The majority of submissions supported a prohibition of some kind , however there was no clear preference for any of the three options . Only 16 submissions stated their lack of support for any of the prohibition options presented .
The main themes from the submissions were : �
Unions , professional organisations and peak health bodies supported Option 1 ( a prohibition on the use of all engineered stone ).
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Industry groups , while not necessarily supportive of a prohibition , acknowledged there is an issue with silicosis in engineered stone workers . They believe it can be addressed through regulation of high risk crystalline silica processes previously agreed by WHS ministers ( Option 5a in the Silica Decision RIS ).
Some industry groups highlighted specific evidence gaps they would like to see addressed before a decision can be made to prohibit the use of engineered stone . These included :
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Scientific evidence that crystalline silica in engineered stone creates a higher level of risk than crystalline silica in natural stone and other products .
Evidence that risks associated with engineered stone cannot be appropriately controlled by additional regulation of high risk crystalline silica processes .
The majority of stakeholders acknowledged there is not currently enough evidence to determine a threshold crystalline silica content at which engineered stone can be worked with safely ( for example , the 40 % threshold proposed in Options 2 and 3 ).
Around half of PCBUs working with or supplying engineered stone supported Option 3 , commenting that a licensing scheme for work with lower silica engineered stone would enhance compliance in the sector .
5.3 Information that informed the impact analysis
The consultation paper sought specific information from businesses working with engineered stone to inform the impact analysis . This included business size , workforce data , revenue and proportion of work carried out with engineered stone ( with varying silica content ) and natural stone products . The Agency thanks the many PCBUs working with engineered stone that provided this information in their submissions , and acknowledges the effort involved . The provided data highlight that the vast majority of these PCBUs work with both engineered stone and natural stone , which differs from the assumption made in our preliminary considerations of the impacts of a prohibition on use of engineered stone in the Silica Decision RIS .
5.4 Stakeholder views on options
5.4.1 The status quo
A small number of submissions ( 16 ) were not supportive of a prohibition but preferred to maintain the status quo – maintaining the current regulatory framework – including the recently agreed additional regulation of high-risk crystalline silica processes . This support was based on :
� a need for consistent regulatory approaches between engineered stone and other products with similar crystalline silica content ( i . e ., natural stone , concrete , brick and tiles )
� the significant investment already made by many PCBUs to protect their workers from the risks of respirable crystalline silica ( RCS ) by implementing appropriate control measures . This investment
DECISION REGULATION IMPACT STATEMENT Prohibition on the use of engineered stone Page 51 of 107