The ACTU and its affiliates support the prohibition on the use of all engineered stone products, irrespective of the percentage of silica content, with an exemption to be provided for the handling, transport and any other activity associated with safely managing or removing engineered stone which is already in situ. This approach would be similar to the prohibition on the use of all forms of asbestos containing materials.
The prohibition on the use of all engineered stone products should remain in place until:
- It can be demonstrated by independently gathered, analysed and reviewed scientific evidence that higher order risk control measures will maintain exposures below the 50% action level of the WES for RCS.
- The establishment of a national exposure standard for dusts/particulates from the processing of engineered stone. Such an approach would be similar to that taken for wood dusts and would ensure coverage of constituents of the complex mixtures of engineered stone – e.g. all forms of crystalline silica, amorphous silica, pigments and resins bound to particulates.
- If a cut-off threshold for percentage of silica in the bulk product is to be established, this must be for all forms of silica (i.e. must include amorphous silica and cristobalite) that can produce respirable crystalline silica during processing, installation and removal.
- A robust, tripartite licensing regime is introduced that licenses both the importers, manufacturers and fabricators of engineered stone products. The regulatory regime should provide for significant penalties applying to the purchase, acquisition or installation of engineered stone products from non-licensed importers, manufacturers or fabricators of engineered stone products.
The issues of “legacy” engineered stone will need addressing – to ensure the safety of workers involved in the removal and remodelling of in situ engineered stone products. This should include an appropriate licensing scheme based upon the approach used for legacy asbestos containing materials.
