Dust Exposure Standards

Dust Exposure Standards – Respirable Crystalline Silica

DR ELIZABETH GIBSON reports on the CMPA’s response to questions posed in a recently released discussion paper.

The Australian Government Department, Safe Work Australia released a discussion paper on The Role of Chemical Exposure Standards in Work Health and Safety Laws (November 2015).

As detailed in the discussion paper, chemical exposure standards represent airborne concentrations of individual chemical substances in the worker’s breathing zone, which, according to current knowledge, should not cause adverse health effects nor cause undue discomfort to nearly all workers.

To help assess the options for a review of exposure standards and work health and safety laws, the Australian Government need to know more about the businesses who use these chemicals, including if they are aware of their legal obligations to:

• Meet mandatory exposure standards;
• If required—carry out ad hoc or routine air monitoring to ensure compliance with mandatory exposure standards; and
• Minimise chemical exposures, so far as is reasonably practicable.

It is also important to understand how exposure standards are being used in the broader context, for example where it is reasonably practicable to reduce exposure below the prescribed standard. This is particularly important where an exposure standard has not been updated for some time, and might not be adequate to protect the health and safety of workers.

The CMPA submission (submitted via email on 18 December 2015) responded to the questions posed by Safe Work Australia in the discussion paper as follows below.

Questions
1. DO YOU USE EXPOSURE STANDARDS IN YOUR WORKPLACE?
If yes—how do you use exposure standards? (e.g. to assess or control exposure, review controls etc.)
If yes—do you meet exposure standards or seek to minimise chemical exposures further?

• Exposure Standards (ES) are used for Respirable Crystalline Silica in quarries.
• ES are generally used to determine a workers exposure, the necessity of health surveillance and the effectiveness of controls.
• Within the quarry industry most activity can be undertaken without exposure being equal to or above the ES.
• Activity around the fixed plant such as inspection, cleaning or maintenance often relates to exposure being above the limit and workers are protected through the use of Personal Protective Equipment.

2. HOW MUCH DOES ENSURING COMPLIANCE WITH EXPOSURE STANDARDS COST YOUR BUSINESS (INCLUDING AIR MONITORING COSTS)? PLEASE PROVIDE EXAMPLES IF POSSIBLE.

• Monitoring is generally conducted annually in the early stages of a dust management program. Monitoring costs are based on number of samples taken and typically range between $2000 and $5000.
• Compliance cost include monitoring, training and education, health surveillance and physical dust control assets and their maintenance.

3. ARE YOU AWARE OF OTHER EXPOSURE OR ADVISORY STANDARDS IN AUSTRALIA OR OVERSEAS (E.G.DEVELOPED BY INTERNATIONAL BODIES OR COMPANIES)? DO YOU USE THEM? IF SO, PLEASE EXPLAIN HOW.

• Are aware but have no knowledge of them being used.

4. SHOULD AUSTRALIA’S EXPOSURE STANDARDS BE HEALTH-BASED OR PRAGMATIC? WHY?

• A mixture of both health-based and pragmaticexposure standards depending on the chemical and its application.
• Industries have different processes that may or may not ensure workers are not being exposed, therefore “as low as is reasonably practicable may be the preferred option”.
• This should not be an option when considering high risk substances such as lead, asbestos and so forth.

5. SHOULD EXPOSURE STANDARDS BE MANDATORY (E.G. PRESCRIBED BY LAW) OR ADVISORY? PLEASE PROVIDE REASONS.

• In light of the number of exposure standards in Australia and the requirement to conduct an RIS on each exposure standard being reviewed, it is doubted that it is possible to mandate all and conduct ongoing reviews so as to ensure current best practice and knowledge is captured.
• If chemicals were risk rated it may be more effective to mandate those of higher risk, with Safe Work Australia setting Australian Exposure Standards and leaving the remainder as advisory exposure standards utilising international resources such as ACGIH or SCOEL.

6. IF EXPOSURE STANDARDS BECAME ADVISORY, WOULD THIS CHANGE THE WAY YOU APPROACH THE MANAGEMENT OF RISKS? PLEASE PROVIDE REASONS.

• If advisory exposure standards were underpinned by having to “reduce risk as far as is reasonably practicable” the approach taken by a responsible employer would not differ.

7. DO YOU SUPPORT MANDATING A SMALLER NUMBER OF EXPOSURE STANDARDS AND KEEPING THEM UP TO DATE? PLEASE PROVIDE REASONS.

• As previously stated and based on the discussion paper it appears impossible to take any other course of action and still ensure that international best practice and knowledge is utlised within Australian industry.

8. DO YOU HAVE ANY VIEWS ON HOW TO PRIORITISE WHICH CHEMICALS SHOULD HAVE A MANDATORY EXPOSURE STANDARD?

• A risk based approach in consultation with industry and employee representation may be a suitable option.
• The assessment could take into account, known health effects, previous occupational illness data, methods of application, commonality of use.

9. WHAT PROCESS SHOULD BE USED TO REVIEW AND KEEP EXPOSURE STANDARDS UP TO DATE?

• Reviews should be scheduled well in advance so as stakeholders have adequate notice and time to prepare resources to ensure the effectiveness of the reviews.
• The schedule should prioritise chemicals that are in the higher risk rating category.
• Reviews must be conducted in consultation with all stakeholders.
• Reviews should take into account international best practice and knowledge.
• Reviews of mandated exposure standards must include a RIS.
• Reviews of advisory standards must take into account “as low as is reasonably practicable” for the particular industry using that chemical.

The CMPA is in the process of developing Guidelines for Dust Management in Quarries that will provide a template for a Dust Management Plan which can be tailored to individual quarry requirements. There will be a workshop and training given on this Guideline on Wednesday 16 March 2016. Please contact the Secretariat for further details or see the enclosed flyer.

 

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