Option 2: Specific mandatory requirements to reduce RCS exposures from work with engineered stone
Option 2 would introduce measures to require that PCBUs must not process, direct or allow workers to process engineered stone, unless the processing and housekeeping are controlled.
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This would mean any cutting, grinding, trimming, sanding, abrasive polishing and drilling of engineered stone using power tools or other mechanical plant must be controlled using one or more of the following systems:
- a water suppression (wet cutting) system
- an on-tool dust extraction system
- local exhaust ventilation system
- other effective controls e.g. separation of workers from processes that generate RCS.
In addition, all workers who process engineered stone must be provided with and wear respiratory protective equipment that is of suitable size and fit.[1]
PCBUs must also adopt good housekeeping practices, such as using low water pressure wet sweeping or an H class rated vacuum cleaner to clean floors, walls, and other surfaces, and have processes in place for management of RCS slurry.
Specific requirements for working with engineered stone could be further supported by licensing of fabricators (see option 3), and exposure and health monitoring requirements (see option 4B and 4C) to monitor the effectiveness of controls over time.
Option 2 provides for greater certainty over flexibility. We would expect higher costs, but also better safety outcomes and operational efficiencies for the regulator
In instances where PCBUs are not already using effective controls, mandatory requirements are expected to add additional costs. However, we do not currently have enough information on these costs. We are interested in understanding from submitters what potential costs would be and whether this could be prohibitive to entering or remaining in the market. We are also interested in whether submitters consider that creating mandatory requirements would be of benefit where there are PCBUs not controlling risks at the accepted standard.
Mandatory requirements clarify the requirements that must be met by duty holders and the regulator. We would expect that bad actors are recognised and are forced to adapt. We would also expect that this will be more operationally efficient for the regulator to enforce.
Questions about Option 2: Specific mandatory requirements to reduce RCS exposures from work with engineered stone
4. Do you support or oppose requiring specific requirements for working with engineered stone? Tell us why.
Additional questions for businesses
23. What do you expect the cost to your business to be to implement any outlined requirements, such as water suppression (wet cutting) systems or local exhaust ventilation systems?
24. How long would you or your business require to implement any outlined requirements?
25. Are there any controls on workplace practices that would not be practicable?
26. Do you believe that the controls you have in place are adequate without mandatory controls? Please explain.
How does option 2 compare with what you are already doing?
27. How does option 2 compare with what you are already doing?
Footnote
[1]These controls had either already been introduced or agreed to by all Australian state jurisdictions before the ban was imposed.