Construction dust is created when working with materials such as cutting timber studs, chasing or cutting into concrete, mixing plasterboard mortar or during demolition work.
The dust usually contains:
- Silica, the most abundant mineral on earth found in large amounts in sand, sandstone, granite and quartz
- Non-silica like gypsum, cement, limestone and marble, or
- Wood such as softwood, hardwood and wood-based products such as MDF and chipboard.
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RCS SILICA | NEW SILICA CODE | CONTROL MEASURES | RISK ASSESSMENT | SWMS | SDS | RPE | FIT TESTING | FIT CHECKING | HEALTH MONITORING | AIR MONITORING | TRAINING COURSE
Respirable crystalline silica (RCS)
While breathing in any quantity of dust is a health risk, silica dust is particularly harmful because the particles are small enough to be inhaled into the lungs. When inhaled into the lungs it can cause scarring and irreparable damage that over time leads to respiratory diseases such as silicosis, lung cancer and even renal failure.
Respirable crystalline silica (RCS) is a hazardous substance, which requires a risk assessment to identify whether it poses a significant risk in your workplace. There is no recognised safe level of exposure to RCS but you mustn't exceed the standard of 0.05mg/m3 in an eight-hour work day.
You must monitor the air and workers' health to determine levels of exposure and assess the risks for anyone performing ongoing work with silica containing products.
Master Builders gets lots of questions about wearing respirable protective equipment, for example tight-fitting respirators and the legal requirement to fit test individual workers.
New Code of Practice for silica
The Managing respirable crystalline silica dust exposure in construction and manufacturing of construction elements Code of Practice 2022 (the Code) is an approved code of practice under the Work Health and Safety Act 2011 (WHS Act).
The Code is a practical guide on how to meet your legislative obligations to manage the risk of exposure to respirable crystalline silica (RCS) in construction work, and the manufacturing of construction elements.
The Code applies to all construction work and manufacturing of construction elements, and workplaces covered by the WHS Act where this work is undertaken.
People conducting business or undertaking (PCBUs) have a duty to, so far as is reasonably practicable, the health and safety of each worker while at work.
Complying with the Code
PCBUs must adopt a risk management process, including eliminating exposure to RCS, so far as is reasonably practicable, or if it is not reasonably practicable to eliminate exposure to RCS, by minimising it so far as is reasonably practicable.
To meet their health and safety obligations, PCBUs need to:
- Identify RCS hazards - see Sections 4 and 5 of the Code.
- Choose the right controls - see Section 6 of the Code.
- Monitor and review the controls - see Sections 9 and 11 of the Code.
The Code outlines two methods for choosing the right controls:
- Method 1: Using the controls table.
- Method 2: Using exposure data to choose dust controls that work.
Section 2 of the Code provides flowcharts to help PCBUs work through the two methods and explains how they link to the duties related to air monitoring and health monitoring.
Method 1: Using the controls table
Appendix 4 of the Code is a controls table, outlining recommended controls for a range of common tasks in construction and manufacturing. The tasks are based on power tools and mechanised plant, as well as several housekeeping tasks that can make RCS airborne.
For each task, the table outlines:
- Engineering or work practice control methods
- The respiratory protective equipment (RPE) for that task, depending on:
- How long the shift is
- If the task is done outdoors, or indoors/enclosed area
- When health monitoring is required.
If the recommended combination of control methods and RPE are used for that task, and they are used properly, the PCBU does not need to conduct air monitoring to assess the risk from that task.
For further information, see ‘Air monitoring’.
Method 2: Using exposure data to choose dust controls that work
The PCBU does not have to use the recommended controls included at Appendix 4.
If the PCBU does not use the controls table to choose dust controls, the PCBU must follow the hierarchy of controls to choose dust controls.
This means the PBCU must:
- Eliminate the risk (see Section 7.1)
- If eliminating the risk of RCS is not reasonably practicable, the PCBU must use higher order controls. These include:
- Substituting the hazard to eliminate or minimise the risk (see Section 7.2)
- isolating the hazard (see Section 7.3)
- Using engineering controls (see Section 7.4).
If the risk of RCS exposure remains after using the above controls, the PCBU must use the following controls to minimise the risk:
- Administrative controls (see Section 7.5)
- Respiratory protective equipment (see Section 7.6).
The dust controls, or combination of controls, chosen by the PCBU must keep exposure to RCS below the workplace exposure standard.
The PCBU must have an air monitoring report that provides statistically valid exposure data that shows the controls you have chosen for the task reduce exposure to RCS to below the workplace exposure standard, including RPE if required.
Control measures
Hierarchy of Controls
Use the following Hierarchy of Controls to determine what level of control you need to manage the risks associated with breathing in dust:
- Elimination – work with the building designer to standardise room sizes and eliminate the need to cut materials to length on-site by having materials pre-cut to length before being delivered
- Substitution – substitute materials for ones that don’t contain silica and use fibre cement shears instead of circular saws or grinders
- Engineering – use on-tool dust collection and dust extraction when cutting materials with saws or other tools that produce dust and use water suppression when demolishing buildings
- Administration – perform cutting tasks outside in well-ventilated areas and rotate workers on cutting tasks to reduce exposure
- Personal protective equipment – use the right RPE for the task and ensure it's fit-for-purpose. Ensure the RPE fits the individual correctly using fit testing. RPE should never be used as the only control measure for dust exposure. Train workers on the correct use and maintenance of RPE.
Planning and risk assessment
You should consider the risks of dust exposure before work starts to ensure appropriate actions are taken to limit the amount of dust generated during work tasks.
Anyone working on a construction site could be exposed to hazardous levels of silica dust, but those especially at risk include bricklayers, carpenters and plasterers when installing fibre cement products, labourers, demolition workers and floor finishers.
SWMS for RCS
Construction work carried out in an area that may have an atmosphere contaminated with RCS is high risk construction work and will require a safe work method statement.
Section 3.1.1 of the Code provides further information on Safe Work Method Statements (SWMS) requirements, and a sample SWMS is provided in Appendix 2.
Safety data sheets (SDS) for silica
A safety data sheet (SDS) is a document that lists information on the hazards and safe use of a chemical or product. It is prepared by the manufacturer, distributor, or importer of the chemical or product. It includes information on the physical and chemical properties, health and environmental effects, exposure control, spill and emergency procedures, and disposal guidelines of the chemical or product. It is a requirement that you have the SDS on site for any chemicals or product you are using.
Do importers and suppliers need to provide SDS’?
Where the product or material is classified as a hazardous chemical, manufacturers, importers, and suppliers are required to provide a SDS.
DoI need an SDS on site for products containing silica?
Any of your products that contain 1 per cent of silica or more will require you to keep the SDS on site to be accessed.
Respiratory protective equipment (RPE)
Respiratory protective equipment (RPE) is needed if the higher order dust controls used to manage RCS exposure are not able to reduce exposure to below the workplace exposure standard.
When does a PCBU need to provide RPE?
If the PCBU does require the use of RPE at the workplace, the PCBU must ensure the RPE provided is:
- Suitable having regard to the nature of the work and any hazard associated with the work
- A suitable size and fit and reasonably comfortable for the worker who is to use or wear it
- Maintained, repaired or replaced so that it continues to minimise risk to the worker who uses it, including by ensuring that the equipment is clean and hygienic, and in good working order.
The PCBU must also ensure the RPE is used or worn by the worker, so far as is reasonably practicable.
The PCBU must not charge or impose a levy on a worker for the provision of RPE, or any other item of personal protective equipment.
Methods to determine if a PCBU is required to provide RPE
Method 1: Using the controls table
The controls table at Appendix 4 of the Code outlines the following recommended controls for each common construction and manufacturing tasks:
- Engineering or work practice control methods
- The RPE for that task, depending on:
- How long the shift is
- If the task is done outdoors, or indoors/enclosed area.
If the PCBU is using the controls table, they must follow the recommended combination of controls for the task, including RPE. This requirement will often depend on the shift length, and if the task is done outdoors or indoors/enclosed area.
The controls table also outlines the Minimum Protection Factor (MPF) for the RPE that must be used. Section 7.6.1 includes a table that outlines what types of RPE are suitable for each MPF.
Note: If RPE is needed to protect the worker carrying out the task, the PCBU should consider the following controls for other persons in or near the work area:
- Isolation, such as exclusion zones (refer to Section 7.3)
- Administrative, if isolation is not reasonably practicable (refer to Section 7.5)
- RPE, if isolation and administrative controls are not reasonably practicable (refer to Section 7.6).
Method 2: Using exposure data to choose dust controls that work
If the PCBU does not use the controls table to choose dust controls, the PCBU must follow the hierarchy of controls to choose dust controls.
The PCBU must have an air monitoring report that provides statistically valid exposure data that shows the controls the PCBU has chosen for the task reduce exposure to RCS to below the workplace exposure standard.
If the air monitoring report shows that the controls the PCBU has chosen for the task do not reduce exposure to RCS to below the workplace exposure standard, the PCBU must make sure RPE is used by the worker.
Section 7.6 provides information to assist the PCBU with selecting appropriate RPE, with a table in Section 7.6.1 that outlines the Minimum Protection Factor (MPF) for different types of RPE.
Note: If RPE is needed to protect the worker carrying out the task, the PCBU should consider the following controls for other persons in or near the work area:
- Isolation, such as exclusion zones (refer to Section 7.3)
- Administrative, if isolation is not reasonably practicable (refer to Section 7.5)
- RPE, if isolation and administrative controls are not reasonably practicable (refer to Section 7.6).
Does RPE require fit testing?
Under WHS Regulation Section 44, the PCBU must ensure that any personal protective equipment, which includes RPE, is:
- Suitable having regard to the nature of the work and any hazard associated with the work
- Suitable size, fit and reasonably comfortable for the worker.
Fit testing is required for all tight-fitting RPE to ensure it is a suitable size, fit and reasonably comfortable for the worker. This includes:
- All types of disposable and reusable half-face RPE, including negative pressure, powered air purifying and airline/air-fed types
- All types of full face RPE, including negative pressure, powered air purifying and airline/air-fed types.
Section 7.6.2 of the Code provides information on the three methodologies for fit testing, including qualitative and quantitative methods. This section provides a table outlining what methodologies are suitable for different specific types of RPE.
Section 7.6.2 also provides information on how frequent fit-testing should be, and who is competent to provide fit-testing.
Note: PCBUs should ensure workers who undergo fit-testing, or are required to wear tight-fitting respirators during work, are clean-shaven or have no hair between their face and the seal of the respirator face piece (this can interfere with a proper fit). However, loose-fitting RPE can be used with facial hair.
What is RCS fit testing?
Fit testing detects if air is leaking into a respirator through gaps in the seal between the respirator face piece and the worker’s face.
The performance of any tight-fitting respirator relies heavily on having a good seal between the respirator and the wearer’s face. If the respirator doesn’t create an effective seal, contaminated air can leak into the respirator.
Respirators are not a one-size-fits-all item of Personal Protective Equipment (PPE). As each individual person’s face varies significantly in shape and size, it’s important that a suitable tight-fitting respirator is chosen for each worker.
It's important to choose the right respirator for the job. The fit of a respirator to a worker's face is critical. Have workers fit tested to ensure the respirator is comfortable and capable of giving the right level of protection. The amount of time the respirator is worn also needs to be considered.
Read more about RCS via WorkSafe Queensland and the specific controls you must implement when working with or around RCS.
How is fit testing done?
The PCBU must ensure that any personal protective equipment (this includes RPE) is:
- suitable having regard to the nature of the work and any hazard associated with the work; and
- a suitable size, fit and reasonably comfortable for the worker.
Fit-testing is required for all tight-fitting RPE to ensure it is a suitable size, fit and reasonably comfortable for the worker. This includes:
- All types of disposable and reusable half-face RPE, including negative pressure, powered air purifying and airline/air-fed types; and
- All types of full face RPE, including negative pressure, powered air purifying and airline/air-fed types.
The Managing respirable crystalline silica dust exposure in construction and manufacturing of construction elements Code of Practice 2022 (the Code) provides information on the three methodologies for fit-testing, including qualitative and quantitative methods. This section provides a table outlining what methodologies are suitable for different specific types of RPE.
The Code also provides information on how frequent fit-testing should be, and who is competent to provide fit-testing.
Note: PCBUs should ensure workers who undergo fit-testing, or are required to wear tight-fitting respirators during work, are clean-shaven or have no hair between their face and the seal of the respirator face piece (this can interfere with a proper fit). However, loose-fitting RPE can be used with facial hair.
For an accredited fit tester, visit Australian Institute of Occupational Hygienists Inc. Respirator Fit Testing Training & Accreditation Program (AIOH RESP-FIT).
What are the methods of fit testing?
There are three methods used for fit testing:
- Qualitative (QLFT) – Aerosol taste test (ATT) - Providing the person can taste the selected agent, if they can’t taste the aerosol wearing the disposable/ filtering facepiece or a half face reusable respirator fitted with a particulate filter while undertaking the set movement activities, then an acceptable fit has been achieved.
- Quantitative (QNFT) – Ambient aerosol condensation nuclei-counting (CNC) uses the ambient aerosols in the immediate fit-testing environment to measure the amount of aerosol inward leakage getting inside the respirator compared to the amount outside the respirator. This ratio of reduction indicates the fit factor being achieved during the fit-test.
- Quantitative (QNFT) – Controlled negative pressure (CNP) method uses the principle of ‘controlled negative pressure’ – it creates a slight negative pressure inside of the respirator being tested (while the wearer holds their breath and remains still) and monitors the pressure in order to measure any face seal leakage. Quantitative fit-testing is the preferred way to fit-test RPE, as it doesn’t depend on tasting or smelling a test agent and is suited to testing a wider range of RPE.
When and how often should fit testing be done?
Fit testing should be carried out before the respirator is selected and used by a worker for the first time. It should also be carried out at least once per year to ensure it continues to fit adequately and whenever there’s a change in the wearer’s facial characteristics or features which may affect the facial seal, such as weight loss or gain and each time a new make or model of tight-fitting respirator is issued.
Who can complete a fit test?
Any fit testing should be carried out by a competent person. This could be someone within your business who has appropriate qualifications and experience, the manufacturer or supplier of the respirator, or a consultant, such as a hygienist of medical professional.
How do I know if a worker’s been fit tested?
Once a worker passes a fit test, a written record of the results should be kept for each worker with information that should include:
- Type of test performed (qualitative vs. quantitative)
- Make, model, style and size of respirators tested
- Date of the test
- Result of the test.
This information will guide you – as their employer – to which type of respirator they have been fit tested to use safely. Workers are only permitted to use the specific respirator outlined in their written record.
We recommend that this information be produced in the form of a fit test record card that can be easily kept on hand by the worker.
Fit checking
Fit-checking should be carried out each time a fit-tested respirator is used.
Facial hair
PCBUs should ensure workers who undergo fit-testing, or are required to wear tightfitting respirators during work, are:
- clean-shaven, or
- Have no hair between their face and the seal of the respirator face piece as it can interfere with a proper fit. This is important as respirable crystalline silica particles are smaller than facial hair.
Read more via the Code and the specific controls you must implement when working with or around RCS or attend one of our silica awareness courses to learn more.
It's important to choose the right respirator for the job. The fit of a respirator to a worker's face is critical. Have workers fit tested to ensure the respirator is comfortable and capable of giving the right level of protection. The amount of time the respirator is worn also needs to be considered.
Read more about RCS via WorkSafe Queensland and the specific controls you must implement when working with or around RCS.
Health monitoring
The WHS Regulation requires PCBUs must provide health monitoring to workers who are carrying out ongoing work using, handling, generating or storing RCS and there is a significant risk to the worker's health because of exposure.
The Code advises that significant risk exists when:
- A worker has been doing jobs that, even when using higher order controls, e.g., substitution, isolation, engineering controls, generate enough RCS that RPE is needed to do keep exposure below the workplace exposure standard, and
- The worker needed to wear RPE to work safely on 30 days or more in a year, or
- The PCBU is reasonably certain the worker will need to wear RPE more than 30 days in the next twelve months.
Note: RPE use only counts towards the 30-day trigger when wearing RPE is required by the Code. Any other RPE use does not count towards the 30-day trigger.
For example, a PCBU following the controls table at Appendix 4 requires a worker using a tile saw to use an integrated water delivery system for wet cutting. The controls table does not require RPE use.
If the PCBU chooses to provide the worker with RPE to further minimise exposure, this does not count towards the 30-day trigger.
If the worker chooses to wear RPE as an additional control, this does not count towards the 30-day trigger.
What does health monitoring involve?
The PCBU must make sure that any health monitoring is done by a registered medical practitioner (e.g., a doctor) with experience of doing health monitoring.
The PCBU also must:
- Give workers and new workers information about health monitoring
- Consult workers on the doctor chosen to do the health monitoring
- Pay all costs related to health monitoring
- Provide the doctor with information about the worker, including:
- The work that the worker is, or will be, carrying out that has triggered the requirement for health monitoring
- If the worker has started that work—how long the worker has been carrying out that work.
Schedule 14, Table 14.1 of the WHS Regulation specifies the minimum requirements for health monitoring for crystalline silica, which includes:
- Demographic, medical, and occupational history
- Records of personal exposure
- Standardised respiratory questionnaire
- Standardised respiratory function test
- Chest x-ray full size pa (posteroanterior) view.
Section 10.2 of the Code outlines what health monitoring should involve and outlines the PCBU duties (including the above information).
What if a worker refuses health monitoring?
Some workers may be reluctant to take part in health monitoring. This may be because they are anxious about the medical results. This may be because they are anxious about what it could mean for their job. It could be both reasons.
PCBUs should include information on the purpose of health monitoring in worker training, and should encourage workers to participate, as early diagnosis and treatment can prevent more serious and life-threatening conditions from developing.
Supporting a worker in these circumstances can be achieved by ensuring they know how health monitoring will benefit them; making the process easy for them to follow; and reminding them that their workplace, family, and community want them to be as safe and health as possible.
Health and Safety Representatives (HSRs) at a workplace, where applicable, may also be of assistance in this process and encourage workers to participate in screening for silicosis.
If the conversation with a worker on health monitoring has stalled, it may assist the PCBU to contact Workplace Health and Safety Queensland (WHSQ) inspectors for assistance or further information.
The PCBU may also consider contacting:
- The relevant union for the workers. Worker representation groups will have special skills for talking to workers about the importance of their health and safety in a supportive and empowering manner
- A doctor with experience conducting health monitoring. The medical professional will be able to explain the importance of spotting the signs of illness or disease as early as possible
- The worker may also advise the worker to speak with an employee assistance program (EAP). EAPs provide free, professional, and confidential counselling services, and may be able to help address any anxiety related to the health monitoring.
Section 10.4 provides further information on steps that a PCBU can take to support workers who are anxious about health monitoring.
What are the obligations for the importers and suppliers of construction elements?
Importers and suppliers have a duty under the WHS Act to ensure, so far as is reasonably practicable, that the substance they import/supply is without risks to health and safety of workers.
This includes importers and suppliers of silica-containing materials, including construction elements such as:
- Cement, concrete and aggregates, including precast concrete products such as fibre-cement sheeting
- Bricks, tiles, blocks, pylons, and pavers
- Grout, mortar, asphalt, sand, and stone
- Wall panels
- Geosynthetics.
Importers and suppliers are required by the WHS Act to meet their obligation by providing information about:
- The purpose for which the substance has been designed and manufactured
- The results of any calculations and analysis, testing in relation to the substance, including any hazardous properties
- Any conditions necessary to ensure the substance is without risks to health and safety.
Section 3.3 of the Code outlines specifically what information importers and suppliers should provide to meet these legislative requirements. This includes providing information on whether the construction element or material contains one per cent or more crystalline silica.
This information can be provided in a technical or safety data sheet, product labels fixed to each bundle/pallet/packet or similar documents.
What do these obligations mean?
This means that if you make sure workers are using the controls recommended in the controls table for that task, and make sure they are using them correctly, you do not need to conduct air monitoring.
That is because the controls have been proven to be effective, using statistically valid exposure data. You can also rely on statistically valid exposure data for the specific task and controls used from previous air monitoring reports, which could be provided by other business owners, manufacturers, industry associations or unions.
The duty is on the PCBU to be certain that the exposure data is statistically valid; and that it is relevant to the task, controls, and conditions. If they are not, then they can’t be certain on reasonable grounds that the controls used are effective.
If the PCBU is uncertain whether the existing exposure data is statistically valid, they should consult with a competent person (e.g., a certified occupational hygienist, or a recognised equivalent competency under an international certification scheme, e.g., certified industrial hygienist).
Air monitoring
Air monitoring for RCS Air monitoring must be carried out to check for airborne RCS at the workplace if:
- The PCBU is not certain, on reasonable grounds, if the workplace exposure standard has been exceeded
- The PCBU needs to work out if there is a risk to health.
- The PCBU can be certain on reasonable grounds that the workplace exposure standard has not been exceeded, if:
- All workers doing tasks that can generate RCS at the workplace are correctly using the controls that are recommended for that task in the controls table in Appendix 4 of this Code, including RPE if required, or
- The PCBU has an air monitoring report that provides statistically valid exposure data that shows the controls you have chosen for the task reduce exposure to RCS to below the workplace exposure standard, including RPE if required.
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