Many submissions predicated their support for either Option 2 or 3 on the belief that lower silica engineered stone can be worked with safely . This was based on :
� the availability of engineered stone products with less than 40 % crystalline silica
� �
� a perceived lower risk of RCS exposure from processing engineered stone with lower silica
an assumption that RCS levels generated from processing lower silica engineered stone would be comparable to that generated from natural products ( e . g . granite and sandstone ) with a similar silica content , and can therefore be worked with safely
a lack of evidence that dust generated from processing engineered stone , while qualitatively different from natural stone dust , causes more harm , and
� these options presenting less overall disruption to the market and industry . 5.4.3.1 Setting a crystalline silica content threshold
Many submissions commented on whether 40 % silica content was the appropriate demarcation point between lower and higher risk engineered stone products . The majority of submissions agreed there is insufficient evidence to support this percentage .
WorkSafe Victoria submitted that the 40 % threshold used to define engineered stone in the Victorian Occupational Health and Safety ( OHS ) Regulations is not health based and may not be the most appropriate percentage to define a prohibition . The definition of engineered stone used for their licensing scheme , ( where a PCBU must be licensed to work with engineered stone with 40 % or more crystalline silica content ), was designed to capture the majority of engineered stone available in the market at that time .
While the AIOH supports a complete prohibition on work with all engineered stone ; their submission outlined that , if this was not agreed and a threshold was to be set , work with engineered stone should only be permitted where the product has a silica content below 10 %. This was based on an analysis of reported RCS exposure data from Australian workplaces processing engineered stone and evidence in international studies . The Lung Foundation Australia , the Public Health Association of Australia , the Royal Australian College of Physicians , and Cancer Council Australia submissions were consistent with that of the AIOH – supporting a complete prohibition but if a threshold was to be set , it should be silica content below 10 %.
5.4.4 A licensing framework for working with lower silica engineered stone ( Option 3 )
Of the 57 submissions who supported continued work with lower silica engineered stone , 38 submissions supported a licensing framework for work with lower silica engineered stone , as outlined in Option 3 . Approximately 80 % of those submissions were from PCBUs working with engineered stone or individual stonemasons , and the remainder were from industry groups , professional organisations and government agencies . Support for licensing was based on :
� improved regulator visibility of PCBUs working with engineered stone
�
� the ability to link licensing with training and reporting requirements recently agreed by WHS ministers for all high risk silica work ( Option 5a )
strengthening regulatory controls through the ability to cancel or suspend licences for PCBUs who do not meet safe work standards , and
DECISION REGULATION IMPACT STATEMENT Prohibition on the use of engineered stone Page 53 of 107