Dust in the Extractive Industry

RON KERR, Honorary CEO and ELIZABETH GIBSON, General Manager of CMPA provides a copy of our Submission on Dust.

We as an association have tirelessly tried to bring this to our members attention from our very first issues of Sand & Stone through training resources and policy documents, submissions and presentations to our regulators. To that extent even a senate enquiry (2005).

The intent is to ensure that all people working on the sites are educated in dust management and aware of their obligations. I am concerned that the effort and outcomes are not being followed through by our regulators and bodies responsible for this. Example would be the failed outcome requirements of the senate enquiry. If one is to consider carefully the significance of dust and the impact from it and the awareness of the department of mines as far back as 1967 a document of which was sent out to all quarrying companies in Victoria, which all should read, you would feel that this should no longer be a community issue let alone a business issue. The reality is our industry and its regulation have ensured a reasonable high standard of compliance but when I move around the countryside and talk to those in the community the issue of dust is still at the forefront of many of their discussions.

Closer investigation though brings to question that there are other sectors or other business with like task that are not under the responsibility of work authorities and are slipping under the radar when it comes to compliance. Those that are complying and have in place the management systems and there monitoring evidence and have invested in the capital plant to supress and or collect the dust emissions are left at a financial disadvantage. The impact of this in the long run in the marketplace is that noncompliance is being rewarded with market share. At the same time the industry is drawn further into the vortex of the dust issue and the health liability within other sectors. There is no current factual evidence proving those sectors, if compliant to the current Workplace Exposure Standard of 0.1 mg/m3 respirable crystalline silica, that there have been health issues.

The following is the submission made on 30th April to Safe Work Australia on their proposal to lower the Workplace Exposure Standard for Respirable Crystalline Silica to 0.02 mg/m3.

Background

CMPA is very much aware of respirable crystalline silica dust (RCS) and thepotential adverse impact on employees’ health and has been instrumental in raising this issue and subsequently compliance among Members through:

• CMPA pre-employment, periodic and exit employment health assessments proforma;
• CMPA instructions for medical practitioners;
• Work Safely Reference Manual;
• Holding dust workshops 2016;
• Development of the CMPA Dust Management Guideline March 2016;
• Delivering dust training;
• Workshop on Dust Thursday 23 May 2019 at Quality Hotel, 265 Mickleham Road, Tullamarine; including presenters from EPA Victoria, WorkSafe Victoria, Monash University (Occupational Physician) etc. with a view to modernising the current CMPA Guideline.

A written and oral submission was made by CMPA to the Senate Community Affairs References Committee “Workplace Exposure to Toxic Dust” 29th September 2005. https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Community_Affairs/Completed_inquiries/2004-07/toxic_dust/index

The CMPA submission highlighted the need for consistent and systematic enforcement of Workplace Exposure Standards (WES) for Respirable Crystalline Silica (RCS). This was supported by submissions from other organisations. A recommendation from the Senate Committee was as follows:

Recommendation 7

5.87 That the Minister for Employment and Workplace Relations raise with the Workplace Relations Ministers’ Council the need to ensure enforcement of hazardous substance regulations and the need to enact nationally consistent standards in a more timely manner.

However, the Government’s response whilst in support of the recommendation 7 never addressed the issue of enforcement of WES for RCS specifically across Australia.

Other recommendations that were not implemented included:

Recommendation 2

3.60 That the Australian Safety and Compensation Council extend the surveillance of Australian Work-Based Respiratory Events (SABRE) program Australia-wide and that the program provide for mandatory reporting of occupational lung disease to improve the collection of data on dust-related disease.

Recommendation 7 and 2 are also supported by the Australian Institute of Occupational Hygienists (AIOH) Position Paper Respirable Crystalline Silica (December 2018).

Discussion: A case for no change in WES

It is understood that the community has seen recent upsetting pictures of young men in the benchtop processing/cutting industry with silicosis which may have led to a hasty reaction to propose ever-decreasing WES by various Governments nationally and internationally. However, the real issue is whether compliance (backed up by consistent enforcement from the Regulators) to the current WES of 0.1 mg/m3 was occurring at the time. More quantitative research needs to be undertaken to demonstrate that dust mitigation measures such as water suppression are indeed adequate protection from RCS.

It is acknowledged by the AIOH paper that there is “… an ever-increasing published literature on the topic (RCS), sometimes with opposing views…”. This suggests that there may be selective review of the literature to justify changing of WES. The AIOH goes on state “…recommends limiting worker exposure to RCS to as low as reasonably practicable (ALARP) to be at all times below an 8-hour time weighted average (TWA) guidance exposure value of 0.1 milligram (mg) respirable fraction in each cubic metre (m3) of air. In addition, a TWA value of 0.05 mg/m3 should be applied as an action level…”. The AIOH supports this position in that “current and historical evidence, including that from the Australian workforce, indicates that if enforced it appears to be protective of the incidences of silicosis…”.

Additionally, the proposal by Safe Work Australia does not take into consideration the lack of accurate measurement of the proposed very low WES for RCS.

Recommendations:

1. That the current WES for RCS of 0.1 mg/m3 with action level of 0.05 mg/m3 remain which is also supported by the AIOH.
2. That there is consistent and systematic enforcement of the current WES for RCS by Regulators with qualified and experienced staff across Australia for all affected industries.
3. If the current WES for RCS is to be lowered, then a staged introduction over 5 years should be considered for the quarry industry.
4. That there is a centralised Australian register for the reporting of RCS dust related lung disease.

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