2022 Consultation Regulation Impact Statement Managing the Risks of Respirable Crystalline Silica at Work

The AIOH submission was made to SWA addressing the options presented in the Consultation Regulatory Impact Statement (CRIS). The options included Option 4 (a national licensing framework for those working with engineered stone) and Option 5a (Additional regulation of high-risk crystalline silica processes for all materials including engineered stone) which are both supported by Option 2 (National awareness and behaviour change initiatives).

However, these policy options only partially address the wider problem facing Australian employers and workers, resulting in an increasing strain on our public health system. The additional complementary options that are missing are:

1. Progressing the implementation of a ban on the use of high quartz containing engineered stone; and
2. The need for a Centre for Disease Prevention and Control, with a multi-disciplinary Institute of Occupational Health.

We outline in our submission, the need for other activities that are both crucial and complementary to those above, which include:

o The urgent need to increase the number of specialist resources to support the effective implementation of regulatory and non-regulatory options in each State and Territory health and safety regulator;
o Regulatory improvements to product labelling requirements; and
o The need for High Resolution Computerised Tomography (HRCT) as a mandatory minimum regulatory requirement for health monitoring.

We recognise that the economic analysis of policy options is required for due process, however, we note that placing a monetary value on human life is inconsistent with the objectives of government intervention. We raise concern that the cost modelling methodology does not consider the many other diseases that are known to result from over-exposure to RCS and therefore the estimates presented are a gross under-estimate of the true cost to Australia.