There is no evidence to demonstrate that prohibiting engineered stone with 40 % or more crystalline silica ( Options 2 and 3 ) will prevent all adverse health effects associated with exposure to dust from engineered stone .
Options 2 and 3 are expected to reduce worker risk compared to the base case , due to an assumed reduction in RCS exposure as a result of working with a lower silica product , albeit less than Option 1 . However , a prohibition that is limited to higher silica content engineered stone may lead to a perverse outcome whereby PCBUs , workers and the public assume that the permitted material is safe to work with when this has not yet been demonstrated . This may result in further non-compliances with the WHS laws . If Option 2 or 3 are preferred , it will be important for clear messaging that , in accordance with WHS laws , any work with engineered stone with < 40 % crystalline silica still requires strict controls in place to minimise worker exposure to any dust or other emissions generated .
The licensing framework for work with legacy products ( all options ) and the licensing framework for work with lower silica engineered stone may only have incremental benefits over the base case , as any permitted work with engineered stone will still be subject to the prohibition on uncontrolled processing and the additional requirements for high risk crystalline silica processes ( see base case ).
The licensing frameworks will provide visibility to regulators of those PCBUs undertaking licensed work , and assurance to consumers and workers that PCBUs are appropriately authorised to undertake the permitted work with engineered stone .
Some industry stakeholder submissions have suggested a benefit of the licensing framework for work with lower silica engineered stone would be increased compliance . It would also provide an ability to link licensing work with training and reporting requirements recently agreed to by WHS ministers ; and give WHS regulators the ability to cancel or suspend licences for PCBUs who do not meet safe work standards .
The administrative cost , for both PCBUs and governments , of managing and complying with a licence scheme may outweigh the benefits .
4.9 Breakeven analysis
Breakeven analysis estimates the number of illnesses and deaths that would need to be prevented by each prohibition option to offset the costs of the option .
4.9.1 Results of breakeven analysis
Table 16 shows the cost of each of the options over the appraisal period , and the total number of silicosis cases that are required to be prevented over this period to offset these costs . The number of cases of silicosis cases that would be needed to breakeven was determined by dividing the net present cost over the appraisal period by the $ 4.9 million expected value of life saved and illness avoided ( see B . 9.5 ). A detailed description of the approach used to undertake the breakeven analysis is provided in Appendix B .
DECISION REGULATION IMPACT STATEMENT Prohibition on the use of engineered stone Page 48 of 107