Engineered Stone Legacy Removal SWMS (Post-Ban)

Engineered stone legacy removal covers the removal, repair, minor modification and disposal of engineered stone benchtops, panels and slabs that were installed before the national prohibition took effect. From 1 July 2024 the manufacture, supply, processing and installation of engineered stone benchtops, panels and slabs is prohibited across Australia because of the rapid and severe silicosis seen in engineered stone fabrication workers. Critically for this work, the prohibition does not require installed engineered stone to be torn out — a fitted benchtop is safe while it remains undisturbed — but the moment it is cut, ground, drilled or broken to remove it, it becomes one of the highest respirable crystalline silica (RCS) hazards in any trade, because engineered stone can exceed 90 per cent crystalline silica by mass.

Work on legacy engineered stone sits inside a specific permitted-work and notification framework, not the ordinary cutting regime. Removing, repairing, minor-modifying or disposing of legacy engineered stone is permitted, but the work is controlled processing of a crystalline silica substance and the WHS regulator must be notified before the work is carried out, where processing means using a power tool or other mechanical plant to crush, cut, grind, trim, sand, abrasive polish or drill the stone. The controlling exposure figure remains 0.05 mg/m3 as an eight-hour time-weighted average, reframed as a workplace exposure limit from 1 December 2026, and because engineered stone is so silica-rich, wet methods, on-tool extraction and respiratory protection must all be applied together. This document is written on the basis that legacy removal is high-risk silica work requiring a silica risk control plan, regulator notification, air monitoring and health monitoring.

Hazards identified

9 hazards covered, sorted by priority.

Control measures

Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.

1. 1Elimination: where the benchtop can be removed whole without on-site processing — unfastened and lifted out intact — do so, eliminating the silica-generating cutting entirely.
2. 2Substitution: where the slab must be sectioned, use wet cutting rather than dry grinding, and break the work into the fewest cuts that allow safe removal.
3. 3Engineering: wet methods with water delivered to the cutting face, combined with on-tool dust extraction through an H-class (HEPA) vacuum, applied together because of the very high silica content of engineered stone.
4. 4Engineering: isolate the work area with containment or local exhaust where the layout allows, and protect surfaces so settled dust can be removed completely.
5. 5Administrative: notify the WHS regulator before carrying out the legacy engineered stone work, as required by the permitted-work notification framework for removal, repair, minor modification and disposal.
6. 6Administrative: prepare a silica risk control plan before the work commences, given that legacy removal is high-risk processing of a crystalline silica substance, and make it available at the workplace.
7. 7Administrative: arrange air monitoring to validate that the controls hold below the exposure standard, and notify the regulator of any result that exceeds the standard within the prescribed period.
8. 8Administrative: enrol workers in health monitoring supervised by a registered medical practitioner, including respiratory function testing and low-dose high-resolution chest CT, and retain records confidentially for at least 30 years.
9. 9Administrative: provide full decontamination — wet wipe-down and H-class vacuuming of the area, tools and equipment, and worker decontamination — before leaving the work area, and never transport contaminated items or clothing uncontained.
10. 10Administrative: double-bag or seal engineered stone waste and dust, label it, and dispose of it in line with jurisdictional waste requirements at an appropriate facility.
11. 11PPE: a powered air-purifying respirator is recommended for engineered stone removal given the silica load, at minimum a fit-tested P2 respirator, selected and maintained per AS/NZS 1715 and AS/NZS 1716, with disposable coveralls that are removed and bagged on decontamination.
12. 12PPE: hearing protection, eye protection to AS/NZS 1337.1, gloves, and Class I or Class II safety footwear with protective toecap to AS/NZS 2210.3.
13. 13Administrative: all workers must hold a valid White Card (General Construction Induction Training, CPCCWHS1001) before entering any construction workplace.
14. 14Administrative: conduct a pre-start toolbox talk covering the removal sequence, dust controls, decontamination and waste handling, record attendance, and review and update this SWMS whenever the work scope changes, after any incident, when a worker or health and safety representative raises a concern, or at minimum every 12 months.

Applicable Codes of Practice

High-Risk Silica Work triggered

Worked example

A stonemasonry contractor is engaged to remove an installed engineered stone kitchen benchtop, fitted in 2021, as part of a kitchen renovation. Because the benchtop predates the prohibition it is legacy engineered stone, and removing it is permitted work — but only as controlled high-risk processing of a crystalline silica substance. Before the job the contractor notifies the WHS regulator of the legacy engineered stone work and prepares a silica risk control plan that is kept on site. The crew first attempts to release the benchtop whole by removing the fixings and lifting it out intact, eliminating cutting; where a section must be cut to clear a return, a wet-cut tool with water to the blade is used together with an H-class vacuum, because the stone is silica-rich. The kitchen is sheeted to protect surfaces, and every operator wears a powered air-purifying respirator and disposable coveralls. Air monitoring is conducted to confirm the controls hold below the exposure standard. On completion the area, tools and equipment are wet-wiped and H-class vacuumed, the workers decontaminate and bag their coveralls, and the stone and dust are sealed, labelled and disposed of at an appropriate facility. Monitoring records are retained and the workers are enrolled in health monitoring with a registered medical practitioner.

Related legislation

• Model Work Health and Safety Act — primary duty of care; the duty to consult workers; the reckless-conduct offence; and notifiable-incident provisions, as enacted in each jurisdiction.
• Model Work Health and Safety Regulations — the prohibition on engineered stone benchtops, panels and slabs from 1 July 2024; the permitted-work and notification framework for removal, repair, minor modification and disposal of legacy engineered stone; and the crystalline silica high-risk processing, silica risk control plan, air monitoring and health monitoring provisions, as enacted in each jurisdiction.
• Workplace exposure standard for respirable crystalline silica: 0.05 mg/m3 (eight-hour time-weighted average), which must not be exceeded; reframed as a workplace exposure limit from 1 December 2026.
• Engineered stone waste must be disposed of in line with jurisdictional waste management requirements at an appropriate facility.
• Victoria operates under the Occupational Health and Safety Act 2004 and the Occupational Health and Safety Regulations 2017, with the engineered stone prohibition, legacy-work and silica provisions applying through the Victorian instruments.

Frequently asked questions