Notification of air monitoring results – respirable crystalline silica (RCS)

What is processing?

Processing in relation to CSS is defined in the WHS Regulations as:

• the use of power tools or mechanical plant to carry out an activity involving the crushing, cutting, grinding, trimming, sanding, abrasive polishing or drilling of a CSS
• the use of roadheaders involving material that is a CSS
• quarrying involving material that is a CSS
• mechanical screening involving material that is a CSS
• tunnelling involving material that is a CSS, or
• a process that exposes, or is reasonably likely to expose, a person to RCS during manufacture or handling of a CSS (for example cleaning and maintenance processes such as sweeping that may disturb settled RCS).¹

This definition is designed to capture all activity with a CSS that has the potential to generate and expose workers or others at the workplace to respirable crystalline silica (RCS).

Information on identifying processing of a CSS can be found in the Safe Work Australia Working with crystalline silica substances: Guidance for PCBUs.

When processing is controlled

Regulation 529B states that processing of CSS is controlled if control measures to eliminate or minimise risks arising from the processing are implemented so far as is reasonably practicable, and at least one of the following measures are used during the processing:

• the isolation of a person from dust exposure
• a fully enclosed operator cabin fitted with a high efficiency air filtration system
• an effective wet dust suppression method
• an effective on-tool extraction system, and
• an effective local exhaust ventilation system.

If a person is still at risk of being exposed to respirable crystalline silica (RCS) after one or more of the measures above are used, the person must be provided with respiratory protective equipment (RPE) and must wear the RPE while the work is carried out, in order for the processing to be controlled.

If the measures identified above are not reasonably practicable, the processing of a CSS is controlled if a person who is at risk of being exposed to RCS during the processing is provided with RPE and wears the RPE correctly while work is being carried out.²

RPE for the purpose of the regulations means personal protective equipment (PPE) that is designed to prevent a person wearing the equipment from inhaling airborne contaminants, and complies with Australian standards:

• AS/NZS 1716:2012 (Respiratory protective devices), and
• AS/NZS 1715:2009 (Selection, use and maintenance of respiratory protective equipment).

Identifying and managing risks from RCS

If the PCBU has identified that processing of a CSS is carried out at the workplace, the PCBU must assess whether the processing is high risk and document this in writing. If the PCBU is unable to determine if the processing is high risk, it must be assumed that it is high risk until the person is able to determine otherwise, through a subsequent assessment.

High risk processing of crystalline silica substances

High risk in relation to the processing of CSS is defined in the WHS Regulations as the processing of a CSS that is reasonably likely to result in a risk to the health of a person at the workplace.

When determining whether the processing of a CSS is high risk, and therefore reasonably likely to result in a risk to the health of a person at the workplace, a PCBU must have regard to the following:

1. the specific processing that will be undertaken,
2. the form or forms of crystalline silica present in the CSS
3. the proportion of crystalline silica contained in the CSS, determined as a weight/weight (w/w) concentration,
4. the hazards associated with the work, including the likely frequency and duration that a person will be exposed to RCS,
5. whether the airborne concentration of RCS that is present at the workplace is reasonably likely to exceed half the workplace exposure standard (WES³),
6. any relevant air and health monitoring previously undertaken at the workplace, and any previous incidents, illnesses or diseases associated with exposure to respirable crystalline silica at the workplace.

There is no one factor that can determine the outcome of an assessment. When assessing whether the processing of a CSS is high risk PCBUs must consider all of these factors. This is because there are instances where two identical CSS processes may produce different assessment outcomes.

Additional requirements if processing of a CSS is high risk

If it has been determined that the processing or CSS is high risk, there are additional requirements for PCBUs who are carrying out processing of CSS including:

• developing a silica risk control plan
• provide crystalline silica training to any worker the PCBU reasonably believes may be involved in the processing of a CSS that is high risk or be at risk of exposure
• undertake air monitoring for RCS in accordance with regulation 50
• provide health monitoring for all workers carrying out the processing of a CSS

Safe Work Australia has published guidance to assist PCBUs to understand and meet the additional requirements for processing a CSS that is high risk in the Working with crystalline silica substances: Guidance for PCBUs.

Air monitoring in relation to processing of CSS that is high risk

Regulation 50 of the WHS Regulations requires a PCBU to undertake air monitoring to determine the airborne concentration of a substance or mixture which has a WES if:

• you are uncertain on reasonable grounds whether or not the airborne concentration of RCS at the workplace exceeds the WES for RCS, or
• monitoring is necessary to determine whether there is a risk to health from RCS at the workplace.

This means that, in addition to any air monitoring necessary to identify whether the processing of a CSS is high risk, PCBUs may also need to undertake additional air monitoring to meet the obligations of regulation 50.

Air monitoring to determine a worker’s exposure involves measuring the level of RCS in the breathing zone of workers using a personal sampler during their usual shift activities, including routine breaks.

The WHS Regulations require PCBUs to keep the results of air monitoring for 30 years. PCBUs must also ensure that the records are readily accessible to people at the workplace who may be exposed to RCS. Any previous air monitoring results in relation to processing of a CSS that is high risk must also be taken into consideration as part of the assessment to determine if the processing of a CSS is high risk, if the air monitoring was relevant and was conducted prior to undertaking the assessment.

Reporting airborne concentration of RCS above the WES

The WES for respirable crystalline silica in the Comcare jurisdiction is a time weighted average (TWA) of 0.05 mg/m³.

If air monitoring for RCS has been undertaken for processing of a CSS that is high risk and the results show the airborne concentration of RCS has exceeded the WES for RCS, the PCBU must report the results to the WHS regulator.

The results must be reported even if workers are wearing appropriate and correctly fitted respiratory protective equipment (RPE), which provides protection from exposure to RCS.

The results must be reported to the regulator as soon as reasonably practicable and no more than 14 days from the date that the air monitoring result was provided to the PCBU.

The air monitoring results must be reported to the WHS regulator in a form (PDF, 265.2 KB) approved by the WHS regulator.

Health monitoring

Division 6 of Part 7.1 of the WHS Regulations requires PCBUs to provide health monitoring to any worker carrying out ongoing work at a workplace using, handling, generating or storing hazardous chemicals and there is a significant risk to the worker's health because of exposure to a hazardous chemical.

This means that where there is significant risk to a worker's health arising from ongoing exposure to RCS, whilst undertaking processing of a CSS that is high risk, the worker must be provided with health monitoring.

Depending on the circumstances, health monitoring may not only be required for workers who are directly generating RCS by regularly undertaking processing of a CSS that is high risk but also for workers who may regularly be in the vicinity of RCS or in contact with RCS in other ways such as through cleaning work areas or equipment.

PCBUs have a responsibility to determine if there is a ‘significant risk’ to determine whether they need to undertake health monitoring. The level of risk depends on the frequency, duration and level of exposure to airborne RCS.

PCBUs should start health monitoring at the time a worker is first employed or when they first start work involving high risk processing of a CSS and are at significant risk of exposure to RCS. This is so any changes to the worker’s health can be detected as early as possible. If workers have been carrying out high risk processing of a CSS and have not been provided health monitoring, the PCBU must organise it as soon as possible.

When workers have completed the health monitoring, PCBUs must take reasonable steps to obtain the health monitoring report from the registered medical practitioner who carried out or supervised the monitoring as soon as reasonably practicable after the monitoring is carried out.³

The PCBU must give a copy of the health monitoring report to the worker as soon as practicable after the person obtains the report.⁴

PCBUs must also provide a copy of the health monitoring report to Comcare as soon as reasonably practicable after obtaining the report if the report contains:

• information that a worker may have contracted a disease, injury, or illness as a result of carrying out work using, handling, generating, or storing silica, or
• recommendations that the PCBU take remedial measures (such as stopping a worker from continuing to do particular work or implementing additional controls).

Health monitoring reports must be kept confidential and for at least 30 years.

More information

For more information about health monitoring go to Health monitoring

To submit a health monitoring report, complete the Health Monitoring Report Form (PDF, 126.3 KB), attaching a copy of the health monitoring report and email to notify@comcare.gov.au or fax 1300 305 916.

Footnotes

1. WHS Regulations 529A.

2. WHS Regulations, 529B(2).

3. WHS Regulations 374.

4. WHS Regulations 375.