The ACTU and affiliated unions have been actively engaged with the National Dust Disease Taskforce (NDDT) since its inception. We therefore welcome any progress to ensure that workers, across a range of industries, will be afforded better protections from exposures to silica and other hazardous dusts.
We support the key strategy areas particularly the inclusion of a licensing system for businesses using engineered stone. But we are concerned that the proposed Priority Action Areas (PAA) provide a 3-year time frame for a licensing scheme and omits any commitment to implement a ban on the importation and use of high content silica engineered stone. The timeframe to establish a licensing scheme is too long, especially given actions already underway in Victoria.
The focus in the Draft Vision on prevention of disease is supported, but this is not accompanied by a parallel (and in the short and longer term more important) action on the prevention of exposures. For any sustainable change, prevention of exposures must be the approach taken at a national policy and regulatory level and at a workplace level.
In contrast to questions asked in the NDDT Second Consultation paper there is no reference to an exploration of the issues associated with a ban on the use of high silica content engineered stone or any industry development of safer substitutes. This is a significant oversight.
The ACTU acknowledges that actions have been taken but as previously submitted, the current regulatory framework does not provide adequate protection for workers – for example:
- there is no dust specific regulation or broad health and safety regulation that requires the hierarchy of control to be used by a PCBU/employer for ALL harmful dust exposures
- there is no proposed national Regulation to prevent exposures to respirable crystalline silica dust when using engineered stone
- the revised workplace exposure standard is a move in the right direction, but is not health based
- there is no National Code of Practice regarding general silica or other occupational dust exposures.
It is very important that any recommendations of the NDDT are cognizant of the principles of our health and safety regulatory framework. The objects of the WHS Acts in Section 3.1.g note that the objects of the Act include:
providing a framework for continuous improvement and progressively higher standards of work health.
The adoption of a ban on the importation and use of high silica content engineered stone supplemented by a licensing scheme is totally consistent with these objectives.