Silica Management Plan for Construction: Mandatory Requirements and Best Practice

From October 2025, all PCBUs who direct workers to carry out work involving respirable crystalline silica must establish and maintain a silica worker register. The register must record the identity of each worker, the nature of the work involving silica exposure, the dates on which the worker carried out that work, and the results of any health monitoring conducted for that worker. This register serves a dual purpose. It provides the PCBU with a tool to track cumulative exposure across its workforce, and it creates a longitudinal record that supports epidemiological research into silicosis and other silica-related diseases. The register must be kept for at least 40 years from the date of the last entry, reflecting the long latency period of silica-related diseases. PCBUs must ensure the register is updated in real time as workers commence and cease silica-related tasks. A spreadsheet stored on a shared drive is technically compliant but a purpose-built system with automated reminders and audit trails provides far stronger evidence of due diligence in the event of a regulatory inspection or prosecution.

The current workplace exposure standard for respirable crystalline silica in Australia is 0.05 milligrams per cubic metre as an eight-hour time-weighted average. From December 2026, the new workplace exposure limit under the harmonised WEL framework will halve this value to 0.025 milligrams per cubic metre. This reduction reflects the growing body of evidence that silicosis can develop at exposure levels previously considered safe. For construction businesses, meeting the new limit will require more than incremental improvements. Many common construction tasks including concrete cutting, grinding, drilling, demolition, and tunnelling routinely generate airborne silica concentrations that exceed even the current standard when controls are inadequate. Businesses that are currently achieving compliance at the 0.05 level may find themselves non-compliant when the limit tightens. The transition period is not an extension to continue operating at the old level. It is time provided for businesses to implement the engineering and administrative controls necessary to meet the lower limit from day one of its commencement.

The revised Code of Practice for Managing Risks of Respirable Crystalline Silica from Engineered and Natural Stone took effect in February 2026. While originally focused on engineered stone, the code has been expanded to address RCS risks across all industries including construction. The code prescribes a hierarchy of controls starting with elimination, such as substituting silica-containing materials with alternatives where practicable. Where elimination is not reasonably practicable, the code requires engineering controls including water suppression, on-tool dust extraction, enclosed cutting systems, and ventilated work areas. Administrative controls such as task rotation, exclusion zones, and exposure time limits supplement but do not replace engineering controls. The code specifies minimum requirements for respiratory protective equipment including the type, fit testing frequency, and maintenance regime. Under Section 26A of the WHS Regulation 2025, compliance with this code becomes a legally binding obligation from 1 July 2026. Construction PCBUs must review their silica management practices against the code and close any gaps before that date.

A compliant silica management plan must begin with a register of all tasks and processes that generate or may generate respirable crystalline silica. For each task, the plan must document the silica content of the material being worked, the expected airborne concentration based on monitoring data or published exposure benchmarks, and the control measures applied to reduce exposure below the workplace exposure limit. The plan must assign responsibility for implementing and monitoring each control measure to a named person. It must include a health monitoring program that specifies the type and frequency of medical examinations for each exposed worker, consistent with the requirements of the WHS Regulation 2025. The plan must describe the training provided to workers on silica hazards, control measures, the correct use and maintenance of RPE, and the symptoms of silica-related disease. Emergency procedures for uncontrolled dust release events must be documented. The plan must specify the review frequency, which should be at least annually or whenever there is a material change in work processes, materials, or monitoring results.

Exposure monitoring for respirable crystalline silica must be conducted using personal sampling methods. Static or area monitoring does not provide an accurate representation of individual worker exposure and is not accepted by regulators as a substitute for personal monitoring. Personal sampling involves fitting a calibrated sampling pump and cyclone to the worker within their breathing zone for the duration of the task or shift. Samples must be analysed by a laboratory accredited by the National Association of Testing Authorities using the gravimetric method for respirable dust mass and X-ray diffraction or infrared spectroscopy for crystalline silica content. Results must be compared against the applicable workplace exposure limit and recorded in the worker's exposure record. Where monitoring results exceed or approach the exposure limit, the PCBU must review and upgrade control measures before the worker is permitted to resume the task. Monitoring should be repeated after any change to work methods, materials, ventilation systems, or RPE to confirm that the revised controls are effective in maintaining exposure below the limit.