The Heavy Cost Of Not Implementing Adequate Control Measures

Recently much attention has been focused on silica and coal dust exposure. This is due to the multiple positive Silicosis diagnoses from employees working in the engineered stone industry and the spate of mine dust related diseases in Queensland (as reported by ABC news in February). The reason for the recent spate of these illnesses is likely to be due to an absence of control measures or inadequacy of implemented control measures.

One thing that can be said is that there appears to be a trend of heavy reliance on Respiratory Protection. This is possibly due to its cost and the perceived simplicity of implementation. This is all well and good if the respiratory protection is providing adequate exposure control. JTA performs multitudes of exposure assessments and frequently discovers issues that reduce the effectiveness or render the Respiratory Protective Equipment (RPE) ineffective, including:

• Incorrect fitting
• Un-shaven wearer
• Selection of inadequate respirator type
• Inadequate maintenance

The diseases caused by respirable silica and coal dust can take many years to present, even decades! This means that when there is a lack of, or inadequate, control it will take some time until this becomes apparent and can be addressed. It will result in continued diagnosed cases long after the control inadequacies are resolved, similar to asbestos fibre exposure and mesothelioma.  This highlights the need to evaluate exposure, the adequacy of control measures and to perform health surveillance on a regular basis

Hierarchy of Control

The Hierarchy of Control refers to the ways of controlling risk and these must be considered in a particular order. As SafeWork Australia point out, the WHS/OHS Regulations make it mandatory for duty holders to work through this hierarchy when managing risk.

1. Elimination
   The most effective control measure involves eliminating the hazard and associated risk. Keep in mind that eliminating hazards is often cheaper and more practical to achieve at the design or planning stage. If you cannot eliminate the hazard, then you must minimise as many of the risks associated with the hazard as reasonably practicable.
    
2. Substitution
   If it is not reasonably practicable to eliminate a hazard and associated risks then you can substitute the hazard with something safer (i.e. using stones with lower crystalline silica content).
    
3. Engineering / Isolation
   The third option is to use a control measure that is physical in nature including mechanical ventilation, sharper cutting tools, using wet processes or physical separation by distance or using barriers E.g. cutting/ grinding rooms or remote control systems.
    
4. Administration
   Any risk measures that remain must be minimised by administration controls (so far as is reasonably practicable). E.g. work methods or procedures, training, instruction.
    
5. Personal Protective Equipment (PPE)
   Finally, any remaining risk must be minimised with suitable respiratory protection. In order to be successful, these must be fitted, worn and used correctly as well as maintained and replaced when required.

The hierarchy of control is not just a page filler in the Safety Legislation. It’s the fundamental basis for exposure control and is critical in preventing occupational disease.

Read ‘Take Note - Silica Is Being Termed The New Asbestos’
Download the Cancer Council Silica Dust factsheet