The recent Department of Employment and Labour statement that the elimination of silicosis in non-mining sectors remains “on the radar” is, on the surface, a positive development.

The Department is correct: silicosis remains a serious occupational health issue. It is irreversible, progressive and caused by exposure to respirable crystalline silica dust. Construction, brick manufacturing, stone fabrication and other industries continue to expose workers to silica-containing materials.

But from a South African SHEQ professional’s perspective, there is something deeply uncomfortable about the phrase “on the radar.”

Silicosis should not merely be on the radar.

It should be on the risk assessment. It should be in the occupational hygiene programme. It should be in the method statement. It should be in the toolbox talk. It should be measured, controlled, audited and reported. And, most importantly, workers should not have to develop an irreversible disease before we can demonstrate that the system worked.

We have known about this for decades

South Africa has not recently discovered the risks associated with silica dust.

The Department itself published guidance years ago acknowledging the significant problem of silica exposure in industries including sandstone, ceramics, refractory and foundry operations. Government's stated objective was to significantly reduce silicosis and ultimately eliminate it from workplaces by 2030.

The regulatory framework has also developed considerably. The Occupational Health and Safety Act places a general duty on employers to provide and maintain, as far as reasonably practicable, a working environment that is safe and without risk to employees' health. Critically, the Act requires employers to eliminate or mitigate hazards before resorting to personal protective equipment.

The Hazardous Chemical Agents Regulations provide a much more specific framework for dealing with hazardous chemical exposure, while the regulations expressly address crystalline silica and its occupational exposure limits.

So the problem is not that South Africa lacks awareness.

The problem is converting awareness into consistent control at the workplace level.

The SHEQ question should be: “Where is the control?”

A SHEQ professional walking onto a construction site should not be satisfied because the contractor has a silica policy sitting in a file.

The real questions should be:

  • Have silica-containing materials been identified?
  • Has respirable crystalline silica been identified as a significant occupational health hazard?
  • Has a suitable risk assessment been conducted?
  • Has occupational hygiene monitoring been performed where required?
  • Are workers actually exposed above the applicable limits?
  • What engineering controls are being used?
  • Is cutting being performed using wet methods?
  • Is local exhaust ventilation appropriate and effective?
  • Are housekeeping methods preventing dust from becoming airborne?
  • Are workers being prevented from using unsafe dry-cutting practices?
  • Is respiratory protective equipment being used correctly where it is still required?
  • Has fit testing been conducted where appropriate?
  • Are workers trained on the actual hazards rather than simply being given a generic induction?
  • Are contractors being subjected to the same standards?
  • And perhaps most importantly: Can the employer demonstrate that exposure is being controlled?

The 2024 Hazardous Chemical Agents regulations specifically prohibit the use of dry methods to cut or grind crystalline-silica-containing materials.

That is the kind of practical requirement that should be driving the conversation.

Not whether silicosis is still “on the radar.”

A concerning gap between research and reality

There is another issue that deserves attention.

The Department's 2026 announcement relates to research intended to establish the prevalence and trends of silicosis in non-mining sectors and develop strategies to reduce exposure and eliminate silicosis by 2030.

However, the study described in the announcement examined prevalence and deaths over the period 2012 to 2018.

The research involved 225 workers, with 178 having more than ten years' work experience. None reported a previous diagnosis of silicosis, while chest X-rays identified one case, resulting in a reported prevalence of 0.5%.

That information is useful.

But as a SHEQ professional, I would immediately ask:

What does a dataset covering 2012–2018 tell us about exposure conditions in 2026?

Workplaces change. Construction methods change. Materials change. Machinery changes. Contractor structures change. Informal work changes. PPE practices change.

A risk assessment based on conditions from eight to fourteen years ago would not be considered adequate for managing today's workplace.

So why should our understanding of a potentially fatal occupational exposure be allowed to operate on a similar timeline?

We need to stop measuring the problem only after the damage has occurred

One of the biggest challenges with occupational health hazards is that the traditional safety mindset does not always translate well.

With a physical safety incident, the consequence can be immediate.

A worker falls from scaffolding today and the incident is recorded today.

Silicosis does not work like that.

A worker can be exposed repeatedly over years without experiencing an obvious immediate consequence. The absence of an incident report does not mean the control system is working.

This is why occupational hygiene is so important.

If we are serious about eliminating silicosis, we need to measure exposure rather than simply measure compliance paperwork.

A company should not be able to say:

“We have never had a case of silicosis.”

and use that as evidence that its controls are effective.

The more meaningful question is:

“What does our exposure monitoring tell us about the air our workers are breathing?”

That is a fundamentally different approach.

PPE cannot become the convenient answer

From a SHEQ perspective, one of the biggest red flags would be an organisation attempting to solve silica exposure primarily by handing workers respirators.

Respiratory protection has an important role. But it should not become a substitute for engineering and process controls.

South Africa's OHS framework already recognises this principle: hazards should be eliminated or mitigated before reliance on PPE.

If a worker is cutting a silica-containing product and creating a visible cloud of dust, putting a mask on that worker does not magically make the process safe.

The hierarchy of controls should be driving the conversation:

Eliminate → Substitute → Engineer → Administrate → PPE

Can the hazardous process be eliminated?

Can the material or process be substituted?

Can dust generation be engineered out or substantially reduced?

Can the process be isolated?

Can wet cutting, extraction, enclosure or other engineering controls be implemented?

Only after these controls have been considered should PPE become the primary remaining barrier.

And even then, PPE has to be properly selected, maintained, fitted and used.

The real challenge may be the smaller contractor

There is another area where the South African SHEQ conversation needs to become more realistic.

It is relatively easy for a large organisation with an occupational hygienist, SHEQ department, medical surveillance programme and substantial resources to establish a sophisticated silica management programme.

The challenge is the smaller contractor.

The small construction company.

The brick-cutting operation.

The stone fabricator.

The informal or semi-formal workplace.

The subcontractor working on a larger project.

These are precisely the environments where a generic safety file can create the illusion of compliance while the actual exposure remains uncontrolled.

A 300-page safety file does not control silica dust.

A signed toolbox talk does not control silica dust.

A risk assessment that says “wear a dust mask” does not constitute an effective occupational hygiene programme.

Controls control hazards. Paperwork records controls.

We need to remember the difference.

The mining sector shows that milestones matter

Interestingly, the mining industry has already demonstrated the value of setting measurable occupational health milestones.

South Africa's mining industry adopted occupational health milestones around the elimination of occupational lung diseases, and the 2024 milestones moved toward tighter exposure targets. The newer milestones include a target that by December 2034, 95% of exposure measurement results should be below 0.03 mg/m³ for respirable crystalline silica dust.

That is a much more useful conversation.

A target can be measured.

A target can be audited.

A target can be reported.

A target can identify failure.

“On the radar” cannot.

So what should South Africa be doing?

If we genuinely want to eliminate silicosis, I believe the conversation needs to move toward five things.

  1. Measure exposure

We need better occupational hygiene data across high-risk non-mining sectors.

If we do not know what workers are being exposed to, we cannot credibly claim that the hazard is controlled.

  1. Focus enforcement on high-risk activities

We should be looking closely at activities such as dry cutting, grinding, crushing, drilling, polishing and other processes that can generate respirable crystalline silica.

The Department has already demonstrated historically that enforcement can make a difference. In one 2007 case involving a tombstone manufacturer, inspectors identified hazardous silica exposure, issued contravention notices and prohibited unsafe dust-cleaning practices.

That kind of targeted enforcement should remain part of the solution.

  1. Make contractors part of the system

Principal contractors and clients cannot simply outsource occupational health risk to subcontractors.

If a project creates silica exposure, the entire contractor management system should reflect that risk.

  1. Improve worker education

Workers need to understand that silica is not simply “dust.”

They need to understand the long-term consequences of exposure and, more importantly, how the control measures protect them.

  1. Measure performance through outcomes and leading indicators

Instead of asking only:

“Do you have a silica policy?”

ask:

“What are your latest exposure results?”

Instead of:

“Have your workers been trained?”

ask:

“Can workers demonstrate the correct dust-control procedure?”

Instead of:

“Do workers have respirators?”

ask:

“Why is respiratory protection necessary, and what engineering controls are already in place?”

That is what mature SHEQ management looks like.

Silicosis needs to move from policy to practice

There is no question that the Department is correct to continue prioritising silicosis.

There is also no question that research, policy, regulation and government oversight have an important role to play.

But after decades of awareness, we should be asking whether the language we use reflects the urgency of the problem.

Silicosis should not merely remain “on the radar.”

It should be actively managed through risk assessments, occupational hygiene monitoring, engineering controls, worker consultation, medical surveillance, contractor management, training, inspections, enforcement and continuous improvement.

For the SHEQ profession, this is where our responsibility becomes particularly important.

We are often the people standing between a regulatory requirement and what actually happens on the shop floor, construction site, workshop or fabrication area.

Our job is not simply to make sure that the correct document exists.

Our job is to ask whether the control actually works.

Because ultimately, the success of a silicosis elimination strategy should not be measured by how many seminars we hold, how many policies we publish, or whether the disease remains “on the radar.”

It should be measured by something much simpler:

How many workers are breathing unsafe levels of silica dust today?