Response to Select Committee Question Hazards and Controls For Working with Fibre Cement Sheet Products (e.g. Linea Weatherboard) on Fletcher Residential Building Sites Prepared By: Peter Stratford Environment, Health & Safety Manager Fletcher Residential Ltd 28 November 2014 Response to Select Committee Table of Contents Questions Posed .........................................................................................................................................3 Executive Summary .....................................................................................................................................3 Silica Dust in Construction ...........................................................................................................................4 Awareness of the Hazard and Controls ........................................................................................................5 1. Hazard Register........................................................................................................................................... 5 2. Site Safety Handbook ................................................................................................................................. 6 3. Safety Data Sheets ...................................................................................................................................... 6 4. Site Specific Safety Plans (SSSP) ................................................................................................................. 7 5. Training ....................................................................................................................................................... 7 6. Product Warning Labels and Markings....................................................................................................... 9 7. Hazard Boards........................................................................................................................................... 10 Programmes to Support the Embedding of Hazard Controls for Fibre Cement ............................................. 11 1. Contractor Qualification, SSSP and Induction Processes ......................................................................... 11 2. Hazard Identification and Control ............................................................................................................ 12 3. Site Safety Inspections and Monitoring of Contractor Safety Performance ............................................ 13 4. Non-Compliance Reporting ...................................................................................................................... 14 5. Environmental Monitoring and Health Surveillance ................................................................................ 15 6. Use of Specialist Linea-Cladding Contractors ........................................................................................... 15 Audit of Site Activities to Validate the Application and Effectiveness of Fibre Cement Controls ................... 16 1. Access to Documentary Information Supporting Safe Work Practices .................................................... 16 2. Use in a Well-Ventilated Location ............................................................................................................ 17 3. Engineering Controls re Local Exhaust Extraction or Containment at Source ......................................... 18 4. Use of Appropriate Cutting Blades ........................................................................................................... 19 5. Use of Dust Masks and Respirators .......................................................................................................... 19 6. Use of Other Protective Personal Equipment .......................................................................................... 20 7. Other Considerations................................................................................................................................ 20 8. Summary................................................................................................................................................... 21 Appendix 1 – SDS for Fibre Cement Products (Linea) .................................................................................. 22 Page 2 of 28 Response to Select Committee Question Posed Question: What processes do Fletcher Building use to identify products that may cause potential harm, and what do they do to mitigate potential harm? Please note that the response to this question is provided using the specific example of fibre cement sheet products, as this was the example product discussed with the Select Committee on 24 November, following questions by one of the members. Executive Summary The hazard posed by silica dust in fibre cement products is well documented on Fletcher Residential building sites, including in the Company’s Hazard Register, Site Safety handbook, Site Specific Safety Plans, training material, hazard notice boards and in warning labels both on the product and its packaging. All cement products contain crystalline silica. However, this is not a health hazard if operations generating dust are managed and / or breathing protection is used to ensure that workers are not exposed to dust concentrations that exceed workplace exposure levels. The controls which must be applied in order to work safely with fibre cement products are well-promoted by the Company. They are also well understood and practiced by Contractors on-site. This includes the need for machining operations to be confined to well-ventilated locations, engineering controls to contain dust at its source, the use of appropriate machining tools, the use of respiratory protection and other personal protective equipment (PPE), training for operators in safe handling practices, environmental monitoring and health surveillance, underpinned by ample safety signage, hazard communication, product warnings and safe handling documentation. Fletcher Residential has extensive safety systems, programmes and resources to ensure that appropriate hazard controls in relation to fibre cement are well embedded and consistently applied across all of its sites. This includes robust processes for Contractor qualification, training, induction and for the development and review of Contractor Site Specific Safety Plans. These are underpinned by the Company’s own hazard identification and control strategies, site safety inspections and monitoring of Contractor safety performance, systems to identify and manage non-compliances, environmental monitoring and health surveillance programmes and by an emerging trend of contracting specialist fibre cement installers who are proving to be better resourced and equipped to work with the product. An audit of the Company’s primary sub-divisional development at Stonefields in Auckland was undertaken to validate the application and effectiveness of fibre cement controls. The audit found that there was ready access to documentation on safe work practices with fibre cement products. It also found consistently good practices in place when working with fibre cement products including; restricting activities to well-ventilated locations, using local exhaust extraction and dust containment at source to prevent particles becoming airborne, selection of and use of appropriate machining and tooling equipment, consistent use of appropriate respiratory protection and other PPE. Opportunities for continuous improvement had been identified, with some already seized-upon, particularly in respect of lifting the standard of engineering controls, improving dust containment particularly during clean-up and disposal, tighter monitoring of Contractor compliance, extending training programmes and developing integrated PPE-management programmes. Page 3 of 28 Response to Select Committee Silica Dust in Construction WHAT IS SILICA? Silica is a natural substance found in materials on construction sites, such as concrete, bricks, rocks, stone, sand and clay. Dust containing silica is created when these materials are cut, ground, drilled or otherwise disturbed. If the silica particles in this dust are small enough (known as respirable crystalline silica or RCS) it can be breathed deep into the lungs and cause damage. The dust that can be breathed in is not always visible to the naked eye. Tasks which may expose construction workers to silica dust include: • Sawing, hammering, sanding, drilling, grinding and chipping concrete or masonry (bricks, stone and fibre cement products). • Demolishing concrete and masonry structures. • Abrasive blasting of concrete and other materials (especially where sand is used as the abrasive). • Dry sweeping or the pressurised air blowing of concrete and rock. • Chipping, hammering and drilling rock. Also the crushing, loading, hauling and dumping of rock. Page 4 of 28 Figure 1 - Silica is the second most common element found on earth Response to Select Committee Awareness of the Hazard and Controls There is a high level of awareness on Fletcher Residential building sites of the hazard presented by fibre cement products. There is a similarly high level of awareness of appropriate controls to protect workers from harm. This awareness is driven from the following: 1. Hazard Register The hazard of airborne vapours, fibres and dusts (including fibre cement and silica) is well documented in the Company’s hazard register. Figure 2 (below) details the hazard and applicable controls from the latest version of the register Figure 2 - Hazard Register Entry re Fibre Cement Dusts, Silica The hazard register is reviewed regularly (most recently on 19th September 2014) and provided to Fletcher Residential Contractors following each review. The latest edition of the hazard register was provided to 260 Contractors on 22nd September 2014. The range of controls to be applied as detailed in the hazard register includes: • • • • • • Engineering controls providing local exhaust extraction Operations to be undertaken in well ventilated areas at source of dusts (i.e. cutting) Mandatory use of Protective Personal Equipment (PPE) including dust masks and respirators Monitoring of the workplace for respiratory hazards Health Surveillance (i.e. lung function testing) of Fletcher Residential personnel Outputs from monitoring fed back into the hazards management process The hazard register contains additional controls around hazardous substances generally as detailed in figure 3 (below). The range of controls highlighted includes: • • • • • • Page 5 of 28 Hazardous substance being detailed in Contractor Site Specific Safety Plans (SSSP) Fletcher Residential reviewing and approving hazardous substances Hazardous substances to be accompanied by Safety Data Sheets (SDS) Emergency Management Plans to be prepared by Contractors and approved by Fletcher Residential PPE as detailed in the SDS to be worn Adequate ventilation Response to Select Committee • • Safe storage and handling Limiting quantities to the smallest quantities required for current operations Figure 3 – Hazard Register Entry re Hazardous Substances Generally 2. Site Safety Handbook The Fletcher Residential Site Safety Handbook details safe work procedures and site safety rules applicable to all Company building sites. The Site Safety Handbook is reviewed regularly (most recently on 19th September 2014) and provided to Fletcher Residential Contractors following each review. It is also used to support induction of new Contractors. The most recent version was provided to 260 Contractors on 22nd September 2014. The Site Safety Handbook summarises the hazard controls applicable to Fibre Cement Dusts, Silica and Hazardous Substances generally. Additionally it establishes minimum PPE requirements as shown in figure 4 (below): Figure 4 - Extract from Site Safety Handbook 3. Safety Data Sheets The hazard register establishes the requirement that all hazardous substances introduced to site must be accompanied by current and applicable Safety Data Sheets (SDS). SDS are held at each Fletcher Residential Divisional Office and are able to be produced within 10 minutes as required under the Hazardous Substances and New Organisms Act 2006. Safety Data Sheets have historically been distributed to Contractors on an ad-hoc basis. A recent continuous improvement initiative has identified the need to obtain and compile all SDS into a Page 6 of 28 Response to Select Committee compendium (paper and electronic) and issue to all Contractors periodically, and to new Contractors on induction. This initiative is ongoing. The SDS for James Hardie Fibre Cement Sheet Products (including Linea weatherboard) is attached as Appendix 1. It establishes the need for the following controls in relation to Linea: • • • • • • • Work outdoors with ample ventilation Minimise dust creation by using recommended tooling and cutting methods Clean work area regularly by wet sweeping or vacuuming Reduce exposures by engineering controls (e.g. process modification, local exhaust ventilation, capturing substances at source) Use safety glasses or dust resistant goggles when cutting Wear protective gloves and clothing Wear dust mask, half-face respirator or full-face respirator 4. Site Specific Safety Plans (SSSP) All Contractors are required to detail any hazardous substances they may use on-site in their Site Specific Safety Plan. Where hazardous substances are used, the Contractor must identify the hazardous substance, record it in the hazardous substances register and submit it for approval by Fletcher Residential as part of their SSSP, together with the applicable safety data sheet (SDS). As a recent continuous improvement initiative, Fletcher Residential has developed a “Head” Site Specific Safety Plan unique to each sub-divisional development. The Head SSSP restates applicable safe work procedures and controls and details other strategies and programmes to keep all personnel safe on-site. The Head SSSP includes a consolidation of all hazardous substances both from Contractor SSSPs and from SDS held by Fletcher Residential. 5. Training Training is provided to Contractors by representatives of James Hardie on an as-required basis. The most recent training was delivered to Auckland North Contractors in July 2014 and prior to that in February 2014 by Greg Jones, Installation Training Manager. Training covers the following:2 • • • Instruction on the hazard of silica and the risks it poses Instruction on safe working practices (see Figure 5 below) including: o Working in outdoor areas with adequate ventilation o Minimising dusts by using recommended cutting practices appropriate to the material (for Linea this is a dust-reducing saw with HardieBlade™ saw blade) o Local exhaust extraction and HEPA filters o Warning others in the immediate area to avoid breathing dust o Wearing a properly-fitted, approved dust mask or respirator (P1 or P2) o During clean-up using HEPA vacuums or wet clean-up methods – not dry sweep Instruction on recommended installation methods Additionally, James Hardie provide an Accredited Contractor programme which supports contractors with the purchase of recommended dust-reducing equipment (saws, drills, fastening tools), extraction systems, HEPA filters and HardieBlade™ saw blades. Fletcher Residential actively promotes participation in this programme by its Contractors. 2 Taken from James Hardie: ‘Best Practice – Working Safely with James Hardie Fibre Cement Products’ March 2014 Page 7 of 28 Response to Select Committee Figure 5 - Extract from 'Best Practices' Training Document Page 8 of 28 Response to Select Committee 6. Product Warning Labels and Markings Linea weatherboard is delivered to site on shrink-wrapped pallets. The shrink–wrap contains the following warning label which is prominently displayed: Figure 6 - Warning Label on Linea Packaging Additionally, each panel of weatherboard is embossed with the following warning: “Product contains sand, a source of respirable silica. Do not breathe dust as it may lead to serious personal injury or death. Follow installation instructions and MSDS” Figure 7 – Sheet of Linea Weatherboard Embossed with Warning Message Page 9 of 28 Response to Select Committee 7. Hazard Boards A recent continuous improvement initiative has seen the introduction of hazard boards to Fletcher Residential building sites (see Figure 6 below). The hazard board details silica dusts as a hazard when applicable (i.e. when Linea is being machined) and allows applicable controls to be detailed. It also reinforces the Company’s rule of, “Never operate equipment without guards and safety devices in place”. Hazard Boards will be situated at appropriate entry points to sites or otherwise prominently within the sub-division and will be referenced when inducting visitors to site. Figure 8 - Hazard Board Detailing Silica Hazards and Controls Page 10 of 28 Response to Select Committee Programmes to Support the Embedding of Hazard Controls for Fibre Cement The following programmes exist to ensure that recommended hazard controls are applied and embedded on all Company sites. This applies to both hazardous substances generally and to fibre cement (Linea) hazards specifically. 1. Contractor Qualification, SSSP and Induction Processes Robust processes exist to ensure Contractors are appropriately qualified, trained, resourced and inducted to work safely on Fletcher Residential sites. This includes the following requirements: • That all tasks be detailed, risk assessed and controlled in a written task analysis (JSEA) which is to be submitted by each Contractor / Sub-Contractor as a component of their Site Specific Safety Plan (SSSP). Each task analysis must to be reviewed and approved by Fletcher Residential before work commences. Working with hazardous substances is among a handful of tasks which are identified by the Company as involving specialist procedures and considerations. • That all Contractors, Sub-Contractors and their Employees hold a Site Safe Building Construction Passport (or equivalent) as a minimum requirement. Site Safe passports ensure that each person on-site has a basic level of safety training with the requirement for refresher training two yearly. • That all Contractors, Sub-Contractors and their Employees are inducted so as to be able to perform their duties safely and competently while on site. Contractor inductions include: o o o o o o o Page 11 of 28 Site Specific Safety Plans Fletcher Residential safe work procedures Hazards and applicable controls Accident and hazard reporting requirements Emergency procedures Protective Personal Equipment (PPE) requirements Site Safe passport training • The provision of training and competency registers for all Sub-Contractors and Employees indicating an appropriate level of competency or the provision of appropriate supervision. • In addition to acknowledging hazards identified by Fletcher Residential, all Contractors are required to detail hazards which they introduce in the course of their work and applicable controls. • Disclosure of any hazardous substances they may use on-site. All hazardous products must be stored and handled according to the safety data sheet (SDS), including the use of any applicable personal protective equipment. If a specific emergency response in relation to hazardous substances is required to be developed (e.g. spill procedures), then these must be detailed in the Site Specific Safety Plans. • Detail the nature and frequency of safety consultation and communication strategies they will utilise while on-site, including: toolbox talks, pre-start assessments, health and safety meetings and co-ordination meetings. • Identify and detail all potential emergency scenarios as part of their SSSP including: Response to Select Committee o o o o o o o • Responsibilities Evacuation Procedures Assembly areas Alarms First Aiders Key Contact Numbers Procedure to communicate emergency information to Employees / Sub-Contractors Additionally, Contractors shall be responsible for adhering to the safe work practices and any other health and safety requirements of Fletcher Living and for ensuring they comply with all relevant health and safety legislation and regulations. 2. Hazard Identification and Control Fletcher Residential does not manufacture any hazardous products. However numerous hazardous substances are introduced to site, either by Fletcher Residential or by its Contractors. The following section describes the Company’s systems for the management of hazards, including hazardous substances. Fletcher Residential has established robust hazard management strategies, including in relation to hazardous substances, to ensure all workplace hazards are being appropriately identified, assessed and controlled. This is achieved by undertaking all hazard management work in conjunction with employees, maintaining a hazard register to document all safety issues and controls and training all employees in the use and application of controls for each identified hazard likely to affect them. This includes: Hazard Identification: Hazards are systematically identified prior to commencement of each stage of the sub-divisional development. Hazard identification is also carried out throughout the development duration. Hazards are recorded in the Hazard Register and are also posted on site Hazard boards and kept up to date. Hazards are systematically identified using a range of techniques including, but not limited to: o o o o o o Task analysis Area analysis Process analysis Review and analysis of hazardous substance registers Employee and Contractor incident reporting Outcomes from incident investigations Hazard Assessment: All identified hazards are assessed with regard to their potential to cause harm and the type of harm likely. These are detailed in the Hazard Register. All assessments of risk or likelihood are conducted in consultation with employees from the areas where the hazards were identified. These employees will be competently trained and suitably experienced to be able to assess the risk and identify the practical controls for a task analysis. Each of the hazards is then evaluated to determine its Hazard Rating. The two factors to be considered are; severity (what is the potential to cause harm when someone comes in contact with the hazard) and probability (to what extent is anyone exposed to the hazard)? All identified hazards are categorised as either significant hazards or other hazards. The Company’s Health and Safety Committee reviews all site hazard reports. All significant hazards and controls that are new will be entered into the Hazard Register. In this way all sites are aware of the hazard when the Hazard Register is used for induction or training of new Employees or Contractors. Hazard Control: All hazards are controlled and significant hazards are controlled through the application of the three-step control hierarchy of elimination, isolation or minimisation (in descending order of preference). The final choice of the control option is based on factors such as: Page 12 of 28 Response to Select Committee o o o o The nature and severity of harm that could be caused The risk of injury or illness occurring from exposure to the hazard The techniques currently available to control the hazard The availability and cost of each of the possible control options. Having identified and assessed all hazards, Fletcher Residential takes “all practicable steps” to control each significant hazard, based on the factors listed above, using the hierarchy of controls. If minimisation is the only option, then each Employer on-site (including Fletcher Residential in relation to its Employees) is required to: o o o Provide personal protective equipment (PPE), and ensure there is a system to ensure it is used; Monitor employees’ exposure to the hazard, and; With the informed consent of employees, monitor the health of employees in relation to the hazard. Hazard Monitoring: Monitoring of hazard control measures is achieved through: o o o o o o o o Site inspections Safety observations Near miss reporting Site audits Review of Safety Data Sheets (SDS) Environmental monitoring Periodic employee health monitoring Obtaining specialist advice A continuous improvement initiative to improve the Company’s system for managing hazardous substances is the undertaking of a comprehensive MOSHH assessment as per the Approved Code of Practice for the Management of Substance Hazardous to Health in the Place of Work. The initiative is proposed for early 2015. 3. Site Safety Inspections and Monitoring of Contractor Safety Performance A robust system exists for the monitoring of Fletcher Residential sites to ensure compliance with Safe Work Procedures (including those in relation to fibre cement products). Fletcher Residential sites are subject to a schedule of safety inspections and monitoring activities including: Page 13 of 28 • Daily monitoring of the site by Fletcher Residential Construction Supervisors, with noncompliances reported in the Company’s event management system. The documentation used for reporting non-compliances is shown in Figure 9 below and prompts the Supervisor both in relation to hazardous substances (SDS available, properly stored, safely handled, appropriate PPE available) and in relation to PPE (dust mask / respirator provided, worn, in good condition). • Detailed Site Safety Inspections (audits) – completed monthly by Construction Supervisors • Safety Observations completed monthly by Senior Managers in which Contractors are engaged in face-to-face conversations around safe and unsafe behaviours. • Informal safety reporting by any person on site who witnesses either an unsafe condition or unsafe behaviour. Contractors are encouraged to self-report safety concerns; although little traction has been achieved to date. More work is needed here as Contractor self-reporting to Response to Select Committee the Company presents a valuable opportunity to work collaboratively on improving safety management. • Additional inspection regimes by Contractors as detailed in their Site Specific Safety Plans. Figure 9 - Site Safety Inspection Form 4. Non-Compliance Reporting An equally robust system exists for the reporting of non-compliances. Where any inspection identifies an unsafe condition or unsafe behaviour, corrective action must be taken to remedy the deficiency. Corrective Actions are to be recorded on the inspection documentation and entered into the Company’s event management system. A date by which corrective actions are to be taken is recorded. Unsafe acts and conditions are rectified as soon as is physically possible. Where delays in resolution are expected, such situations will be made safe immediately and progress on full correction communicated to employees on a regular basis. Corrective Page 14 of 28 Response to Select Committee action-due reminders will be automatically generated for the action owner prior to the due date and will be escalated to Senior Managers. A review of all reporting in the 2014 calendar year indicates only one reported non-compliance with Linea weatherboard; that being a failure to wear required PPE. Figure 10 (below) details all PPE non-compliances for the same period and indicates only the one violation in relation to Respirators. PPE Violations 2 4 10 4 1 Eye Protection Hard Hats Hi-Viz 32 Footwear Hearing Protection Respirator Figure 10 - PPE Violations 2014 YTD 5. Environmental Monitoring and Health Surveillance Fletcher Residential is currently extending its environmental monitoring and health surveillance programme on all Company sites. Environmental monitoring is proposed to include silica, treated timber dusts, synthetic manmade fibres and nuisance dusts. As these operations are undertaken in a wellventilated, outdoors environments, it is believed that exposures for each are well below the applicable Workplace Exposure Standard (WES) levels. Appropriate information and recommendations will be provided to Contractors as outputs from the Company’s environmental monitoring and health surveillance programmes. 6. Use of Specialist Linea-Cladding Contractors Fletcher Residential has been trialling a programme in which specialist Linea installers are contracted in place of general Carpenters and Joiners. James Hardie operates an Accredited Installer programme in which Specialist Contractors, who have adopted best practice methods and equipment, are recommended as specialist installers of fibre cement products. To-date, two Linea cladding specialist firms have been contracted. One of those was included in the audit detailed in section 4 (below). This programme may be widened further if performance-based outputs support the initiative. Page 15 of 28 Response to Select Committee Audit of Site Activities to Validate the Application and Effectiveness of Fibre Cement Controls On 25th November 2014 a comprehensive audit and observation of work practices in relation to Linea weatherboard was undertaken at Stonefields, Auckland to validate the effectiveness of existing controls. Stonefields is the Company’s foremost sub-divisional development with the largest concentration of Contractors nationwide. The audit involved observation of workplace practices and interviews with all six Carpentry/Joinery Contractors on-site in relation to their understanding of the hazards posed by silica and application of recommended controls. Those interviewed were the Principals, and some employees of: o o o o o o Anton Homes Kingsford Consulting DBG Builders G&V Construction JADS Ltd. Multiquip Ltd. (a specialist Linea cladding Contractor) 1. Access to Documentary Information Supporting Safe Work Practices All Contractors spoken to had a good level of understanding in relation to the hazard and risks posed by silica. There was also a good understanding of the applicable controls and safe working practices. All Contractors were able to produce documentation from their vehicles which highlighted hazards and safe work practices in relation to Linea. Safe Work Documentation used by G&V Construction Safe Work Documentation used by Multiquip Ltd Safe Work Documentation used by DBG Builders Safe Work Documentation used by JADS Ltd Page 16 of 28 Response to Select Committee 2. Use in a Well-Ventilated Location All Contractors were observed to have set-up their primary Linea cutting operation in a well-ventilated location outside of the building structure. Platforms were provided on scaffolds to facilitate cutting operations outside of the building when working on upper floors. When cutting within the building itself it was noted that there were no internal wall linings present, with the building consisting of frames only to all sides. One Contractor acknowledged cutting within an open garage, which had block walls to three sides (although this was not observed). He was instructed to relocate his cutting to outside of the garage. The Construction Supervisor for the site was asked to closely monitor the Contractor’s compliance moving forward. All Contractors claimed to warn other personnel nearby when Linea cutting operations were about to commence and advised them to keep clear of dusts. They also claimed to exercise situational awareness around the prevailing wind direction and impact on others likely to be in the dust path. This practice was not able to be observed during the audit. There needs to be continued focus on this control element so as to lift the overall performance of the safety management programme. Additionally there are opportunities for continuous improvement in identifying and eliminating any lingering dry-sweeping practices and supporting improvements around disposal of waste product. External Cutting Setup of Multiquip External Cutting Setup of Anton Homes Page 17 of 28 Linea Stacked on Dedicated Scaffold Platform to Support External Cutting When Working on Upper Floors Response to Select Committee 3. Engineering Controls re Local Exhaust Extraction or Containment at Source All Contractors were observed to be using some form of local exhaust extraction or containment at source. Only two of the Contractors were presently undertaking Linea operations and had drop-saws available for inspection. Both had local exhaust extraction with a “tool start” feature attached to a vacuum system and HEPA filter. This is the ideal engineering control and needs to be promoted amongst all Contractors as the required standard. All Contractors had skill saws with local exhaust extraction systems. Two had attachments allowing the saw to be connected to their HEPA vacuum systems (again the standard to be aspired to by all). The other Contractors used a less reliable dust collectors attached to the saw. Tool-start vacuum HEPA of Anton Homes Vacuum HEPA of Kingsford Consulting Dust Collector attached to Hitachi C7YA circular saw of G&V Construction Tool-start vacuum HEPA of Multiquip Ltd Page 18 of 28 Response to Select Committee 4. Use of Appropriate Cutting Blades All Contractors were observed to be using dust-reducing HardieBlade™ saw blades. The dust reducing blades generate larger dust particles and reduce the risk of respirable silica. Blades were observed on both the drop saws and circular saws. HardieBlade on Anton Homes drop-saw HardieBlade used by G&V Construction HardieBlade used on DBG Builders circular saw HardieBlade on circular saw of JADS Ltd 5. Use of Dust Masks and Respirators Awareness of the need to wear respiratory protection was widely understood. All Contractors were found to have supplies of appropriate respiratory protection in their vehicles. On inspection, all were found to be using P1 or P2 particulate masks or respirators compliant with AS/NZS1715: 2009, Selection, Use and Maintenance of Respiratory Protective Equipment. One Contractor acknowledged that his practice was to use either local exhaust extraction or respiratory protection. The Contractor was advised that as per the Safety Data Sheet for Linea, the requirement was to use engineering controls and PPE. The Construction Supervisor for the site was asked to closely monitor the Contractor’s compliance moving forward. Page 19 of 28 Response to Select Committee P1 particulate face mask used by Anton Homes P2 particulate face mask used by G&V Construction Half-face particulate respirator used by DBG Builders Half-face particulate respirator used by Multiquip Ltd. 6. Use of Other Protective Personal Equipment All Contractors acknowledged that they used eye protection and protective gloves when working with Linea as recommended by the Safety Data Sheet. Additionally all claimed to use hearing protection when operating saws. The chart shown as Figure 10 tends to support this with only a handful of violations being observed in respect of eye protection and hearing protection and none in respect of gloves. In discussions with Contractors it was observed that all would benefit from adopting a systematic PPE programme which includes selection, fitment, training, maintenance and replacement. This will adopted as a continuous improvement initiative for the forthcoming year. 7. Other Considerations All Contractors reported that they had programs in place, including induction and training, by which they instructed their Sub-contractors and Employees in appropriate controls in relation to Linea. They claimed that the hazard and its controls were well understood and practiced by their personnel. However, all acknowledged that they would appreciate additional Toolbox Talks being developed and provided by Fletcher Residential to drive awareness further. An extensive programme of safety communications including Toolbox Talks is already provided by the Company to its Contractors; however this request will be adopted as a continuous improvement initiative in the New Year. There was a moderate level of awareness of occupational disease in general. When prompted on the subject, all Contractors were willing to be engaged and had anecdotal reports of colleagues or family who Page 20 of 28 Response to Select Committee had either died as a result of occupational illness or who were suffering chronic illnesses now. When drawn further, all were interested in receiving further information and most expressed interest in participating in a program of environmental monitoring or health surveillance. Two Contractors reported that they already participated in a health surveillance programme including lung function testing. 8. Summary Prior to the audit, there was a general perception among Construction Managers and Supervisors that there was a good level of understanding in relation to fibre cement hazards, underpinned by a strong level of safety performance in the workplace. The audit has largely supported this belief, although identified a number of opportunities for continuous improvement. In summary the audit found that: • There were high levels of documentation on-site providing guidance as to safe working practices. This information was well known to all Contractors and readily accessible • Cutting activities were largely confined to either external locations, or to well-ventilated areas within the open structure of the building. There were exceptions with the need for Supervisors to more closely monitor practices • Engineering controls using either local exhaust extraction with vacuum systems and HEPA filters or dust collection systems at the source of dusts were well used. Opportunities should be seized to drive engineering controls toward the higher end. • Use of recommended cutting tools and HardiBlade™ saw blade were well established. • Use of appropriate respiratory protection and other PPE was well understood and practiced. There is however a need for more tightly-integrated PPE programmes and for Construction Supervisors to more closely monitor the workplace with a view to identifying and eliminating noncompliances. A collateral assessment was undertaken at the Company’s Auckland South building sites by the Divisional Construction Manager, John Washington. That assessment largely corroborated the findings of this audit. It found that levels of hazard awareness and safety performance were largely in line with those observed at Stonefields, again with opportunities for continuous improvement as noted above. Page 21 of 28 Response to Select Committee Appendix 1 – SDS for Fibre Cement Products (Linea) Page 22 of 28 Response to Select Committee Page 23 of 28 Response to Select Committee Page 24 of 28 Response to Select Committee Page 25 of 28 Response to Select Committee Page 26 of 28 Response to Select Committee Page 27 of 28 Response to Select Committee Page 28 of 28