The Health and Safety Executive (HSE) has published new sector-specific guidance for businesses involved in the fabrication and use of engineered stone, as part of their ongoing focus on occupational health. The guidance is aimed at tackling the health-impact of crystalline silica dust and will be the focus for a nationwide programme of inspections in the sector over the next twelve months.
What is engineered stone and why is it high risk?
Engineered stone is a manufactured product made from crushed natural stone or minerals bonded together with resin. Unlike many natural stones, engineered stone typically contains extremely high levels of crystalline silica, in some cases up to 95%. When it is cut, ground or polished, it can generate very large quantities of respirable crystalline silica (RCS) dust, which has been shown to cause severe and accelerated silicosis. The guidance will be relevant to those involved in fabricating the material and also those fitting, for example, kitchens and bathrooms which commonly feature such products.
Whilst the risk posed by RCS are relatively well known, HSE has highlighted the concerning cases of two young workers who have passed away in recent years from work-related silicosis, caused by RCS. Damage to health may occur before any symptoms become apparent, and silicosis can continue to progress even after exposure has stopped.
What does the new HSE guidance require?
The central message of the guidance is that the dry cutting of engineered stone is unacceptable. With HSE stating that exposure levels during dry cutting of engineered stone can be five to ten times higher that those generated by equivalent wet-cutting methods.
The guidance sets out clear expectations for employers, including:
- eliminating dry cutting and adopting on-tool water suppression;
- effectively controlling secondary exposure from mist and contaminated surfaces;
- using lower silica engineered stone products where reasonably practicable;
- providing appropriate respiratory protective equipment as a supplement to engineering controls, not a substitute; and
- implementing health surveillance for workers exposed to respirable crystalline silica.
We recommend that consideration is not limited to the immediate workforce. Employers should also consider their duties under section 3 of the Health and Safety at Work etc. Act 1974, specifically in relation to external contractors, such as cleaning personnel who may be engaged to clean machinery used in the cutting of the engineered stone. This should include the frequency of cleaning such machines and the use of powered air purifying respirators with an assigned protection factor of at least 20 when processing, cleaning or maintaining such machinery. Consideration should also be given to the likelihood of such dust being present on work clothes.
Inspections
HSE has emphasised that failures to implement effective controls in line with the guidance, can be expected to result in regulatory action being taken. Inspectors have already begun site visits as part of a programme of more than 1,000 inspections over the next year, targeting fabrication businesses and others working with engineered stone.
Given this specific regulatory focus, any identified breaches of duty are likely to be met with enforcement action. This announcement aligns with HSE’s continued focus on occupational health and disease.
What should businesses be doing now?
For engineered stone businesses, the priority is to review current working practices against the HSE guidance and established COSHH essentials for stone workers. Businesses should ensure that controls are robust, documented and effective ahead of ongoing inspection activity.
- review current working practices against the HSE guidance;
- ensure that practices in operation mirror written policies and procedures;
- monitor and supervise working practices, so far as reasonably practicable, to ensure controls are applied correctly and systems followed;
- consider whether individuals not in their direct employment may be exposed to RCS as a result of their activities (for example, external cleaning contractors or maintenance contractors); and
- provide appropriate information, instruction and training to the workforce on the risks associated with silica exposure.
For more information or advice, please contact the Brodies Health and Safety Team.
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