioners.

The notification system set up for this register is flexible, to accommodate the preferences of

individual clinicians or reporting agencies. For example, although reporting of dust diseases via an

online portal would appear to be optimal, presently some clinical notifiers may prefer to report using

a paper‐based notification form and faxing. Queensland Health has aimed to streamline the

notification process and enable notifications that are as rapid as possible9.

Legislative reforms and standards for monitoring and control of respirable dust and respirable

crystalline silica in the mining industry

In 2017, Queensland introduced additional legislative reforms that relate to the monitoring, control and reporting of respirable dust and respirable crystalline silica in the mining industry. Specifically, this legislation requires the implementation of risk‐based occupational hygiene monitoring programs and the reporting of all personal exposure data to a central exposure database that is maintained by DNRME. This data is reviewed to understand industry exposure trends and to monitor individual mine site compliance. These reforms have resulted in significant reduction in respirable dust and silica exposures for Queensland mine workers.

A series of standards and guidelines10 were also introduced to ensure the effectiveness of dust control and monitoring including:

Monitoring respirable dust in coal mines (Recognised Standard 14);

Underground respirable dust control in coal mines (Recognised Standard 15); and

Guideline for management of respirable crystalline silica in Queensland mineral mines and quarries (QGL02).

In addition, substantive enhancements have been made to the quality of health surveillance11. Mandatory medical examinations must be performed in accordance with new standards for the delivery of spirometry, chest X‐ray examinations and follow‐up testing of workers with abnormal screening results. New training programs for doctors performing assessments, spirometry technicians and radiologists have been developed or endorsed with an accompanying register12 of medical practitioners approved by DNRME that must only be used. All retired and former mine or quarry workers can now access free lung health checks, organised and paid by DNRME every five years for life. Any detection of disease must be reported.

These reforms have resulted in significant reduction in respirable dust and silica exposures for Queensland mine and quarry workers, as well as improved early detection and reporting of disease.

9 See https://www.health.qld.gov.au/public‐health/industry‐environment/dust‐lung‐disease‐register/making‐a‐notification. See also https://www.health.qld.gov.au/public‐health/industry‐environment/dust‐lung‐disease‐register/about‐the‐register 10 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/legislation‐standards/recognised‐standards 11 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/medicals/dust‐lung‐disease 12 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/medicals/register‐providers

13

Occupational dust lung disease in mining

Types of mine dust lung disease

Mine dust lung diseases (MDLD) are caused by long‐term exposure to high concentrations of respirable dust, generated during mining and quarrying activities. MDLDs include a range of occupational lung conditions, including but not limited to CWP, mixed‐dust pneumoconiosis (MDP), silicosis, chronic obstructive pulmonary disease (COPD) and asbestosis.

When MDLD was first re‐identified in Queensland, there was a strong focus on CWP. However, miners are at risk from a broad range of lung conditions from the same, or combination of, respirable dust hazards.

As at 31 October 2019, 124 individual workers with one or more type of MDLD have been reported to the Queensland Government (DNRME) since 1984. Nine of these cases have progressed to the most severe stage of disease referred to as progressive massive fibrosis. Monthly updates of these figures are provided on DNRME’s website13.

OIR data shows that 88 workers’ compensation claims for MDLD have been accepted in Queensland (not all cases identified through DNRME result in accepted compensation claims for a variety of reasons).

In line with the Taskforce’s focus, mining and quarry workers can be exposed to respirable crystalline

silica across a broad range of activities in both underground and open‐cut operations. Unlike the

engineered stone benchtop industry, these exposures arise from naturally occurring crystalline silica

from materials with lower silica content. Of the 124 reported cases, 26 include a diagnosis of silicosis,

and none of these are considered accelerated silicosis.

Key learnings from the re‐identification of mine dust lung disease in Queensland

Since the 2015 re‐identification of CWP in Queensland (and other mine dust lung diseases including

silicosis), the Queensland Government has been working to reform dust management and health

surveillance requirements for these respiratory hazards to improve prevention and early detection of

disease.

The following key learnings from the re‐identification of mine dust lung disease in Queensland are summarised below for the Taskforce’s consideration:

management of hazards for health risk is paramount (i.e. risk assessment, controls, monitoring exposures and effectiveness of controls and health surveillance to ensure any disease is detected early);

partnership between all stakeholders is crucial, including employers and operators, unions, medical profession, academia and regulators;

awareness, education and information must be provided;

acknowledgment that respiratory hazards cause a range of diseases (not just silicosis) and there are other respiratory diseases caused by silica exposure, such as chronic obstructive pulmonary disease and lung cancer;

13 See https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/accidents‐incidents/mine‐dust‐lung‐diseases

14

the importance of ensuring digital data capture occurs in a way that can be used for analysis and research to inform effectiveness of controls in specific job roles and operations in the mining context;

understanding the risk of exposure is complicated (and includes measuring workers’ exposure, assessing effectiveness of controls and movement of workers between sites) – tying this to whether health surveillance is implemented runs a high risk of workers who should have medical assessments not being tested – health surveillance should be mandatory unless a risk assessment shows otherwise;

the effectiveness and quality of health surveillance must be validated;

personal monitoring must be standardised as well as minimum standards for controlling exposure;

health surveillance must continue into retirement due to the long latency of disease as the risk of disease is not eliminated when exposure ceases – the reporting of disease diagnosed in retired or former workers is significantly important to the health of those workers and to the evaluation of the effectiveness of health hazard management across the mining industry; and

combined fitness for work and health surveillance processes can be difficult to manage due to competing interests between employment security, risk management and health protection.

In addition to the material outlined above, DNRME has also provided comment (specific to occupational dust in the mining sector) on consultation questions 1 – 8 outlined by the Taskforce (Attachment 3).

Findings report:

Phase one audits of engineered stone benchtop

fabricators in South East Queensland

Attachment 1.docx Page 2 of 24

Executive Summary

Research in Australia and overseas has found that workers fabricating bench tops from engineered stone

can be exposed to levels of respirable crystalline silica (RCS) which are hazardous to their health.

Engineered stone bench tops can contain up to 95 per cent crystalline silica. Cutting, grinding, sanding

and polishing these bench tops generates large amounts of respirable crystalline silica (RCS) putting

workers’ health at risk. Exposure to respirable-sized particles can lead to a range of respiratory diseases

including silicosis, a serious and irreversible lung disease. Workers exposed to RCS are also at increased

risk for chronic obstructive pulmonary disease (COPD), kidney disease and lung cancer.

Workplace Health and Safety Queensland (WHSQ) within the Office of Industrial Relations is undertaking

a proactive, industry-wide audit of stone bench top fabricators in Queensland in response to findings of

the 2017 Queensland Inquiry into the re-identification of Coal Workers' Pneumoconiosis, the August 2017

New South Wales Parliamentary First Review of the Dust Diseases Scheme and the concerns of medical

experts relating to an increase in silicosis diagnoses among workers in the industry.

Phase 1 of the compliance audits involved comprehensive field based research at 10 pilot workplaces in

South-east Queensland undertaken by or under the supervision of WHSQ’s certified occupational

hygienist. The purpose of the pilot audits was to:

• identify stone benchtop manufacturing processes that expose workers to respirable

crystalline silica (e.g. workers performing shaping, saw operation, polishers)

• understand the types of controls used in the industry

• assess workers personal exposure to respirable crystalline silica with respect to the existing

dust controls measures such as water suppression, local exhaust ventilation, slurry

management

• assess and determine the effectiveness of risk control measures in place to manage

respirable crystalline silica exposure of workers.

The audit process included an initial walk through survey to identify respirable crystalline silica generating

processes, assessing the work processes which included collecting personal air-monitoring samples to

quantify exposures (3 full days of sampling at each workplace to capture a representative number of

workers – 30 days of sampling in total). Workers were grouped into similarly exposed groups (SEGs) and

the results of the personal exposure monitoring were used to estimate exposures for each SEG, see Table

1 below, allowing them to be measured against the current Workplace Exposure Standard (WES) for RCS

of 0.1mg/m3.


SEG Description

Estimated SEG

exposure

(mg/m3)*

Shapers

Workers cut holes in slabs for taps, sinks or stovetops and

conducted joinery and associated edge grinding of stone

predominantly using powered hand tools.

0.69

Saw Operators Workers operated bridge saws or similar slab cutting

equipment that used a cutting blade on stone.

0.06

Finishers

Workers conducted all fabrication tasks associated with

finishing a bench-top after it had been cut by slab cutting

equipment. This included both shaping and polishing processes

predominantly using hand tools.

0.057

Computer Numerical

Control (CNC)

Router/Water Jet

Operators

Workers operated CNC routers or other similar equipment that

used a cutting tool on stone. This group included water jet

operators.

0.056

Polishers Workers bevelled edges and polished stone using powered

hand tools.

0.05

Labourer/Supervisor Workers that conducted support tasks including operating

forklifts and general labouring or supervision.

0.045

The personal exposure monitoring results revealed that:

88% of samples collected contained RCS

9% of results and the similarly exposed group (SEG) for Shapers exceeded the workplace

exposure standard (WES) for RCS (0.1 mg/m3).

35% of results and five out of the six SEGs exceeded 50% of the WES (0.05 mg/m3). It is standard

occupational hygienist practice that 50% of the WES is set as the action level where controls need

to be improved to reduce exposure.

70% of results and all SEGs exceeded 0.025 mg/m3). This is the Threshold Limit Value 1 at which

nearly all workers may be repeatedly exposed, day after day, over a working lifetime, without

adverse effects to their health. However above this level there is a significant risk to health and

RPE and health monitoring is expected.

Workers in the Shapers SEG who are generally required to use grinders are at highest risk of

exposure, with an estimated exposure of approximately seven times the WES.

These results indicate that in addition to an improvement in higher order controls, respiratory

protective equipment (RPE) must be worn to manage residual exposure risks and health

monitoring is required to detect changes in workers’ health.

1 American Conference of Governmental Industrial Hygienists 2018 Threshold Limit Value for respirable crystalline sil ica https://www.osha.gov/dsg/annotated-pels/tablez-1.html

https://www.osha.gov/dsg/annotated-pels/tablez-1.html


The Phase 1 audits revealed widespread non-compliance with work health and safety laws within the

industry and found that:

Dry cutting, grinding or polishing exposed workers to excessive amounts of dust.

Water suppression was being used as the primary dust control.

The results of monitoring indicated that water suppression alone was not always sufficient to

ensure the safety of workers, especially when using grinders to cut stone.

Respiratory protective equipment was not used by workers when using water supressed tools.

Housekeeping required improvement across all sites, as evidenced by a build-up of dust on floors,

walls and other surfaces.

Personal exposure monitoring was not previously conducted at any of the sites visited.

Health monitoring was not conducted at any of the sites visited.

Phase 1 audits allowed WHSQ to identify effective dust controls and this evidence was used to develop a

Safety alert – Immediate action required to prevent exposure to silica for engineered stone benchtop

workers and the Protecting workers from exposure to respirable crystalline silica – Guide to safe bench top

fabrication and installation industry guide which outline effective dust controls and other safety

matters. The alert and guide provide clear and urgent advice on immediate actions to be take n in the

workplace and legal requirements to be complied with to ensure worker safety.

Phase 2 of the compliance audits, led by 22 specially trained inspectors supported by OIR occupational

hygienists commenced on 20 September with over 130 workplaces identified for audit by the end of

2018.


Contents

1. Introduction.................................................................................................................................................. 6

2. Background................................................................................................................................................... 7

3. Management of risk ...................................................................................................................................... 8

3.1 Workplace Exposure Standard (WES) ...................................................................................................... 8

3.2 Action Level........................................................................................................................................... 8

3.3 Health risks............................................................................................................................................ 8

4. Program Purpose........................................................................................................................................... 8

5. Assessment process....................................................................................................................................... 9

5.1 Who was monitored .............................................................................................................................. 9

6. Results........................................................................................................................................................ 10

6.1 Observations - wet processes ............................................................................................................... 10

6.2 Observations- dry processes ................................................................................................................. 10

6.3 Observations- housekeeping practices .................................................................................................. 11

6.4 Feedback regarding benchtop Installation ............................................................................................. 11

7. Personal sampling ....................................................................................................................................... 12

7.1 Shapers ............................................................................................................................................... 12

7.2 CNC Router/Water Jet Operators .......................................................................................................... 13

7.3 Saw Operators ..................................................................................................................................... 12

7.4 Finishers.............................................................................................................................................. 12

7.5 Polishers ............................................................................................................................................. 13

7.6 Labourer/Supervisor ............................................................................................................................ 13

7.7 RCS exposures within each SEG............................................................................................................. 13

8. Discussion ................................................................................................................................................... 15

8.1 Shapers ............................................................................................................................................... 16

8.2 Saw operators ..................................................................................................................................... 16

8.3 Finishers.............................................................................................................................................. 17

8.4 CNC router/water jet operators ............................................................................................................ 17

8.5 Polishers ............................................................................................................................................. 18

8.6 Labourer/Supervisor ............................................................................................................................ 18

8.7 Respiratory protective equipment ........................................................................................................ 19

8.8 Health monitoring................................................................................................................................ 19

9. Enforcement action ..................................................................................................................................... 19

10. Recommendations................................................................................................................................... 20

Appendix A - Air monitoring methodology ........................................................................................................... 21

Appendix B - Effective dust controls..................................................................................................................... 23


1. Introduction Workplace Health and Safety Queensland (WHSQ) within the Office of Industrial Relations is undertaking a proactive,

industry-wide audit of stone bench top fabricators in Queensland in response to findings of the 2017 Queensland

Inquiry into the re-identification of Coal Workers' Pneumoconiosis, the August 2017 New South Wales Parliamentary

First Review of the Dust Diseases Scheme and the concerns of medical experts relating to an increase in silicosis diagnoses among workers in the industry.

Engineered and natural stone used for bench tops contains crystalline silica, also called quartz. Cutting, grinding and

polishing natural or engineered stone generates respirable crystalline silica (RCS), which puts workers' health at risk. Engineered stone bench tops can have a very high crystalline silica content of up to 95%.

Phase 1 of the compliance audits involved comprehensive field based research at 10 pilot workplaces in South -east

Queensland undertaken by or under the supervision of OIR’s certified occupational hygienist. The audit process

included an initial walk through survey to identify respirable crystalline silica generating processes, assessing the

work processes which included collecting personal air-monitoring samples to quantify exposures (3 full days of

sampling at each workplace to capture a representative number of workers – 30 days of sampling in total). The

purpose of the pilot audits was to:

identify stone benchtop manufacturing processes that expose workers to respirable crystalline silica (e.g. workers performing shaping, saw operation, polishers)

understand the types of controls used in the industry

assess workers personal exposure to respirable crystalline silica with respect to the existing dust controls measures such as water suppression, local exhaust ventilation, slurry management

assess and determine the effectiveness of risk control measures in place to manage respirable crystalline silica exposure of workers.

During phase 1, WHSQ assessed each individual worker’s exposure to respirable crystalline silica using personal

exposure monitoring. To do this workers were assigned into similarly exposed groups (SEGs) based on the process or

task they completed for the majority of their work day. There were six identified SEGs as follows: shapers, saw

operators, finishers, CNC Router/Water Jet Operators, polishers and labourers/supervisors. The results of the

personal exposure monitoring were used to estimate exposures for each SEG and this allowed them to be measured against the current Workplace Exposure Standard for respirable crystalline silica of 0.1mg/m3.

The collection of samples was carried out using standard occupational hygiene methodology and in accordance with

the Australian Standard on respirable dust sampling (AS 2985: 2009 – Workplace atmospheres – Method for

sampling and gravimetric determination of respirable dust). The overall sampling strategy (i.e. who was sampled,

how many samples were collected and expected similar exposure groups (SEGs)) were designed to assist in

establishing a reasonable belief about the risk to health of workers, gather evidence about the tasks and processes that generate RCS and understand industry controls being used.

The findings from phase 1 auditing (based on personal air monitoring results, observations during the walkthrough survey and general dust management principles) allowed WHSQ to identify effective dust controls which focus on:

Capturing or suppressing dust at the source of generation.

Using processes that generate less dust (e.g. CNC routers for sink or stovetop cut outs).

Containing water mist or waste created from process water suppressed processes. Providing distance or physical barriers between workers and dust generating processes.

Frequently cleaning surfaces to prevent the build-up of dust.

In addition, only certain types of respiratory protective equipment should be used to protect workers from residual

exposure risks of respirable crystalline silica.


2. Background Crystalline silica is a basic component of soil, sand, granite, and many other minerals. There are three forms of

crystalline silica including quartz, cristobalite and tridymite. Quartz is the most common form of crystalline silica and

is found in products such as concrete, mortar, brick, blocks, pavers, tiles, natural and composite stone benchtops.

Quartz content in stone benchtops can vary widely depending on the type of stone. Engineered stone can contain up to 95% quartz whereas a natural stone such as granite contains approximately 35%.

Workers may be exposed to airborne RCS during stone benchtop manufacturing processes when cutting, grinding,

sanding and polishing, and during the installation of the stone benchtops.

RCS is a significant health-hazard for workers. RCS is too small to be seen under normal lighting, the small particle

size allows it to stay airborne for long periods of time and it is easi ly inhaled deep into the lungs where it can be

deposited and lead to a range of respiratory diseases, including silicosis, chronic obstructive pulmonary disease and

lung cancer.

Silicosis is a serious and irreversible lung disease that causes permanent disablement and early death, and it is made

worse by smoking. It is commonly caused by exposure to RCS over many years, but extremely high short -term exposures, as may occur when working with engineered stone benchtops, can cause it to develop rapidly.

Engineered stone has been widely used in Australian kitchens and bathrooms for the last 15 years. There is only one

known manufacturer of engineered stone in Australia based in Victoria. Engineered stone products are commonly manufactured in China, Spain and Israel.

Within Australia, smaller benchtop fabricators generally source their stone from numerous suppliers/wholesalers,

however some larger fabricators import their stone directly. There are approximately 130 workplaces engaging in

the fabrication of engineered stone products in Queensland, with almost 80% located in the southern region of the state.

Figure 1 (below) provides a general description of work flow in the stone -benchtop fabrication industry. Each workplace varied slightly depending on work organisation, staff and layout.

Figure 1 - Stone benchtop fabrication and installation process (general)


3. Management of risk

3.1 Workplace Exposure Standard (WES)

The current legislated workplace exposure standard (WES) for respirable crystalline silica in Australia is 0.1 mg/m 3

TWA 2. Exposure standards do not identify a dividing line between a healthy or unhealthy working environment and are not considered as a strict acceptable level of exposure to workers.3

3.2 Action Level

Exposure standards for RCS are being reviewed and revised worldwide, including in Australia currently.4 OSHA have

recently reduced their permissible exposure limit to 0.05 mg/m3 with an action level of 0.025 mg/m3 for health

monitoring. This is the Threshold Limit Value 5 at which nearly all workers may be repeatedly exposed, day after day,

over a working lifetime, without adverse effects to their health. However above this level there is a significant risk to health and RPE and health monitoring is expected.

For this intervention, an action level of 50% of the exposure standard, that is 0.05 mg/m3, was used for individual

and similarly exposed group (SEG) results as a trigger to improve control measures in line with standard occupational

hygienist practice.

3.3 Health risks

Under the Work Health and Safety Regulation 2011, PCBUs must ensure that risks from exposure are minimised as

far as is reasonably practicable, not just until a statutory limit has been achieved. The enforcement procedure used

by inspectors reflected this by focusing on control combinations known to reduce exposure to well below the current WES. This is because just complying with a statutory maximum does not mitigate health risks.

A recent OSHA literature review identified that the estimated risk of silicosis from 45 years exposure at 0.1 mg/m 3

(current WES) ranges from 60 to 773 cases per 1 000 and 0.05 mg/m3 is between 20 and 170 cases per 1 000. At two

and a half times the current exposure standard (0.25 mg/m3) the risk of silicosis from 45 years of exposure is approaching 100%.6

4. Program Purpose

The purpose of the program was to:

identify stone benchtop manufacturing processes that expose workers to RCS understand the types of controls used in the industry

assess workers personal exposure to RCS and determine how effective current controls, specifically water suppression, are at managing dust risks.

2 8-hour Time-weighted Average (TWA) means the maximum average airborne concentration of a substance when calculated over an eight-

hour working day, for a five-day working week. 3 Safe Work Australia, 2013. Guidance Note on the Interpretation of Workplace Exposure Standards for Airborne Contaminants . 4 Safe Work Australia. 2018. Workplace exposure standards review methodology. Retrieved from Safe Work Australia:

https ://www.safeworkaustralia.gov.au/workplace-exposure-standards-review-methodology 5 American Conference of Governmental Industrial Hygienists 2018 Threshold Limit Value for respirable crystalline silica

https://www.osha.gov/dsg/annotated-pels/tablez-1.html 6 OSHA. (2016, March 25). Occupational Exposure to Respirable Crystalline Silica; Final Rule. Federal Register Volume 81, Number 58 . United States of America: United States Departement of Labour, available at: https://www.gpo.gov/fdsys/pkg/FR-2016-03-25/pdf/2016-04800.pdf

https://www.osha.gov/dsg/annotated-pels/tablez-1.html

https://www.gpo.gov/fdsys/pkg/FR-2016-03-25/pdf/2016-04800.pdf


5. Assessment process Ten (10) sites were selected at random from a list of fabricators compiled through assistance of suppliers,

WorkCover Queensland and internet searches. Engineered stone was the primary material used for benchtops at nine out of ten sites. Natural stone was the primary material used by Company 3.

Table 1 (below) provides a breakdown of businesses and workforce size.

Table 1 - Business name, location and approximate fabrication worker numbers.

Businesses Number of fabrication

workers Company 1 <= 5

Company 2 6 to 10 Company 3 <=5

Company 4 >10 Company 5 6 to 10

Company 6 <= 5

Company 7 >10 Company 8 6 to 10

Company 9 6 to 10 Company 10 >10

The assessment process included an initial walk through survey to identify RCS-generating processes, assess the process which included collecting personal air-monitoring samples to quantify exposures.

The assessment only targeted fabrication of stone not the installation of stone. Installers made up a large portion of

each businesses’ workforce, however they were out of the scope of this intervention. Any feedback/comment from the PCBUs collected on this type of work was recorded.

The assessment of benchtop installers is expected to be targeted in future interventions.

5.1 Who was monitored

Similarly exposed groups (SEGs) were identified at each workplace during the walkthrough survey. Workers were

assigned a SEG based on the process or task they completed for the majority of their work day (qualitative). Personal

air samples were collected from workers in each of these groups. Table 2 below lists the groups and the tasks and description for each SEG.

Table 2 – Similarly exposed groups and process descriptions

SEG Description

Saw Operators Workers operated bridge saws or similar slab cutting equipment that used a

cutting blade on stone.

CNC Router/Water Jet

Operators

Workers operated CNC routers or other similar equipment that used a cutting

tool on stone. This group included water jet operators.

Shapers Workers cut holes in slabs for taps, sinks or stovetops and conducted joinery

and associated edge grinding of stone predominantly using powered hand tools.

Polishers Workers bevelled edges and polished stone using powered hand tools.

Finishers

Workers conducted all fabrication tasks associated with finishing a bench-top

after it had been cut by slab cutting equipment. This included both shaping and

polishing processes predominantly using hand tools.


SEG Description

Labourer/Supervisor Workers that conducted support tasks including operating forklifts and general

labouring or supervision.

Air-monitoring was conducted over several days at each workplace to capture representative number of workers.

Samples collected were analysed in an accredited laboratory7 to determine RCS content. Personal exposure

monitoring was used to measure workers’ exposure to airborne concentrations of RCS (as respirable quartz and

cristobalite). Refer to Appendix A for a detailed description of the methodologies used for personal exposure monitoring and analysis of results.

6. Results

6.1 Observations - wet processes

Water suppression was the primary engineering control used to

manage dust at all workplaces visited. Examples of water supressed

equipment included water attached bridge saws, water-fed routers,

waterjet cutting machines, water supressed polishing machines and water attached grinders and polishers.

Water feeds attached to machinery and hand tools supressed dust to the point where visible dust was not observable. As a consequence of applying water to rotating tools, RCS contaminated water mist was ejected from the process. This mist may have exposed workers by; drying in the air, being of respirable size and breathed in, or depositing on surfaces and later drying, only to becoming airborne again when disturbed.

Businesses assumed that where water suppression

was used, RPE was unnecessary.

6.2 Observations - dry processes

Only one of the ten workplaces conducted dry cutting

as a primary process. They complete sink and stovetop

cut-outs, dry grinding, edge grinding and bevelling

without water suppression or local exhaust

ventilation. This was replaced with wet cutting and

grinding methods after enforcement action. Five of

the ten workplaces self-reported that they used dry

cutting previously to fabricate benchtops.

None of the workplaces visited sanded or polished

stone dry. Dry cutting, grinding and polishing is

unnecessary and can be readily substituted for wet

methods.

This position is supported by the fact that all workplaces who self-reported previously using dry cutting were able to do the same tasks with wet methods.

7 Laboratory analysis of personal air monitoring samples collected was conducted by TestSafe Australia

Figure 3 - Photo of two workers conducting dry cutting. Dust is visible on the floor and workers clothing. Enforcement action was taken to prohibit the process until exposure risks

were managed. Photo by WHSQ.

Figure 2 - Photo of a pneumatic polisher

and grinder with water feeds.


6.3 Observations - housekeeping practices

A slurry of stone and water was created by wet processes. All the sites visited had some form of curbing and

channelling installed to contain and remove the slurry. In many cases slurry was allowed to dry on the floor and

other surfaces leaving deposits of dry stone dust that could be disturbed and made airborne. The use of fans in the

workplace for cooling or ventilation was likely to increase the rate in which wet surfaces dried.

It is likely that this poor housekeeping would increase the level of airborne RCS within the workplace and contribute

to the exposure levels of all fabrication workers. Poor cleaning methods included the use of compressed air, dry

sweeping or high pressure water. Poor cleaning may have generated airborne dust causing exposure.

6.4 Feedback regarding benchtop Installation

Installers, those workers that perform work off-site at customer/client locations, made up a large portion of each

businesses’ workforce, however their RCS exposure was not monitored during the project. One of the t en businesses subcontracted the installation of stone.

During the installation process, it was self-reported that alterations to slabs were sometimes required if they didn’t fit and re-work/adjustment was required. Some businesses also conducted sink and stovetop cut outs on site.

Businesses reported that:

alterations were rare

grinders were provided to installers to use on site

in some cases sink or stovetop cut outs were completed during installation these tasks were commonly conducted dry without any form of dust control.

Even a small amount of dry cutting or grinding can generate large amounts of dust putting these workers at risk. It is important to note that the work undertaken by installers would be classified as construction work.

A fact sheet has been developed on installing stone benchtops and it is likely that installers will be the focus of a

third phase of audits in 2019.

Figure 4 - Instead of dry sweeping, squeegees were commonly used to move stone slurry into floor grates.

Photo by WHSQ

Figure 5 - Photo of dust deposits allowed to dry. Fans may have assisted in drying wet

surfaces leaving dry stone deposits.


7. Personal sampling

Table 3 below provides a breakdown of individual exposure measurements and estimated SEG exposures. Both sets

of figures are expressed as 8-hour time-weighted averages (TWA). The geometric standard deviation (GSD) is a

marker of variation of the data. For all SEGs the GSD was approximately between 2 and 2.5, this is common of workplace situations.

An action level of 50% of WES was used as an indicator of when controls improvement was required to manage exposure risks.

Table 3 - Summary of individual monitoring results (8-hour TWA) and SEG statistical analysis

SEG

Geometric

standard

deviation

(GSD)

Range of

exposures

(mg/m3)

Estimated SEG

exposure

(mg/m3)*

Number of

results that

exceeded the

action limit

(50% of the WES)

Number of

results that

exceeded the

WES

Shapers (n = 11) 2.21 0.069 – 1.03 0.69 11 10

Saw Operators (n = 55) 2.025 <LOQ – 0.142 0.060 23 2

Finishers (n = 47) 2.14 <LOQ – 0.110 0.057+ 16 2

CNC Router/Water Jet

Operators (n = 10) 2.35 <LOQ – 0.045 0.056+ 0 0

Polishers (n = 25) 2.48 <LOQ – 0.097 0.050 5 0

Labourer/Supervisor (n = 13) 1.62 <LOQ – 0.058 0.045+ 2 0

Workplace Exposure

Standard (TWA) 0.1mg/m3

*95% UCL +approximation of the 95% UCL as the data was not lognormal

Note: the exposure results obtained may not be representative of the performance at all workplaces. This i s due to variable factors such as

di fferent processes, tasks, tools, equipment, site layout and workload.

7.1 Shapers

The individual airborne RCS levels measured for the Shapers (11 samples) ranged from a minimum of 0.069 mg/m3 to a maximum of 1.03 mg/m3

The median individual RCS level measured was 0.21 mg/m3 The estimated SEG exposure was 0.69 mg/m3, over six times the WES

All results exceeded the action limit with ten results exceeding the WES.

7.2 Saw Operators

The individual airborne RCS levels measured for the Saw Operators (55 samples) range from a minimum of less than the LOQ to a maximum of 0.142 mg/m3

The median individual RCS level measured is 0.045 mg/m3

The estimated SEG exposure is 0.060 mg/m3 which exceeds the action level of 50% of the WES

Of a total of 55 valid samples that were collected, 23 results exceed the action limit with two exceeding the WES.

7.3 Finishers

The individual airborne RCS levels measured for the Finishers (47 samples) range from a minimum of less than the LOQ to a maximum of 0.110 mg/m3



The estimated SEG exposure is 0.057 mg/m3 which is above the action level of 50% of the WES Of a total of 47 samples, 16 results exceed the action limit with two results exceeding the WES.

7.4 CNC Router/Water Jet Operators

The individual airborne RCS levels measured for the CNC Router/Water Jet Ope rators (10 samples) range from a minimum of less than the limit of quantitation (LOQ) to a maximum of 0.045 mg/m3


The estimated SEG exposure is 0.056 mg/m3 which exceeds the action level of 50% of the WES

All of the ten samples were below the action limit and WES.

7.5 Polishers

The individual airborne RCS levels measured for the Polishers (25 samples) range from a minimum of less than the LOQ to a maximum of 0.097 mg/m3

The median individual RCS level measured is 0.023 mg/m3 The approximate estimated SEG exposure is 0.050 mg/m3 which is at the action level of 50% of the WES

Of a total of 25 samples, five results exceed the action limit with no results exceeding the WES.

7.6 Labourer/Supervisor

The individual airborne RCS levels measured for the Labourer/Supervisors (13 samples) range from a minimum less than the LOQ to a maximum of 0.058 mg/m3

The median individual RCS level measured is 0.032 mg/m3 The approximate estimated SEG exposure is 0.045 mg/m3 which is just under the action level of 50% of the

WES

Of a total of 13 samples, two results exceed the action limit with no results exceeding the WES.

7.7 RCS exposures within each SEG

Figure 6 below shows a graph of the individual exposure measurements of each SEG.

The green line indicates the 0.025 mg/m3

The orange line indicate the action level of 50% of the workplace exposure standard (0.05 mg/m3) where control measures should be improved to reduce exposure.

The red line indicates the current WES (0.1 mg/m3)

The plot for the Shapers SEG is an order of magnitude higher than every other SEG.

The graph identifies that approximately 70% of the exposures are above the green line (0.025 mg/m3) at which RPE and health monitoring is expected.

Ten individual measured concentrations exceeded the WES for the Shapers SEG, compared with four for every other SEG combined (two in Finishing, two in Saw operators).

The majority of individual measured concentrations for the CNC Router/Water Jet operators, Labourer and

Supervisor and Polishing SEGs are below the orange line (action level).


0.00

0.02

0.04

0.06

0.08

0.10

0.12

0.14

0.16

mg/m3 RCS exposure range by SEG mg/m3

CNC Router/Water Jet Finishing Labourer/Supervisor Polishing

Saw Operator Workplace Exposure Standard Action Limit TLV

0.00

0.20

0.40

0.60

0.80

1.00

1.20

mg/m3

Shaper

Figure 6 - Graph of individual exposures (8hr TWA) for each SEG


8. Discussion

It was found that 88% of all samples collected contained RCS. This is significant as water suppression was

used in the majority of dust generating processes. Statistical analysis of the SEGs identified:

All estimated SEG exposures exceeded 0.025 mg/m3 (25% WES) the level at which RPE and health

monitoring is required.

Five SEGs equalled or exceeded the action level of 0.05 mg/m3 (50% WES), the level at which

controls require improvement.

The Shapers SEG estimated exposure was approximately seven times the WES.

In regards to individual results:

70% of samples exceeded 0.025 mg/m3

35% of samples exceeded 0.05 mg/m3

9% of samples exceeded the WES (0.1 mg/m3), a statutory maximum.

The results indicate that water suppression on its own it not 100% effective at preventing airborne RCS. This may be due to:

Not all material being sufficiently wet when cut, ground or polished Contaminated water mist created by wet processes not being contained – as evidenced by dust

settled on surfaces

Speed of cutting equipment

Design of equipment.

This is supported by other agencies findings regarding effectiveness of water. 8,9

Monitoring results and process observations suggest that exposures can be affected by:

Proximity to the tasks, i.e. the closer the worker is to the source of contamination/process, the more likely it is that contaminant can enter their breathing zone, however, workers exposed to purely background levels are still at risk (supervisors and labourers)

Location of worker/task within area (ventilation)

Individual worker techniques (e.g. placing a hand over grinder/polisher)

Type of machine or hand tools used(bridge saw vs CNC router, grinder vs polisher) Speed of machine

Design of machine (e.g. open guards vs closed on CNC).

In summary:

Workers in the Shapers SEG are at highest risk of exposure Workers that use grinders are at higher risk than other workers An improvement of controls is required for SEGs exceeded 50% of the exposure standard

All workers in the fabrication workshop require RPE to manage residual risks and health monitoring to detect changes in their health.

8 Jared H. Cooper, D. L. (2014). Respirable Silica Dust Suppression During Artificial Stone Countertop Cutting. Annals of Occupational Hygiene, 122-126. 9 National Institute for Occupational Safety and Health. (2016). Evaluation of Crystalline Silica Exposure during Fabrication of Natural and

Engineered Stone Countertops. United States of America: Centers for Disease Control and Prevention.


8.1 Shapers

The shapers SEG was comprised of workers that undertook the joinery of stone and completed cut outs

for sinks, taps or other holes using powered hand tools. Only two sites had shapers, Company 4 and

Company 10. These workplaces allocated each worker a specific task rather than allocating a worker a

specific benchtop to see through to completion.

The shapers SEG estimated exposure was 0.69 mg/m3, approximately seven times the WES.

The majority of tasks completed required the use of water suppressed grinders to cut and grind stone.

The use of grinders places workers at greater risk of exposure to RCS. 10 This may be due to:

higher speeds of grinders drying water that has been applied

an insufficient water supply or flow rate to supress dust

water mist contaminated with RCS being ejected by the rotating blade.

While Company 4 primarily used wet work, the highest measured concentration for the SEG, 1.03 mg/m3,

was from a day the worker reported conducting small amounts of dry cutting and grindi ng during the

shift. Engineering controls including mechanical ventilation were installed to prevent exposure however

the personal exposure monitoring results indicate that it was not effective. RPE was not typically worn by

workers at Company 4, regardless, exposures this high go beyond the protection afforded by half face air

purifying respirators.

At Company 10 wet methods were used following a prohibition notice for uncontrolled dry cutting. Even

with the use wet methods, all individual results for Shapers at this workplace returned measured

concentrations above the WES. While the Shapers at Company 10 wore fit tested half face respirators to

protect against exposure, further control was required to manage dust.

The use of grinders with cutting discs places workers a high exposure risks, even when water suppression

is used. Alternative means exist to cut sink and stovetop cut outs, including CNC routers. If grinders are

required to be used, they must be water suppressed and RPE worn to protect workers.

8.2 Saw operators

Saw operators used bridge or mitre saws to cut slabs to size. All saws observed were water suppressed,

with water feeds directed at either the blade, slab, or both. The machines could either be manual or

computer controlled.

The estimated SEG exposure was 0.060 mg/m3, above half the WES, an action level for an improvement in

control.

75% of individual measured concentration in this SEG exceeded 0.025 mg/m3. This is despite the use of

wet methods for cutting slabs.

Likely factors that contributed to the exposure levels recorded for these workers include:

10 National Institute for Occupational Safety and Health, 2016. Engineering Control of Silica Dust from Stone Countertop Fabrication and Installation, Houston: s.n.


the speed of operation, size and RPM of the blade

the design of guarding and how well it contained water mist the operators positioning in relation to the process

whether enough water was supplied for the saw speed both in terms of flow rate and volume.

8.3 Finishers

The finishers SEG comprised of workers that undertook any task required to finish a benchtop after it had

been cut to size. Because work was organised by each benchtop rather each task, workers within this SEG

rotated through the various stages of fabrication to see each slab to completion. They joined stone, shaped edges, cut sink, tap and stovetop holes and then polished stone using powered hand tools.

The estimated SEG exposure was 0.057 mg/m3, is above half the exposure standard, an action level for improvement of control.

70% of the individual measured concentrations in this SEG exceeded 0.025 mg/m3, despite the workers

using water-attached tools.

Similar to the Shapers SEG, workers in this group also used grinders which placed these workers at higher

risk of exposure. However, individual measures concentrations in this SEG were not as high as the Shapers SEG, likely due to task rotation.

8.4 CNC router/water jet operators

Routers and water jet machines are able to complete sink and stovetop cut outs. Some even leave an

edge that does not require further polishing.

The estimated SEG exposure for this group was 0.056 mg/m3.

Figure 6 shows that the all of individual measured concentrations are below the yellow line (action level)

however the estimated SEG exposure is above the action level (0.05 mg/m3). This is due to larger variation between worker results (GSD 2.35) and a small sample size (n = 10).

Figure 8 – Newer CNC bridge saws were

fitted with bay doors. Photo by WHSQ. Figure 7- Older manual bridge saws without any means to prevent workers from standing close to the process when

operating the saw. Photo by WHSQ.


The results indicate that using a router or water jet machine to cut sink and stovetop cut outs results in

far less exposure to workers. This is consistent with other jurisdictions findings when monitoring workers

conducting grinding or cutting tasks vs using CNC routers.11

When comparing individual results between this SEG, the Finishing SEG and Shapers SEG:

40% of results exceeded 0.025 mg/m3 for the CNC router/water jet operators SEG 70% of the results exceeded 0.025 mg/m3 for the Finishing SEG

100% of results exceeded 0.025mg /m3 for the Shapers SEG.

It is important to note that routers and water jet cutters cannot replace all tasks completed by the

Shapers or Finishers, but rather they can be used reduce exposures of these SEGs. If sites had one of

these machines, a recommendation was made to the workplace in their report to use them for sink,

stovetop and tap holes rather than using grinders.

8.5 Polishers

The Polishers SEG comprised of workers that polished stone using hand-held polishers with resin discs as

their primary task. The workplaces used water-attached hand-held polishers to prevent dust being

released. Dry grinding or polishing was not undertaken.

The estimated exposure for a worker in this SEG was 0.050 mg/m3, half the exposure standard.

Figure 6 shows that the majority of individual measured concentrations below the yellow line (action

level) however the estimated SEG exposure is equal to the action level (0.05 mg/m3). This due to larger variation between worker results (GSD 2.48) and a small sample size (n = 25).

48% of individual measured concentrations exceeded 0.025 mg/m3 with the highest result, 0.097 mg/m3,

just below the WES.

Polishers applied water via a central feed, the rotation of the tool caused water to be sprayed outwards

when operated. This meant that workers may have both been exposed from their own polishing and that of other workers in close proximity.

Containing the water spray created by the polisher is required to manage the exposure of these workers.

8.6 Labourer/Supervisor

Labourers and supervisors conducted support tasks that may have included supervision, cleaning, driving

forklifts or general labouring.

The estimated SEG exposure was 0.045 mg/m3, just under half the exposure standard. This is a concern

because the workers of this SEG did not conduct fabrication related tasks. The exposure to these workers may be a reflection of the high background levels.

84% of individual measured concentrations exceeded 0.025 mg/m3 with the highest result, 0.058 mg/m3,

exceeding half the WES.

11 National Institute for Occupational Safety and Health. (2016). Evaluation of Crystalline Silica Exposure during Fabrication of Natural and Engineered Stone Countertops. United States of America: Centers for Disease Control and Prevention.


The exposures to this SEG could be a result of:

dust generated from other processes or workers

poor housekeeping (i.e. disturbing settled dust) using poor cleaning techniques that generated dust (high pressure water, compressed air, dry

sweeping).

8.7 Respiratory protective equipment

Respiratory protective equipment (RPE) is a type of personal protective equipment (PPE) designed to

protect the wearer from airborne contaminants. Respiratory protective equipment in the form of

reusable or disposable, tight fitting half face respirators were commonly available for use at all workplaces visited but not worn by workers.

It was assumed by businesses owners and workers that respiratory protective equipment was not

required for wet processes. Where dry processes were conducted RPE was commonly the only control to

protect workers. In the instances where RPE was worn, the following problems were common:

RPE was worn incorrectly RPE was worn by workers with facial hair or beards

Workers were not fit-tested for the type and size of RPE provided

Workers did not correctly clean, maintain or store reusable respirators.

Businesses owners and individual workers knowledge about fit testing and being clean shaven to

maintain an effective seal was poor. Only one of the ten businesses visited had fit tested workers, and only due to previous enforcement action by an inspector.

Based on the results of the monitoring, RPE is needed to protect against exposure to RCS. For tight fitting

air purifying respirators to be effective workers need to be fit tested to the type and size provided as well

as be clean shaven.

8.8 Health monitoring

Health monitoring was not conducted at any of the sites, despite the fact that 70% of individual measured

concentrations exceeded 0.025 mg/m3. Feedback from businesses indicated the obligation to monitor workers health wasn’t either known, considered or understood.

Recommendations were provided for nine of the ten workplaces to conduct health monitoring. Company

3 did not receive enforcement action to conduct health monitoring because individual and estimated

average concentrations for RCS were below 0.025 mg/m3

9. Enforcement action

After the walkthrough survey or as a result of personal air monitoring e nforcement action was taken in

the way of improvement and prohibition notices to ensure compliance with work health and safety

legislation.

A total of 23 improvement notices were issued for inadequate dust control issues, use and fit testing of respiratory protective equipment and health monitoring.

A total of five prohibition notices were issued for dry cutting and other matters.


10. Recommendations

Communicate to industry effective controls to reduce or manage dust identified during the project.

Feedback from PCBUs indicated that there is limited knowledge about RCS risks and practical ways to

manage those risks. In response to the outcomes of these phase one audits of stone bench top

fabricators, WHSQ has taken immediate action to ensure employers comply with their health and safety duties and workers in the industry are protected:

The Minister for Education and Minister for Industrial Relations, the Honourable Grace Grace MP, announced in Parliament and the media on 18 September 2018 that a safety alert and guide had been distributed to industry which included a prohibition on dry cutting of engineered stone benchtops.

The industry safety alert ‘Silicosis in stone bench top fabrication’ and guidance ‘Protecting workers from exposure to respirable crystalline silica – guide to safe bench top fabrication and installation’ were distributed directly to the stone bench top industry and published on www.worksafe.qld.gov.au on 18 September 2018.

Correspondence was also sent to approximately 360 entities identified through the Queensland Building and Construction Commission licence database.

OIR has established an industry working group to support the development of a silica code of practice by early 2019. This will be followed by the development of an additional code on silica dust in the construction industry more broadly in early 2019.

OIR is also undertaking ongoing work to develop a regulatory response to the risk posed by silica in the stone benchtop industry,

Expand WHSQ enforcement activities targeting RCS in the benchtop fabrication industry.

All stone bench top fabricators in Queensland (approx. 130 businesses) are to be audited by the end

of 2018. The compliance focus for the second stage has been built around minimising the risk to the

health of workers through the assessment criteria outlined in the audit tool including: o Prohibition of dry cutting o Inadequate wet cut practices o Inadequate local exhaust ventilation practices o Worker isolation o Workplace ventilation o Housekeeping (ie limiting secondary exposure risks arising from poor housekeeping

practices) o Health monitoring for workers exposed to RCS o Provision, maintenance and fit test of respiratory protective equipment o Information and consultation with workers regarding the risks of RCS

http://www.worksafe.qld.gov.au/


Appendix A - Air monitoring methodology

Respirable dust sampling and analysis was conducted in accordance with Australian Standard AS2985

“Workplace Atmosphere – Method for Sampling and Gravimetric Determination of Respirable Dust”.

Personal sampling

Personal sampling was used to measure an individual’s unprotected exposure to dust during the course of

their usual work activities, and includes both exposed and non-exposed time (e.g. breaks).

Samples were collected from within each workers’ breathing zone using a sampling pump attached to a

SIMPEDS cyclone sampling head, containing a 25mm diameter polyvinyl chloride (PVC) (5µm) filter, via a

flexible hose. The pump was operated at 2.2 litres/minute for a period of 4–8 hours on each worker. The

flow rate of each pump was measured before and after a sample was collected. If the difference between

the flow rates was more than 5%, the sample was deemed invalid. Sampling was carrie d out for the whole

shift where possible, however a sampling time of less than a whole -shift was accepted provided it was

more than 4 hours and representative of a worker’s normal duties.

During personal monitoring, observations were made of the tasks undertaken as well as their frequency,

duration, and the dust exposure controls in place to provide context to results. These observations are

outlined in Table 3.

Sample analysis

Sample analysis of total respirable dust and quartz content was carried out by TestSafe Australia. The samples were weighed for total respirable dust using method number WCA. 191 Gravimetric determination of respirable dust. Samples were then analysed by X-Ray diffractometry (XRD) using Method Number WCA.220, Determination of crystalline silica (alpha-quartz & cristobalite) in respirable dust.

Results methodology

Individuals - exposure results that exceeded the action limit of 50% of the exposure standard are a trigger

to review the existing exposure controls and to conduct health monitoring of workers. Individual results

in excess of the workplace exposure standard (WES) for RCS require an immediate improvement in

exposure controls (including respiratory protection).

Similarly exposed groups (SEGs)

The personal sampling results of individual workers within each SEG was combined in order to estimate

the airborne concentration level that each group of workers was exposed to. The IHSTAT12 program was

used to carry out a statistical analysis of the combined results. The 95% upper confidence limit of the

mean (average) of the groups’ results (95% UCL)13 was used to compare against the WES to determine

risk to workers health.

12 Mulhausen, J., 2007. American Industrial Hygienists Association - IHSTAT+ v1.01. [Online] 13 95% UCL is a number that one can be 95% confident that the true mean (average) concentration of the work group is below that value.


Where the 95% UCL exceeded the action limit of 50% of the exposure standard, a review the existing

exposure controls and the provision of health monitoring for all workers in the SEG was triggered. An

action limit of 50% of the workplace exposure standard is an important tool to protect the health of

workers when used as limit for when action would be required to manage risk.

Where the 95% UCL result for the SEG was greater than the WES immediate improvement in e xposure

controls (including respiratory protection) was required.

Limit of quantitation

A limit of quantitation (LOQ) is the lowest level the laboratory analysis method was able to confidently

detect and report on from a sample. The treatment of results that are less that the LOQ (<LOQ) is

controversial and still an active field of research. For this assessment, where the laboratory reported

results <LOQ for weight of RCS, these results were changed to 0.005mg, which is half the LOQ.

Limitations

The measurement results and conclusions presented in this report are limited by the methods of sample

collection and analysis, and are representative only of the conditions and circumstances which were

present at the time of sampling. Consequently, the results of this report should be considered to be, at

best, an estimate of exposure (not absolutes) and not necessarily representative of all operating

conditions or periods of time.

On 20 August 2018 SKC Limited announced the failure of an air sampling component to meet

International respirable dust sampling standards. This component was used by WHSQ in carrying out the

air sampling at your workplace. As a result of the failure, dust levels workplaces may in fact be up to 30%

lower than those measured by WHSQ. WHSQ has written to the ten benchtop fabricators sampled in

2017-2018 to advise them of the fault and committed to re-sampling workers in early 2019. SKC Ltd’s

sampling cyclones have been removed from service and sampling cyclones have been purchased that

meet international and Australian standards for respirable dust sampling.


Appendix B - Effective dust controls

Effective dust controls have been outlined below based on observations during the walkthrough survey

and general dust management principles. Testing the effectiveness of the outlined controls could be an

area for further work.

Generally, controls should focus on:

Capturing or suppressing dust at the source of generation. Using processes that generate less dust (e.g. CNC routers for sink or stovetop cut outs).

Containing water mist or waste created from process water suppressed processes. Providing distance or physical barriers between workers and dust generating proce sses.

Frequently cleaning surfaces to prevent the build-up of dust.

In addition, RPE should also be used to protect workers from residual exposure risks of RCS.

Shapers/Finishers

Controls to prevent exposure for the shapers and finishers should focus on el iminating or substituting the

use of grinders with cutting discs. This could be achieved by conducting cutting tasks on a router waterjet cutter or bridge saw.

Effective controls to minimise dust when grinders are used include:

using water-attached or on tool extracted grinders

applying a constant flow of water over the slab (sheet flow wetting) or wet the slab with water prior to cutting

isolating the worker conducting the cutting from other workers using screens or physical barriers

Saw and CNC Router/Water jet operators

Effective controls for the Saw and CNC Router/Water Jet operators include:

containing or capturing water mist using plastic shrouds, flaps or brush guards around the tool (refer to Figure 9 and 10)

isolating the worker from the process either through physical barriers like bay doors or through distance

maintaining water control systems to ensure an adequate flow of water during cutting preventing water drying on surfaces.

Figure 9 - CNC router without plastic shrouding to contain dust

and water mist. Photo by WHSQ.

Figure 10 - CNC router with plastic shrouding. Photo by WHSQ.


Polishers

Effective controls to minimise exposure to the polishers include:

using water-fed polishers to conduct all polishing and grinding work, containing or controlling water spray created by the polisher by retrofitting a brush guard or

covering the spray using the operators hand

isolating workers from other processes or workers by provided physical barriers such as screens between workstations

local exhaust ventilation or natural ventilation to remove or dilute airborne dust

preventing water drying on surfaces in the operators work zone

wearing aprons and boots to prevent clothes becoming wet and dusty.

Supervisors/Labourers

Since the labour/supervisor SEG workers do not conduct any tasks that generate RCS, it is likely their exposures are the result of:

RCS generating processes of other workers

disturbance of dust due to poor housekeeping or cleaning methods.

Controls to minimise exposure should be focused on:

Improving housekeeping by conducting regular cleaning with low pressure water or H class vacuum cleaners

Controlling dust generated from the fabrication processes of other workers.

Respiratory protective equipment

Work health and safety legislation requires risks to be managed as far as is reasonably practicable

following the hierarchy of control. RPE is a form of personal protective equipment, the lowes t order of

control in the hierarchy. Whilst effective at protecting workers from RCS, RPE does not reduce the level of

RCS in the air. RPE is used to manage the remaining or residual risks following the implementation of

other higher order controls, including water suppression or local exhaust ventilation.

The results of monitoring from all SEGs identified that workers need to wear respiratory protective equipment to manage exposure risks, regardless of the type of engineering control used.

A good respiratory protection program includes the following elements:

correctly selecting appropriate RPE

medical screening of RPE users training in the correct use and maintenance of RPE

ensuring RPE is correctly used

fit testing and fit checking inspection, maintenance and repair of RPE

correct storage

keeping records.

Managing respirable crystalline silica dust exposure in the stone benchtop industry

Code of Practice 2019

PN12527 Managing respirable crystalline silica dust exposure in the stone benchtop industry Code of Practice 2019 Page 2 of 48

This Queensland code of practice has been approved by the Minister for Education and Minister for Industrial Relations under section 274 of the Work Health and Safety Act 2011 and will commence on 31 OCTOBER 2019.

PN12527

© The State of Queensland 2019

Copyright protects this document. The State of Queensland has no objection to this material being reproduced, but asserts its right to be recognised as author of the original material and the right to have the material unaltered.

The material presented in this publication is distributed by the Queensland Government as an information source only. The State of Queensland makes no statements, representations, or warranties about the accuracy or completeness of the information contained in this publication, and the reader should not rely on it. The Queensland Government disclaims all responsibility and all liability (including, without limitation, liability in negligence) for all expenses, losses, damages and costs you might incur as a result of the information being inaccurate or incomplete in any way, and for any reason.


Contents

1. Foreword ............................................................................................................................ 5

1.1 Scope and application .................................................................................................. 5

2. Introduction ........................................................................................................................ 5

3. Consultation ....................................................................................................................... 8

3.1 Consulting with workers and the role of workers ........................................................... 8

3.2 Consulting, cooperating and coordinating activities with other duty holders .................. 9

4. Duties of manufacturers, importers and suppliers of stone benchtops ................................ 9

4.1 Manufacturers ............................................................................................................ 10

4.2 Importers and suppliers .............................................................................................. 10

5. Planning for stone benchtop fabrication and installation ................................................... 11

5.1 What is the workplace exposure standard for respirable crystalline silica dust? .......... 12

5.2 Prohibition on uncontrolled dry cutting/processing ...................................................... 13

5.3 Developing a respirable crystalline silica dust control plan .......................................... 13

6. Identifying respirable dust hazards ................................................................................... 14

6.1 Fabrication workers and others at risk ........................................................................ 15

6.2 Air monitoring ............................................................................................................. 16

7 Controlling respirable crystalline silica dust risks ............................................................... 19

7.1 The hierarchy of control measures ............................................................................. 19

7.1.1 Water suppression ............................................................................................... 20

7.1.2 Local exhaust ventilation (LEV) ............................................................................ 20

7.1.3 Natural ventilation ................................................................................................ 21

7.2 Prevent workers breathing in dust .............................................................................. 22

7.2.1 Enclose water suppression processes ................................................................. 22

7.2.2 Isolating workers .................................................................................................. 23

7.2.3 Administrative controls to minimise exposure ....................................................... 23

7.2.4 Use Respiratory Protective Equipment ................................................................. 24

7.3 Clean up ..................................................................................................................... 29

7.3.1 Workers’ clothing ................................................................................................. 30

7.3.2 Housekeeping ...................................................................................................... 30

7.3.3 Wet slurry and recycled water .............................................................................. 31

7.4 Reviewing control measures ....................................................................................... 32

7.4.1 Daily and routine checks ...................................................................................... 32

7.4.2 Review and revision of controls ............................................................................ 32

8. Installing stone benchtops ................................................................................................ 33

9. Health monitoring ............................................................................................................. 35

10. Information, training, instruction and supervision ............................................................ 39

11. Other hazards in the stone benchtop industry ................................................................ 40

Appendices .......................................................................................................................... 40


Appendix 1 – Dictionary ............................................................................................... 40

Appendix 2 – Example respirable crystalline silica dust control plan ............................ 40


1. Foreword This code of practice on managing respirable crystalline silica dust exposure in the stone benchtop

industry is an approved code of practice under section 274 of the Work Health and Safety Act 2011

(WHS Act).

An approved code of practice is a practical guide to achieving the standards of health, safety and welfare

required under the WHS Act and the Work Health and Safety Regulation 2011 (WHS Regulation).

Under section 26A of the WHS Act duty holders must comply with an approved code of practice

or follow another method, such as a technical or industry standard, if it provides an equivalent or

higher standard of work health and safety than the standard required in this code.

A code of practice applies to anyone who has a duty of care in the circumstances described in the code.

In most cases, following an approved code of practice would achieve compliance with the health and

safety duties in the WHS Act, in relation to the subject matter of the code. Like regulations, codes of

practice deal with particular issues and do not cover all hazards or risks that may arise. The health and

safety duties require duty holders to consider all risks associated with work, not only those for which

regulations and codes of practice exist.

Codes of practice are admissible in court proceedings under the WHS Act and WHS Regulation. Courts

may regard a code of practice as evidence of what is known about a hazard, risk or control and may rely

on the code in determining what is reasonably practicable in the circumstances to which the code

relates.

An inspector may refer to an approved code of practice when issuing an improvement or prohibition

notice. This may include issuing an improvement or prohibition notice for failure to comply with a code of

practice where equivalent or higher standards of work health and safety have not been demonstrated.

1.1 Scope and application

This code provides practical guidance for persons conducting a business or undertaking on how to

manage risks associated with respirable crystalline silica dust exposure in the stone benchtop industry.

This includes work to fabricate, process, install, maintain or remove engineered and natural stone

benchtops.

This code provides information on how to implement measures to eliminate or minimise so far as is

reasonably practicable the risk of exposure to respirable crystalline silica. See Appendix 1 for a

definition of key terms.

2. Introduction Stone benchtops can be made from natural stone, such as granite and marble or from engineered stone.

Engineered stone is a man-made product made up of crushed stone such as quartz, resins and other

additives. Quartz is a form of crystalline silica found in granite, sandstone, quartzite, various other rocks,

and sand. The crystalline silica content in stone benchtops can vary widely depending on the type of

stone used. Engineered stone benchtops can contain up to 95 per cent crystalline silica whereas certain

natural stones can contain less.1 Granite, for example, may contain from 25 to 45 per cent, while certain

varities of marble (e.g. calcite, dolomite, and onyx) may contain little or no silica. The risks are much

greater where the stone contains high levels of silica.

1 Safe Work Australia: Crystalline silica and silicosis

https://www.safeworkaustralia.gov.au/silica


The table below outlines the variation in silica content that can exist in different types of stone.

Product Silica content

(up to)

Engineered stone 90 per cent or higher

Sandstone 70 – 100 per cent

Granite 20 – 45 per cent (typically 30%)

Slate 20 – 40 per cent

Marble 2 per cent

Limestone 2 per cent

Cutting, grinding, trimming, sanding or polishing stone benchtops produces very small particles of dust,

including respirable crystalline silica, that are invisible to the naked eye. When breathed in, respirable

crystalline silica exposure over time can cause fatal lung disease.

Workers fabricating, processing, installing, maintaining or removing stone benchtops without appropriate

control measures in place may be exposed to high levels of respirable crystalline silica. Workers can

also be exposed to respirable crystalline silica from poor housekeeping methods which disturb dust,

including dry sweeping, using compressed air or high pressure water cleaners, general purpose vacuum

cleaners not designed for use with hazardous dusts, or by allowing the accumulation of dust within the

workplace.

Generally, workers have a higher risk to their health from exposure to respirable crystalline silica during

fabrication of stone benchtops. The more cutting, grinding, trimming, sanding or polishing a worker does

the higher the risk to their health. Without adequate controls in place these practices generate dust or

mist clouds which may contain very high respirable crystalline silica concentrations.

Stone benchtops that are already installed in the home or workplace do not represent a risk to health

unless they are disturbed through mechanical processing such as cutting, sanding or polishing.

Information about the controls required during on-site installation, maintenance or removal is provided in

section 8.

In 2017, Work Health and Safety Queensland (WHSQ) conducted compliance audits at 10 workplaces in

South East Queensland in order to assess the risks to health from respirable crystalline silica in the

stone benchtop industry. The purpose of the audits were to:

• identify stone benchtop fabrication processes that expose workers to respirable crystalline silica

(e.g. workers performing shaping, saw operation, polishing)

• understand the types of controls used in the industry

• assess and determine the effectiveness of risk control measures in place to manage respirable

crystalline silica exposure of workers, which included water suppression, local exhaust ventilation

and slurry management

• assess workers’ personal exposure to respirable crystalline silica with respect to the existing dust

control measures.

Key findings of the audits were that:

• a number of unsafe practices such as uncontrolled dry cutting of stone, poor dust control

measures, lack of respiratory protective equipment and a lack of appropriate health monitoring of

workers

• [as a result of these sub-standard work practices] many workers in the industry were exposed to

very high levels of respirable crystalline silica and as such are at significant risk of developing

silicosis


• to effectively control exposure to respirable crystalline silica a range of isolation, dust suppression,

dust extraction, respiratory protection and housekeeping controls are required

• without proper controls in place in a fabrication workplace, other workers in the vicinity, for

example office workers, may also be exposed to levels of respirable crystalline silica that are

hazardous to their health.

Health effects of respirable crystalline silica

Respirable crystalline silica is a significant health hazard for workers. It is too small to be seen under

normal lighting and the small particle size allows it to stay airborne for long periods of time. It is easily

inhaled deep into the lungs where it can be deposited and lead to a range of respiratory

diseases, including silicosis, progressive massive fibrosis, chronic obstructive pulmonary

disease and lung cancer2. Respirable crystalline silica also increases the risk of developing chronic

renal disease, autoimmune disorders3 and other adverse health effects including an increased risk of

activating latent tuberculosis.

Silicosis is a serious, irreversible lung disease that causes permanent disability and can be fatal.

Respirable crystalline silica dust particles are deposited in lung tissue, causing inflammation and

scarring and reducing the lungs’ ability to take in oxygen. Silicosis may continue to worsen even long

after exposure stops.

As the disease progresses, a worker may experience:

• shortness of breath

• severe cough

• weakness.

It is important to note that damage to lungs from silicosis is permanent and symptoms of the disease

may not appear for many years. Workers may not present with any symptoms, even at the point of initial

diagnosis, which is why prevention and health monitoring are critical. Health monitoring requirements are

detailed in section 8.

There are three types of silicosis:4

• Acute silicosis is very rare and results from exposure to very short-term and very large amounts of

silica (e.g. less than one year, may be weeks or months)

• Accelerated silicosis results from short term large amounts of inadequately protected exposure to

silica (1 to 10 years exposure) – this was once rare, but has become evident in engineered stone

benchtop workers

• Chronic silicosis results from long term exposure (10+ years of exposure) to low levels of silica.

There is no cure for silicosis, however all respirable crystalline silica related diseases are preventable by

using proper controls to prevent or minimise exposure in the workplace.

An effective silicosis prevention strategy should be based on primary, i.e. controlling the release of

respirable crystalline silica dust at source using engineering methods, and secondary, i.e. respiratory

protective equipment along with air and health monitoring) prevention approaches5.

2 In 1997 the International Agency for Research on Cancer (IARC) made the following evaluation: Crystalline silica inhaled in the form of quartz

or cristobalite from work-related sources is carcinogenic to humans (Group 1). Safe Work Australia: Crystalline silica health monitoring. 3 Australian Institute of Occupational Hygienists Respirable Crystalline Silica and Occupational Health Issues Position Paper (2018) 4 Royal Australian College of Physicians: Frequently Asked Questions – Accelerated silicosis 5 https://www.who.int/occupational_health/publications/newsletter/gohnet12e.pdf

https://www.racp.edu.au/advocacy/division-faculty-and-chapter-priorities/faculty-of-occupational-environmental-medicine/accelerated-silicosis/faqs


3. Consultation

3.1 Consulting with workers and the role of workers

WHS Act section 47(1): The person conducting a business or undertaking must, so far as is reasonably practicable, consult with workers who carry out work for the business or undertaking who are, or are likely to be, directly affected by a matter relating to work health or safety. WHS Act section 48(2): If the workers are represented by a health and safety representative, the consultation must involve that representative.

Consultation involves sharing of information, including about sources of exposure and associated health

risks, giving workers a reasonable opportunity to express views and taking those views into account

before making decisions on health and safety matters.

Consultation with workers, and, where applicable their representative, is required at each step of the risk

management process and improves decision-making about health and safety matters and assists in

reducing work related injuries and disease. A safe workplace is achieved when everyone involved in the

work communicates with each other to identify hazards and risks, talks about health and safety concerns

and works together to find solutions.

Workers must be consulted on health and safety matters, including but not limited to:

• identifying the tasks and processes that may result in dust and respirable crystalline silica

exposure

• developing a respirable crystalline silica dust control plan

• making changes to processes or procedures that generate respirable crystalline silica

• proposing changes that may affect worker health and safety, e.g. positioning of work spaces or

non-fabrication areas and ventilation systems

• making changes to controls to protect workers from respirable crystalline silica;

• resolving health and safety issues

• monitoring the health of workers exposed to respirable crystalline silica, including deciding on the

medical practitioner to carry out the health monitoring

• monitoring the conditions at the workplace

• providing information and training for workers.

A person conducting a business or undertaking should also have policies and procedures in place to

facilitate the prompt reporting of any health and safety issues, and ensure workers understand and are

familiar with those.

WHS Act section 28

While at work, a worker must:

• take reasonable care for his or her own health and safety

• take reasonable care that his or her acts or omissions do not adversely affect the health and safety of

other persons

• comply, so far as the worker is reasonably able, with any reasonable instruction that is given by the

person conducting the business or undertaking to allow the person to comply with this Act.

Workers must co-operate with any reasonable policy or procedure of the person conducting the business or undertaking relating to health or safety at the workplace that has been notified to workers.


The WHS Act includes a duty on workers to take reasonable care for their own health and safety, and to

take care that doing or failing to do something does not adversely affect the health and safety of other

persons.

Workers are required under the WHS Act to comply, as far as they are reasonably able, with any

reasonable instruction that is given by the person conducting the business or undertaking to allow the

person to comply with this Act.

Workers are also required to co-operate with any reasonable policy or procedure that relates to health or

safety at the workplace (e.g. reporting health and safety issues, wearing respiratory protective

equipment and the use of certain tools) notified to workers by the person conducting the business or

undertaking.

3.2 Consulting, cooperating and coordinating activities with other duty holders

WHS Act section 46(1): If more than one person has a duty in relation to the same matter each person must, so far as is reasonably practicable, consult, cooperate and coordinate activities with all other persons who have a duty in relation to the same matter.

A person conducting a business or undertaking may share responsibility for a health and safety matter

with other business operators who are involved in the same activities or who share the same workplace.

In these situations, duty holders must, so far as is reasonably practicable, exchange information to find

out who is doing what.

They must work together in a cooperative and coordinated way so that all risks are eliminated or

minimised as far as reasonably practicable, for example:

• Consultation, cooperation and coordination must occur between other duty holders on a construction

site, including principal contractors, builders and sub-contractors (e.g. carpenters, plumbers and

electricians, tilers, cabinet makers), involved in, or near any modification to a stone benchtop during

installation to ensure the risk to health associated with exposure to respirable crystalline silica is

eliminated or minimised so far as is reasonably practicable, and to ensure information, training and

instruction has been provided where applicable.

• Consultation and collaboration between labour hire firms, host employers, and their workers is

essential to providing a safe work environment and monitoring worker health. Health monitoring for

stone masons who are labour hire workers is a shared duty between the persons conducting a

business or undertaking (e.g. the labour hire firm) and the stone benchtop fabrication business to

ensure health monitoring is provided and includes making decisions on who will arrange health

monitoring and how the cost will be shared.

Further guidance on consultation is available in the Work health and safety consultation, co-operation

and co-ordination Code of Practice 2011.

4. Duties of manufacturers, importers and suppliers of stone benchtops Manufacturers, importers and suppliers of engineered and natural stone for benchtop fabrication must ensure so far as is reasonably practicable that stone products are without risks to health and safety. It is critical that duties down the supply chain are met due to the hazardous properties of natural and engineered stone when fabricated, processed, installed, maintained or removed.

https://www.worksafe.qld.gov.au/__data/assets/pdf_file/0020/58205/WHS-consultation-coop-coord-COP-2011.pdf

https://www.worksafe.qld.gov.au/__data/assets/pdf_file/0020/58205/WHS-consultation-coop-coord-COP-2011.pdf


4.1 Manufacturers Manufacturers of engineered stone have a duty to ensure, so far as is reasonably practicable, that the stone is manufactured to be without risks to the health and safety of workers when used for the purpose for which it is manufactured.

WHS Act section 23: A person conducting a business or undertaking who is a manufacturer must ensure, so far as is reasonably practicable, that a substance to be used at a workplace is manufactured to be without risks to health and safety of workers who: • use the substance for a purpose for which it is designed or manufactured; • handle and store the substance at the workplace • carry out any foreseeable activity at the workplace relating to the proper use, handling or disposal

of the substance • are in the vicinity of a workplace and who are exposed to the substance or whose health and

safety may be affected by a use or activity of the substance.

The manufacturer must carry out any analysis or testing of the engineered stone necessary to meet their duties and give adequate information to all parties the engineered stone is provided to about:

• the purpose for which the substance has been designed and manufactured • the results of any calculations and analysis, testing in relation to the engineered stone, including

any hazardous properties • any conditions necessary to ensure the engineered stone is without risks to health and safety

when correctly used for the purpose for which it was manufactured.

Manufacturers must provide the following information to all parties their stone product is provided to:

• the amount of crystalline silica contained in the product

• the hazardous properties and risks to health of respirable crystalline silica

• appropriate controls that must be implemented when fabricating or processing, including during installation, maintenance or removal of stone benchtops made from the product.

When the stone is provided to a fabrication business information may be provided in:

• technical or safety data sheets

• product labels fixed to each slab

• similar documents.

Manufacturers, on request, must give all parties who are provided with information on the stone any amendments or updates that are made to this information.

Engineered and natural stone is supplied in slabs which are then used to make benchtops. The slabs of stone themselves are not in a form that would be classified as causing lung damage. It is the respirable crystalline silica dust generated when the stone slabs are cut and shaped (e.g. profiled, polished and edged) to the required size that may cause permanent lung damage.

4.2 Importers and suppliers Importers and suppliers of natural and engineered stone have a duty to ensure, so far as is reasonably practicable, that the stone is without risks to the health and safety of workers when used for the purpose for which it is made.

WHS Act section 24 and 25: A person conducting a business or undertaking who imports or supplies a substance must ensure, so far as is reasonably practicable, that a substance to be used at a workplace is without risks to health and safety of workers who:


• use the substance for a purpose for which it is designed or manufactured; • handle and store the substance at the workplace; or • carry out any foreseeable activity at the workplace relating to the proper use, handling or disposal

of the substance. • are in the vicinity of a workplace and who are exposed to the substance or whose health and

safety may be affected by a use or activity of the substance. The importer or supplier must carry out any analysis or testing necessary to meet their duty and must give adequate information to each person the stone is provided to about: • the purpose for which the stone has been designed and manufactured; • the results of any calculations and analysis, testing in relation to the stone, including any

hazardous properties; and • any conditions necessary to ensure the stone is without risks to health and safety when used for

the purpose for which it was manufactured.

Importers of natural and engineered stone must take all reasonable steps to obtain information from the manufacturer and then pass this information on when supplying the stone.

If this information is not available, importers must carry out, or arrange the carrying out of, any calculations, analysis, testing or examination that may be necessary to ensure, so far as is reasonably practicable, that the stone is without risks to the health and safety of any person.

The following information must be given to all parties the stone product is provided to:

• the amount of crystalline silica contained in the product;

• the hazardous properties and risks to health of respirable crystalline silica; and

• appropriate controls that must be implemented when fabricating or processing stone benchtops

made from the product.

The information may be provided in:

• technical or safety data sheets

• product labels fixed to each slab; or

• similar documents.

In addition to the information listed above, importers and suppliers could also reference any relevant guidance, for example, technical guides or Codes of Practice, as a resource on their website.

Importers and suppliers, on request, must so far as is reasonably practicable, give all parties who are provided with information on the stone any amendments or updates that are made to the relevant information.

5. Planning for stone benchtop fabrication and installation

WHS Regulation section 49: A person conducting a business or undertaking at a workplace must ensure that no person at the workplace is exposed to a substance or mixture in an airborne concentration that exceeds the exposure standard for the substance or mixture.


5.1 What is the workplace exposure standard for respirable crystalline silica dust?

Workplace exposure standards are airborne concentrations of a particular substance, such as respirable crystalline silica, that must not be exceeded.

The exposure standards are listed in the Workplace Exposure Standards for Airborne Contaminants. The exposure standard for respirable crystalline silica is currently 0.1 milligrams per cubic metre6 (mg/m3) (8 hour Time Weighted Average (TWA).7

The workplace exposure standard for respirable crystalline silica is likely to be exceeded if the amount of dust a worker breathes over a full shift contains more respirable crystalline silica than the amount shown here next to a five cent piece.

The workplace exposure standard for respirable crystalline silica does not represent a line between ‘safe’ and ‘unsafe’ airborne concentrations. Everyone is different, and this means that some people might experience adverse health effects below the exposure standard. Under the WHS Regulation persons conducting a business or undertaking:

• must eliminate risks to health and safety, or if that is not reasonably practicable

• minimise them so far as is reasonably practicable.

Exposure to respirable crystalline silica must be controlled to as low as reasonably practicable, not simply to below the workplace exposure standard.

Short term excursions

The eight hour TWA workplace exposure standard allows for short term excursions above the workplace exposure standard during periods of exposure to an airborne contaminant provided they are compensated for by extended periods of exposure below the standard during that working day. For example, this would mean periods of cutting (higher potential exposure) followed by periods of other activities such as installation without onsite modification (low potential exposure). In practice, the actual concentration of an airborne contaminant arising from a particular process may fluctuate significantly with time. Even where the TWA workplace exposure standard is not exceeded over the period of a shift, short term excursions over the eight hour TWA workplace exposure standard should be controlled.

A process is not considered to be under reasonable control if short term exposures exceed three times the TWA workplace exposure standard for more than a total of 30 minutes per eight hour working day, or if a single short-term value exceeds five times the eight-hour TWA workplace exposure standard for any length of time8.

The use of engineering controls such as water suppression and local exhaust ventilation should mean the TWA workplace exposure standard is not exceeded, even for short periods.

Adjustment of exposure standards for extended work shifts or overtime

In some circumstances the exposure standard needs to be adjusted to account for greater exposure that occurs during extended work shifts and to comply with the WHS Regulations.

An eight-hour TWA workplace exposure standard is based on exposure that occurs in an eight hour working day over a five-day working week followed by 16 hours of no exposure. Where workers have a working day longer than eight hours, a working week longer than 40 hours, or work shift rotations in

6 The workplace exposure standard for respirable crystalline silica is currently under review by Safe Work Australia and may change as a result. 7 The eight hour time-weighted average (TWA) is an eight-hour TWA exposure standard for the maximum average airborne concentration of a

particular substance when calculatedpermitted over an eight-hour working day in a five-day working week. 8 Further guidance on interpreting exposure standards is available at www.safeworkaustralia.gov.au.

~0.1mg of respirable crystalline silica – equivalent to the workplace exposure standard

https://www.safeworkaustralia.gov.au/doc/workplace-exposure-standards-airborne-contaminants


excess of either eight hours a day or 40 hours a week, the TWA workplace exposure standard may need to be adjusted to compensate for the greater exposure during the longer work shift and the decreased recovery time between shifts.

Several mathematical models can be used for adjusting exposure standards for extended work shifts. These models include the ‘Brief and Scala Model9’, the US ‘Occupational Safety and Health Administration Model10’, the ‘Pharmacokinetic Model’ of Hickey and Reist11, and the Quebec Model12. All models provide valid methods for adjusting exposure standards.

The main difference between these models is the degree of conservatism. Selection of a model will depend on the information available and it is important that a competent person such as a certified occupational hygienist is engaged to adjust the exposure standards to account for shift variations or longer work weeks.

It should be noted that exposure standards are never adjusted upwards, even for shifts less than eight hours.13

Further guidance on interpreting exposure standards is available at www.safeworkaustralia.gov.au.

5.2 Prohibition on uncontrolled dry cutting/processing Persons conducting a business or undertaking must not allow workers to undertake uncontrolled dry

cutting or processing of engineered or natural stone.

Uncontrolled dry cutting or processing means cutting, grinding, trimming, sanding, polishing or drilling

stone containing crystalline silica without effective controls to eliminate or minimise the risk of exposure

to respirable crystalline silica. Respiratory protective equipment does not control dust; it protects the

workers health.

Existing work health and safety laws in Queensland effectively prohibit uncontrolled dry cutting or

processing of engineered stone or natural stone with high levels of crystalline silica as it will expose

workers to levels of respirable crystalline silica that exceed the current workplace exposure standard.

5.3 Developing a respirable crystalline silica dust control plan Due to the significant risks to health from respirable crystalline silica and the large amounts of respirable crystalline silica dust (wet or dry) generated during the work processes involved in fabricating, processing, installing, maintaining or removing stone benchtops it is critical to plan the work so that all sources of dust are identified and the appropriate combination of control measures are in place. The person conducting a business or undertaking must eliminate or minimise the risk of exposure to respirable crystalline silica so far as reasonably practicable.

There are many factors that will impact on the amount of respirable crystalline silica dust workers may potentially be exposed to, including:

• the type of stone and the silica content of the product being used (refer to product label, technical data sheet or similar document)

• the size of the dust (wet or dry) particles being generated

• the amount of dust in the breathing zone of a worker

9 Brief R, Scala R. Occupational Exposure Limits for Novel Work Schedules, American Industrial Hygiene Association Journal. 36:467-469, 1975. 10 Paustenbach D. Occupational Exposure Limits, Pharmacokinetics and Unusual Work Shifts. Patty’s Industrial Hygiene and Toxicology, Vol III, Ed Harris, R. L., New York, John Wiley & Sons, 11-277, 2000. 11 Hickey J, Reist P. Application of Occupational Exposure Limits to Unusual Work Schedules. American Industrial Hygiene Association Journal. 38:613-621, 1977. 12 Institut de recherché Robert-Sauvé en santé et en securité du travail, (IRSST), Guide for the adjustment of Permissible Exposure Values (PEVs) for unusual Work Schedules, 3rd Edition, IRSST, Montréal, 2008

http://www.safeworkaustralia.gov.au/


• the work activities being undertaken and the controls in place, e.g. wet cutting and local exhaust ventilation

• how long a worker may be exposed to respirable crystalline silica dust (wet or dry) (e.g. a full shift, or rotating out of the work zone)

• how often a worker is breathing in respirable crystalline silica dust (wet or dry) (e.g. every day).

A person conducting the business or undertaking that fabricates and processes stone benchtops should develop a written respirable crystalline silica dust control plan to identify all potential tasks that may result in exposure to respirable crystalline silica and the control measures to be used to prevent or minimise exposure.

The respirable crystalline silica dust control plan should consider ways to:

• eliminate or minimise the amount of dust (wet or dry) being produced and released into the air

• prevent dust (wet or dry) being breathed in by workers

• clean up any dust (wet or dry), slurry or other waste produced

• decontaminate workers’ clothing and footwear.

The respirable crystalline silica dust control plan should cover:

• the percentage silica content of the product/s being used

• all sources of respirable crystalline silica dust (wet or dry) relevant to that workplace;

• details of the dust (wet or dry) controls to be implemented for each activity following the hierarchy

of controls to manage the risk of respirable crystalline silica exposure as follows:

- engineering controls, such as water suppression and local exhaust ventilation (LEVs) should always be used to eliminate or minimise dust exposure

- engineering controls should be used in combination with other controls, for example, barriers to prevent other workers entering a work area where processing of the stone containing crystalline silica is taking place;

- clean up and disposal of dust or wet slurry, and decontamination of workers clothing

- appropriate respiratory protective equipment must always be used and always in combination with engineering and other controls (see section 6 for further information on controlling respirable crystalline silica dust risks and section 6.3.4 for further information on respiratory protective equipment)

• how the dust (wet or dry) control measures will be integrated into daily shift routines (e.g. tool box

talks, pre-start checks and daily cleaning of work areas)

• how air monitoring will be used to assess whether the controls are working, see further information

in section 6.2

• systems in place to routinely inspect, maintain and monitor controls and equipment to ensure they

are clean and functioning effectively

• ongoing monitoring and review strategies, particularly in response to incidents, control failure, or

exposure standard exceedances

• communication of risks and controls, exceedances and reporting mechanisms.

The respirable crystalline silica dust control plan should be developed in consultation with workers involved in carrying out the tasks and the relevant health and safety representative of the work group if one exists.

If a plan has been developed it should be made available to a medical practitioner carrying out health monitoring. An example respirable crystalline silica dust control plan is provided at Appendix 2.

6. Identifying respirable dust hazards The first step in managing risks associated with exposure to respirable crystalline silica is to identify respirable dust (wet or dry) hazards.


Potential respirable crystalline silica dust hazards may be identified in a number of different ways, including:

• conducting a walk-through assessment of the workplace

• observing the work and talking to workers and/or health and safety representatives (HSRs) about

how work is carried out

• inspecting the plant and equipment that is used as part of the fabrication and other relevant

processes

• undertaking air monitoring at the workplace

• inspecting workplace surfaces for build up of settled dust.

Respirable crystalline silica can be generated and released into the atmosphere during the fabrication of stone benchtops in a number of ways, including:

• cutting, grinding, trimming, drilling, sanding or polishing stone using both powered hand tools or machinery without proper controls in place

• poor slurry management, for example letting the slurry dry out before disposing it

• poor housekeeping methods including dry sweeping and the use of compressed air or high-pressure water

• accumulated dust becoming airborne as a result of vehicles and people moving around the workplace

• inadequate cleaning allowing excessive build-up of dust around equipment and workstations

• wind or air-movement in the workplace causing disturbance of settled dust.

6.1 Fabrication workers and others at risk Workers may be exposed to respirable crystalline silica when cutting, grinding, sanding and polishing during fabrication, installation, removal or maintenance of stone benchtops. Workers performing other tasks in or near areas where these processes are being undertaken may also be exposed to high levels of dust (wet or dry).

During audits of the industry undertaken by WHSQ, workers undertaking similar tasks were grouped together.

The fabrication workers most at risk of exposure included:

• shapers

• saw operators

• finishers

• machine operators (excluding saw operators)

• polishers.

Other workers at risk of exposure to respirable crystalline silica include:

• workers carrying out non-fabrication tasks, including supervision, maintenance, cleaning, driving forklifts and general labouring

• workers carrying out work adjacent to on-site installation (further information regarding on-site installation is in section 8).

These workers may experience exposure as a result of:

• dust generated during uncontrolled fabrication processes

• poor housekeeping (e.g. disturbing settled dust)

• poor cleaning techniques that distribute dust (e.g. high pressure water, compressed air, dry sweeping).

Potential risk to office workers at fabrication workplaces should also be considered. These workers may be exposed if adequate controls are not implemented and subsequent background levels of respirable crystalline silica are high or if their roles mean they frequently access processing areas. For example, office workers frequently walking through or performing tasks in areas near where the processing of stone benchtops is undertaken may be exposed to high levels of respirable crystalline silica.


Certain tools release more respirable crystalline silica dust into the air

When identifying respirable crystalline silica dust hazards it is important to consider that certain

processes and tools generate more respirable crystalline silica. Workers who operate powered hand

tools to cut, grind or polish stone, such as circular saws or grinders, have some of the highest respirable

crystalline silica exposures of all fabricators. These tools are often used to complete tasks including

cutting holes for sinks and stove tops or during shaping edging and profiliing stone. These tasks may

occur in a workshop environment or on job sites during installation.

6.2 Air monitoring

WHS Regulation section 50 (1) A person conducting a business or undertaking must ensure that air monitoring is carried out to determine the airborne concentration of a substance to which an exposure standard applies if:

• uncertain on reasonable grounds whether or not the airborne concentration exceeds the exposure standard; or

• monitoring is necessary to determine whether there is a risk to health.

(2) A person conducting a business or undertaking at a workplace must ensure that the results of air monitoring carried out under subsection (1) are— (a) recorded, and kept for 30 years after the date the record is made; and (b) readily accessible to persons at the workplace who may be exposed to the substance or mixture.

Air monitoring to determine a worker’s exposure (as per WHS Regulation 49) involves measuring the

level of respirable crystalline silica in the breathing zone of workers using a personal sampler during the

course of their usual shift activities (including routine breaks). Air monitoring must be conducted to

determine whether there is a risk to a worker’s health, or if there is any uncertainty that the exposure

standard is being exceeded.

While air monitoring does not prevent disease and is not an alternative to controlling exposure, it is important to:

• check the ongoing effectiveness of any control measures

• check that any new controls are working effectively

• ensure the workplace exposure standard is not being exceeded at the workplace

• inform workers of the pattern of exposure to the risk of respirable crystalline silica

• help choose the right level of respiratory protection

• inform health monitoring requirements.

Personal sampling of workers at stone benchtop fabrication businesses undertaken by WHSQ has

established the airborne concentration of respirable crystalline silica created a significant risk to health

and safety.

Similarly exposed group of workers

Description Range of exposures (mg/m3)

Shapers Workers cut holes in slabs for taps, sinks or stovetops and conducted jointing and associated edge grinding of stone predominantly using powered hand tools.

0.69 to 1.03

Saw operators Workers operated bridge saws or similar slab cutting equipment that used a cutting blade on stone.

0.06 to 0.142

Finishers

Workers conducted all fabrication tasks associated with finishing a bench-top after it had been cut by slab cutting equipment. This included both shaping and polishing processes predominantly using hand tools.

0.057 to 0.110


Similarly exposed group of workers

Description Range of exposures (mg/m3)

Machine operators (excluding saw operators)

Workers operated CNC routers or other similar equipment that used a cutting tool on stone. This group included water jet operators.

From less than limit of quantitation (LOQ) to 0.045.

Polishers Workers bevelled edges and polished stone using powered hand tools.

From LOQ to 0.097.

Labourer/ supervisor

Workers that conducted support tasks including operating forklifts and general labouring or supervision.

From LOQ to 0.058.

When air monitoring is required

Due to the high silica content of engineered stone, the significant risks to health from respirable crystalline

silica and the large amounts of respirable crystalline silica dust generated during uncontrolled stone

benchtop fabrication, a person conducting a business or undertaking that fabricates stone benchtops must

undertake air monitoring.

Stone benchtop fabrication businesses are required to undertake baseline air monitoring:

• within six months of:

- the code commencing (for existing businesses); or

- a new stone benchtop fabrication business starting

• at six monthly intervals for the first two years.

After a baseline is established, air monitoring is required:

• in response to the triggers outlined below; or

• at least every 12 months.

Triggers for air monitoring outside of schedule above. When:

• there are major changes to work practices (e.g. new equipment being commissioned), production,

processes (e.g. redesign of the work process), procedures or control measures since the last

assessment which may reasonably be expected to result in new or additional exposures

• a health monitoring report indicates an adverse result in circumstances where the baseline or

previous monitoring reports for that worker did not indicate any abnormality

• an HSR requests a review of control measures (as provided under the existing WHS regulation),

and current air monitoring records are not available

• the results of worker consultation indicate monitoring is required, for example, receipt of a

substantiated complaint from a worker or their representative, or when a substantiated matter is

raised by an entry permit holder regarding possible contravention of the workplace exposure

standard, and current air monitoring records are not available

• there are changes to the workplace exposure standard where previous air monitoring results have

indicated levels above the new WES.

Stone benchtop fabrication businesses that only fabricate very low silica content stone benchtops (e.g.

marble) may be able to seek an exemption from the requirement for air monitoring from the regulator.

This exemption can be sought under section 685 of the WHS Regulation, which outlines specific matters

the regulator must consider in making a decision on an exemption application.

The respirable dust sampling plan and air monitoring

The person conducting a business or undertaking should ensure:

• air monitoring under this code is conducted by an independent competent person (certified

occupational hygienist, or a recognised equivalent competency under an international certification


scheme, e.g. certified industrial hygienist) not involved in the business or undertaking of fabricating

stone benchtops

• a respirable dust sampling plan is developed by the independent competent person that is

representative of worker numbers, workers shift work, tasks performed and conditions at the

fabrication workshop

• the respirable dust sampling plan is developed in consultation with workers, and where applicable,

any HSRs

• an investigation is conducted when a personal air sampling result exceeds the workplace exposure

standard, irrespective of whether respiratory protective equipment was worn. The result of the

investigation should be documented, include any corrective actions taken to eliminate or prevent

the exposure, and provided to workers and if requested, their representatives. An investigation

report must also be made available to an inspector on request

• the competent person provides evidence they:

- undertake sampling in accordance with AS 298514

- undertake sampling on a day that is representative of usual exposure across a 40 hour week

- the air monitoring devices used are calibrated in accordance with the manufacturer’s instructions

- have met the minimum number of samples recommended in Occupational Hygiene Monitoring and

Compliance Strategies15 as shown in the table below.

Group/work force size Sample size required

1 1

5 5

10 9

15 – 17 12

25 – 29 15

50 22 Source: abbreviated from NIOSH Manual of Analytical Methods (2012)

From Occupational hygiene monitoring & compliance strategies, p69

Air monitoring report

The air monitoring report should include:

• background to, and the purpose of the air monitoring

• reference to the applicable eight-hour time weighted average (TWA) workplace exposure standard

• information on the calibration of the sampling equipment used

• what sampling was undertaken and what measurements were taken (static, personal, grab or continuous), and how

• details of the persons, or similarly exposed groups sampled

• any similar exposure groups that may potentially be exposed but were not sampled

• a description of the process measured, the work patterns, and the hazards involved

• identification of tasks or processes not measured that are a likely exposure source

• the control measures observed in place, and their performance

• how and where the samples were analysed (i.e. laboratory and technical details)

• identified exposure sources, discussion of results, compliance with standards, the adequacy of controls and an assessment of risk

• the results related to the sampling plan, including whether the estimated exposure for a similar exposure group has exceeded the workplace exposure standard

• specify the technique used to analyse and interpret the data (e.g. Occupational Hygiene Monitoring & Compliance Strategies (AIOH) or EN 689)

14 AS 2985 Workplace atmospheres—Method for sampling and gravimetric determination of respirable dust 15 Grantham, D & I Firth (2014). Occupational Hygiene Monitoring and Compliance Strategies. Australian Institute of Occupational Hygienists

Inc. https://www.aioh.org.au/resources/publications1/publications


• recommendations for improvement (e.g. action plan for controls, training, health monitoring)

• recommendations for further air monitoring to measure the effectiveness of any proposed changes.

The air monitoring report must be made available to an inspector on request and should be made available to the medical practitioner conducting relevant health monitoring. In addition a person conducting a business or undertaking at a workplace must ensure that the results of air monitoring carried out are recorded, kept for 30 years after the date the record is made; and readily accessible to persons at the workplace who may be exposed to respirable crystalline silica and their representatives.

7 Controlling respirable crystalline silica dust risks

WHS Regulation section 35: A duty holder, in managing risks to health and safety, must— (a) eliminate risks to health and safety so far as is reasonably practicable; and (b) if it is not reasonably practicable to eliminate risks to health and safety – minimise those risks so far as is reasonably practicable.

WHS Regulation section 36: If it is not reasonably practicable for a duty holder to eliminate risks to health and safety, the duty holder must minimise risks, so far as is reasonably practicable, by doing one or more of the following— (a) substituting (wholly or partly) the hazard giving rise to the risk with something that gives rise to a lesser risk; (b) isolating the hazard from any person exposed to it; (c) implementing engineering controls. If a risk then remains, the duty holder must minimise the remaining risk, so far as is reasonably practicable, by implementing administrative controls. If a risk then remains, the duty holder must minimise the remaining risk, so far as is reasonably practicable, by ensuring the provision and use of suitable personal protective equipment.

Prevention at the source (water suppression, isolation, on-tool extraction or other exhaust ventilation) is

the most effective means of controlling respirable crystalline silica dust. These controls should be

accompanied by lower order controls such as respiratory protective equipment and appropriate clean-up,

maintenance and training to ensure the risk is eliminated or minimised so far as is reasonably

practicable.

7.1 The hierarchy of control measures Some control measures are more effective than others. Control measures can be ranked from the

highest level of protection and reliability, to the lowest. This ranking is known as the hierarchy of control.

You must always aim to eliminate a hazard and associated risk. Elimination is the most effective control

measure and must always be considered before all other control measures.For example, using products

that do not contain crystalline silica (quartz) would eliminate the hazard completely. However, care

should be taken to ensure any new materials are safe to use and don’t introduce new hazards.

If this is not reasonably practicable, the risk must be minimised by using one or more of the following

approaches:

• Substitution – replace a hazardous process or material with one that is less hazardous (e.g. using products with less crystalline silica such as a lower crystalline silica content natural stone).

• Isolation – separating the workers from the hazard and work areas (e.g. installing barriers between workers and machines that produce respirable crystalline silica dust (wet or dry), both for workers generating the dust and workers nearby, such as in adjacent offices).

• Engineering controls – are physical in nature, including mechanical devices or processes that eliminate or minimise the generation of dust (wet or dry), such as local exhaust ventilation,


including on-tool extraction, and/or water suppression should be used to control each dust generating process.

If a risk remains, it must be minimised by:

• implementing administrative controls, so far as is reasonably practicable. For example, plans to routinely clean the work area and vacuum any residual dust off clothing.

• providing workers with, and training them in the use of, personal protective equipment (PPE), for example, respiratory protective equipment (RPE) such as powered air purifying respirators must be used. (see section 7.2.4).

Administrative control measures and PPE rely on human behaviour and supervision. If used on their

own, they tend to be least effective in minimising risks.

Use a combination of methods

A combination of control measures should always be used to manage the risk of respirable crystalline

silica when fabricating, processing, installing, maintaining or removing stone benchtops. Using water

suppression, a local exhaust ventilation system and respiratory protective equipment together is an

example of a combination of control measures.

7.1.1 Water suppression

Water suppression uses water at the point of dust generation to dampen down or suppress dust before it

is released into the air. Water suppression is the most common form of dust control in the stone

benchtop industry. Powered hand tools such as grinders or polishers, and large machinery including

bridge saws, routers or polishing machines fitted with water feeds are available from manufacturers and

retailers in Australia.

Equipment or machinery used for water suppression should:

• have an appropriate ingress protection (IP) rating for use with water suppression

• have the water feed attached and an adequate number of water feeds directed at the contact point to prevent dust being released during the process

• have a consistent water flow and adequate water pressure (usually at least 0.5L/min) during operation

• be fitted with guards, plastic flaps or brush guards designed to manage the water spray or mist containing respirable crystalline silica

• be maintained according to manufacturer’s instructions.

See section 7.2.1 for managing respirable crystalline silica contaminated mist resulting from water

suppression processes.

In the case of retrofitting, or introducing water suppression into an existing process as a new control,

consideration needs to be given to the current electrical equipment’s IP rating. Only tools and machinery

that have been specifically designed for use with water attachments should be used. A thorough check

of electrical equipment, including electrical cords, should also be undertaken to ensure safety when

undertaking wet cutting or other processing.

The use of a handheld spray bottle, sponge or garden hose to separately apply water to rotating tools is

not permitted. These methods are inadequate to suppress dust and dangerous if used with power tools

that are not designed for use with water.

7.1.2 Local exhaust ventilation (LEV)

Local exhaust ventilation is used to remove airborne contaminants before they reach the breathing zone

of workers. It is the most effective control for large quantities of respirable crystalline silica dust (dry or

wet) as it is applied close to the source of generation. Local exhaust ventilation systems include a

shroud (a suction casing that surrounds the wheel/stone), an on-tool hose attachment, and a vacuum

system. The dust or mist is collected within the shroud, drawn into the hose attachment to the vacuum,

where it is filtered and discharged. When correctly designed and used a local exhaust ventilation system


is able to both capture and contain dust or mist generated from a process. See section 7.3 for

information on clean up of tools and equipment throughout the day.

Silica dust (dry or wet) is very abrasive to local exhaust ventilation equipment, which must be regularly

inspected for damage and properly maintained.

Figure 1: On-tool extraction16

Where the slab can be lifted, place a sacrificial backer-board or spoil-board under the stone slab during cutting or trimming. This prevents dust from being released below the slab thereby increasing the effectiveness of on-tool extraction. MDF or particle board would be suitable for this purpose.

Figure 2: Use of a sacrificial board

Whether a sacrificial backer board can or cannot be used, other controls must be in place. See section

7.1 for further information.

7.1.3 Natural ventilation

Workplaces should have an adequate supply of fresh air.

General ventilation within a room or building can be provided by natural means, such as opening

windows and doors. Fans may support the movement of air but should be arranged so that clean air

streams are drawn past workers, and contaminated ones away from workers but not into the direction of

others (e.g. workers or adjacent businesses).

Caution should also be exercised to ensure fans do not dry wet slurry before it can be cleaned up.

Improving the general ventilation to a room or building may help reduce the concentration of

contaminants in the air but cannot be relied as the way to ensure exposure to respirable crystalline silica

16 Image used with permission from Hilti (Aust)


is managed. Other methods to prevent respirable crystalline silica being released into the atmosphere

must be used.

7.2 Prevent workers breathing in dust Respirable crystalline silica carried in the air as dust or in water mist can be further controlled through

guards, enclosures and barriers. In addition to those controls respiratory protective equipment and

operational procedures should also be used.

7.2.1 Enclose water suppression processes

As a consequence of applying water to rotating tools, respirable crystalline silica dust contaminated

water spray is ejected from the process.

This water spray can expose workers to respirable crystalline silica by:

• being breathed in with the water spray/mist

• drying in the air and breathed in

• depositing on surfaces, including clothing, and later drying, only to become airborne again when disturbed.

Controls should be used to enclose water spray when using water suppression systems. These

methods include using guards, plastic flaps or brush guards around the rotating blade or tool or

equipment.

Figure 3: Diagram of additional guards to bridge saw

In addition, other controls that minimise exposure by managing the water spray from water suppression

processes include:

• providing distance between the work process and the worker (for example operator positioning when using bridge saws or routers)

• providing distance between workers using powered hand tools and other workers at the workplace

• providing physical barriers between different workers and workstations to prevent the water mist moving into other work areas or towards other workers, including office workers.

Routine maintainence and cleaning also is necessary to ensure guards continue to work effectively.


Figure 4: CNC Router with plastic shrouding. Source – WHSQ Inspectorate

7.2.2 Isolating workers

Isolation is an effective control strategy used alongside engineering controls to reduce to a minimum the

number of workers potentially exposed to any residual respirable crystalline silica.

This can be achieved through:

• using physical or temporary barriers such as temporary walls or sheeting, noting barriers do not prevent dust drift and should only be used where natural ventilation is sufficient and dust release is controlled

• enclosing slab cutting, grinding, trimming or polishing equipment

• using fabrication rooms – i.e. water suppression tools or on-tool extraction in a room with an extraction system

• providing workers with a separate room or area away from dust generating processes for food preparation and dining

• [During onsite installation] conducting work outside (follow manufacturer’s instructions and ensure contaminated dust does not travel in the direction of other workers or other premises).

Figure 5: An example of isolation, with workers outside of the barrier. Source – WHSQ Inspectorate

7.2.3 Administrative controls to minimise exposure

Administration controls are work practices or procedures that are designed to minimise exposure to a

hazard. Due to the levels of dust generated when fabricating, installing, maintaining or removing stone

benchtops administrative controls should not be used on their own. Administrative controls on their

own will not provide sufficient control, but rather are intended to enhance higher order control

measures.

Work practices

The way in which work is conducted can influence the generation of respirable crystalline silica dust and

exposure to workers.

While the use of higher order controls such as water suppression and local exhaust ventilation together

with respiratory protective equipment are critical to minimising the exposure of workers to respirable


crystalline silica dust (wet or dry), the following work practices may also assist in reducing the amount of

exposure:

• planning to make the minimum number of cuts for each job

• using machinery and equipment with integrated dust suppression or those designed to generate less dust such as water jet cutters

• implementing systems to ensure routine, or daily checks of critical controls, such as guards and local exhaust ventilation, as well as respiratory protective equipment

• wetting slabs before cutting, grinding, trimming or polishing to remove dust and aid with water

suppression

• washing slabs after fabrication to remove any residual dust

• good housekeeping including regular cleaning of work areas

• ensuring workers wash their hands and face thoroughly before eating, drinking or leaving the workplace.

Rotating workers between high exposure and low exposure tasks does not control dust and is not

acceptable as a primary control. However, it can be part of a suite of measures taken to minimise the

risk to health due to the exposure of workers to respirable crystalline silica.

Safe work procedures

How power tools, equipment and other machinery are used by workers influences the generation of dust.

Before plant or equipment is used in your workplace, you must provide your workers and other persons

who are to use it with information, training, instruction or supervision that is necessary to protect them

from risks, including respirable crystalline silica dust, arising from its use.

Safe work procedures should be developed that include instructions on:

• the correct use of guarding and dust control measures

• how to operate the plant and equipment in a manner that reduces dust exposure

• how to carry out inspections, shut-down, cleaning, repair and maintenance of both the plant and dust control measures

• emergency procedures

• the use of personal protective equipment, such as protective footwear, eye wear, respiratory protective equipment, or an apron.

In addition to safe work procedures, warning signs (Figure 6) should be erected to communicate

respirable crystalline silica dust hazards and required personal protection controls.

Figure 6: Warning signs

7.2.4 Use Respiratory Protective Equipment

A respiratory protective equipment (RPE) program must be implemented unless suitable and sufficient

air monitoring that estimates the true mean of worker exposure has been carried out and exposure has

been assessed as being less than the exposure standard using the 95 percent upper confidence limit.

The RPE program should include:

• providing suitable RPE

• fit testing (if relevant to the RPE used)

• a use, maintenance and repair program

• a facial hair policy for tight fitting respirators


• providing information, training and guidance to workers.

WHS Regulation, sections 44-47: If personal protective equipment (PPE) is to be used at the workplace, the person conducting the business or undertaking must ensure that the equipment is selected to minimise risk to health and safety including by ensuring that the equipment is:

• suitable for the nature of the work and any hazard associated with the work

• a suitable size and fit and reasonably comfortable for the person wearing it

• maintained, repaired or replaced so it continues to minimise the risk

• used or worn by the worker, so far as is reasonably practicable.

A person conducting a business or undertaking who directs the carrying out of work must provide the worker with information, training and instruction in the proper use and wearing of personal protective equipment; and the storage and maintenance of personal protective equipment.

A worker must, so far as reasonably able, wear the PPE in accordance with any information, training or reasonable instruction and must not intentionally misuse or damage the equipment.

RPE should never be used as the primary means for exposure control because higher order controls are more effective. RPE is the least effective form of controlling dust exposure according to the hierarchy of controls, as it does not remove the hazard and relies on correct fit and use by the worker, as well as adequate supervision. However, RPE must be provided and worn correctly for the full duration of the task to manage any residual dust.

Selecting suitable RPE for respirable crystalline silica

A hood or head top type, full face or half face powered air purifying respirator (PAPR) (see Figure 7) with

at least a P2 filter must be worn as a minimum by workers carrying out:

• fabricating, processing, cleaning or maintenance work in a fabrication workshop (including labourers and supervisors)

• processing tasks during on-site installation.

PAPR respirators are required because of the high silica content of engineered stone and certain natural

stones and the significant health risk from exposure when undertaking these tasks. These types of

respirators are also more suitable for Queensland’s hot and humid climate and work environments and

for wearing for longer periods.

The risks to health from exposure to respirable crystalline silica should also be assessed for any persons

working adjacent to or visiting the workshop, e.g. administrative staff or salespeople, and appropriate

control measures implemented. Processes should be in place to ensure incidental access by other staff

or visitors is minimised or scheduled for periods when fabrication, processing, cleaning or maintenance

is not occurring.

PAPRs work by using a fan to draw or push air in through the filter compared to negative pressure

respirators which require the user to draw air through the filter which can be taxing on the user and lead

to fatigue.

A minimum of a P2 filter combined with PAPR can provide protection up to 50 times the current

exposure standard, a level considered necessary when working with engineered stone.

While PAPR represents the minimum required RPE in Queensland for relevant work in the stone

benchtop industry, supplied air respirators may also be used. However, as an air compressor’s intake

may draw air that is contaminated by exhaust emissions from the compressor engine or another nearby

source it is recommended a carbon monoxide alarm is used. Further information on managing the risk

of carbon monoxide poisoning from air compressors is available at worksafe.qld.gov.au.


Figure 7: Head top full face PAPR17

Figure 8: half face PAPR with safety glasses18

Figure 9: Half face PAPR19

Workers should be consulted on RPE to ensure individual fit and medical factors have been considered.

Quantitative Fit Testing

Due to the high silica content of engineered stone, the associated potential exposure levels and to

comply with current Australian Standards, PAPR which rely on a tight seal will require quantitative fit

testing by a competent person (i.e. an in-house person, manufacturer, supplier or consultant properly

trained and proficient in the fit-test method being used). Fit testing measures the effectiveness of the

seal between the respirator and the worker’s face. If there is not a good seal, contaminated air,

potentially containing RCS, could leak into the respirator.

Hood and headtop type PAPRs do not require fit testing as they cover the whole head and do not rely on

a tight seal.

17 Image used with permission from 3M 18 Image used with permission from CleanSpace Technology Pty Ltd 19 Image used with permission from CleanSpace Technology Pty Ltd


Fit testing ensures workers wear a respirator that is suitable to their individual facial characteristics. As

facial characteristics vary from person to person, it is unlikely that one model or size of RPE will fit

everyone and different sizes and models of respirators are available to accommodate these differences.

Facial hair, including beards, moustaches, sideburns and stubble impinging on the seal will stop a

respirator from sealing properly.

Workers who are required to wear tightfitting respirators must:

• be clean-shaven; or

• ensure there is no hair between their face and the seal of the respirator face piece as it can interfere with a proper fit. This is important as respirable crystalline silica particles are smaller than facial hair (see Figure 10: Comparison of facial hair with respirable crystalline silica particle size.Figure 10 below); and

• ensure facial hair, clothing or jewellery do not interfere with the respirator seal or inhalation/ exhalation valve operation.

Figure 10: Comparison of facial hair with respirable crystalline silica particle size20.

Fit testing is required to be carried out:

• by a competent in-house person, manufacturer, supplier or consultant

• before wearing a tight-fitting respirator for the first time

• each time a new make or model of tight-fitting respirator is issued

• whenever there is a change in the worker’s facial characteristics or features which may affect the facial seal (for example large weight loss or gain)

• on a regular basis upon risk assessment

• at least annually.

Competency of fit testers

Fit testers must be properly trained and proficient in the fit-test method being used.

There is no approved fit-test training or competency standard in Australia at present however relevant

competencies would include21:

• knowledge of the respirators used for the fit test

20 Respiratory Protective Equipment Industry Considerations Air Quality Working Group Information Package - Part 10 (2018) Australian

Tunnelling Society and Engineers Australia. Sourced at http://www.ats.org.au/wp-content/uploads/2018/12/AQWG-Part-10-of-12-RPE-Industry-Considerations-v0.07.pdf 21 International Standard ISO 16975-3:2017 Respiratory protective devices – Selection, use and maintenance – Part 3: Fit-testing procedures

indicates fit-test operator competency


• knowledge of the fit-test method

• ability to set up all applicable equipment and monitor its function

• ability to carry out the test and evaluate the results

• ability to identify likely causes of fit-test failure.

Seal checking

Each time a tight-fitting respirator is put on, the worker should carry out a seal check. A seal check is a

quick check to ensure the respirator, which has been fit tested, is properly positioned on the face and

there is a good seal between the respirator and face. Seal checks do not replace the need for a fit test.

Manufacturer’s instructions should be followed on how to carry out a seal check.

Maintenance of RPE

Under the WHS Regulation RPE must be maintained, repaired or replaced so as to ensure that it

continues to be effective. RPE maintenance should be carried out by a competent person in accordance

with the manufacturer’s instructions. A competent person is defined in the WHS Regulation as a person

who has acquired through training, qualification or experience the knowledge and skills to carry out the

task.

A maintenance program should include procedures for:

• daily cleaning and inspection of RPE by the worker for wear, damage and flat batteries

• appropriate storage (e.g. in a dry, clean and sealed container) – each worker should be provided with a dedicated container to store their RPE. Clean, dry RPE should be stored away from dust and out of direct sunlight, and face pieces should be stored so that they are not subject to distortion

• identification and repair or replacement of any worn or defective components of the equipment including filters (including availability of replacement parts)

• regular periodic inspection, maintenance and testing of respiratory protective equipment in accordance with the manufacturer’s instructions

• record keeping, including:

- details of any issues, including the date (for reusable only)

- user records including training provided

- fit testing records for each worker including: o type of test performed o make, model, style and size of respirator tested o date of the test o result of the test

- maintenance records including filter replacement and RPE maintenance schedules

- RPE program records, including procedures for use and audits or evaluations.

Care should be taken to ensure the RPE maintenance program takes into account the environmental

conditions the RPE is being used or stored in (e.g. hot work vans) as the rubber seals may persish and

require replacing more frequently.

Training workers on the correct use and maintenance of RPE

When issuing RPE, training must be provided to ensure that workers correctly use and maintain RPE.

Training should be provided by a competent person such as a health and safety consultant, a trained

person in-house, a representative from a RPE manufacturer or supplier, an occupational hygienist or the

holder of a Certificate 4 in Work Health and Safety with expertise or experience in this area. Where the

training is being provided in-house, the in-house trainer should themselves have had training from a

competent person (as above).

Training in the use of RPE should cover the following topics:

• why RPE is required


• when RPE is required to be worn

• how RPE works

• the limitations of RPE

• how to correctly put on and take off RPE

• how to conduct a seal check

• how to clean and maintain RPE

• when and how to replace filters and batteries (including rechargeable batteries)

• how and where to store RPE when not in use.

Ongoing training and supervision may be required to ensure that RPE is used correctly by workers.

Under existing work health and safety laws, workers must take reasonable care for their own health and

safety, comply with any reasonable instruction, and cooperate with any reasonable policy or procedure

of the person conducting a business or undertaking relating to health or safety. This means a worker

must use or wear RPE in accordance with any workplace policy and information, training or reasonable

instruction given.

Other personal protective equipment (PPE)

In addition to respirators, other PPE may be required to be used to protect workers depending on the

particular work task. The appropriate PPE can be determined by conducting a risk assessment.

Before beginning any dust generating work, conditions likely to affect the health and safety of workers

should be assessed and the provision and use of appropriate personal protective equipment should be

arranged.

The following items of PPE are examples of what may be used depending on the task and identified

risks, in order to prevent the deposit of water containing respirable crystalline silica on clothing that may

later dry and become dusty:

• protective footwear (e.g. rubber boots/gumboots – refer to AS/NZS 2210.1 Safety, protective and occupational footwear – Part 1: Guide to selection, care and use)

• protective clothing (e.g. waterproof overalls or an apron).

7.3 Clean up Stone slabs are often delivered to the fabrication business for processing with a layer of dust or sand, or sent out for installation after processing without being washed down. To minimise the risk, stone slabs should be washed prior to processing and again before sending out for installation.

During a shift it is important to keep respirators on and clean the area, tools and equipment after

finishing each job using an H class vacuum cleaner or wet methods such as low pressure hosing,

mopping or wet wiping down surfaces.

Figure 11: Hepa filter warning label

Dry sweeping methods, such as using brooms, or using compressed air to clean up a fabrication

workshop are not permitted as these methods can recirculate respirable crystalline silica into the air.

Household vacuum cleaners must never be used where respirable crystalline silica dust is or may be

present, even if they have a HEPA filter.


Figure 12: Warning label

7.3.1 Workers’ clothing

Decontamination of workers clothing and PPE

Worker clothes, uniforms and boots must be cleaned frequently to prevent the transfer of respirable

crystalline silica dust from work areas to break rooms, other areas of the workplace, or into the home.

H class vacuum cleaners are an easy and effective way to remove excess silica debris from clothes and

other PPE.

H class vacuum units should be positioned at the exits of stone benchtop processing areas so workers

can decontaminate their clothes before routine breaks or leaving at the end of their shift. Water for hand,

face, and hair cleaning should also be provided. A low-pressure hose or tray of water may also be useful

for cleaning the bottom of footwear to prevent tracking dust into carpeted areas such as the office or

showroom.

It should be noted that the use of effective controls such as water suppression and local exhaust

ventilation should result in minimal dust settling.

7.3.2 Housekeeping

General cleaning and housekeeping

Regular cleaning should be undertaken to prevent the build up of dust on floors, walls, other surfaces

and equipment. Cleaning should be conducted at least at the end of each day.

To ensure good housekeeping practices:

• implement daily and thorough housekeeping and cleaning procedures for wet slurry and settled dust to prevent dust build up on surfaces in areas where the stone is processed (e.g. walls and building support structures such as girders and cross members)

• use low pressure water, wet sweeping or a H class rated vacuum cleaner to clean floors, walls and other surfaces

• regularly clean vehicle track or high use areas and keep them wet during the day

• prohibit the use of dry sweeping or compressed air to clean surfaces or clothing

• provide low pressure water from hoses for cleaning between tasks

• ensure all waste products are disposed of in a manner that minimises the risk of dust being redistributed over the workplace (e.g. covered, kept wet, bagged).

PPE cleaning and maintenance

The PPE should be cleaned after use to ensure that dust that may contain respirable crystalline silica

does not accumulate on the PPE. This may entail hosing off with water or wet-wiping in the case of

waterproof gumboots, aprons and gloves.

Under the WHS Regulation PPE must be maintained, repaired or replaced to ensure that it continues to

be effective. A maintenance program should include procedures for daily cleaning and inspection of PPE

by the worker for wear and damage, and identification and repair or replacement of any worn or

defective components of equipment.


Plant inspection and maintenance

WHS Regulation section 213: A person with management or control of plant at a workplace must ensure that maintenance, inspection, and if necessary testing, of plant is carried out by a competent person in accordance with manufacturer’s recommendations, or if those aren’t available, in accordance with recommendations of a competent person. If it is not reasonably practicable to comply with the manufacturer’s recommendations or the recommendations of a competent person, the inspection and testing must occur annually.

Plant must be routinely inspected, maintained and repaired according to the manufacturer’s

specifications or, in the absence of such specifications, in accordance with a competent person’s (i.e. a

person who has acquired through training, qualification or experience the knowledge and skills to carry

out the task) recommendations.

With regard to the dust control system, the inspection of plant should identify any:

• wear and tear, corrosion or damaged parts

• air leaks in pneumatic tools

• kinks, holes or leaks in water suppression or dust extraction equipment

• filters in need of replacing

• damage to guards and flaps that contain water spray.

Hand-held powered plant should be regularly inspected, repaired or replaced when necessary, and any

damaged or worn parts (such as grinding wheels) identified should be replaced.

A system of routine daily checks on plant and equipment designed to control dust should be

implemented to ensure they are working effectively. Failures or problems identified should be rectified

and workers should be encouraged to report concerns to the person conducting the business or

undertaking.

7.3.3 Wet slurry and recycled water

Management of wet slurry

Wet slurry is the resultant waste from dust generating processes that are water supressed. This slurry

has the potential to build up from the continuous processing using water suppressed equipment and

machinery. While wet the slurry is not hazardous, if it is allowed to dry the dust can become airborne

when disturbed and expose workers to respirable crystalline silica.

Wet slurry must be managed by:

• capture or containment through floor grading, grates, curbing and channelling

• keeping floors and surfaces wet

• regularly cleaning, including at the end of each day to prevent wet slurry drying overnight.

Any wet slurry dewatered to still be wet but of a cake consistency should be disposed of in a way that

minimises the risk of dust being redistributed over the workplace (e.g. covered, kept wet, bagged).

Recycled water

Water recycled on-site for use in water suppression must be effectively filtered to remove respirable

crystalline silica particles. Without an appropriate filtration system there is a risk that continual recycling

of water will increase the concentration of respirable crystalline silica in the water over time and

subsequently the level of respirable crystalline silica in the mist arising from the water suppression

activities.


7.4 Reviewing control measures

WHS Regulation section 37: A duty holder who implements a control measure to eliminate or minimise risk to health and safety must ensure that the control measure is, and is maintained so that it remains, effective, including by ensuring that the control measure is and remains: (a) fit for purpose; and (b) suitable for the nature and duration of the work; and (c) installed, set up and used correctly.

WHS Regulation section 38: (1) A duty holder must review and, as necessary, revise control measures implemented under this

regulation so as to maintain, so far as is reasonably practicable, a work environment that is without risks to health or safety.

(2) A duty holder must review and, as necessary, revise a control measure in the following circumstances— (a) the control measure does not control the risk it was implemented to control so far as is reasonably practicable (e.g. the results of monitoring show that the control measure does not control the risk or a notifiable incident occurs because of the risk); (b) before a change at the workplace that is likely to give rise to a new or different risk to health or safety that the measure may not effectively control; (c) a new relevant hazard or risk is identified; (d) the results of consultation by the duty holder indicate that a review is necessary; (e) a health and safety representative requests the review because of a circumstance under (a), (b), (c) or (d) affects or may affect the health and safety of a member of the work group represented by the health and safety representative; and the duty holder has not adequately reviewed the control measure in response to the circumstance.

7.4.1 Daily and routine checks

The control measures put in place to protect health and safety should be routinely reviewed to make

sure they are effective.

For example, daily start up checks should be done to ensure:

• machine and water mist guards and local exhaust ventilation are fitted correctly and working effectively

• local exhaust ventilation filters are clean and replaced according to the manufacturer’s instructions

• an adequate water supply for water suppression

• RPE is in good condition and seal checked.

The workplace should also be routinely monitored for signs of visible dust on work surfaces or clothing

as that may be an indication some controls not working effectively.

Air monitoring, undertaken as required to measure the concentration of respirable crystalline silica dust

in the worker’s breathing zone during fabrication, is an additional check of the effectiveness of controls.

7.4.2 Review and revision of controls

If control measures are not working effectively they must be revised to ensure effective risk control

measures are implemented. The same steps undertaken during initial hazard identification can be used

to check control measures.

Consult workers and where applicable their HSRs and consider the following:


• Are there any key triggers that indicate when controls are not working to their designed specification or operation?

• The results of air monitoring, in particular whether there was an exceedance of the workplace exposure standard (see section 5.1)

• Any health monitoring reports recommending a review of control measures (noting that health monitoring results must not be disclosed to any person without the worker’s consent).

• When workers may have taken ill

• The outcomes of consultation with workers (or their representatives) and HSRs, or worker complaints

• Have the control measures introduced new hazards?

• Could the proposed new control measures introduce new hazards?

• Have all respirable dust hazards been identified?

• Have new work methods or new equipment made the job safer?

• Are safety procedures being followed?

• Has the training and instruction provided to workers on how to work safely been successful?

• Are workers and where applicable their HSRs actively involved in identifying respirable dust hazards and possible control measures?

• Are workers using the supplied PPE/RPE during relevant work tasks?

If problems are identified, go back through the risk management steps, review information and make

further decisions about risk control.

8. Installing stone benchtops Workers may be exposed to crystalline silica if cutting, grinding, trimming, sanding, drilling or polishing is

undertaken during the installation of stone benchtops. Generally, workers have a higher risk of exposure

to respirable crystalline silica during fabrication rather than installation of the stone benchtop. However,

the more cutting, grinding, trimming, sanding or polishing a worker does the higher the risk to their

health.

Respirable crystalline silica will not be released if the benchtop installation is completed without further

cutting, grinding, trimming, sanding, drilling or polishing onsite.

Eliminate the need for cuts or alterations

Workers installing stone benchtops that have been completely fabricated in a workshop with no

additional cutting or fabrication required on site, should have minimal exposure to respirable crystalline

silica compared to workers involved in fabrication.

The need for cutting, grinding, trimming, sanding or polishing during installation should be eliminated by:

• Accurate measuring – whether by templates, diagrams or infrared measuring devices, eliminating measuring errors will eliminate the need for alterations.

• Cutting sink, tap and stove top holes at the workshop – mark and cut the location and size of holes during the fabrication stage or obtain the sink to ensure it fits before installation.

• Taking the slab back to the fabrication workshop when alterations, other than minor modifications, are required.

• Consulting and communicating with principal contractors and clients to prevent alterations on site.

Fabrication and processing on site

There may be circumstances that result in the need to fabricate stone benchtops oversize and trim onsite to fit. Where onsite trimming or alteration cannot be avoided it should be conducted in a controlled exclusion zone with additional controls outlined below. Uncontrolled dry cutting, trimming, grinding or polishing stone is prohibited because it exposes workers and others to large amounts of respirable crystalline silica.


When cutting, grinding, trimming, sanding or polishing stone benchtops during installation the person

conducting the business or undertaken must manage the risk of exposure to respirable crystalline silica

using the control measures set out in section 7 of this code, including:

• Water suppression, see section 7.1.1

• Local exhaust ventilation (LEV) with sacrificial backer board, see section 7.1.2

• Isolating workers, see section 7.2.2

• Respiratory protective equipment, see section 7.2.4.

In addition to using water suppression and local exhaust ventilation, other measures should be used

including:

• conducting work in a well-ventilated area, for example outside (follow manufacturer’s instructions and ensure contaminated dust does not travel in the direction of other workers or other premises); and

• excluding workers and others not involved with the cutting or grinding task, for example electricians, by restricting access to the area.

Personal protective equipment

Persons conducting a business or undertaking should also ensure stone benchtop workers are:

• using the recommended respiratory protective equipment (see section 6.3.4). Respiratory protective equipment must always be used and always in combination with engineering and other controls

• provided with personal protective equipment including disposable coveralls or an apron, safety boots or gumboots and hearing protection.

Clean up after installation

Proper clean up of the installation site and associated exclusion zones is important to minimise the risks

to health from exposure to respirable crystalline silica to other people, including other trades and

occupiers of premises.

Keep respirators on and thoroughly clean the area, tools and equipment after finishing the job using

either an H class vacuum cleaner or wet methods such as hosing, mopping or wet wiping down

surfaces.

Dry sweeping methods such as brooms or using compressed air should not be used as these methods

can recirculate respirable crystalline silica into the air.

All stone waste materials including wet slurry and captured dust should be disposed of in a manner that

minimises the risk of dust being redistributed.

Safe work method statements (SWMS)

WHS Regulation section 299: When carrying out high risk construction work, a person conducting a business or undertaking must ensure that a safe work method statement is prepared or has already been prepared by another person.

A safe work method statement (SWMS) for high risk construction work must be prepared before the onsite installation of stone benchtops involving any processing that may release respirable crystalline silica dust is undertaken, for example cutting, grinding, trimming, sanding, drilling or polishing.

High risk construction work is defined as including work ‘carried out in an area that may have a

contaminated or flammable atmosphere’ (WHS Regulation, section 291(l)). As a result, high risk

construction work includes work carried out in an area that may be contaminated with respirable

crystalline silica dust. Therefore, a SWMS should be prepared before carrying out any onsite installation

involving any processing, modification or repair to stone benchtops.

The SWMS must:

• identify the type of high risk construction work being done


• specify the health and safety hazards and risks to health arising from the work

• describe how the risks will be controlled

• describe how the control measures will be implemented, monitored and reviewed.

A SWMS is not required for work undertaken during fabrication at a workshop, but is required for onsite

installation where any processing (e.g. cutting, grinding, drilling or polishing) of the slab may occur.

9. Health monitoring

WHS Regulation section 368: A person conducting a business or undertaking must ensure health monitoring is provided to a worker carrying out work for the business or undertaking if the worker is carrying out ongoing work using, handling generating or storing hazardous chemicals and there is a significant risk to the worker’s health because of exposure to a hazardous chemical referred to in Schedule 14, table 14.1. Schedule 14 of the WHS Regulation lists the requirements for health monitoring for crystalline silica including the type of health monitoring.

Health monitoring means monitoring of a person’s health to identify changes in their health status

because of exposure to certain substances.

Health monitoring for workers exposed to respirable crystalline silica primarily screens for silicosis,

chronic obstructive pulmonary disease, autoimmune and other diseases associated with respirable

crystalline silica. Health monitoring is necessary to detect the early signs of health effects from exposure

to respirable crystalline silica and prevent the development of silicosis. Workers with silicosis do not

manifest any symptoms until the disease is well advanced.

Who should be provided health monitoring

Under the WHS Regulation, a person conducting a business or undertaking must ensure that health

monitoring is provided to the following workers:

• shapers

• saw operators

• finishers

• machine operators (excluding saw operators)

• polishers

• labourer/supervisor involved in the fabrication or installation of stone benchtops.

This is because there is a significant risk to their health during fabrication, processing and installation of

stone benchtops (due to the high silica content of engineered stone and certain natural stones and the

amount of respirable crystalline silica generated). Health monitoring of workers in higher risk roles

should be undertaken.

In addition, other workers who are regularly exposed to respirable crystalline silica at, or exceeding the

exposure standard (e.g. supervisors, maintenance workers, office staff and salespeople) should also be

provided with health monitoring.

Remember, workers with silicosis may not have any symptoms and silicosis is irreversible.

Worker reluctance to participate in health monitoring

Some workers may be reluctant to participate in health monitoring and this will usually be because they

are anxious about the medical results or the impact of the results on their job, or both. Persons

conducting a business or undertaking should include information on the purpose of health monitoring


into training and encourage workers to participate, as early diagnosis and treatment can prevent more

serious and life-threatening conditions from developing.

Supporting a worker in these circumstances can be achieved by ensuring they know how health

monitoring will benefit them, making the process easy for them to follow and, reminding them that their

workplace, family and community want them to be as safe and healthy as possible. HSRs at your

workplace (where applicable) may also be of assistance in this process and encourage workers to

participate in screening for silicosis.

If the conversation with a worker on health monitoring is stalled it may assist the person conducting a

business or undertaking to contact WHSQ inspectors for assistance or further information. The person

conducting a business or undertaking may also consider contacting the relevant union for the workers.

Worker representation groups will have special skills for communicating with workers about the

importance of their health and safety in a supportive and empowering manner.

Providing a health monitoring program

A person conducting a business or undertaking must:

• give information to workers and prospective workers about health monitoring requirements

• ensure health monitoring is carried out by or under the supervision of a registered medical practitioner with experience in health monitoring

• consult workers in relation to the selection of the registered medical practitioner

• pay all expenses relating to health monitoring

• provide certain information about a worker to the registered medical practitioner

• take all reasonable steps to obtain a report from the registered medical practitioner as soon as practicable after the monitoring has been carried out

• provide a copy of the report to the worker, and to all other persons conducting a business or undertaking who have a duty to provide health monitoring for the worker, e.g. where labour hire is used

• provide the Queensland work health and safety regulator (the regulator) with a copy of the report if the report contains adverse test results or recommendations that remedial measures should be taken

• keep reports as confidential records for at least 30 years after the record is made

• not disclose the report to anyone without the worker’s written consent unless required under the WHS Regulation.

Minimum requirements for health monitoring

Under Schedule 14 Table 14.1 of the WHS Regulation the minimum requirements for health monitoring

for crystalline silica are:

• demographic, medical and occupational history

• records of personal exposure

• standardised respiratory questionnaire;

• standardised respiratory function test, for example, FEV1, FVC and FEV1/FVC

• chest X-ray full size PA view.

All full size PA chest x-rays are to be taken and read consistent with ILO guidelines22 (i.e. classified by a

B reader or a radiologist who has undertaken Royal Australian and New Zealand College of Radiologists

approved training equivalent to the B Reader accreditation).

A B-reader is a radiologist who has undertaken specialised training to detect dust lung diseases such as

silicosis, coal workers’ pneumoconiosis, mixed dust pneumoconiosis and progressive massive fibrosis.

22 International Labour Organization (ILO) International Classification of Radiographs of Pneumoconioses


All lung function tests must be performed according to the Thoracic Society of Australia and New

Zealand (TSANZ)23.

Safe Work Australia’s Crystalline silica health monitoring guide provides further information on health

monitoring for respirable crystalline silica.

When should health monitoring occur?

Health monitoring should be provided:

• before a worker starts work to establish a baseline from which changes can be detected (unless the worker has participated in health monitoring within the previous two years and the results of the tests are available)

• periodically:

- every 12 months – standardised respiratory questionnaire and standardised respiratory

function test;

- every three years – a chest X-ray*, the standardised respiratory questionnaire, and

standardised respiratory function test

- more frequently on the advice of a registered medical practitioner with experience in health

monitoring

• exiting employment at the workplace - as per baseline if the routine 12-month tests have not been conducted, and it has been more than two years since the previous chest x-ray.

*Note: as stonemasons may work for multiple workplaces within a few years it is important to ask the

worker when they last participated in workplace health monitoring in order to avoid the potential for

excessive x-rays (e.g. baseline, periodic, exit).

Suitable medical practitioners

Health monitoring must be done or supervised by a doctor with experience in health monitoring. As an

example, any doctor who is a fellow of the Australasian Faculty of Occupational and Environmental

Medicine will have the necessary experience. A list of these practitioners can be found on the Royal

Australasian College of Physicians website.

These lists are not exhaustive and other doctors may have the necessary experience required to

conduct health monitoring for respirable crystalline silica. Workers must be consulted when selecting a

doctor and their preference considered if they request a particular doctor.

The following information should be supplied to the doctor:

• the name and address of the business

• the name and date of birth of the worker

• a description of any of the worker’s tasks that relate to crystalline silica

• how long the worker has been doing the work.

Providing the medical practitioner with any available air monitoring reports would assist them when

carrying out a health monitoring assessment.

The health monitoring report

The person conducting the business or undertaking must obtain a health monitoring report from the

doctor who carried out the health monitoring. The health monitoring report should only contain

23 Standards for the delivery of Spirometry for coal mine workers, sourced at

https://www.dnrme.qld.gov.au/__data/assets/pdf_file/0003/1274421/tsanz-spirometry-standards.pdf

https://www.safeworkaustralia.gov.au/doc/crystalline-silica-health-monitoring

https://www.racp.edu.au/about/college-structure/australasian-faculty-of-occupational-and-environmental-medicine/find-a-consultant

https://www.racp.edu.au/about/college-structure/australasian-faculty-of-occupational-and-environmental-medicine/find-a-consultant


information relating to the health monitoring commissioned by the PCBU as required under WHS

Regulation 2011.

The health monitoring report should include:

• name and date of birth of worker

• the doctor’s details (name and registration number)

• business details (name and address)

• the dates each aspect of health monitoring was undertaken

• details of test results that indicate whether or not the worker has been exposed to respirable crystalline silica

• the professional view regarding whether:

- the worker has contracted a disease, injury or illness as a result of work with crystalline silica

- any remedial measures that can be taken by the business

- the worker can continue in his/her current work

- medical counselling is required for the worker

Once the health monitoring report has been received from the doctor the person conducting the business or undertaking should act on the results and recommendations and advice contained in it.

Under sections 375 – 377 of the WHS Regulation a copy of the health monitoring report must be provided as soon as practicable after obtaining the report to:

• the worker, even if they leave employment at the workplace

• all other persons conducting a business or undertaking who have a duty to provide health monitoring for the worker, e.g. where labour hire is used

• the regulator,if the report contains:

- any advice that test results indicate the worker may have contracted a disease, injury or

illness as a result of carrying out the work using, handling, generating or storing hazardous

chemicals that triggered the requirement for health monitoring; or

- any recommendation that the person conducting the business or undertaking take remedial

measures, including whether the worker can continue to carry out the work using, handling,

generating or storing hazardous chemicals that triggered the requirement for health

monitoring.

It is recommended workers provide their general practitioner with a copy of the health monitoring report, and retain a personal copy along with any exposure history, particularly when the worker moves to other employment. This will assist an assessing medical practitioner conducting any further health monitoring to compare any previous results with new test and examination results.

The report must not be disclosed to any person without the worker’s written consent unless required under the WHS Regulation (e.g. sections 375–377 outlined above).

If the report indicates that a worker is experiencing adverse health effects or signs of illness as a result of exposure to respirable crystalline silica the control measures at the workplace must be reviewed and if necessary revised.

A person conducting a business or undertaking must ensure that health monitoring reports in relation to a worker carrying out work for the business or undertaking are kept as a confidential record: (a) identified as a record in relation to the worker; and (b) for at least 30 years after the record is made.

Treatment programs for adverse health effects should only be discussed between the worker and the medical practitioner and not included in the health monitoring report.

Workers experiencing adverse health effects or signs of illness as a result of exposure to respirable crystalline silica can access further information on health screening and workers’ compensation insurance at worksafe.qld.gov.au.

https://www.worksafe.qld.gov.au/silicosis


10. Information, training, instruction and supervision

WHS Act section 19(3)(f): A person conducting a business or undertaking must ensure, so far as is reasonably practicable, the provision of any information, training, instruction or supervision that is necessary to protect all persons from risks to their health and safety arising from work carried out as part of the conduct of the business or undertaking.

WHS Regulation section 39(2) and (3): A person conducting a business or undertaking must ensure that information, training and instruction provided to a worker is suitable and adequate having regard to:

- the nature of the work carried out by the worker;

- the nature of the risks associated with the work at the time of the information, training and instruction; and

- the control measures implemented.

The person must ensure, so far as is reasonably practicable, that the information, training and instruction provided under this regulation is provided in a way that is readily understandable by any person to whom it is provided.

A person conducting a business or undertaking must provide all workers involved in the fabrication,

installation, maintenance or removal of stone benchtops with information, and training on the risks from

respirable crystalline silica dust along with all other risks at the workplace.

The person conducting a business or undertaking must also consult, cooperate and coordinate with

other duty holders to ensure other workers that may be exposed to respirable crystalline silica through

these activities have received adequate training, information and instruction on the nature of the work

and the associated risks and controls.

The aim of this training is to educate workers on the hazards, risks, potential health impacts and

effective control mechanisms for respirable crystalline silica.

Training topics should include:

• Health hazards associated with respirable crystalline silica dust exposure (including signs and symptoms of silicosis)

• Operations and materials that can produce respirable crystalline silica dust (wet or dry) exposures

• Engineering controls and safe work practices used to protect workers

• The importance of proper equipment control and maintenance

• Housekeeping procedures

• Proper use of respirators and the respirator program, including the requirement for fit testing

• The details of the exposure control plan for respirable crystalline silica dust (if applicable)

• Personal hygiene procedures to reduce exposure

• Health monitoring requirements, including the purpose, description and benefits of health monitoring and outline information and support available to workers in the event of an adverse report

• How smoking can compound the risk of developing silicosis and other lung disease.

In addition, workers involved in fabrication and processing activities should be provided with more

general work health and safety information and training including:

• Effects of noise on their hearing and health

• Queensland’s work health and safety laws, including this code of practice and other hazards in the workplace

• Work health and safety policies, and relevant procedures at the workplace

• The risk management process

• Inspection and maintenance programs in place at the workplace


• How to access information such as manufacturer's instructions about hazards

• Emergency procedures, including staff with specific emergency roles and responsibilities.

The person conducting the business or undertaking must also consider other persons at the workplace

who may be exposed to respirable crystalline silica (e.g. office staff) and what training or information

they should be provided with on the risks and control measures in place to manage the risks of

respirable crystalline silica dust.

Information, training and instruction must be provided in such a way that it is easily understood and the

person conducting the business or undertaking should ensure any training is undertaken by a competent

person. A competent person includes a health and safety consultant, a trained person in-house, a

representative from a RPE manufacturer or supplier, an occupational hygienist or the holder of a

Certificate 4 in Work Health and Safety with expertise or experience in this area.

Records of training provided to workers should be kept, documenting who was trained, when and on

what.

11. Other hazards in the stone benchtop industry Persons conducting a business or undertaking and workers in the stone benchtop industry should also

consider their duties and obligations in relation to managing the risks presented by other hazards in the

industry:

See more information on how to:

• manage the risks associated with slips, trips and falls

• manage the health and safety risks associated with noise, refer to the Managing noise and preventing hearing loss at work Code of practice

• prevent eye and hand injuries

• manage the risks associated with mechanical lifting of slabs (e.g. via gantries, cranes or fork and jib devices)

• manage the health and safety risks of manual tasks, refer to the Hazardous Manual Tasks Code of Practice

• manage the risks of carbon monoxide in breathing air during air compressor use (e.g. petrol powered generators and equipment such as hand-held saws in the vicinity of PAPR) as air drawn into the respirator may be contaminated with carbon monoxide. PAPR with particulate filters are not effective against toxic exhaust and as such may present a serious risk to workers who feel protected.

Appendices Appendix 1 – Dictionary

Appendix 2 – Example respirable crystalline silica dust control plan

https://www.worksafe.qld.gov.au/injury-prevention-safety/workplace-hazards/slips-trips-and-falls

https://www.worksafe.qld.gov.au/__data/assets/pdf_file/0009/58176/Noise-preventing-hearing-loss-COP-2011.pdf

https://www.worksafe.qld.gov.au/__data/assets/pdf_file/0009/58176/Noise-preventing-hearing-loss-COP-2011.pdf

https://www.worksafe.qld.gov.au/forms-and-resources/newsletter/esafe-newsletters/esafe-editions/esafe/february-2017/preventing-eye-and-hand-injuries-in-the-manufacturing-industry

https://www.worksafe.qld.gov.au/construction/workplace-hazards/cranes

https://www.worksafe.qld.gov.au/__data/assets/pdf_file/0008/58166/Hazardous-manual-tasks-COP-2011.pdf

https://www.worksafe.qld.gov.au/__data/assets/pdf_file/0008/58166/Hazardous-manual-tasks-COP-2011.pdf

https://www.worksafe.qld.gov.au/injury-prevention-safety/hazardous-exposures/carbon-monoxide-in-breathing-air-during-air-compressor-use

Appendix 1 – Dictionary

Key terms

In the context of stone benchtop fabrication:

Air monitoring – is the process of collecting air samples to measure airborne contaminants to monitor workers’ exposure. The Safe Work Australia publication Workplace Exposure Standards for Airborne Contaminants provides best practice guidance on air monitoring, for example:

• Where monitoring of airborne contaminants is done to estimate a person’s exposure, the monitoring must be carried out in the breathing zone of the person (section 2.5)

• Breathing zone means a hemisphere of 300 mm radius extending in front of a person’s face and measured from the midpoint of an imaginary line joining the ears.

Crystalline silica – is the crystalline form of the abundant naturally occurring mineral silica or silicon dioxide (SiO2). It is present in almost all types of rocks, sand, clays, shales and gravel and in construction materials such as concrete, tiles and bricks.

Engineered stone – is an industrially manufactured product made up of crushed stone such as quartz, resins and other additives. Also called artificial or composite stone.

Fabrication – the process of transforming an unfinished stone slab into a specific end product for installation.

Finishing – work to “finish” a benchtop after it has been cut and includes workers who shape (see shaping) the stone and polish.

Machine operators (excluding saw operators) – workers who operate computer numerical control (CNC) routers or water jets.

Maintenance:

• generally, this will be referring to the maintenance of plant or equipment, including dust suppression controls; but also

• covers mechanical polishing or processing of existing stone benchtops.

Polishing – work to bevel edges and polish stone using powered hand tools.

Powered air purifying respirators (PAPR) are respirators that work by using a fan to draw or push air in through a filter. Different types include:

• half-face and full-face respirators have a tight seal that stops contaminants being inhaled. These respirators must be fit tested by a competent person using quantitative methods, and must be seal checked each time the worker uses it.

• Hood, helmet or head top respirators cover the breathing zone and use positive air pressure to stop contaminants being inhaled. Fit testing is not required.

Processing – carrying out mechanical operations on the stone slab in order to transform it to the end product for example cutting, polishing, trimming and grinding.

Quartz – the most abundant form of crystalline silica. The term quartz can be used in place of crystalline silica.

Respirable crystalline silica – crystalline silica particles which are small enough to penetrate deep into the lung. These particles are too small to be seen under normal lighting and the small particle size allows it to stay airborne for long periods of time.

Respirable dust – small solid particles that are less than 10 micrometres (µm) in diameter and can breathed deeply into the smallest, non-ciliated, airways of the lungs where oxygen and carbon dioxide are exchanged. Respirable particles are too small to be seen by the naked eye.

https://www.safeworkaustralia.gov.au/system/files/documents/1804/workplace-exposure-standards-airborne-contaminants-2018_0.pdf


Saw operators – workers who operate bridge saws or similar slab cutting equipment which uses a blade to cut stone.

Shaping – cutting holes in stone for taps, sinks or stovetops, joinery of stone pieces and edge grinding predominately using powered hand tools.

Slurry – a semi-liquid mixture, typically of fine particles of dust suspended in water.

Workplace exposure standard – The workplace exposure standard for respirable crystalline silica is currently 0.1 milligrams per cubic metre (mg/m3) Time Weighted Average (TWA)).

Appendix 2 – Example respirable crystalline silica dust control plan

Respirable crystalline silica dust control plan for fabricating or processing stone benchtops containing crystalline silica (quartz)

This template will help your business to document the controls used to manage the risks of exposure to respirable crystalline silica dust (wet or dry) during fabricating or processing of stone benchtops. You will need to add details regarding the safe systems of work and practices specific to your operations.

This respirable crystalline silica dust control plan was prepared on [__/__/__] and will be reviewed on [__/__/__].

Business details

Name

Address

Contact information (names and phone numbers)

Details of relevant stone products being used

Product Silica content (sourced from SDS or technical guide)

SDS reference details

Example

Product 1 [name]

Example

70 – 90 %


Controlling the risk of exposure to respirable crystalline silica

Place Task Control methods Respiratory protection

Work practices How controls are integrated into daily activities (daily/routine checks and clean-up (see sections 7.3 - 7.4.1))

Example only

Fabrication Workshop

Example only

Use of Bridge Saw

Example only

Wet suppression system using built in blade water feed nozzle.

Water spray/mist guards.

Example only PAPR

• Head-top/hood type

• Full/half face

Example only

Ensure:

• water supply to the saw is turned on and operational before starting the saw

• water is flowing to the cutting area prior to blade making contact with stone

• spray guards are in place before commencing work

• regular clean down of saw table and surrounding areas

Example only

Tool box talks, pre-start checks and daily cleaning of work areas. E.g. daily checks:

• water supply & flow

• safety and spray guards are in place

• Equipment (including guards) have no visible damage, no visible build up of residue, no blockages

• Work area is kept clean & slurry managed to prevent drying out

• PAPR (tight fitting) seal checked each time the respirator is worn

• PAPR filter check/replace o damaged, soiled or

breathing becomes difficult

o set hours of use, e.g. 30 days

• PAPR performance check o battery charge o filter alarm o flow rate test


Example only

Fabrication Workshop

Example only

Housekeeping - areas adjacent to a workshop, i.e. office and kitchen

Example only

Wet methods or H Class vacuum should be used to ensure all areas adjacent to fabrication/processing areas are kept free of dust.

Example only

Not required

Example only

• Wet wipe surfaces.

• Use a wet mop or H Class HEPA-filtered vacuum on floors.

• Use a H Class HEPA-filtered vacuum on surfaces that cannot be wet.

Example only

Example only

Fabrication workshop - maintenance

Example only

Plant & equipment maintenance

Example only

Clean any dust residue using wet methods or H Class vacuum before maintaining plant or equipment

Example only

Minimum P2 disposable when replacing filters and maintaining exhaust ventilation systems

Example only

• Wet wipe surfaces.

• Use a mop or vacuum on floors.

• Vacuum surfaces that cannot be wet.

Example only

Example only

On-site installation e.g. construction site

Example only

Handheld Angle Grinder (Dry)/ Manual Router for Edge Profiles

Example only

Minor modification/cut outs only.

Controlled dry processing (e.g. using LEV - shroud/hose attached to a H Class HEPA-filtered vacuum) may only be performed where it is not feasible to use wet methods.

Example only

Head-top type (including high impact visor, type 1 hard hat) PAPR

Example only

• SWMS to be prepared and given to the PC/PCBU.

• Check that shroud, hose and other dust extraction equipment is intact and properly installed.

• Ensure the H-class vacuum is maintained, inspected and tested in accordance with manufacturer’s instructions including that the H Class HEPA filter is correctly installed and operational.

• Clean up area - vacuum or wet-wipe surfaces that cannot be wet down

Example only


Respiratory protective equipment program

PCBUs whose workers wear respirators are required to develop and implement a respiratory protection program.

Powered Air Purifying Respirators (PAPR) Register

Worker/s Respirator details (e.g. make, model, size)

RPE supplied <date>

Fit test (tight fitting respirators) conducted by [initials] & [date]

Scheduled retest <date>

Training in use conducted by [initials] on [date]

Maintenance schedule (E.g. monthly/Annual as per manufacturer’s instructions)

Relevant documents E.g. ‘Clean shaven’ policy for tight fitting respirators; user manuals (use, care and maintenance))

Example only

Worker X

Example only

Safe-T-Air model T ½ half face tight fit PAPR size S

Example only

_ _/_ _/_ _ _ _

Example only

Worker Y (multi-user)

Example only

Safe-T Helmet and visor with belt pack PAPR


Details Carried out

(date & initials)

Actions arising from air monitoring report recommendations

Air monitoring - baseline, periodic & in response to specific triggers (see code section 6.2)

Example only

Baseline scheduled

• Carried out by [insert name of independent competent person] within 6 months

• Carried out by [insert name of independent competent person] 6 - 12 months



Example only

_ _/_ _/_ _ _ _

_ _/_ _/_ _ _ _

_ _/_ _/_ _ _ _

_ _/_ _/_ _ _ _

Example only

E.g. review of controls, health monitoring, communication of results

Example only

Annual air monitoring

• Carried out by [insert name of independent competent person]


Example only

_ _/_ _/_ _ _ _

_ _/_ _/_ _ _ _

Example only

Annual air monitoring

• In response to [insert specific trigger] (see code section 6.2)


Example only

_ _/_ _/_ _ _ _

Review and revision of controls (see code section 7.4.2)

Example only

Engineering controls will be reviewed on [insert date]

Example only

[insert date]

Example only

[insert date]

• Scheduled _ _/_ _/_ _ _ _ _ _/_ _/_ _ _ _

• In response to [insert specific trigger] _ _/_ _/_ _ _ _ _ _/_ _/_ _ _ _


Other items to consider in preparing the respirable crystalline silica dust control plan:

• training (see code section 10)

• health monitoring – at entry, periodically and at exit (unless previous results are available)

• consultation with workers on health and safety matters

• consultation, cooperation and coordination with other duty holders.

1

Attachment 3

Response to Taskforce consultation questions for occupational dust in the mining sector

1. Issues underlying increasing rates of silicosis

In Queensland’s mining sector, the re‐identification of silicosis and other MDLDs was due to a series of failures across the risk management of respiratory hazards. These failures were across preventative controls and monitoring, through to insufficient health surveillance and have been well documented by a number of reviews and inquiries conducted in Queensland1.

This has led to increased awareness in Queensland of the importance of the following actions:

leadership across employers, unions and the regulator;

awareness of respiratory hazards, the potential health harms and consequences to long‐term health and impact on society;

risk assessments and education on the hierarchy of controls and availability of controls to mitigate exposure;

monitoring of the hazard to evaluate effectiveness of controls and understand worker exposure;

effective individual and group health surveillance including appropriate screening tests and follow‐up investigation, standards for delivery, training and accreditation of medical practitioners and data capture of medical results;

reporting to the regulator of hazard monitoring results and disease diagnoses; and

quality assurance through audit of risk management systems, delivery of medical examinations and clinical decision‐making.

2. Ways to collect information to help understand the problem

In the short‐term, it is recommended that targeted advice is sought from groups across industry, government workplace health and safety regulators and unions to supplement consultation such as through the Taskforce’s consultation paper. A basic understanding of worker exposure, controls and disease prevalence will semi‐quantitatively identify the risk profile and industry sectors with and without mature systems in place.

A more substantive approach would require the collection of respiratory hazard monitoring and worker health screening data. In Queensland coal mining, dust monitoring results2 and medical assessment data3 must be reported to the government regulator.

Queensland’s coal mining industry has a mandatory fitness for work and health surveillance system, the Coal Mine Workers’ Health Scheme (CMWHS). While significant reforms have recently been made to the CMWHS to effectively detect MDLD early, it has been operating in some form since 1982. The Queensland resources regulator holds these medical records for over 211,000 individuals. While there are data quality issues from the legacy paper‐based system, the dataset provides a resource to assess the health of the coal mining workforce and how medical examinations are being delivered. While such a dataset is unlikely to be as immediately available for other industries like artificial stone benchtops, sourcing and evaluating medical records from workers in these industries would reveal key

1 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/medicals/dust‐lung‐disease/inquiries 2 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/hazards/dust/monitoring‐data 3 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/medicals/coal‐workers‐health/frequency

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learnings of the nature of disease, prevalence and the effectiveness of health surveillance and help to prevent future disease incidence or progression.

In addition to health surveillance data, the Queensland Government (DNRME) also holds over 83,000 personal respirable dust and respirable silica monitoring results back to 2000 for all Queensland’s coal mines. Diesel particulate data and inhalable dust data is also being submitted periodically to DNRME’s Mines Inspectorate, and currently up to 16,000 personal monitoring results have been reported. This allows for trending across the coal industry, and compliance action by the inspectorate. It has driven more rigorous controls from industry and ensured workers’ education regarding MDLD and exposure at work be more widely integrated. In the future it will provide important information regarding exposure profile and prevalence of disease, as well as the combined / additive effect of exposure to dust, silica, and diesel.

The main focus of reforms to the CMWHS were driven by an independent review of medical records undertaken by Monash University, in collaboration with the University of Illinois at Chicago. The ‘Monash review’ found systematic failures across the CMWHS and made 18 recommendations for improvement in its July 2016 report4.

3. Gaps in current protections for workers

Inevitably there are gaps in protections when workers develop workplace related disease. Work to better understand the problem (as discussed in the response to Question 2 below) will inform this. Following the re‐identification of MDLD in Queensland and reforms progressed by the Queensland Government in response, the key gaps in protections that have been observed (with likely similarities in other industries) include:

inappropriate, ineffective or absent controls across the hierarchy including respiratory protective equipment;

lack of risk awareness across organisational culture, education of workers and in safety and health management systems;

insufficient or inadequate monitoring of exposure; and

ineffective health surveillance.

4. Good practice and its causes

The Queensland Government has seen that good practice ultimately arises when there is universal acceptance of the risk and a shared objective to make effective changes. Given the incidence of disease that has occurred in Queensland, all stakeholders have worked together to address the issue which is a key factor to the success of the reforms to‐date across both disease prevention measures and changes to ensure disease is detected early.

Disease prevention

Mining, maintenance or processing activities can result in the release of dust particles into the air. Exposure to dust in mining and quarrying continues to be a major risk to the health of workers that must be managed. Queensland mining legislation requires operators to have a safety and health management system to ensure the level of risk to persons is as low as reasonably achievable. Risk is to be managed through a systematic process to:

identify, analyse and assess risk;

avoid or remove unacceptable risk;

implement risk control measures ;

monitor levels of risk and the adverse consequence of retained residual risk;

4 https://www.dnrme.qld.gov.au/__data/assets/pdf_file/0009/383940/monash‐qcwp‐final‐report‐2016.pdf

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investigate and analyse causes of serious accidents and incidents;

review effectiveness of risk control measures; and

mitigate the potential effects arising from retained residual risk.

The risk of workers being exposed to hazardous dust particles should be controlled using the hierarchy of controls. Controls should focus on higher‐order controls (i.e. elimination, substitution and isolation of the hazard) as the most effective means of treating the hazard. The Queensland Government (DNRME) provides a range of resources on dust controls on its website5 including the following standards and guidelines6:

Monitoring respirable dust in coal mines (Recognised Standard 14)

Underground respirable dust control in coal mines (Recognised Standard 15)

Guideline for management of respirable crystalline silica in Queensland mineral mines and quarries (QGL02).

Queensland mining legislation states that exposure to dust particles must not exceed exposure limits. Where exposure cannot be eliminated, all reasonable steps should be taken to minimise exposure to a level well below the exposure limit. Current exposure limits (8 hour time weighted average) for respirable coal and silica dust in Queensland coal and metalliferous mines and quarries are provided below (currently under review by Safe Work Australia):

coal dust (containing < 5% quartz) – 2.5 mg/m3

crystalline silica (including quartz, cristobalite, trydimite) – 0.1 mg/m3

All Queensland mines and quarries must provide respirable dust data to DNRME. Datasets are published online7 and are presented for similar exposure groups. These identify groups of workers who have the same general exposure to risk, for example because they perform similar tasks in similar locations or use the same types of materials or processes. Figure 1 shows an example of reported respirable silica levels at underground coal mines.

DNRME’s Safety in Mines Testing and Research Station (SIMTARS) now delivers training8 in the use of measuring devices to collect, interpret, evaluate and report on respirable dust exposure.

DNRME’s Mines Inspectorate also implements regular inspections of mines and quarry compliance with regulatory requirements for dust control and monitoring. Further detail is available in the Queensland Mines and Quarries Safety Performance and Health Reports9.

5 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/hazards/dust 6 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/legislation‐standards/recognised‐standards 7 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/hazards/dust/monitoring‐data 8 https://www.dnrme.qld.gov.au/simtars/training/ohs‐courses/dust‐monitoring 9 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/accidents‐incidents/safety‐performance

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Figure 1 ‐ Respirable crystalline silica levels at underground coal mines for the longwall workers Similar Exposure Group

Detecting disease early

As a result of the re‐identification of MDLD in Queensland, changes to health surveillance have been significant. The objective of health surveillance now clearly includes:

respiratory health screening for the early detection of disease;

ensuring workers who have abnormalities are referred for diagnosis and management; and

collecting, analysing and reporting on health surveillance data to monitor trends in lung disease.

Coal mining

The statutory CMWHS10 ensures all Queensland coal mine workers have mandatory health surveillance and fitness for work medical examinations at the following career stages, organised and paid for by their employer:

baseline examination on entering the industry;

on change of employer (medical examinations may not need repeating, i.e. chest X‐ray, if in‐date);

at least once every 5 years (or more frequently as decided by the supervising doctor); and

on permanent retirement from the industry (at the worker’s request).

The examinations are prescribed in an approved form that must be used, which applies to all underground and open‐cut workers, with the respiratory component now including:

detailed work history and respiratory questionnaire;

lung function testing by spirometry;

10 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/medicals/coal‐workers‐health

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chest X‐ray examination using the International Labour Organization (ILO) International Classification of Radiographs of Pneumoconioses (ILO Classification)11; and

referral of workers with abnormal screening results for high resolution computed tomography, laboratory lung function tests (i.e. diffusion capacity of the lungs for carbon monoxide) and review by a specialist respiratory physician in accordance with the CMWHS Clinical Pathway Guidelines12.

Register of approved doctors and medical providers

To deliver medical examinations under the CMWHS, doctors and medical providers must undertake additional training, be accredited against criteria to demonstrate adequate experience and qualifications and be approved by the department. Prior to assessing an applicant for approval and registration under the CMWHS, the Queensland Government (DNRME) requires annual accreditation through an external provider Quality Innovation Performance13.

Performing an examination without approval is an offence under the regulations.

In addition to be being fit and proper to carry out the function, the following criteria and training is required for each of the following medical providers participating in the CMWHS:

Doctors conducting and supervising examinations

- have general or specialist registration with the Australian Health Practitioner Regulation Agency (AHPRA);

- post‐graduate qualification in occupational medicine or occupational health or an international equivalent, as per the Australian Qualifications Framework (AQF); or

- have the following combination of qualifications and experience:

o have attained a Fellowship of the Royal Australian College of General Practitioners (FRACGP); or

o have attained a Fellowship of the Australian College of Rural and Remote Medicine (FACRRM); or

o hold Vocational General Practitioner with AHPRA specialist registration; and

o have conducted at least 24 assessments and/or specific advice for the purposes of health surveillance (in any industry) each year over the last 5 years; or

o have conducted at least 24 assessments and/or specific advice regarding fitness to work (in any industry) each year over the last 5 years; or

o been employed/contracted to provide occupational health advice to a company/companies for at least 12 months in the last 5 years.

- have the following experience specific to the coal mining industry:

o have conducted at least 24 medicals for coal mine workers (face‐to‐face assessments, such as for the CMWHS, or employer‐specific pre‐employment medicals) each year over the last 3 years; or

o over‐sighted at least 24 medical assessments each year for coal mine workers conducted by other health professionals each year over the last 3 years; or

11 http://www.ilo.org/safework/info/WCMS_108548/lang‐‐en/index.htm 12 https://www.dnrme.qld.gov.au/__data/assets/pdf_file/0005/1278563/cmwhs‐clinical‐pathways‐guideline.pdf 13 https://www.qip.com.au/standards/coal‐mine‐workers‐health‐scheme/

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o provided at least 24 injury/illness management services each year to coal mine workers (for example for workers compensation purposes) each year over the last 3 years.

- have visited within the last 3 years, an operating coal mine;

- have completed the relevant University of Illinois at Chicago DNRME physician training program14.

Doctors conducting examinations under a supervising doctor

- have general or specialist registration with AHPRA;

- have completed the relevant University of Illinois at Chicago DNRME physician training program15.

Radiologists providing ILO reports

- have registered as a specialist in radiology with AHPRA;

- have attained a Fellowship of the Royal Australian and New Zealand College of Radiologists (FRANZCR);

- successfully completed the National Institute for Occupational Safety and Health (NIOSH) B Reader Program16;

- maintain B Reader proficiency by both:

o completing a minimum of 8,000 ILO Classifications over 4 years; and

o successfully completing the NIOSH B Reader re‐test every 4 years

- comply with the RANZCR Standards of Practice for Diagnostic and Interventional Radiology;

- report chest X‐rays in accordance with the Guidelines for the Use of the ILO International Classification of Radiographs of Pneumoconioses17;

- comply with the Technical Requirements for B Readers18.

X‐ray imaging practice

- can demonstrate compliance with the Standards for Acquiring Digital Chest Radiography Images for Medical Surveillance of Queensland Coal Mine Workers19.

Spirometry (lung function) practice

- can demonstrate compliance with the Thoracic Society of Australia and New Zealand Standards for the Delivery of Spirometry for Coal Mine Workers20.

Spirometry training course

- can demonstrate compliance with the Thoracic Society of Australia and New Zealand Standards for Spirometry Training Courses21.

14 https://web.cvent.com/event/033d107d‐dd89‐4b54‐a161‐8d046f0dddb8/summary 15 https://web.cvent.com/event/033d107d‐dd89‐4b54‐a161‐8d046f0dddb8/summary 16 https://www.cdc.gov/niosh/topics/chestradiography/breader.html 17 https://www.ilo.org/global/topics/safety‐and‐health‐at‐work/resources‐library/publications/WCMS_168260/lang‐‐en/index.htm 18 https://www.dnrme.qld.gov.au/__data/assets/pdf_file/0019/1410814/b‐reader‐tech‐requirements.pdf 19 https://www.dnrme.qld.gov.au/__data/assets/pdf_file/0012/1276797/standards‐for‐digital‐chest‐radiography‐images‐for‐medical‐surveillance‐of‐queensland‐coal‐mine‐workers.pdf 20 https://www.dnrme.qld.gov.au/__data/assets/pdf_file/0003/1274421/tsanz‐spirometry‐standards.pdf 21 https://www.dnrme.qld.gov.au/__data/assets/pdf_file/0004/1274422/tsanz‐spirometry‐training‐standards.pdf

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Further information about requirements and the register of approved providers is available on the department’s website22.

Dual read process and Lungscreen Australia

The CMWHS has adopted the chest X‐ray ILO Classification reporting process used in the United States NIOSH Coal Workers’ Health Surveillance Program. This requires chest X‐rays to be independently (blind) read by at least two B Reader qualified specialists to generate a final ILO Classification report. If there is disagreement between the first two readers, the X‐ray may be read by up to 5 B Readers before the final report is issued.

In July 2016, the Queensland Government (DNRME) utilised US‐based B Readers managed by the University of Illinois at Chicago to provide this dual‐reading service to Queensland's coal mine workers. Sending X‐rays to US‐based readers was an interim solution until an Australian‐based service was established. On 1 March 2019, Lungscreen Australia replaced US‐based readers for all Queensland coal mine worker chest X‐rays. All chest X‐rays must now be sent to Lungscreen Australia as DNRME’s approved provider.

Lungscreen Australia classify coal mine worker chest X‐rays to the ILO Classification and will provide the final ILO report to the referring doctor and a copy of the image and report directly to DNRME. Other Australian B Readers registered with DNRME can undertake the first ILO Classification and provide this to Lungscreen Australia to complete the dual‐reading process (including any further reads to adjudicate disagreements).

Mineral mine and quarry workers

While not as prescriptive, health surveillance is also required for mineral mine and quarry workers where the operator determines it necessary after assessing the risk. This is largely based on dust monitoring results where the Guideline for management of respirable crystalline silica in Queensland mineral mines and quarries (QGL02) requires health surveillance where worker exposure is over 50 per cent of the exposure limit. QGL02 details the requirements for health surveillance examinations that mirror many of the standards used in the CMWHS. The Queensland Government is currently reviewing the health surveillance requirements for mineral mine and quarry workers to identify further improvements that may be required.

Health surveillance into retirement

Due to the long‐latency of disease, health surveillance must continue into retirement or after a worker leaves the mining or quarrying industry. The risk of disease developing is not eliminated when exposure ceases. The Queensland Government offers free respiratory health assessments for retired and former coal, mineral mine and quarry workers to the same standards provided to active miners under the CMWHS. Workers who have been employed for at least 3 years in mines or quarries, with at least 6 months in Queensland are eligible every 5 years for life (or more frequently on doctor advice). Assessments can be organised by contacting DNRME’s Health Surveillance Unit on (07) 3818 5420 or [email protected]. Any required travel and accommodation costs are also covered.

Reporting disease

Disease reporting to DNRME by doctors and mining operators is mandatory in Queensland. Diagnoses are included in health assessment reports for coal mine workers provided to DNRME by doctors. Operators must report certain diseases prescribed under the Coal Mining Safety and Health Regulation 2017 (Qld) and the Mining and Quarry Safety and Health Regulation 2017 (Qld).

The Queensland Workers’ Compensation Scheme regulator (OIR) also provides DNRME with details of accepted compensation claims for mine dust lung disease. Together with information from

22 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/medicals/register‐providers

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Queensland Health’s new Notifiable Dust Lung Disease Register, DNRME will have a more robust account of mine dust lung disease diagnoses in Queensland.

Quality assurance

To ensure reforms made to the CMWHS deliver effective early detection of disease, DNRME has initiated a series of clinical and administrative audits of health surveillance. In addition to addressing specific complaints, these audits include:

doctor compliance with the CMWHS Clinical Pathways Guideline to ensure workers with abnormal screening results have been appropriately followed‐up;

clinical review of spirometry tests undertaken by registered spirometry clinics;

review of X‐ray imaging and ILO reporting quality by registered practices and radiologists; and

review of administrative requirements by registered doctors and medical providers and DNRME’s contracted services (i.e. Lungscreen Australia, Quality Innovation Performance).

Communications

The Queensland Government has provided a range of resources for employers, operators, workers and medical practices on mine dust lung disease prevention, detection and support. Most notably these include:

Miners’ Health Matters23 online information portal with videos of medical specialists, workers and employers discussing important messages about mine dust lung diseases;

free pocketbook guides on health surveillance, dust protection and disease types that can be ordered online24;

toolbox talks, presentations, posters and FAQs for operators to use onsite25; and

suite on information and guidance on the department’s website26.

5. Poor practice and barriers preventing good practice

In the mining industry, the Queensland Government has observed that it can be challenging for some small businesses and contractors to implement occupational exposure monitoring and health surveillance. Generally, this is related to:

absence of structured systems that large organisations can accommodate;

less connection with information from industry bodies and the regulator;

changing work demands and related transitory workforce, and working across industries; and

cost.

6. People impacted and those to be involved in solutions

These issues have an obvious impact on workers affected by disease, but also their families, colleagues and the broader community. The Queensland Government has found that, in addressing mine dust lung disease, the full range of stakeholders must be involved in solutions including industry, workers, unions, contractors and labour hire providers, health and safety and workers’ compensation regulators, medical profession including the public health system, and academia.

23 https://www.dnrme.qld.gov.au/miners‐health‐matters 24 https://www.dnrme.qld.gov.au/business/mining/pocket‐guides‐order‐form 25https://www.vision6.com.au/em/message/email/view?a=23788&id=1193315&k=TT2wlP5UYSVsLr3H__fXdJnlBZZatSlmn118IrZPmTI 26 https://www.business.qld.gov.au/industries/mining‐energy‐water/resources/safety‐health/mining/medicals

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7. Examples of current work, projects or research

The Queensland Government continues to embed and sustain reforms in response to mine dust lung disease. In addition to reforms that have now become business as usual, additional projects and research that are being progressed include:

mobile health unit to improve accessibility to respiratory health checks to miners across regional Queensland expected to be available by late 2020;

delivery of a fully digital health records system for coal miners, employers and doctors to complete health assessments online and directly into the DNRME database by 2020;

prevalence study of coal mine dust lung disease in Queensland (tenders closed 22 October 2019);

review of computed tomography scanning of Queensland coal miners by a joint team of specialist radiologists from Australia and the United States expected to be completed in early 2020;

cancer and mortality study among Queensland coal miners to be delivered over the next 2 years in partnership with Monash University that has been co‐funded by the National Health and Medical Research Council;

a particulates research project in partnership with the University of Queensland into the health risks of exposure to particulates in the resources sector—project will establish the current state of knowledge and opportunities for further work in relation to monitoring, exposure, controls and health impacts in the resources sector;

stakeholder consultation by end of 2019 on the interaction between fitness for work and health surveillance outcomes and how doctors are engaged by mining companies; and

establishment of a Resources Medical Advisory Committee as a formal government body to provide ongoing expert medical advice to ensure the framework in place to protect the health of coal, mineral mine and quarry workers remains effective.

8. Other issues for Taskforce consideration

In considering solutions for lung disease prevention and health surveillance, differences between industries and diseases need to be taken into account. For example, more sensitive computed tomography scans and laboratory lung function tests (i.e. diffusion capacity for carbon monoxide) are a part of follow‐up investigations required for Queensland miners who have abnormalities on screening (i.e. from chest X‐ray or spirometry). However, these more sensitive tests may be appropriate for screening to detect early stages of acute or accelerated silicosis, particularly in young workers that are at risk over shorter periods of high exposure in the much smaller artificial stone benchtop industry.

Any consideration of applying these tests to 50,000 mine and quarry workers across regional Queensland as screening examinations would need to evaluate the benefit versus the cost (economically and radiation exposure), practicalities and accessibility. Mine and quarry workers are more likely to develop mine dust lung disease later in life after decades of exposure. Screening during this extended timeframe for a chronic disease that develops slowly, is more likely to detect disease early.

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Attachment 4

Queensland workers’ compensation entitlements (as at 1 July 2019)

Under the Queensland workers’ compensation scheme, workers with latent onset terminal conditions, including dust disease injuries are eligible for lump sum compensation up to $714,455. In addition, the worker’s dependants are eligible for lump sum compensation up to $95,590 and a further $12,745 for funeral expenses. If a deceased worker did not receive any lump sum compensation, dependants are eligible for maximum death entitlements of up to $688,350 plus weekly compensation in respect of dependant children.

Importantly, the Workers’ Compensation and Rehabilitation and Other Legislation Amendment Act 2019 which was passed on 22 October 2019 amends the definition of ‘terminal condition’ to remove the two‐year time period. This will ensure workers diagnosed with a terminal work‐related condition and a life expectancy greater than two years are not excluded from accessing this payment. This amendment applies for injuries that were sustained on or after 31 January 2015. This date aligns with the changes for deemed diseases for firefighters with certain cancers and ensures that this provision benefits workers with a terminal lung dust disease, including terminal silicosis.

Workers with non‐terminal dust diseases are entitled to compensation for lost time earnings and all reasonable medical expenses, including hospitalisation, surgery, rehabilitation, medication and medical aids.

In addition, workers with pneumoconiosis are eligible for an additional lump sum payment of up to

$127,440 based on the seriousness of their pneumoconiosis in accordance with section 128G of the

Workers’ Compensation and Rehabilitation Act 2003 (the Act). A worker does not need any permanent

impairment to access this lump sum compensation. A worker who experiences deterioration of their

pneumoconiosis can access a top up of their pneumoconiosis lump sum (section 128J of the Act).

Lost time earnings compensation is paid at 85% of the worker’s normal weekly earnings (NWE) or

100% under industrial agreement (whichever is the greater) for the first 6 months, then at 75% NWE

or 70% Queensland Ordinary Times Earnings (QOTE) for the next 1.5 years. After that, if their

permanent impairment is assessed as likely to be over 15% DPI, they receive 75% NWE or 70% QOTE

or otherwise at the single pension rate. Entitlement to lost time earnings ceases between 2 and 5

years.

In addition, the worker may be eligible for a caring allowance if the insurer is satisfied that the worker depends on day‐to‐day care for the fundamental activities of daily living; and the care is to be provided to the worker at the worker’s home on a voluntary basis by another person in relation to whom compensation is not payable.

A worker is eligible for lump sum compensation if they are assessed as having a permanent impairment. This payment may be up to a maximum of $1,362,865 (including lump sum compensation, additional lump sum compensation for greater than 30% degree of permanent impairment (DPI)(section 192(2)) and lump sum compensation for gratuitous care (section 193(6) of the Act) depending on the worker’s level of impairment.

Workers can also seek common law damages from negligent employers (workers under 20% must choose between a statutory lump sum and common law).

Guideline for assessing engineered stone workers exposed to silica

Purpose The Guideline for assessing engineered stone workers exposed to silica (the Guideline) documents the recommended process for assessing and managing workers exposed to respirable crystalline silica from fabricating and installing engineered stone. The objective is to provide guidance for medical practitioners identify silica-related respiratory disease in workers in the engineered stone industry and includes:

• the process for respiratory testing and chest radiology,

• follow-up investigations and referrals to appropriate medical specialists where initial screenings indicate abnormal results,

• follow-up health assessment, including recommendations for further review for workers exposed to respirable crystalline silica who do not currently have a diagnosis for silica-related disease.

The Guideline supports robust and consistent diagnoses for potential cases of silicosis and, particularly for potential cases of accelerated silicosis, ensure the diagnostic process is undertaken in a reasonable timeframe. The Guideline is based on current best practice for diagnosing and assessing occupational lung diseases as endorsed by Queensland’s medical profession.

Background Crystalline silica (quartz) is a common mineral found in most rocks, sands, and clays and products such as concrete, mortar, bricks, natural and composite stone benchtops. Workers involved in cutting, grinding, shaping and polishing engineered stone may be exposed to very fine respirable silica dust (respirable crystalline silica). Inhalation of respirable crystalline silica can cause diseases such as chronic bronchitis, emphysema, lung cancer, scleroderma and silicosis. Unlike natural stone such as granite, which typically contains only up to 30% silica, engineered stone can have silica concentrations of over 90%. Therefore, it is critical that appropriate controls are in place to eliminate or minimise a worker’s chance of inhaling respirable crystalline silica. Since issuing a safety alert on 18 September 2018, the Office of Industrial Relations has conducted compliance audits of all known Queensland businesses that fabricate engineered stone. These audits identified unsafe practices such as uncontrolled dry cutting, poor dust control measures, lack of respiratory protective equipment and a lack of appropriate health monitoring of workers. As a result of sub-standard work practices, many workers in the industry were exposed to unsafe levels of respirable crystalline silica. Workers who have

Guideline for engineered stone workers exposed to silica (Version 1) Page 2 of 11

fabricated or installed engineered stone prior to 2018 are considered to be at a high risk of occupational exposure to respirable crystalline silica. The Guideline was developed by the Office of Industrial Relations in collaboration with members of the Practitioner Guidance for Silicosis Reference Group (the Reference Group). The Reference Group was an outcome of the Silica Exposure Medical Roundtable held on 9 November 2018 which identified the need for guidance for medical practitioners to ensure robust diagnosis and consistent management of workers exposed to respirable crystalline silica from engineered stone. The Reference Group included key health specialists from the Thoracic Society of Australia and New Zealand, the Australasian Faculty of Occupational and Environmental Medicine, the Australian and New Zealand Society of Occupational Medicine, the Royal Australian and New Zealand College of Radiologists, and the Australian College of Rural and Remote Medicine. The Reference Group was also supported by the Australian Institute of Occupational Hygienists; Queensland Health, WorkCover Queensland, and the Department of Natural Resources, Mines and Energy.

Implementation The Guideline sets out the process for assessing the respiratory health of a worker with exposure to respirable crystalline silica from engineered stone for silica-related diseases, including referrals for additional testing or investigations which may be required depending on the individual worker’s circumstances. Medical Practitioners should use their clinical judgement to determine the most appropriate testing for the worker, including for example, if a potentially high-risk worker should be referred directly for a High Resolution CT scan (HRCT) and respiratory function testing in the first instance or referred directly to a respiratory physician for evaluation. The pathway chosen by the clinician should consider the worker’s history, presentation, accessibility to testing, and their unique circumstances. If a worker has sustained, or is suspected to have sustained, a work-related injury from working with engineered stone, they may be entitled to compensation. Please refer to worksafe.qld.gov.au or call WorkCover Queensland on (07) 3006 8365. From 1 July 2019, specialist medical practitioners who have diagnosed a worker with an occupational dust lung disease are also obligated to notify the Notifiable Dust Lung Disease Register administered by Queensland Health. Further information about this initiative is available at www.health.qld.gov.au/public-health/industry-environment/dust-lung-disease-register. The Guideline does not replace existing obligations to provide health monitoring to workers exposed to respirable crystalline silica from engineered stone under Queensland’s work health and safety laws. The Work Health and Safety Act 2011 places a duty on a person conducting a business or undertaking (usually the employer) to ensure, so far as is reasonably practicable, the health of workers is monitored to prevent illness or injury. The Work Health and Safety Regulation 2011 (the WHS Regulation) places specific duties on a person conducting a business or undertaking (e.g. the employer) to provide health monitoring to workers who use hazardous chemicals. Silica is a hazardous chemical which

http://www.health.qld.gov.au/public-health/industry-environment/dust-lung-disease-register

http://www.health.qld.gov.au/public-health/industry-environment/dust-lung-disease-register


requires health monitoring. The requirements in relation to health monitoring of workers exposed to respirable crystalline silica are contained in the WHS Regulation and associated codes of practice. The Guideline does not cover the treatment of workers diagnosed with silica-related diseases. Treating doctors should make clinical decisions about treatment based on the individual worker’s circumstances. Review period This Guideline is current as at 1 November 2019 and should be reviewed no less than every two years.

Guidelines for clinical assessment of workers fabricating and installing engineered stone

Medical Practitioner

Has the worker been exposed to

respirable crystalline silica from

engineered stone?(A)

Has the worker been

health screened previously?

Occupational Physician

• Complete Occupational

Exposure Questionnaire(E)

Is the worker high risk B)

• Fabricated or installed engineered

stone before 2018; or

• year dry cutting; or

• years wet cutting; or

• respiratory symptoms?

Recommended further

review: 1 – years(H)

• HRCT(F)

• Blood tests(G)

• Lung function testing(C)

• ILO CXR(D)

• Lung function testing(C)

• ILO CXR(D)

• HRCT(F)

• Blood tests(G)

Clinical assessment of possible

reason for appointment

NO

NO

Any ONE

ABNORMAL

ALL

NORMAL

ALL

NORMAL

Occupational Physician and/

or Respiratory Physician

• Complete required follow-

up investigations

Respiratory Physician

Recommended further

review: 1 year(H)

Does the worker have any

symptoms and/or changes in

results?

Further review at medical

practitioner s discretion(H)

NO

Any ONE

ABNORMAL

and/or

respiratory

symptoms

Not High

Risk

YES

YES

NO

Further reviews as

determined by the MDT

ALL NORMAL

Any ONE

ABNORMAL

YES

Multi-disciplinary team

review to determine

diagnosis

YES

High Risk


Supporting documentation for the Guideline A: Medical practitioners first reviewing a person potentially exposed to respirable

crystalline silica are to consider whether the person:

• is a worker,

• has fabricated or installed engineered stone, and

• has previously been health screened. Given the unique nature of engineered stone, it is recommended that workers be referred to an Occupational Physician for assessment of exposure, symptomology and lung functioning, noting that silica related disease may extend beyond the respiratory system (see note G), which is beyond the scope of the Guideline.

An Occupational Physician referred a worker, who is a current or former worker in the engineered stone industry, should refer to the additional guidance set out in (E) below.

B: Workers may be considered ‘high risk’ if the worker has any of the following risk factors:

• fabricated or installed engineered stone prior to 2018, or

• engaged in dry cutting engineered stone for one (1) year or more, or

• engaged in wet cutting for three (3) years or more, or

• respiratory symptoms. Consideration should also be given to the use and type of respiratory protective equipment (including whether fit testing and fit checking was undertaken), whether engineering controls and exhaust ventilation were in place, and the standard of work practices and housekeeping. An exposure history questionnaire will assist with determining whether there are any other environmental and occupational factors that are relevant (such as exposure to respirable crystalline silica in other industries for an extended period of time). In each instance, a clinician should use a low threshold for determining whether or not the worker should be considered ‘high risk’.

C: Lung function testing should include a standardised respiratory function test, including FEV1, FVC, FEV1/FVC. A test of diffusing capacity should be considered for high risk workers.

Spirometry The ‘thresholds’ for FEV1 and impairment are defined by the comparison of absolute

measurements to reference values, or longitudinal studies that show excessive declines in FEV1.

The thresholds below require further review by a respiratory physician where:

• absolute FEV1 is less than the Lower Limit of Normal (LLN), OR

• absolute FEV1 is less than 70% predicted from Global Lung Function Initiative (GLI) reference values—whichever is lower—assuming that age, height and race are entered correctly, OR

• longitudinal decline of FEV1 is greater than 15% change of predicted GLI over any period of time.

Abnormal screening of lung function requires an individualised approach.


Diffusing lung capacity (DLCO) DLCO results less than the LLN require further review by a respiratory physician. DLCO has been known to show disease in some workers even where spirometry results have been above the acceptable thresholds. Therefore, all high-risk workers should be considered for DLCO, including where there is an absence of respiratory symptoms. Workers with a change in DLCO of more than 15% between screenings should be referred for HRCT (see note F).

How respiratory testing should be performed

Respiratory function testing is to be performed in laboratories accredited by the Thoracic Society of Australia and New Zealand (TSANZ) and in accordance with international guidelines, except where unavailable due to geographic location of the worker. In such cases, the referring doctor is to ensure high-quality spirometry and diffusing capacity testing. Refer to https://www.thoracic.org.au/respiratorylaboratoryaccreditation/list-of-accredited-labs

D: A full size PA digital chest x-ray to be read in accordance with Guidelines for the use of the ILO International Classification of Radiographs of Pneumoconiosis (revised edition 2011) by a specialist radiologist with NIOSH B reader accreditation. All patients with a 0/0, 0/- or 0/1 CXR are classified as negative on initial radiological screening. Results are to be recorded in the patient’s file.

It must be noted that the chest radiograph is less sensitive than HRCT chest scanning in the diagnosis of silicosis and other occupational lung diseases (such as emphysema, asthma, fibrosis, lung cancer) and, as such, serves only as a primary screening tool to be used in conjunction with spirometry results, symptomology and exposure risk factors. It is possible for true positive cases of silicosis to be occult on chest radiographs which have an ILO classification of 0/0, 0/- or 0/1.

Further radiology in the form of HRCT chest must be considered where respiratory function testing, symptomology or exposure history is suggestive of need for further investigations, even if the ILO classification is less than 1/0 (see note F). The ILO classification itself should not be used to diagnose silicosis – further investigation with HRCT, correlation with exposure history and specialist review are required for this diagnosis. In addition, it must be noted that pleural disease and parenchymal disease such as emphysema and bronchitis are not subject to the ILO -/- classification system, and careful review of the additional findings reported on the ILO chest radiograph report (particularly in regard to emphysema, hyperinflation, bronchial wall thickening and other features of occupational lung disease) must be interpreted in conjunction with spirometry results and symptomology.

E: To assist with determining risk factors and referral pathways for workers, Occupational

Physicians should complete an occupational exposure history questionnaire. The Office of Industrial Relations is aware of questionnaires which may be suitable for this purpose, including questionnaires developed by Monash University and Curtin University.

https://www.thoracic.org.au/respiratorylaboratoryaccreditation/list-of-accredited-labs

https://www.thoracic.org.au/respiratorylaboratoryaccreditation/list-of-accredited-labs


Occupational Physicians should exercise their clinical judgement to determine which questionnaire is appropriate for their patient.

F: HRCT should be a non-contrast low dose HRCT scan including supine inspiratory and

supine expiratory acquisitions. Thin slice images must be available for interpretation, and it is recommended to reconstruct MIP images and coronal images. The HRCT study should be performed using as low a radiation dose as is practicable to produce diagnostic quality imaging and should be reported by a specialist radiologist with a B reader qualification and/or recognition and credentialing through Royal Australian and New Zealand College of Radiologists.

It is recommended that any diagnostic uncertainty on HRCT interpretation, or other aspects of disease diagnosis, be discussed by a multidisciplinary team approach on a case-by-case basis.

G: In the course of screening for silicosis, other diseases will be identified.

Blood tests may assist in reaching a diagnosis for these workers. The Thoracic Society of Australia and New Zealand specifies that blood tests (including but not limited to serum ACE, rheumatoid factor and an autoimmune screen) have a role in diagnosing silicosis after exposure to engineered stone processing and also form part of the assessment to exclude other diagnoses.

This cohort of workers is at higher than average population risk of developing emphysema, asthma, lung cancer, other pneumoconiosis, asbestos-related pleural and parenchymal lung disease and occupational bronchitis. Referral into appropriate treatment pathways will depend on the spirometry results, imaging findings and symptomology.

Additionally, other diseases may present on chest imaging which are unrelated to the occupational dust exposure, and include, but are not limited to, cardiac pathology, lung infection and inflammatory processes, skeletal disorders and identification of foreign bodies. Identification of these other diseases should prompt appropriate further investigation, history taking and treatment outside the Guideline.

H: The timeframes for further review are a recommendation only. Timeframes should be

adjusted based on the medical practitioner’s clinical judgement and consideration of a worker’s individual circumstances including their past and/or continued exposure to respirable crystalline silica. \Given the latency period of silicosis, it is recommended that workers are reviewed for no less than 10 years post the cessation of exposure.

ATTACHMENT A


Respiratory Function Examination

Standardised respiratory symptoms questionnaire

The below questionnaire must be administered in accordance with the instructions approved by the

British Medical Research Council’s Committee on Environment and Occupational Health.

The actual wording of each question must be used.

Tick the YES or NO column, or enter other codes as indicated in boxes.

When in doubt record as NO.

Preamble

I am going to ask you some questions, mainly about your chest. I’d like you to answer YES or NO

whenever possible.

QUESTIONS YES NO

Cough

1 Do you usually cough first thing in the morning in the winter?

2 Do you usually cough during the day – or at night – in the winter?

If ‘Yes’ to 1 or 2 ask the follow-up question

3 Do you cough like this on most days for as much as three months each year?

Phlegm

4 Do you usually bring up any phlegm from your chest first thing in the morning in winter?

5 Do you usually bring up any phlegm from your chest during the day – or night – in winter?

If ‘Yes’ to 4 or 5 ask the follow-up question

6 Do you bring up phlegm like this on most days for as much as three months each year?

Periods of cough and phlegm

7 In the past three years have you had a period of (increased) cough and phlegm lasting for three weeks or more?

If ‘Yes’ ask the follow-up question

8 Have you had more than one such period?

http://www.mrc.ac.uk/documents/pdf/questionnaire-on-respiratory-symptoms-1986-instructions-to-interviewers/

Respiratory Function Examination (Cont)


QUESTIONS YES NO

Breathlessness

If the worker is disabled from walking by any condition other than heart or lung disease, omit question 9 and enter YES here.

9 Are you troubled by shortness of breath when hurrying on level ground or walking up a slight hill?


10 Do you get short of breath walking with other people of your own age on level ground?


11 Do you have to stop for breathe when walking at your own pace on level ground?

Wheezing

12 Have you had attacks of wheezing or whistling in your chest at any time in the last 12 months?

13 Have you ever had attacks of shortness of breath with wheezing?


14 Is/was your breathing absolutely normal between attacks?

15 Have you at any time in the last 12 months been woken at night by an attack of shortness of breath?

Chest illnesses

16 During the past three years have you had any chest illness which has kept you from your usual activities for as much as a week?


17 Did you bring up more phlegm than usual in any of these illnesses?


18 Have you had more than one illness like this in the past three years?



QUESTIONS YES NO

Past illnesses

19 Have you ever had, or been told that you have had:

a) An injury affecting your chest?

b) Heart trouble?

c) Bronchitis?

d) Pneumonia?

e) Pleurisy?

f) Pulmonary tuberculosis?

g) Bronchial asthma?

h) Other chest trouble?

i) Hay fever?

Tobacco smoking

20 Do you smoke?

If ‘No’ ask the follow-up question

21 Have you ever smoked as much as one cigarette a day (or one cigar a week or 28 grams of tobacco a month) for as long as a year?

If ‘No’ to questions 20 and 21, omit remaining questions on smoking.

22 Do (did) you inhale the smoke?


23 Would you say you inhaled the smoke slightly (= 1), moderately (= 2), or deeply (= 3)?

24 How old were you when you started smoking regularly?

25 Do (did) you smoke manufactured cigarettes?


26 How many do (did) you usually smoke per day on weekdays?

27 How many per day at weekends?

28 Do (did) you usually smoke plain (= 1) or filter tip (= 2) cigarettes?

29 What brands do (did) you usually smoke?

30 Do (did) you smoke hand-rolled cigarettes?



QUESTIONS YES NO


31 How much tobacco do (did) you usually smoke per week in this way (in grams)?

32 Do (did) you put filters in these cigarettes?

33 Do (did) you smoke a pipe?


34 How much pipe tobacco do (did) you usually smoke per day (in grams)?

35 Do (did) you smoke small cigars?


36 How many of these do (did) you usually smoke per day?

37 Do (did) you smoke cigars?


38 How many of these do (did) you usually smoke per week?

For present smokers

39 Have you been cutting down your smoking over the past year?

For ex-smokers

40 When did you give up smoking altogether? (what year)

Comments /notes