SMF009

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Proposed Amendments to the Workplace Exposure Standard (WES) - Public Comment Response Form

Complete and submit this form by 5pm AEST FRIDAY 8 June 2012 to

EXPOSURE STANDARDS FOR SYNTHETIC MATERIALS
Section/page no. / Comment
General comment:
We consider that the proposal should more accurately reflect the evidence detailed in the IARC and AIOH reports. The issues paper does not give sufficient acknowledgement of the need to control and manage 'older' SMF materials particularly where they remain in-situ. The evidence on the new materials is not a rationale for decreasing the current standard for these older materials.
The 2002 IARC report does not 'exonerate' all forms of SMF, rather IARC found that some SMFs are ‘not classifiable as to their carcinogenicity to humans’ (Group 3). In our view the evidence requires the current WES to be divided into 2 components - one WES to reflect the evidence that IARC has moved 'older' SMF materials to Group 3 which should be dealt with separately from a WES for the new low biopersistent fibres being 'exonerated' from classification as carcinogens by the EC.
The hazards of the 'old' SMFs - respirability, bio-persistence and irritation remain. Although the AIOH report at page 12 acknowledges the issue of mechanical irritation the proposed change to the WES does not address mechanical hazards adequately.
It is unclear from the proposed definitions in Appendix A whether the special purpose glass fibres (E-glass and '475' glass fibres) referred to in the IARC report are included. Given that they are classified as Group 2B they should have a separate entry.
This review of the WES for mineral wools has been at the request of ICANZ and as the issues paper acknowledges that the ICANZ/FARIMA Code was done in consultation with unions and is the primary Code used by industry. The ICANZ/FARIMA Code which is based on the current exposure standard has been used by industry for many years with industry being able to comply with that code without difficulty, providing 'reasonably practicable' controls and protections for workers. As the IARC report at 5.2 highlights the particular risks for workers who use or remove SMF products the ACTU expects that any revisions to the Code be developed consultatively with unions.
Do you agree with the amendments to the workplace exposure standard for mineral wools, previously known as synthetic mineral fibres, as revised?
Proposed changes to the WES:
a. Do not agree that the current exposure standard be revised for the 'old' SMF as currently defined and applied in Australia. The current WES should remain in place for these materials and should remain classified as 'hazardous'. The proposed change to the WES for the 'new' materials is supported.
b. Agree that the WES for RCF remain. The inclusion of 1B* in the carcinogen category in Appendix A should be removed.
c. The revised entry in the WES which removes the WES from the headings of MMVF and SMF category is not supported. The WES for old SMFs should retain the current nomenclature. How the 'new' materials fit into the chemical composition and weight criteria is unclear to us.
d. Agree that the any changes be reflected in the HSIS and the Guidance. However for the HSIS, the system must continue to provide for a search capacity under the current terms of SMF, ceramic fibres, glasswool and rockwool.
e. Agree that the inclusion of the carcinogenic classification be recorded. However as there are different classifications for 'old and 'new; materials they will require different and separate entries.
If no, please provide further details

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