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AWU fears silica problem understated in latest Safe Work Australia statement

August 18, 2022

The AWU’s submission to Safe Work Australia’s consultation regulation impact statement (CRIS) on managing the risks associated with workplace silica dust says the union generally agrees with the process but fears the problem is still being understated.

The submission restates the AWU long-standing position that respirable crystalline silica (RCS) is a major hazard for many of its 70,000 national members, and not only those working with engineered stone but also in industries including tunnelling, quarrying, cement work, asphalt, mining, construction, glass and more.

AWU National Secretary Daniel Walton said the submission pointed to a survey of 373 AWU members that confirmed that current regulations are not adequate to protect workers and that employers are not doing enough.


“More than 80% of those surveyed reported exposure to silica or other dust on their worksite – from stone, cement, cement products, roads, rocks or other sources – at least some of the time,” Mr Walton said. “And nearly 75% reported frequent dust exposure (once a week or more).

“Only 40% said their site was properly ventilated to avoid dust build-up, only 23% reporting the use of water suppression of dust, and 19% were not provided with an appropriate face mask, and where they were, only half were fit-tested.

“Alarmingly, 12% of respondents were aware of silicosis cases in their workplace, and 10.5% were aware of at least one other respiratory or lung disease in their workplace.”

The AWU submission contains graphic accounts from AWU members whose lives, and the lives of those around them, have been destroyed by exposure to silica dust.

And it points to a recent Curtin University study that estimates 83,000 to 103,000 cases of silicosis are likely to eventuate based on 2016 exposures.

“The Curtin report also says 10,300 cases of lung cancer are now likely to occur due to workers’ exposure to silica dust,” Mr Walton said.

“This shows the shocking price being paid by workers, their families and the nation due to a long-term lack of action by business and government.”

The submission says the AWU has conducted multiple visits across a number of work sites with trained officials using high-end dust monitoring technology to measure respirable dust particles.


“On all those sites, recorded measures of aerosols (including RCS) were well in excess of workplace exposure standard,” Mr Walton said.

The AWU submission backs three of the original six suggestions put forward by Safe Work Australia, including:

  • Awareness and behaviour change initiatives targeting workers, persons conducting a business or undertaking (PCBUs) and other duty holders in the construction, manufacturing, demolition tunnelling, quarrying, and mining industries.
  • A national licensing framework for PCBUs working with engineered stone, which would include requirements to report health and air-monitoring data to regulators, and require licensees to undertake a risk assessment and develop and implement a control plan.
  • Additional regulation of defined high-risk crystalline silica processes, with additional requirements for all PCBUs undertaking such work including risk assessments, control plans and the reporting of air and health-monitoring data to regulators.

The submission also provides suggestions to improve the CRIS outcome, in response to specific Work Safe Australia questions. These include:

  • Allowing increased functions for WHS entry permit holders to monitor suspected contraventions of the WHS Act, as unions can play a big role in identifying suspected safety breaches and protecting workers, particularly when it comes to identifying microscopic dust including RCS.
  • Increased penalties for PCBU non-compliance with the WHS Act and Regulations, as workers will not be adequately protected unless there are clear and severe penalties for breaches.
  • High-Resolution Computed Tomography, as lung-function tests and chest X-rays are now firmly considered insufficient as monitoring and screening tools.
  • Frequent monitoring of airborne contaminants, as existing monitoring laws are not being used in a way that can provide meaningful health outcomes for workers.


Mr Walton said these suggestions, and the options proposed by the CRIS, should be the bare minimum under the Safe Work changes.

“If considerable effort is not made to provide legislative protections in all industries, then we will see a tsunami of silicosis in the coming years.”

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