Do you know if your silica risk control plan actually has everything it needs, or has it been sitting on file since it was first put together? An out-of-date plan won’t hold up if your controls have changed or an inspector asks to see it.
Here’s what the law requires: if your business carries out high-risk processing of crystalline silica, a silica risk control plan must be in place before that work starts, and it has to meet specific legal requirements to actually count as compliant.
This guide walks through exactly what the plan must contain, who needs to be involved in writing it, and how it fits alongside your other silica obligations in NSW.
What is a silica risk control plan?
Who needs a silica risk control plan?
What must a silica risk control plan contain?
Who must be consulted when writing the plan?
When does the plan need to be reviewed?
How a risk control plan fits with your other silica duties
Frequently asked silica risk control plan questions
Get help putting your silica risk control plan together
A summary of what a silica risk control plan must include
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What is a silica risk control plan?
A silica risk control plan is a documented record of how your business manages the risk of crystalline silica exposure for a specific task. According to SafeWork NSW, it must be completed before any high-risk processing begins, and made available to workers before they start that work.
Who needs a silica risk control plan?
Any business that carries out, or directs and allows a worker to carry out, high-risk processing of a crystalline silica substance needs a plan in place.
Processing becomes high risk once a risk assessment shows it’s reasonably likely to harm a worker’s health, including tasks such as cutting, grinding, drilling, or polishing materials containing silica.
If you cannot confidently determine whether a task is high risk, SafeWork NSW requires you to treat it as high risk until a proper assessment proves otherwise. This means most businesses working with engineered stone, concrete, brick, tile, or similar materials should assume a plan applies unless they can show otherwise.
What must a silica risk control plan contain?
A silica risk control plan must cover the specific processing involved, the basis for the risk assessment, and the control measures you’ll use to manage exposure. A document that skips any of these isn’t a compliant plan, no matter how complete it looks on the surface.
According to SafeWork NSW, here’s what each required section actually needs to cover:
| Required element | What it must show |
| Identification of high-risk processing | Every task at the workplace is assessed as high risk, not just the most obvious one. |
| Specific processing | The exact process being undertaken, such as cutting, grinding or drilling. |
| Risk assessment details | The specific processing, the form and proportion of crystalline silica in the material, and how often and how long workers are exposed. |
| Monitoring and incident history | Results of any prior air or health monitoring, plus any past incidents, illnesses or diseases linked to RCS exposure at the workplace. |
| Exposure standard assessment | Whether airborne RCS is reasonably likely to exceed half the workplace exposure standard, and why the processing was rated high risk. |
| Control measures | What measures are used, and how they’re implemented, monitored and reviewed. |
| Clarity | It needs to be set out in a way workers can actually read and understand, not buried in technical language. |
If the processing also counts as high-risk construction work, a Safe Work Method Statement can be used instead of a separate silica risk control plan, provided it meets the same requirements.
Who must be consulted when writing the plan?
A silica risk control plan written behind a desk, without input from the people doing the cutting and grinding, rarely survives contact with the real job site.
SafeWork NSW requires the plan to be developed in consultation with the workers carrying out the processing, and with relevant health and safety representatives where a work group has one.
This consultation isn’t a formality. It should shape the plan itself, not just be noted as having happened. Practical ways to involve workers include:
- Walking through the actual task with workers before finalising control measures
- Asking workers who carry out the processing daily to flag gaps between what’s written and what happens on site
- Documenting how feedback from workers or health and safety representatives was incorporated into the final plan
The plan must also be made available to workers before they begin processing and provided to any registered medical practitioner involved in workplace health monitoring.
When does the plan need to be reviewed?
A plan that’s accurate on the day it’s signed off can be out of date within months if nothing prompts a second look. SafeWork NSW requires the plan to be reviewed, and revised if necessary, whenever the control measures it describes are reviewed under the WHS Regulation’s general duty to review control measures.
In practice, this means reviewing the plan when any of the following happen:
- A new task, material or piece of equipment is introduced to the process
- The control measures in place aren’t working, such as when a worker is injured or experiences a near miss
- Workplace layout or work practices are about to change
- Consultation with workers, or a request from a health and safety representative, shows that a review is needed
This isn’t a theoretical risk. Since 2018, SafeWork NSW inspectors have conducted more than 5,200 workplace visits related to silica, issuing 2,496 improvement notices, 181 prohibition notices and 33 penalty notices over that period.
An outdated plan is one of the easiest gaps for an inspector to spot.
| “If you’ve changed a tool, a material or a process and your control plan still reads exactly the same, that’s worth a second look. The document should move when the work does.” Kate O’Connor, National Program Manager, Munro Respiratory Services |
How a risk control plan fits with your other silica duties
A silica risk control plan is one part of a broader set of duties that apply when processing is high-risk, not a replacement for any of them. Getting the plan right doesn’t remove the obligation to train, monitor and protect your workers in other ways.
Alongside the plan, PCBUs carrying out high-risk processing must also:
- Provide approved silica awareness training. Workers involved in high-risk processing, or at risk of exposure because of it, need training that’s nationally accredited or approved by SafeWork NSW.
- Conduct air monitoring where needed. If you’re unsure whether RCS levels exceed the workplace exposure standard, air monitoring helps confirm whether your controls are working.
- Provide health monitoring. Workers facing significant ongoing risk from RCS exposure must be offered regular health screening.
- Register high-risk workers. Since 1 October 2025, workers undertaking high-risk processing must also be notified to the Silica Worker Register within 28 days of starting that work.
According to the NSW Government’s silica dashboard,almost 15,000 workers had been registered as of 31 March 2026, showing how widely these obligations now apply across NSW.
Frequently asked silica risk control plan questions
Can one silica risk control plan cover multiple types of processing?
Yes. A single plan can document multiple processing tasks, as long as it provides the required risk assessment details and control measures for each one individually.
Does a silica risk control plan need to be signed off by a specific person?
The plan should be completed by someone with the authority to do so on behalf of the PCBU, and the information in it must be true and correct to the best of their knowledge.
Is training information required in the silica risk control plan itself?
No. Including training details in the plan is optional. However, it’s useful to reference where training records are held, since you’re still required to keep them while a worker carries out the processing and for five years after they leave.
What happens if a silica risk control plan is incomplete or out of date?
SafeWork NSW inspectors have the power to assess workplace compliance with the plan and other WHS provisions, and an incomplete or outdated plan can leave your business exposed to compliance action.
Get help putting your silica risk control plan together
A silica risk control plan shows you’ve thought through the risk, but it doesn’t protect your workers on its own. That happens when the people named in it are properly trained and the respirators it relies on actually fit.
Munro Respiratory Services delivers approved silica awareness training and on-site or remote respirator fit testing across NSW, with records and certificates provided upon completion.
Tell us how many people need training or testing, and we’ll arrange a session that fits around your site.
