5.1. Maintenance of control measures

• WHS Regulation clause 37 - Maintenance of control measures

All control measures must be maintained so they remain effective. This includes ensuring control measures are fit for purpose, suitable for the nature and duration of the work, and installed, set up and used correctly.

For example, a PCBU should conduct daily start up checks to ensure that:

• machine and water mist guards and LEV are fitted correctly and are working effectively
• LEV filters are clean and replaced according to the manufacturer’s instructions
• there is an adequate water supply for water suppression, and
• all RPE is in good, working condition and fit checked.

A PCBU should routinely monitor the workplace for signs of visible dust on work surfaces or clothing as that may be an indication that some controls are not working effectively.

Plant inspection and maintenance

Silica dust is abrasive and can damage and wear plant, including engineering controls.

Plant must be routinely inspected, maintained and repaired according to the manufacturer’s specifications or, in the absence of such specifications, in accordance with a competent person’s recommendations.

Inspection of plant should identify any:

• wear and tear, corrosion or damaged parts
• air leaks in pneumatic tools
• kinks, holes or leaks in water suppression, exhaust ventilation or dust extraction equipment
• filters in need of replacing, and
• damage to guards and flaps that contain water spray.

Hand-held powered tools should be regularly inspected, repaired or replaced when necessary, and any damaged or worn parts (such as grinding wheels) identified should be replaced.

A system of routine daily checks on plant and equipment designed to control dust should be implemented to ensure they are working effectively. Failures or problems identified should be rectified and workers should be encouraged to report concerns to the PCBU.

More information on plant inspection and maintenance can be found in the Code of Practice: Managing risks of plant in the workplace.

Maintenance of RPE

A PCBU must ensure that RPE is maintained, repaired or replaced so that it continues to be effective. A competent person should administer an RPE maintenance program in accordance with the manufacturer’s instructions.

A maintenance program should include procedures for:

• daily cleaning and inspection of RPE by the worker for wear, damage and flat batteries
• appropriate storage:
  • each worker should be provided with a dry, clean and sealed container to store their RPE
  • clean, dry RPE should be stored away from dust and out of direct sunlight, and
  • face pieces should be stored so that they are not subject to distortion
• identification and repair or replacement of any worn or defective components of the equipment including filters (including availability of replacement parts)
• regular periodic inspection, maintenance and testing of RPE in accordance with the manufacturer’s instructions
• record keeping, including:
  • details of any issues, including the date
  • user records including training provided
  • fit testing records for each worker including:
    • type of test performed
    • make, model, style and size of respirator tested
    • date of the test
    • result of the test

• maintenance records including filter replacement and RPE maintenance schedules, and
• RPE program records, including procedures for use and audits or evaluations.

An RPE maintenance program should also consider the environmental conditions the RPE is being used or stored in (for example, hot work vehicles) as the rubber seals may deteriorate and require replacing more frequently.

5.2. Review of control measures

• WHS Regulation clause 38 - Review of control measures

A PCBU must routinely review the control measures they have put in place to ensure they are effective and protect the health and safety of their workers.

Undertaking air monitoring to measure the airborne concentration of silica dust in the workplace is one way to check the effectiveness of controls.

If control measures are not working effectively, a PCBU must revise them to ensure effective risk control measures are implemented. A PCBU can use the same steps that were taken during the initial hazard identification to check control measures.

A PCBU must consult with their workers and, where applicable, their HSRs. They should consider:

• key triggers that may indicate when controls are not working to their designed specification or operation
• the results of air monitoring, in particular whether the workplace exposure standard is being exceeded (see section 3.1)
• any health monitoring reports that recommend reviewing the control measures (noting that health monitoring results must not be disclosed to any person without the worker’s consent)
• if and when workers have become or have reported feeling unwell
• the outcomes of consultation with workers (or their representatives) and HSRs, or worker complaints
• any new hazards the control measures have introduced
• any new hazards proposed control measures could introduce
• any other respirable dust hazards
• if new work methods or new equipment have made the job safer
• if safety procedures are being followed
• whether the training and instruction provided to workers on how to work safely has been successful
• whether workers are using the supplied PPE during relevant work tasks
• whether there has been a reduction in the frequency and severity of incidents, and
• if new legislation or new information has become available and whether it shows that the current controls may no longer be the most effective.

If problems are identified, a PCBU should go back through the risk management steps, review information and make further decisions about risk control.

More information on the risk management process and the hierarchy of control measures can be found in the Code of Practice: How to manage work health and safety risks.