President's Message: Statement on Silicosis Prevention
In my previous Statement on Silicosis Prevention, I wrote of Australia's move towards an import ban on engineered stone products. Recently, all State and Territory Work Health & Safety Ministers reached the decision to ban these materials because of the unacceptable rates of silicosis. In some states, there are 1 in 4 stone workers with silicosis.
Following this decision, came the more technical question: - "If there is to be a ban on engineered stone products, at what concentration of crystalline silica will this prohibition apply?"
Occupational Hygienists have been trained in the hierarchy of control, and our profession is dedicated to anticipating, recognising, evaluating and managing risks to worker health. So eliminating this silica dust risk for this group of workers is not unreasonable to many of us.
Safe Work Australia presented three policy options in their consultation on prohibiting the use of engineered stone, and the AIOH response considered many factors in its response. These included the nature of the hazard, relevant exposure science, at-risk occupations, the main exposure scenarios, the compliance of the sector and the nature of its work. The rationale for a 40% cut-off for crystalline silica content in these manufactured stone products was also assessed.
Available literature and field exposure monitoring showed that even with wet methods, exposure to respirable crystalline silica (RCS) and respirable dust would be too high, and a "safe" percentage concentration cannot be determined. It concluded that a cut-off of 10% crystalline silica (by weight) could be expected to keep average exposures to RCS below the Workplace Exposure Standard (WES). But it warns that other components in engineered stone are also hazardous to health, including the amorphous silica that might be used to replace the crystalline silica content and the various resins and pigments used in all brands sold in Australia.
The AIOH submission argues for a strict precautionary approach.
We recommend the precautionary principle because in the increased likelihood of something causing irreversible harm, even if unsure of the extent of that harm, we should take comprehensive steps to protect worker health.
Therefore, the AIOH submission supports a prohibition on the use of all engineered stone irrespective of its crystalline silica content.
In simple terms, I see that there are 3 main considerations for hygienists when offering a view on the engineered stone ban: -
· disease rates in those working with engineered stone are excessive and warrant the highest order controls
· comprehensive product stewardship is critical, and reducing the silica content alone will not prevent reformulations of manufactured stone products which introduce other toxic dust emissions
· The AIOH has a duty to put forward the science which supports technically sound worker health policies
The AIOH External Affairs Committee includes some of our foremost experts on RCS, who have been working on silicosis prevention for many years. They have produced a substantive and scientifically sound argument that the evidence does not support the nomination of a silica content that will reduce exposure risk to So Far As Is Reasonably Practicable.
I acknowledge that all may not welcome this conclusion and that AIOH primarily focuses on worker health in this submission. Our submission does not explicitly address economic or social implications, including the effect on those businesses manufacturing engineered stone benchtops. We expect these issues to be addressed by others, such as industry groups and those with direct access to the tripartite decision-making process. Our role is to assess and communicate the exposure risk.
I encourage all members to listen to the webinar, read the summary or detailed submission on our Publications & Papers – submissions page and get to know the AIOH case for a ban on engineered stone.
Chances are this topic of conversation will come up for you one day, perhaps across a kitchen benchtop.
Tracey Bence
2023 AIOH President
|
|
|
|
|
|
|
