What does being ‘Clean Shaven’ really mean?
All respirators (except PAPR’s) rely on a good seal between the face and the contact surface of the respirator to prevent inward leakage of airborne contaminants. Facial hair (including stubble) between the sealing surface of the respirator and the wearer’s skin will prevent a good seal.
The various ‘facial hairstyles’ in the training (eg Circle Beard, Balbo, Anchor) offer a GUIDE to what facial hair MAY be acceptable IF and ONLY IF a good seal has been achieved. If any facial hairstyle impacts the ability to achieve a good seal, then the facial hair must be removed.
Is it acceptable for contractors to provide their employees with alternate RPE? (eg A PAPR and retain their facial hair)
Yes. Whilst a disposable P2 respirator offers adequate protection, contractors may consider other options including the purchase of a PAPR. Approval is required by the SIMEC Mining Department Manager prior to use. (Refer SIMEC Mining PPE Procedure QP75 – Attachment 8)
Will any PAPR meet SIMEC Mining RPE requirements for workers with facial hair?
All requests for a worker to use a PAPR must be made via the Approval Form (Refer SIMEC Mining PPE Procedure QP75 – Attachment 8) and requires the relevant SIMEC Mining Department Manager approval prior to use (except for Welders/Boilermakers). Any PAPR used must meet Australian Standards. For contractors, training, ongoing maintenance, storage and cleaning requirements of the PAPR must be provided prior to use.
What happens if I fail my fit test for my disposable P2 respirator?
If after failing multiple disposable P2 respirator ‘fit tests’, alternative options will be considered including a reusable half face respirator with P2 filters.
In the interim, workers will still be required to continue to wear the disposable P2 respirator and be clean shaven until a suitable option is sourced.
If a worker is travelling in a vehicle with a sealed cab, windows closed, air conditioning operating on recirculated air and passes through an orange or red zone without getting out, do they need to be clean shaven? (not stopping or working in these areas)
If travelling through an orange or red zone in a vehicle and not performing work or stopping – then not required to be clean shaven. If performing work in an orange or red zone in a vehicle then yes, must be clean shaven and fit tested.
If controls are in place and the day is clear (FDR0), why cant a ‘Red Zone’ be downgraded to an ‘Orange Zone’?
‘Red Zones’ have been identified as areas where airborne contaminants exist due to the nature of the work being undertaken in those areas. Often the airborne contaminants cannot be seen, due to their size.
The ‘Red Zones’ have been deemed high risk areas following advice from our Occupational Hygienist, taking into account:
• Previous hygiene monitoring data;
• Walk through surveys of the Operations;
• Expert advice of an Occupational Hygienist.
Will SIMEC Mining be fit testing contractors for masks?
An initial 7 week campaign will provide ‘Fit Testing’ services to all employees and contractors required to wear RPE at work.
How will we ensure workers (employees and contractors) have undertaken the training and have been fit tested?
SIMEC Mining will use INX to verify compliance with regular auditing undertaken by the Workforce Development Department.
Has the hierarchy of control been used before going straight to PPE?
Yes. Some good examples of controls currently used (other than PPE) are the water carts and spray bars used across the Operations.
How does this affect control rooms/crib rooms/switch room found in Red Zones?
Whilst in a control rooms/crib rooms/switch room within a Red Zone you are not required to wear RPE.
Why doesn’t the business provide all workers with an airstream or PAPR?
A disposable P2 respirator offers adequate protection from airborne contaminants.
How does sunscreen affect RPE?
Care must be taken with any facial make-up and creams (including sunscreen) applied to the face to ensure they do not interfere with the facial seal.
Who determines when ‘orange and green’ become Red Zones?
The business in conjunction with an Occupational Hygienist will ensure the most appropriate requirements for each Zone are in place, taking into account:
• Previous hygiene monitoring data;
• Walk through surveys of the Operations;
• Expert advice of an Occupational Hygienist.
How short is short duration for visitors with beards?
There is no time limit to be applied to visitors. Visitors by definition are not required to be clean shaven as per the definition in the PPE Procedure. (PPE Procedure QP75.WHS.PPE.001)
Will we be allowed to smoke in the current Designated Smoking Areas within the Red Zones?
Smoking will not be allowed in any Red Zone from Monday, 12 July 2021.
My Team and I are based in the Whyalla Administration Building. We need to travel to our Operational sites for work, including both orange and red zones. Can you please confirm that this means my team will effectively be required to be clean shaven every day in case they are required to go into an orange or red zone?
Your team will not be required to be clean shaven whilst they are working in the Green Zone in the Whyalla Administration Building, but they must be clean shaven prior to entering any Orange or Red Zones. Workers will not be able to work in an Orange or Red Zone until they are clean shaven.
Please provide clearly defined zones of what is Red/Orange/Green, as it relates to Tip Pockets, Mine Site Loading Pads, RSM workshop, Interworks Rail, Base 4 finishing end (rail yard operations), Transport Operations Depot and all rail corridors.
All SIMEC Mining sites will be deemed ‘Orange Zones’ by default except for specific workplaces that will be ‘Green Zones’ or ‘Red Zones’. Specific ‘Zone Maps’ have been provided in the consultation tool box talk and are included in the Procedure. Signage will be updated across the business.
What are the triggers for RPE to be worn in an orange zone?
RPE must be worn when:
Please clarify if the term, ‘clean shaven’ includes the ‘green tick’ facial hair styles as per the pictogram presented in documentation. (Refer Attachment A/see below image)
Yes. The image referred to in the presentation outlines acceptable facial hair ‘styles’, as long as any facial hair does not impact the seal or fit.
Do you need to wear a mask whilst operating closed cabin mobile equipment or light vehicle? Previous advice is that you do not need to as long as the air conditioner filtration system was the right type and the seals of the vehicle were in good condition.
RPE is not required to be worn whilst inside closed cabin mobile equipment. Light vehicles must have external vents closed and windows up.
Why is inside the Pellet Plant not considered a red zone, or some parts of the Pellet Plant, considering that this facility contributes to a large amount of fugitive dust on site?
The Pellet Plant has been classified as an ‘Orange Zone’ based on:
Are there some better maps that show the zones as the orange zone appears to take in parts of the blast furnace and slag pits. Is it safe to assume that this is supposed to just represent the wharf?
The Blast Furnace and Slag Furnace sit within the Liberty Primary Steel boundary. SIMEC Mining has demarcated the Wharf Area as an ‘Orange Zone’.
If the dust hazard is as grave as stated then should we be having lung function tests (or appropriate test done to determine damage done from previous exposure over the years?/ Will there be ongoing/periodical monitoring of personnel’s lung function after establishing a base line?
We are following SafeWork SA’s advice and notice on implementing the clean shaven policy to mitigate the risks associated with exposure to crystalline silica in the workplace. We will continue to review our risk management framework for workplace hazards, including crystalline silica exposure, on an ongoing basis.
If we have to be clean shaven this introduction on new policy then can it done in company time at start of shift for example?
No. All workers must attend work clean-shaven and ready to commence work at the beginning of each shift.
Can we get PAPR’s (fitted hood with a filtered air supply) this would integrate all the protection in one unit could provide better protection and may end up being cheaper in the long run as over a 12hr shift there will be multiple dust masks used per person as old dirty masks should not be reused?
The use of a disposable P2 respirator provides adequate protection. However, SIMEC Mining will be undertaking an analysis of disposable respirators versus re-usable respirators, including PAPRs.
How will this apply to external people e.g. contractors etc and site personnel who only have to access the plant periodically e.g. office staff/bosses?
Depending on where these people go when on site, the clean-shaven requirements may still be applicable. If they go only to a Green Zone, then there is no requirement to be clean-shaven or fit-tested.
What happens on shutdowns are the mandatory dust mask areas still applicable?
This requirement will be applicable at all times regardless of the status of the plant operations.
What happens when/if dust masks that suit you face (fit tested) are not available on site? Possibly another reason to favour of a PRPA solution
In the unlikely event that a disposable P2 respirator does not create an appropriate seal or fit, then other respirators will be provided.
Is the wearing of PAPR for welding and cutting mandatory for all areas?
Yes. Any worker undertaking any welding activity (indoor or outdoor) must be wearing a loose fitting PAPR.
What happens if I forget to shave?
Initially, disposable shavers will be available for use. However, workers must attend work clean-shaven and ready to commence work at the beginning of the shift. Repeated occurrences may result in disciplinary action.
If the silica dust is so small and dangerous, is it safe to be out on site getting it on clothing which will then immediately be worn in an office environment, or even into vehicles with air vents set to recycle?
Advice from our Occupational Hygienist confirms dust deposited on a workers clothing may not necessarily be in the form of respirable size and therefore may not become airborne. However, workers should always follow good personal hygiene at work.
What has changed recently?
SafeWork Australia recently halved the Workplace Exposure Standards (WES) for crystalline silica dust. SafeWork SA has issued an Improvement Notice to SIMEC Mining to ensure a respiratory protection equipment (RPE) process is in place with an appropriate clean shaven and fit testing program by 30 July 2021.
Can we see silica dust?
Generally, no. Often silica dust is 100 times smaller than a grain of sand.
Why is silica dust so bad?
Due to the size of the particles they are very sharp, and when inhaled they damage the lungs. As these particles damage the lungs, scar tissue forms and limits oxygen absorption. Exposure to silica dust can lead to the development of lung cancer, silicosis (an irreversible scarring and stiffening of the lungs), kidney disease and chronic obstructive pulmonary disease.
Why can’t I just wear a mask?
A dust mask provides significant protection, but due to the extremely small size of silica dust, it is imperative workers have an adequate seal and fit. The only way this can be achieved is to be ‘clean shaven’. A two yearly ‘fit test’ is undertaken to confirm this, with high risk workers undertaking a ‘fit test’ annually.
Do I need to be completely shaven?
Generally, yes. However, there are some specific guidelines to ensure that facial hair does not interfere with the integrity of the seal.
Do I need to shave daily?
You must present to work clean shaven. Even a small amount of ‘stubble’ can affect the seal of the respirator.
When do we need to be clean shaven?
To ensure we comply with the SafeWork SA Improvement Notice, we are currently looking at mid-July 2021 as the effective date for our workers that are at heightened risk, with a plan being developed to ensure all workers are fit tested in the coming weeks.
What is a ‘fit test’?
A ‘fit test’ is a test undertaken by a trained professional with a quantitative respirator fit testing machine to ensure you can achieve an effective seal between the respirator and your skin. Each test takes approximately 15 minutes.
Do I need to be clean shaven and fit tested if I work in an office all day?
No. Certain offices and car parks have been deemed ‘green zones’. Maps are currently being drafted for all sites to show where clean shaven will be a requirement.
What about Welders and Boilermakers?
Due to the potential exposure to a number of airborne contaminants, all Welders and Boilermakers must wear loose fitting Powered Air Purifying Respirator (PAPR) whilst undertaking all welding activities (indoors and outdoors). Workers do not need to be clean shaven or fit tested to wear a PAPR.
What if I am a Welder or Boilermaker and am not welding?
If you are in an identified high-risk area (e.g. around a Crusher), then you must continue to wear the PAPR. If you chose not to wear a PAPR in the high-risk area and you want to wear a disposable P2 respirator, then you must be clean shaven and fit tested.
What if my religious beliefs don’t allow me to be clean shaven?
Following presentation of appropriate evidence, the business may support you with an alternative form of respiratory protection.
What about if I have a medical condition that does not allow me to shave daily?
Following presentation of medical evidence, the business may support you with an alternative form of respiratory protection.
What if I am a visitor or only working on site for a short period of time?
Procedures to manage short term workers and visitors are currently being developed.
How did we determine the Zones?
With the assistance of an Occupational Hygienist, the business considered:
