After about 7 calls from contractors asking where they could purchase P2 masks from due to supply chain disruptions, I contacted Work Safe Queensland on what would happen on site if a contractor was unable to get their preferred mask due to this.
The following is their response, which in short suggests the movement away from disposables to half face reusable as filters are more readily available.
Anyone who requires mask fit testing can book a time through our website https://www.awciqld.org.au/mask-fit-testing/
Thank you for your enquiry relating to the unavailability of respirators for use when working with products containing Crystalline Silica and the likelihood of Penalties being applied for not wearing protection.
If the risk is such that respiratory protective equipment (RPE) is required to prevent inhalation of airborne contaminants, then the lack of RPE supply would not be an excuse under reasonably practicable grounds to perform the task without the RPE.
Section 18 of the Work Health and Safety Act (the Act) defines Reasonably Practicable as: –
Reasonably practicable means that which is, or was at a particular time, reasonably able to be done to ensure health and safety, taking into account and weighing up all relevant matters including: –
- the likelihood of the hazard or the risk concerned occurring
- the degree of harm that might result from the hazard or the risk
- what the person concerned knows, or ought reasonably to know, about the hazard or risk, and ways of eliminating or minimising the risk
- the availability and suitability of ways to eliminate or minimise the risk
- after assessing the extent of the risk and the available ways of eliminating or minimising the risk, the cost associated with available ways of eliminating or minimising the risk, including whether the cost is grossly disproportionate to the risk.
So, for certain airborne contaminants such as silica and asbestos, “the degree of harm that might result from the hazard or the risk” is high so the duty holder would not be able to use “the availability” (or unavailability) of disposable P2 RPE as a defence under Section 19 of the Act
This is because there are other suitable RPE options available such as PAPR reusable respirators that have a P2 filter attached to the respirator. The concern regarding lack of availability of disposable P2 respirators does not relate to these reusable respirators. A pre-filter can be used on the P2 filter to extend its usability period and training on the use and maintenance of the respirator and filter can be readily provided. Such training would include the wiping down of the respirator and main filter, disposal of the pre-filter after each use and the storage of such in a clean and robust container.
Regarding silica dust, the use of PAPR reusable respirators that have a P2 filter attached to the respirator will provide the same level of protection as the disposable P2.
As the potential decreased availability of disposable P2 respirators is foreseeable then there is time for employers to select the reusable PAPR respirators and fit-test workers accordingly and provide the training needed.
With regard to the artificial stone benchtop industry, the related code of practice removes the discretion of the employer regarding what RPE is to be used, i.e., a Powered Air Purifying Respirator is mandated, so the issue of potential unavailability of disposable P2 respirators is not relevant to this industry sector.
As always with RPE, knowledge of the likely airborne concentration of the contaminant should be an integral part of the decision on selection of any respirator and filter. A Certified Occupational Hygienist can assist with this.
Considering the information above, it is possible that penalty action could be imposed by an Inspector.
It is hoped this information is appropriate to your enquiry. However, if you require additional information or require clarification of the information provided, please contact Licensing and Advisory Services on 1300 362 128.
Licensing and Advisory Services
Workplace Health and Safety Queensland
Office of Industrial Relations