SMF008
Individual / Organisation: Australian Institute of Occupational Hygienists Inc. (AIOH)
What state/territory are you from?
Incorporated in Victoria but representing its members from all States and Territories
Proposed Amendments to the Workplace Exposure Standard (WES) - Public Comment
Response Form
Complete and submit this form by5PM AEST FRIDAY 8 JUNE 2012to chemicals@safeworkaustralia.gov.au
EXPOSURE STANDARDS FOR SYNTHETIC MATERIALS
Section/page no.
Comment
Issues Paper
The AIOH has issued a Position Paper on synthetic mineral fibres (SMF), which
includes the assessment of health risks, and provides advice to its members as
to the application of an exposure standard so as to control adverse effects at
elevated dust levels. SWA has attached this as suitable background information
to the proposed changes to the WES for SMF.
AIOH considers that the 2002 review by the International Agency for Research
on Cancer (IARC) and subsequent studies listed in the AIOH Position Paper
along with the European classification system of testing to NOTA Q
specifications (Note Q in Australia) exonerates SMF (except for refractory
ceramic fibre (RCF)) from classification as a human carcinogen, and hence the
current respirable fibre exposure standard is inapplicable (except for RCF).
AIOH is of the professional opinion that a Workplace Exposure Standard still
needs to apply to SMF for the following reasons;
1.
It is well documented that exposure to elevated levels of all forms of SMF
dust results in a mild mechanical irritation to the upper respiratory tract
which is temporary and appears not to imply long term health effects. It is
our members experience from monitoring SMF processes and applications
that keeping Inhalable Dust levels below 2 mg/m3 minimises this irritant
effect.
2.
During the removal of, or demolition of structures containing either
low/moderate temperature performance or high temperature performance
SMF products, considerable dust levels may be created, and it is our
member’s experience that such dust consists not only of SMF but of other
disturbed materials such as dust from accumulated industrial fallout,
building waste and debris, and breakdown of any supporting matrix. As
such the AIOH considers that an Inhalable Dust Workplace Exposure
Standard be applied so as to minimise/prevent conditions that may arise in
workers such as upper respiratory tract and eye irritation, rhinitis and the
unpleasant deposition of such dust on mucous membranes.
As such the AIOH supports the changes to the Workplace Exposure Standard.
AIOH requests that the use of SMF products that have been tested and found
to comply with the European Note Q exoneration, which implies lowbiopersistence in human lung tissue, be encouraged.
.
Issues Paper
Appendix A
The current and the proposed notification to end users of SMF for Note Q
Page 1 of 2
SMF008
Individual / Organisation: Australian Institute of Occupational Hygienists Inc. (AIOH)
What state/territory are you from?
Incorporated in Victoria but representing its members from all States and Territories
tested products in SWA documents is minimalistic and difficult to comprehend
by members of the public and workers in general.
The AIOH requests that a suitable explanation of such testing and the issues
surrounding it be placed in the classification and WES for SMF.
AIOH Position
Paper
AIOH stands by the technical conclusions listed in its Position Paper as being a
comprehensive review of the then existing knowledge and practice.
Do you agree with the amendments to the workplace exposure standard for mineral wools, previously known
as synthetic mineral fibres, as revised?
Yes, for the above reasons.
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