The ACTU recommends that a policy framework be developed, like that used for review of Workplace Exposure Standards. The methodology could then be applied to individual substances.
The current regulatory framework for all carcinogens needs reviewing and aligning with the higher order control measures such as elimination and substitution.
The ACTU strongly supports the application of the principle of “as low as reasonably possible” for the control of exposures to Non-Threshold Genotoxic Carcinogens. As by definition, there is no safe level of exposure, the highest level of controls must be applied, i.e. elimination or substitution.
In the interim, as these Non-Threshold Genotoxic Carcinogens will no longer be assigned a workplace exposure standard, all the carcinogens referred to in the consultation paper must be added to a restricted carcinogens list.