Understanding Changes to Crystalline Silica Exposure Standards: Implications for Business

My Grandad worked at Goliath Cement in Railton, Tasmania, for his entire career, alongside many of his neighbours and friends. Whilst he has got through that unscathed, over the past 40 years, my Grandad has watched his mates die around him as they lost their battles with silicosis and other health conditions caused by breathing in silica; the dangers of silica are real and catastrophic; and something we need to be actively managing to keep people safe.

On 1st September 2024, a new exposure standard for crystalline silica went live in Australia, along with extensive changes to the Model WHS Regulations. What does this mean? Any manufacturing, construction, mining, quarrying or tunnelling business has a new set of rules they must comply with.

What is crystalline silica?

Silica (silicon dioxide) is a naturally occurring and widely abundant mineral that forms the major component of most rocks and soils. It is everywhere. Silica can be crystalline (hazardous if breathed in) and non-crystalline (not hazardous to lungs).

Different rock and rock products contain differing amounts of crystalline silica, ranging from marble at around 2% to engineered stone with as high as 97% crystalline silica content.

What is silica dust?

Crystalline silica dust is where the danger is; the crystalline silica becomes hazardous if inhaled when stone or rock is "processed", such as crushing, cutting, drilling, grinding, sawing, polishing, quarrying and tunnelling.

We call the dust from processing crystalline silica Respirable Crystalline Silica (RCS). RCS is invisible to the human eye, 100 times smaller than a grain of sand, which is why silica is so dangerous; just because you can't see it doesn't mean it's not there.

Do you have crystalline silica hazards in your business?

Crystalline silica is most dangerous to health when dust is generated, airborne, and inhaled.

Examples of work that can generate RCS include:

• using power tools to cut, grind or polish natural and engineered stone countertops

• excavation, earth moving and drilling plant operations

• clay and stone processing machine operations

• paving and surfacing

• mining, quarrying, mineral ore treating processes

• mechanical screening

• road construction and tunnelling

• construction labouring and demolition

• brick, concrete or stone cutting, especially using dry methods

• abrasive blasting

• foundry casting

• angle grinding, jackhammering and chiselling of concrete or masonry

• hydraulic fracturing of gas and oil wells

• pottery making

• crushing, loading, hauling and dumping of rock

• clean-up activities such as sweeping dust

What you must do if you have crystalline silica risks in your business

Regardless of your business size, if you work with materials or products that contain more than 1% crystalline silica, you must put controls in place to reduce your people's exposure to RCS.

You must train all workers who may be exposed to RCS in an approved silica course. At the time of writing this, approved courses are not yet available in all states and territories, but I know this is something regulators are actively working to fix.

Under the Model WHS Regulations, you must implement the following controls as a minimum unless you can prove it is not practicable to do so:

i. the isolation of a person from dust exposure;

ii. a fully enclosed operator cabin fitted with a high-efficiency air filtration system;

iii. an effective wet dust suppression method;

iv. an effective on-tool extraction system;

v. an effective local exhaust ventilation system.

If there is a residual risk of RCS exposure after engineering controls are implemented, you must also provide your people with Respiratory Protection Equipment (RPE). The RPE must be fit-tested on your workers by a competent person, and you must give them training, instruction and supervision to ensure they use the RPE effectively. Your workers must follow these instructions, including being clean-shaven at the RPE seal point.

In addition, you must determine whether your people's RCS exposure is "high risk", as defined within the model WHS Regulations. This process is highly technical, and I, along with all current guidance materials, recommend that an occupational hygienist complete it. The occupational hygienist will use personal monitoring devices and other tools to measure the RCS hazards in the air and determine exposure risk using the national exposure standards.

What if you have "high-risk" RCS exposure levels in your business?

If, after your engineering and isolation controls are implemented, your air monitoring indicates there are still high-risk levels of RCS, you will need to implement a Silica Risk Control Plan that meets the requirements outlined in the Model WHS Regulations.

In addition, you will need to implement a health monitoring program for all workers who are exposed to high-risk levels of RCS.

I'm overwhelmed; what can I do?

I've only given you a high-level snapshot. The regulations in place for silica are extensive, and regulators across the country have developed guidance documents to support businesses in getting compliant.

Your starting point to understand what is expected of your business is Section 8 of the Model WHS Regulations in your state or territory. I also recommend checking out Safe Work Australia's Working with Crystalline Silica Substances - Guidance for PCBUs.

If you need support, jump on a discovery call with us, and we can explore how Safety Made Simple can help you meet your obligations.