Safe Work Australia RIS on Engineered stone August 2023 | Page 53

has been in response to recent regulatory changes , including a reduction in the RCS workplace exposure standard and the prohibition on uncontrolled processing of engineered stone . The impact of these new measures should be evaluated before a prohibition is considered
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� the market ’ s recent response to concerns around RCS exposure through the development and supply of lower silica content engineered stone
a prohibition on all engineered stone would have significant impact on small and medium-sized enterprises , with flow on impacts to the wider economy
a lack of clarity around the cause of silicosis cases reported to date – the delay between exposure and diagnosis means it can be difficult to determine if illness is due to exposure to engineered stone , or from natural stone , and
� the impact of recent improved regulatory compliance will not be seen for some time .
5.4.2 A prohibition on the use of all engineered stone ( Option 1 )
There was significant support ( 29 submissions in total ) for a prohibition on the use of all engineered stone . Unions , professional organisations , peak health bodies , individual medical practitioners , WHS professionals and some government agencies supported this option , along with some PCBUs working with engineered stone .
Support for Option 1 was based on : � the high incidence and severity of silicosis in engineered stone workers which has resulted in these workers being over-represented as a proportion of all silicosis cases , and the likely continuation of high case numbers into the future due to the latency of disease
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� a potential link between the differing disease presentation in engineered stone workers ( faster onset and more rapid progression of disease ) and the differing properties of the dusts generated from engineered and natural stone . This includes differences in the physical properties of RCS and the potential additional risks from other components in the in engineered stone ( e . g . resin , pigments )
a lack of evidence to support a crystalline silica “ threshold ” content in engineered stone that poses a lower risk profile for those working with it
a lack of clarity around the impact of other components added to lower silica engineered stone , and the subsequent risk profile of working with this material
a history of those in the stone bench top industry not employing safe working methods and a lack of evidence regarding current compliance with WHS Regulations including meeting the current workplace exposure standard for RCS and controlling dust generation when processing engineered stone , and
the high rate of WHS non-compliance amongst PCBUs working with engineered stone as reported by jurisdictional regulators .
5.4.3 A prohibition on the use of engineered stone containing 40 % or more crystalline ( Options 2 and 3 )
Overall , 57 stakeholders supported a prohibition on the use of engineered stone containing 40 % or more crystalline silica ( Options 2 and 3 ). This included the majority of those PCBUs working with engineered stone who made a submission to this consultation , some industry groups , professional organisations , and government agencies .
DECISION REGULATION IMPACT STATEMENT Prohibition on the use of engineered stone Page 52 of 107