Posted: 28 July 2017
On 11th July 2017 the European Council voted to include “work involving exposure to respirable crystalline silica dust generated by a work process” in Annex 1 Of the Carcinogens and Mutagens Directive. This new text must now be included within this Directive and formally confirms a proven link between work-generated respirable crystalline silica (RCS) and lung cancer.
Member states of the EC will have 2 years to bring this change into national legislation. Despite Brexit, it would appear likely that RCS will fall under the COSHH Carcinogens listing in Schedule 1 of these Regulations. This has wide-reaching applications for many industries including:
Processes involving the use of abrasive wheels and fettling also generate RCS, as the grinding medium deteriorates, irrespective of the actual component being worked on.
The Workplace Exposure Limit for RCS is to remain at 0.1 mg/m3 (8-hour Time-Weighted Average). In the light of the above re-classification, the risk assessments for processes leading to the generation of RCS should be reviewed. The risk assessment review will need to consider the adequacy of exposure monitoring and health surveillance programmes. Where risk assessments have previously considered only “inhalable dust” it is now even more important to consider the RCS fraction in relation to the above limit.
The COSHH Regulations impose additional requirements for substances regarded as carcinogens:
Many forward-thinking companies have already been taking steps to move towards total enclosure, even in industries where control has historically been very poor. For example, enclosed ventilated cutting stations are seen on some construction sites. Properly designed dust control is likely to become an essential design feature, with “on-tool extraction” a standard feature.
Nevertheless, it would appear inevitable that the formal designation of RCS as a lung cancer causing agent will lead to a significant increase in civil claims.
If you require further information or assistance please contact Dr Graham Newport.