6 . What is the best option ?
6 . What is the best option ?
6.1 Recommendation
Recommended options
On the basis of evidence review , impact analysis and stakeholder feedback , it is recommended that WHS ministers prohibit the use of all engineered stone , and implement a licensing scheme for certain work with engineered stone previously installed ( Option 1 ).
Each option was considered in the context of available evidence , consultation feedback , workshop outcomes , and an economic analysis .
Engineered stone workers are dramatically over-represented amongst workers diagnosed with silicosis – the vast majority of silicosis cases identified in recent years are in engineered stone workers , yet they make up only 2 % of those exposed to RCS at work . Exposure to RCS from engineered stone causes silicosis typified by a faster onset and more rapid progression than that caused by RCS from other sources , including natural stone . This has resulted in debilitating disease in young engineered stone workers , the majority of which are under 35 .
When engineered stone is processed , the dust generated contains higher levels of RCS , and that RCS has different physical and chemical properties that likely contribute to the more rapid and severe disease . There is also evidence to suggest that other components of engineered stone may contribute to the toxic effects of engineered stone dust , either alone or by exacerbating the effects of RCS .
There is no scientific evidence for a ‘ safe ’ threshold of crystalline silica content in engineered stone . Further , the risks of the materials used in place of crystalline silica in lower silica engineered stone is largely unknown . Given this , a precautionary approach is the most appropriate policy response .
In addition to the inherent properties of engineered stone and RCS , the re-emergence of silicosis in engineered stone workers is also due to a failure of compliance with existing WHS laws . Importers , manufacturers and suppliers in the engineered stone industry have not provided adequate information on the risks posed by engineered stone . There is little consistency in the information provided by importers , manufacturers and suppliers about the hazardous properties of their products . This is likely to cause confusion and uncertainty on the part of PCBUs about the nature and extent of the health and safety risks to their workers .
PCBUs have not done all that is reasonably practicable to eliminate or minimise those risks , and workers have not taken reasonable care for their own health and safety and that of others . Finally , there has been insufficient compliance and enforcement actions by WHS regulators to drive behaviour change in the sector .
The increased risks posed by RCS from engineered stone , increased rate of silicosis diagnosis amongst engineered stone workers , and the faster and more severe disease progression amongst this group , combined with a multi-faceted failure of this industry to comply with the model WHS laws means that continued work with engineered stone poses an unacceptable risk to workers . The use of all engineered stone should be prohibited .
6.2 Why are other options not preferred ?
A lower silica content engineered stone is not expected to result in improvements in compliance . The features of the sector that have contributed to the current levels of non-compliance remain – the sector is
DECISION REGULATION IMPACT STATEMENT Prohibition on the use of engineered stone Page 56 of 107