The Model Code of Practice for managing respirable crystalline silica (RCS) published by Safe Work Australia is the definitive practical guide to RCS compliance in Australian workplaces. Updated in November 2025, it sets out what employers, contractors, and workers must do to manage the risk of silica exposure. Understanding and implementing it is essential to meet your duty holder obligations under the Work Health and Safety Act.
This guide breaks down the 2025 COP, explains your obligations, and provides actionable steps to implement it in your organisation.
What is the Model Code of Practice?
A Code of Practice (COP) is:
- A detailed practical guide published by a regulator (in this case, Safe Work Australia) that explains how to meet WHS legal obligations
- Not legally binding in itself, but admissible as evidence of compliance in court or regulator investigations
- Endorsed by all Australian state and territory WHS regulators
- Developed in consultation with industry, unions, and experts
- Regularly updated to reflect new evidence and legislative changes
The Model Code of Practice for RCS is distinct from legislation (the WHS Act and Regulations) because:
- Legislation sets the requirement — “Manage the risk of exposure to crystalline silica”
- The COP shows how — specific steps, control hierarchy, monitoring methods, health surveillance procedures
If you follow the COP, you can defend your compliance in the event of a regulator investigation or civil claim. If you don’t follow it, you must demonstrate an alternative approach that is equally effective.
What Changed in the November 2025 Update?
The November 2025 update to the Model Code of Practice incorporated emerging evidence and regulatory refinements:
- Clarified WEL transition — aligned with the December 2026 transition from WES (0.05 mg/m³) to WEL, with guidance on how the COP applies during the transition
- Updated control guidance — reinforced engineering controls as the primary strategy; emphasised local exhaust ventilation (LEV) design standards
- Enhanced health monitoring requirements — clarified who requires baseline and ongoing health surveillance; referenced AIOH guidance on pre-placement and periodic assessment protocols
- Strengthened information and training obligations — specified competency standards for supervisors and hygiene officers; recommended AIOH membership for consultants
- Practical examples — added case studies from Australian worksites (construction, mining, manufacturing) to illustrate control implementation
The full November 2025 update is available on the Safe Work Australia website.
Key Obligations: What the COP Places on Duty Holders
The COP applies to anyone with a duty to manage RCS risk: employers, principals (clients), and self-employed persons. Your key obligations are:
1. Identify RCS Hazards
You must identify where RCS may be present:
- Materials that contain crystalline silica (sandstone, granite, concrete, ceramics, clay, asbestos-containing materials, diatomaceous earth)
- Work tasks that generate RCS dust (cutting, grinding, drilling, blasting, demolition, shotcrete application)
- Worker groups exposed (equipment operators, labourers, supervisors on-site)
Action: Conduct a dust hazard register for each workplace or project. Document all materials and tasks.
2. Assess Exposure Risk
You must assess the risk by considering:
- Exposure likelihood — How often and for how long are workers exposed?
- Concentration — How much silica dust is generated? (This is where exposure monitoring or expert judgement is essential.)
- Available controls — What engineering, administrative, and personal protective equipment controls are already in place?
Action: Use the risk assessment process outlined below (section 7). Document the assessment in your WHS register.
3. Implement Controls (Hierarchy of Controls)
The COP emphasises the hierarchy of controls specific to RCS:
Level 1 — Elimination: Remove the need to work with silica-containing materials or work processes.
– Example: Use synthetic aggregates instead of concrete; use pre-cast components instead of on-site cutting.
Level 2 — Substitution: Replace silica-containing materials with safer alternatives.
– Example: Use engineered stone (with lower silica) instead of natural stone; use rockwool instead of mineral wool.
Level 3 — Engineering Controls: Isolate the hazard or use equipment to control exposure.
– Example: Local exhaust ventilation at grinding stations; water suppression on concrete saws; enclosed cabins on drill rigs.
Level 4 — Administrative Controls: Change work practices to reduce exposure.
– Example: Rotate workers to limit exposure duration; schedule dusty work during low-occupancy periods; use work method permits for high-risk tasks.
Level 5 — Personal Protective Equipment (RPE): Provide respiratory protection as a last resort.
– Example: Fit-tested P2 respirators for workers in uncontrolled exposure environments.
The critical principle: You must work through the hierarchy from top to bottom. RPE alone is not sufficient if higher-level controls are feasible.
4. Monitor Exposure
You must conduct monitoring to:
- Determine whether workers are exposed above the WES (0.05 mg/m³)
- Verify that controls are effective
- Identify tasks or areas where exposure is highest
- Build evidence of compliance
When monitoring is required:
- If you cannot confirm through reasonable investigation that exposure is below the WES, you must monitor.
- If you implement new controls, you must verify their effectiveness with follow-up monitoring.
- Ongoing monitoring is typically required annually or after process changes.
Acceptable monitoring methods:
- Personal air sampling (gravimetric) — NATA-accredited analysis
- Static sampling — sampling in fixed locations to characterise work areas
- Real-time monitoring — continuous measurement for process control and trend identification (not compliant alone but essential for optimisation)
See our articles on Respirable Crystalline Silica Monitoring and Real-Time vs Gravimetric Monitoring for detailed guidance.
5. Health Monitoring and Surveillance
You must provide health monitoring to:
- Establish baseline lung function before exposure begins
- Detect early changes in workers’ health
- Identify if exposure controls are inadequate
Who requires health monitoring:
- All workers with significant RCS exposure (the COP defines this as likely exposure above a threshold; conservative interpretation = all workers in high-risk roles)
- Frequency: baseline assessment before first exposure, then periodic assessment (typically annually or every 2 years depending on exposure level)
Health monitoring must include:
- Medical questionnaire covering respiratory history, smoking, previous silica exposure
- Spirometry (lung function testing) — baseline and periodic to detect decline
- Chest X-ray (CXR) — baseline and periodic (frequency depends on exposure level; typically every 2–3 years)
- Review by an occupational physician or AIOH-certified hygienist
6. Record-Keeping and Documentation
You must retain records for:
- Risk assessments and hazard registers (ongoing, current version plus 5-year archive)
- Exposure monitoring results (30 years for dust samples; 7 years for reports)
- Health surveillance findings (participant confidentiality must be maintained; aggregate results retained 30 years)
- Control maintenance records (demonstrating that engineering controls are serviced and functional)
- Training and induction records (30 years)
Action: Establish a centralised dust control and health register. Document every assessment, monitoring event, and health check.
7. Information, Training, and Competency
You must provide information and training to:
- All workers with RCS exposure
- Supervisors and safety representatives
- Hygiene officers and consultants managing your compliance programme
Content must include:
- What RCS is and which materials contain it
- Health risks (acute and chronic: silicosis, lung cancer, COPD)
- Tasks and exposures at your workplace specifically
- Controls implemented and how to use them
- RPE requirements (if applicable), including fit testing and maintenance
- Health monitoring procedures and what results mean
- Reporting procedures for exposure incidents or health concerns
Competency standards:
The COP references AIOH competency frameworks. Supervisors should have a demonstrated understanding of RCS risks and controls. Occupational hygienists and consultants should be AIOH members or meet equivalent qualifications.
Implementing the Code of Practice in Your Organisation
Step 1: Appoint a Responsible Person or Team
Designate someone (e.g., site manager, WHS officer, or external consultant) to lead RCS compliance. They should have:
- Understanding of RCS risks and controls
- Authority to implement changes
- Access to budget for monitoring and control improvements
- Reporting line to senior management
Step 2: Conduct a Dust Hazard Register
Document:
- All sites, work areas, or projects where RCS work occurs
- Materials present (concrete, stone, foundry sand, etc.)
- Specific tasks (cutting, grinding, drilling, demolition, shotcrete, etc.)
- Worker roles and estimated exposure duration
- Current controls in place
Step 3: Assess Risk for Each Task or Area
For each task:
- Estimate exposure likelihood (high, medium, low) based on task duration, frequency, dust generation
- Consider controls (engineering, administrative, RPE) already in place
- Decide: is exposure likely to be above WES?
- If uncertain, proceed to monitoring (step 4)
Step 4: Commission Exposure Monitoring
- If you cannot confirm that exposure is below 0.05 mg/m³, conduct monitoring
- Use a competent occupational hygienist (e.g., AIOH member or NATA partner)
- Collect personal air samples from 3–5 workers in each high-risk role
- Request NATA-accredited gravimetric analysis with FTIR speciation
- Timelines: 4–6 weeks for initial assessment
Step 5: Implement Control Improvements
Based on monitoring results:
- If exposure exceeds WES: identify and implement engineering controls (e.g., LEV, enclosure, water suppression)
- If exposure is near WES: consider control enhancements and more frequent monitoring
- If exposure is below WES but controls are passive: maintain them and verify annually
- Document all control changes in your risk register
Step 6: Arrange Health Monitoring
Partner with an occupational physician or AIOH-accredited clinic to:
- Conduct baseline assessments (spirometry, CXR, questionnaire) for all workers in RCS roles
- Schedule periodic follow-ups (typically annual to biennial, depending on exposure level)
- Review results with workers confidentially
- Retain aggregate data (without individual identification) in your register
Step 7: Train and Inform
- Conduct annual inductions for all RCS-exposed workers
- Include controls, PPE, health monitoring, and incident reporting
- Provide written information (on-site posters, fact sheets, SMS reminders) in accessible language
- Record attendance and competency
Step 8: Review and Update
- Quarterly: review exposure monitoring trends and control effectiveness
- Annually: audit health monitoring outcomes, training uptake, incident reports
- After process changes: re-assess risk and repeat monitoring if required
- Update your hazard register and communicate changes to workers
The Code of Practice and the December 2026 WEL Transition
The December 2026 transition from WES (0.05 mg/m³) to the new WEL will introduce tighter exposure limits. The November 2025 COP update provides guidance:
- From 1 December 2026, the WEL will replace the WES
- WEL values (pending final publication) are expected to be lower or equal to the WES; exact values will be confirmed by Safe Work Australia
- Transition period: Employers should anticipate stricter limits and begin control improvements now (2025–2026) rather than waiting until December 2026
This is critical: do not delay RCS compliance work until December 2026. If your current controls only meet the WES, they may not meet the WEL. Begin upgrades now. See Silica WEL 2026: Australia Employer Guide for more detail.
Frequently Asked Questions
Q: Do I have to follow the Code of Practice exactly?
A: No. The COP is guidance, not law. However, if you don’t follow it, you must demonstrate that your alternative approach is equally effective at managing RCS risk. In practice, following the COP is the safest approach because it is endorsed by all state regulators and provides strong legal protection.
Q: When must I update my risk assessment?
A: At minimum, annually. Also update if: you introduce new equipment or materials, workers report health concerns, monitoring results change, or regulatory requirements change (e.g., WEL transition in December 2026). Document all updates.
Q: What is the difference between risk assessment and exposure monitoring?
A: Risk assessment is a management tool — you identify hazards and estimate risk level. Exposure monitoring is measurement — you collect air samples to quantify actual exposure and validate your risk assessment. Both are required; they work together.
Q: Can I use real-time monitoring to comply with the COP?
A: Real-time monitoring is valuable for process control and optimisation but is not NATA-accredited and cannot serve as sole evidence of WES/WEL compliance. Use gravimetric sampling (NATA-accredited) as your compliance method; use real-time monitoring to support control design and improvement.
Q: What qualifications should an occupational hygienist have?
A: The COP references AIOH competency frameworks. Prefer consultants who are AIOH members (FAIOH, MAIOH, or GAIOH). If not AIOH, ensure they have equivalent qualifications (e.g., tertiary qualification in occupational health and safety or chemistry) and relevant experience.
Q: Do small businesses have to follow the COP?
A: Yes. The WHS Act applies to all businesses with workers, regardless of size. The COP applies to all employers with RCS exposure risk. Proportionality applies — a small business with one worker and minor RCS exposure will have a simpler programme than a large construction company — but the legal obligation is the same.
Q: How do I record health monitoring results confidentially?
A: Health monitoring results must be kept confidential and separate from general HR records. Use a secure register with individual names and results accessible only to the occupational physician and WHS team. Provide workers with their own results. Retain aggregate summary data (e.g., “5 workers assessed; 1 showed early decline in lung function”) for your compliance register.
Q: What should I do if a worker’s health monitoring shows an abnormality?
A: Immediately: (1) Inform the worker and occupational physician, (2) Conduct a follow-up exposure assessment, (3) Increase monitoring frequency, (4) Review and enhance controls to reduce exposure, (5) Consider temporary redeployment if exposure cannot be reduced. Document all actions and review regularly with the physician.
Q: When does the December 2026 WEL transition happen?
A: 1 December 2026. All workplaces must comply with the new WEL from that date. Begin control improvements now. See Silica WEL 2026 for detailed transition guidance.
Summary
The Safe Work Australia Model Code of Practice for RCS (November 2025 update) is your practical roadmap to compliance. Its eight key steps are:
- Identify RCS hazards
- Assess exposure risk
- Implement controls using the hierarchy (elimination → substitution → engineering → administration → RPE)
- Monitor exposure (gravimetric sampling is the compliance-grade method)
- Provide health surveillance
- Maintain records (30 years for critical items)
- Train and inform workers
- Review and improve
By following the COP, you meet your duty holder obligations, protect workers’ health, and build a strong legal defence against regulatory action or civil claims.
Getting started: If you have not yet assessed your RCS programme against the November 2025 COP, now is the time. Contact an AIOH-accredited occupational hygienist to conduct a compliance review. At Anitech, we guide employers through COP implementation, from risk assessment through health monitoring and control verification.
Ready to strengthen your RCS compliance? Contact us for a no-obligation compliance review.
IMAGE_REQUIREMENTS
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FEATURE (1200×630px): Hierarchical pyramid graphic showing the five control levels (Elimination at top, Substitution, Engineering, Administration, RPE at bottom) with Australian workplace examples (stonecutting, concrete grinding) at each level. Safe Work Australia branding visible.
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BODY_1 (800×450px): Occupational physician conducting spirometry test on a worker with RCS exposure, in a clinic setting. Caption: “Health monitoring — baseline and periodic assessment — is a cornerstone of the Code of Practice.”
