Working with engineered stone
Guidance about working with engineered stone since the ban from 1 July 2024. The guidance is for employers, employees, self-employed persons and persons with management or control of a workplace. It explains exceptions to the ban and how work with engineered stone can be done safely.
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Engineered stone ban
From 1 July 2024, the manufacture, supply, processing or installation of engineered stone benchtops, panels or slabs is banned in Victoria. The engineered stone ban applies to engineered stone benchtops, panels and slabs. Engineered stone products not in these forms are not banned. There are limited exceptions to the ban where work can be performed on engineered stone benchtops, panels and slabs. This includes:
- removal, repair or modification of installed engineered stone benchtop and panels
- disposal of installed or uninstalled engineered stone benchtops, panels and slabs
- research and analysis, and
- to sample and identify engineered stone
Specific controls are required when permitted engineered stone work involves an engineered stone process. An engineered stone process is also considered high risk crystalline silica work and you must comply with the high risk crystalline silica work obligations.
A ban has been introduced as rates of silicosis and silica-related diseases in Australian workers have risen substantially in recent years. A large number of these diagnoses are engineered stone workers as they are exposed to crystalline silica dust in the processing of products such as benchtops, panels or slabs.
More information on the health risks of exposure to crystalline silica dust.
Definition of engineered stone
From 1 July 2024, engineered stone is defined as an artificial product that:
- contains 1 per cent or more crystalline silica, determined as a weight/weight (w/w) concentration, and
- is created by combining natural stone materials with other chemical constituents such as water, resins or pigments, and
- becomes hardened
The following artificial products are not considered engineered stone:
- concrete and cement products
- bricks, pavers and other similar blocks
- porcelain that doesn't contain resin
- sintered stone that doesn’t contain resin
- ceramic wall and floor tiles
- roof tiles
- grout, mortar and render
- plasterboard
The engineered stone ban and exclusions
The ban applies to engineered stone in the form of:
- benchtops, such as those installed in kitchens and bathrooms and outdoor surfaces
- panels, such as kitchen splash backs or floor or wall tiles
- slabs, that might need to be cut to fit a variety of different installation settings
The ban does not apply to engineered stone products that are not benchtops, panels or slabs. This includes, for example, jewellery, garden ornaments, sculptures and kitchen sinks.
The ban does not apply to natural stone. For example, a granite benchtop is not prohibited.
However, if you are working with silica containing products, you may be carrying out a crystalline silica process or a high risk crystalline silica process and specific duties apply.
More information on high risk crystalline silica work.
Repair, remove, modify and dispose of legacy engineered stone
Engineered stone benchtops, panels and slabs are currently installed in many homes and other settings throughout Australia. There may also be stock of uninstalled engineered stone held by businesses such as suppliers and distributors, after the commencement of the ban. These installed products and uninstalled stock are sometimes referred to as legacy engineered stone.
Processing legacy engineered stone benchtops, panels or slabs is permitted for the limited purposes of:
- removal, repair and modification to previously installed engineered stone
- disposal of engineered stone, whether it is installed or not
This means that employers and self-employed persons are permitted to carry out, or direct employers to carry out, the repair, modification, removal or disposal of legacy engineered stone.
If you are performing an engineered stone process, the OHS regulations require that you must use specific measures to control the risks associated with engineered stone. This work must also be treated as high risk crystalline silica work.
- Repair
Making repairs may include fixing a chip or crack in a legacy engineered stone benchtop, panel or slab. It may also involve resurfacing or polishing to remove a scratch, etch, mark or stain on a benchtop or panel.
- Modification
Modification of a legacy engineered stone benchtop, panel or slab may include altering its original form. Examples may include:
- cutting into already installed engineered stone benchtop or panel to create a cavity for the placement of a larger tap, cooktop or powerpoint
- cutting into an already installed benchtop or panel to change the configuration, for example, an L-shape bench to an island bench
- Removal
Removal can involve disassembling or breaking apart a legacy engineered stone benchtop, panel or slab with the intention of disposing of it. For example, a worker uses power tools to remove an engineered stone benchtop and splash back as part of a kitchen renovation.
Engineered stone that has been removed cannot be supplied, processed or installed.
- Disposal
Disposal of legacy engineered stone benchtops, panels or slabs can occur whether installed or not. For example, an employee removes an engineered stone bathroom countertop and takes it to a landfill.
Permitted work for research & analysis and to sample & identify
The installation, supply and processing of engineered stone benchtops, panels or slabs is permitted for the purposes of:
- genuine research and analysis, and
- to sample and identify engineered stone
For example, a university researcher is studying how fire safe various materials are. A business is allowed to supply an engineered stone benchtop to the researcher to carry out the study. The researcher may process the engineered stone to suit the needs of their research. The researcher must use specific control measures if doing any processing of engineered stone required by the study.
Carrying out permitted work safely with engineered stone
An engineered stone process is a process involving engineered stone at a workplace that generates crystalline silica dust. It includes cutting, grinding or abrasive polishing of engineered stone.
If you are performing an engineered stone process for permitted engineered stone work then you must:
- treat the work as high risk crystalline silica work (HRCSW) and:
- prepare a HRCSW hazard control statement
- make sure the work is performed in accordance with the HRCSW hazard control statement
- provide information to job applicants
- provide employees with specific information, instruction and training
- use specific control measures:
- the specific control measures are explained in the section on Required control when undertaking an engineered stone process
You may also be required to undertake atmospheric monitoring and health monitoring for crystalline silica dust exposure.
Consultation
When working with legacy engineered stone, employers must consult, so far as is reasonably practicable, with their employees (and independent contractors) on certain matters related to health and safety that directly affect or are likely to directly affect them. For example, when they are identifying or assessing hazards or making decisions about measures to control risks associated with crystalline silica exposure.
If employees are represented by a health and safety representative (HSR), the consultation must involve that HSR, with or without the involvement of the employees directly.
High risk crystalline silica work
All engineered stone processes are considered to be high risk crystalline silica work and a crystalline silica hazard control statement (hazard control statement) is required.
A crystalline silica hazard control statement is a document. It is prepared for all high risk crystalline silica work (HRCSW) at a workplace.
The hazard control statement sets out:
- the hazards and risks from the work
- the measures to control those risks
- how the control measures will be implemented
A hazard control statement must be set out and expressed in a way that is readily accessible and comprehensible to the persons who use it.
An employer or a self-employed person must not perform HRCSW unless:
- a crystalline silica hazard control statement is prepared for the work before the work begins, and
- the work is performed in line with that hazard control statement
If the work is not performed in line with the hazard control statement, the employer or self-employed person must stop that work immediately or as soon as it is safe to do so. Work must not resume until the hazard control statement is complied with or reviewed and, if necessary, revised in line with the OHS regulations.
An employer must review and revise the hazard control statement:
- whenever the HRCSW changes
- whenever there is an indication that risk control measures are not adequately controlling the risk
- after any incident that occurs during the HRCSW
More information on the duties related to developing a hazard control statement and putting it into effect.
Required controls when undertaking an engineered stone process
An employer or self-employed person must not undertake, direct or allow an employee to undertake an engineered stone process unless specific measures to control risks associated with engineered stone are used. These specific measures are outlined in the following sections.
- When power tools are used
The uncontrolled dry cutting of legacy engineered stone is not permitted in Victoria.
If a power tool or other form of mechanical plant is used to undertake an engineered stone process, an employer or a self-employed person must ensure that the power tool or mechanical plant is used with:
- an integrated water delivery system that meets the requirements in this guidance, or
- an on-tool dust extraction system that meets the requirements in this guidance, or
- if these controls are not reasonably practicable, another type of local exhaust ventilation (LEV)
- Integrated water delivery system
An integrated water delivery system, also known as on-tool water suppression is one of the most effective ways to reduce exposure to crystalline silica dust.
It works by using water at the point of dust generation to dampen down or suppress dust before it is released into the air.
An integrated water delivery system must:
- deliver a continuous supply of water to the point of contact with the stone while the power tool or mechanical plant is in use, and
- if the system uses recycled or recirculated water, adequately treat that water
Suitable water suppression: grinder being used to cut slab
Suitable water suppression: polisher being used to finish benchtop
Inappropriate water suppression: separate hose being directed at work
Inappropriate water suppression: use of spray bottle
- On-tool dust extraction
On-tool dust extraction removes the dust from the source as it is being produced. It is fitted directly onto the tool, with extraction attached to a high efficiency particulate air (HEPA) filtered Dust Class H vacuum cleaner.
An on-tool dust extraction system must:
- be commercially available, and
- be connected to a Dust Class H vacuum or another system that captures any dust generated by the power tool
Dust Class H vacuum means a vacuum that complies with the Class H requirements in AZ/NZS 60335.2.69:2017 Household and similar electrical appliances—Safety—Part 2.69: Particular requirements for wet and dry vacuum cleaners, including power brush, for commercial use or its equivalent.
Figure: Grinder fitted with on-tool extraction
- Local exhaust ventilation
Local exhaust ventilation (LEV) is an engineering control that captures the emission of an airborne contaminant at its source and transports it to a safe emission point, filter or scrubber. On-tool dust extraction is one form of LEV.
While this control measure may reduce background levels of silica dust, it is not as effective as water suppression or on-tool dust extraction in reducing the exposure of employees and is generally not recommended.
Where legacy engineered stone processes are undertaken, another type of LEV, such as a portable LEV system, should be used if it is not reasonably practicable to use an integrated water delivery system or a commercially available on-tool dust extraction system.
LEV that is not on-tool requires proper design, installation, use and maintenance to ensure dust is effectively captured as close as possible to the source, so far as is reasonably practicable, eliminate or reduce the risk of exposure to crystalline silica dust.
- Information, instruction, training and supervision
Employers must provide employees with any necessary information, instruction, training, or supervision required to enable them to perform their work in a way that is safe and without risks to health. This duty also extends to independent contractors (including any employees of the independent contractor) engaged by the employer in relation to matters over which the employer has control.
An employer must ensure that employees who are likely to be exposed to risks associated with high-risk crystalline silica work are given information, instruction, and training in:
- the health risks associated with exposure to crystalline silica dust
- the need for, and proposer use of risk control measures
- how the risk control measures are to be implemented
An employer must ensure that an employee who uses a power tool or other form of mechanical plant to undertake a permitted engineered stone process is provided with information, instruction and training in:
- the use of that power tool or mechanical plant with an integrated water delivery system or an on-tool dust extraction system or local exhaust ventilation
- the use, fit, maintenance and storage of respiratory protective equipment
An employer must ensure that an applicant who applies for employment involving high risk crystalline silica is given information about:
- the health risks associated with exposure to crystalline silica dust
- the need for, and details of measures to control those risks
Training programs need to be practical and 'hands on'. The structure, content and delivery of the training needs to take into account any special requirements of the employees and independent contractors being trained. For example, information, instruction, and training may need to be provided in a language other than English.
Other considerations for how training is delivered include specific skills or experience, disability, literacy, and age. Training programs should also be reviewed periodically and as required to ensure suitable information, instruction and training is provided to employees.
Refresher training needs to be provided as appropriate for the workplace. The frequency of refresher training should be determined having regard to the complexity of the work, the skills required and the frequency with which the tasks or work is carried out.
Employers must provide supervision to employees where supervision is necessary to enable those employees to undertake their work safely. This is particularly important with employees who are more vulnerable such as new, inexperienced, or young employees.
Figure: Safety signage at a worksite with permitted engineered stone processes occurring.
- Respiratory protective equipment
Employers must provide an employee who undertakes an engineered stone process with respiratory protective equipment (RPE) that:
- is designed to protect the wearer from the inhalation of airborne contaminants
- complies with AS/NZS 1716 – Respiratory protective devices, or an equivalent standard
The employer must also ensure the employee uses the RPE.
It is important to check the product information to make sure the RPE meets the requirements of AS/NZS 1716 or an equivalent standard. If it is not clear, contact the supplier or the manufacturer.
RPE needs to have at least a P2 filter and be fit tested for each person to ensure a correct fit. RPE that requires a facial seal, such as half-face respirators, should not be used by people with beards or facial stubble. Where facial hair interferes with the fit of the RPE, a powered air purifying respirator (PAPR) that does not rely on a facial seal needs to be used, such as a PAPR loose fitting helmet.
RPE needs to be selected, used and maintained in accordance with AS/NZS 1715 – Selection, use and maintenance of respiratory protective equipment or equivalent standard.
Employers need to provide employees with information, instruction and training in the use, fit and maintenance of RPE, including the system for storage.
For RPE that requires a facial seal, such as a half-face powered air purifying respirator, a fit check is a quick check to ensure it is properly positioned on the face where it is put on.
Employees should do a fit check every time they put on their respirator in accordance with the manufacturer's instructions.
Recommended RPE for working with engineered stone
PAPR loose fitting helmet
High level of protection:
- positive pressure reduces fatigue
- can be worn with facial hair
- does not require fit testing
PAPR loose fitting hood
High level of protection:
- positive pressure reduces fatigue
- can be worn with facial hair
- does not require fit testing
Half face PARP
Medium level of protection:
- more comfortable over longer periods
- positive air pressure reduces fatigue
- cannot be worn with facial hair
- requires fit testing
- needs to be fit checked with each wearer
Half face negative pressure respirator
Minimum level of protection:
- does not impair vision or mobility
- cannot be worn with facial hair
- requires fit testing
- needs to be fit checked with each wear
Note: When undertaking an engineered stone process, filters used in respirators must be of a particulate type. When undertaking a gluing process, organic type filters may also be required.
- Prohibition on cleaning with compressed air and gases
An employer or a self-employed person must not use compressed air or other compressed gases to clean the following, unless the use of that air or gas does not result in a concentration of respirable crystalline silica that exceeds the exposure standard for crystalline silica:
- a work area where an engineered stone process has been undertaken
- clothing a person wore in a work area where an engineered stone process was undertaken
It is not recommended to use compressed air in any situation where respirable crystalline silica dust may have been produced.
Reducing dust
- Cleaning the work area
When carrying out permitted work with engineered stone, the work area should be cleaned after each job is completed. This is to ensure there is no build-up of respirable crystalline silica dust on equipment such as power tools, working surfaces or the floor. RPE needs to be worn during clean-up activities.
Ensure clean-up and housekeeping processes do not generate dust in the air. For example, use a HEPA filtered Dust Class H vacuum, low pressure hosing, mopping, squeegeeing or wet wiping down surfaces. It is not recommended to ever use compressed air, dry sweeping or high-pressure water to clean up as this is likely to generate airborne dust.
Bags used for containing waste need to be strong enough to ensure they will not tear and release dust. To minimise the risk of a bag tearing or splitting, bags should not be filled more than half full and excess air gently evacuated from the bag in a way that does not cause the release of dust.
- Personal decontamination
When carrying out permitted work with engineered stone, personal protective equipment such as RPE, aprons and boots need to be cleaned after each use to ensure dust does not accumulate. For example, by using a low pressure hose or wiping down with wet rags.
Work clothes should not gather dust if exposure is appropriately controlled during processing work. However, if dust has settled on clothing, the contaminated clothing should be dampened, bagged, and labelled with 'Silica dust hazard'.
Contaminated clothing should not be taken home. It should be sent to a commercial laundry. If a commercial laundry is used, the employer or self-employed person needs to inform the laundry that the clothing is contaminated with silica and ask how they would like to receive the clothing.
- Managing crystalline silica waste
Employers must control the risk of exposure to crystalline silica dust during legacy engineered stone waste management and disposal. For example, when wet slurry is collected, or dust captured by an extraction system is ready for disposal, it needs to be contained and handled in a way that minimises the release of dust. Containers of waste contaminated by silica dust must be identified, for example by a label that clearly states 'Silica dust hazard'.
- Wet slurry
Wet slurry is the waste from dust generating processes that are water suppressed. While it is wet, the slurry is not hazardous. If it is allowed to dry, some dust may be disturbed and become airborne. If there is any risk of exposure to dust for people who may handle the waste (eg employees, waste collectors or waste transfer station staff) the waste needs to be bagged and sealed before it is disposed
When carrying out permitted work with engineered stone, wet slurry needs to be managed using containment measures such as using plastic drop sheets to prevent contamination of the work area and collection of wet slurry by using a HEPA filtered Dust Class H vacuum or mopping, squeegeeing or wet wiping down surfaces.
Atmospheric monitoring
Atmospheric monitoring, also known as air monitoring, means a procedure by which air is sampled within the breathing zone of a person to measure and evaluate the person's exposure to airborne contaminants.
Employers should conduct an ongoing air monitoring program to confirm that the exposure standard for respirable crystalline silica is not being exceeded.
Employers should conduct air monitoring:
- when there are changes to work practices, the materials being used or the work environment
- if a health monitoring report for an employee indicates a negative change in health status which may be related to silica exposure
- if a health and safety representative requests a review of control measures
- if there are changes to the workplace exposure standard, and previous air monitoring results have indicated levels above the new standard
By law, employers must carry out air monitoring if:
- they are not sure if their employees are exposed to levels of silica dust that are above the exposure standard
- they can't work out if there's a risk to employee health without air monitoring
Employers are not required to carry out atmospheric monitoring if they are required to undertake biological monitoring as a part of health monitoring for their employees.
Air monitoring and the interpretation of results, including comparison with the exposure standard needs to be undertaken by a person with the requisite skills, knowledge and experience, such as an occupational hygienist. The Australian Institute of Occupational Hygienists (AIOH) represents the occupational hygiene field. A list of service providers with the right experience to conduct air monitoring can be found on the AIOH website.
Results of air monitoring must be provided to the employees who have been, or may have been, exposed.
Health monitoring
Employers must provide health monitoring if exposure to crystalline silica is likely to have an adverse effect on employees' health.
The purpose of the health monitoring is to monitor the employee's health to identify changes in the employee's health status due to exposure to hazardous substances in the workplace.
Where there is uncertainty about whether or not exposure is likely to have an adverse effect on employees' health, atmospheric monitoring should occur to determine employees' exposure to airborne contaminants when checked against the exposure standard for respirable crystalline silica.
Where health monitoring is required, it should be completed when an employee:
- is hired with a new employer, before they start work
- regularly while they are in the job
- when they finish working for that employer
Former engineered stone licence holders must continue to ensure the health monitoring is conducted under the supervision of specialists if they have an employee who:
- is required to have health monitoring under regulation 169, and
- was employed by them immediately before 1 July 2024, and
- was previously required to have health monitoring under the supervision of a specialist occupational and environmental physician, or specialist respiratory and sleep medicine physician
A list of practitioners can be found on the Royal Australasian College of Physicians website at racp.edu.au. Employers should speak to the occupational physician or respiratory and sleep medicine physician to ensure they have experience with silicosis and other silica dust diseases.
Former engineered stone licence holders must provide a copy of these health monitoring reports to WorkSafe within 30 days of being received.
There are also other circumstances where employers are required to submit health monitoring reports to WorkSafe.
More information about health monitoring requirements.