Silica dust is not a new construction risk.
What is changing is the level of attention being paid to how that risk is controlled.
Concrete can contain crystalline silica. When it is drilled, cut, ground, jackhammered or otherwise mechanically processed, very fine respirable crystalline silica, usually shortened to RCS, can become airborne. Those particles are small enough to travel deep into the lungs and can cause serious and irreversible diseases, including silicosis and lung cancer.
The construction industry has become considerably better at controlling dust-generating work. Water suppression, on-tool extraction, isolation and respiratory protection all have an important place.
But at NON-DRILL, we think there is another question worth asking first:
Does this particular drilling task need to happen at all?
When temporary edge protection is being fixed to concrete, sometimes the answer is no. And that is a much more interesting safety conversation.
Start with elimination, not the dust extractor
The hierarchy of controls is deliberately a hierarchy.
Where a hazard can reasonably be eliminated, eliminating it sits above trying to manage the exposure after it has been created.
Safe Work Australia currently identifies engineering measures such as water suppression, local exhaust ventilation and dust extraction as ways to control respirable crystalline silica when dust-generating work is necessary. PPE sits further down the hierarchy because it does not control the hazard at its source.
That doesn't make dust extraction or respiratory protection unimportant. Far from it.
It means the first question should be:
Can we change the method so this dust-generating activity isn't required in the first place?
For temporary edge protection on concrete and precast structures, that is where the connection method becomes relevant.
If a handrail post requires a new hole to be drilled into the concrete, the project has introduced another concrete-processing task.
If the same edge-protection requirement can instead be engineered around a suitable existing or planned lifting anchor, ferrule, cone anchor, shear stud or other connection, that particular drilling task may disappear from the methodology altogether.
That doesn't eliminate every silica hazard on the project.
It does eliminate one source of silica generation from that installation.
And on a busy construction project, removing unnecessary hazardous tasks is worth doing.
The risk comes from processing the concrete
Crystalline silica in solid concrete is not, by itself, the issue.
The problem arises when silica-containing materials are mechanically processed and fine respirable particles become airborne.
Safe Work Australia specifically identifies drilling, cutting, grinding and similar processing of concrete and other silica-containing materials as activities capable of producing RCS. Current national guidance also notes that aggregates, mortar and concrete can contain widely varying amounts of crystalline silica, which is why assumptions based on a generic percentage are not particularly useful.
That is one reason I would remove the old marketing claim that concrete contains “around 30% silica”.
It might be true of a particular material, but Safe Work Australia's current guidance gives a much wider indicative range and recommends checking the actual material being worked with.
For an engineer or site team, the more useful question is not:
“Exactly what percentage silica is in this slab?”
It is: “Are we going to mechanically process this material, and if so, how are we going to manage the risk?”
Or, even better: “Can we avoid processing it for this task?”
Edge protection creates its own connection decision
Temporary edge protection tends to attract attention because of the obvious risk: the exposed edge.
But the method used to install that protection can create additional hazards of its own.
If posts are being post-fixed into concrete, the methodology may need to consider drilling equipment, airborne contaminants, access to the fixing location, reinforcement and embedded elements, dust control, PPE, cleanup and inspection.
That doesn't mean drilled fixings are inherently wrong. Sometimes they will be the appropriate engineering solution. Our point is simply that they should not become the automatic answer because the edge-protection connection was never considered earlier.
If temporary edge protection is already known to be required, the connection can often be discussed during design, precast detailing, constructability review or temporary-works planning.
That opens up a much better question:
Is there a suitable connection we can use instead of creating another hole?
What NON-DRILL changes
NON-DRILL was designed around using suitable existing or planned structural connections rather than automatically relying on new post-pour drilled fixings. Depending on the structure and project-specific engineering, that can include lifting anchors, ferrules, cone anchors, hairpin-type connections, shear studs and other engineered arrangements.
The important part is not simply that there is no drill in the product name. It is that the connection method can change the work method.
If the edge-protection post can connect to an appropriate engineered point without drilling the concrete, there is no concrete-drilling dust from that particular edge-protection installation.
There is no need to capture dust that has not been generated. There is no drilling task for the crew to perform. And there is one less silica-generating activity for the project to manage. That is the benefit we think deserves more attention.
Silica regulation is getting tighter, not looser
This conversation has also become more important because Australia's regulatory approach to crystalline silica has strengthened considerably.
Safe Work Australia's model WHS Regulations were amended in 2024 to introduce stronger requirements for work involving materials containing at least 1% crystalline silica, including requirements around controlled processing and risk assessment. Those model provisions take effect in individual jurisdictions when they are implemented into the relevant state or territory laws, so project teams need to check the rules that apply where the work is actually taking place.
The current workplace exposure standard for respirable crystalline silica is 0.05 mg/m³ as an eight-hour time-weighted average, and it must not be exceeded. Safe Work Australia also emphasises that exposure should be kept as low as possible.
This is not a particularly good environment in which to say:
“We'll create the dust and then work out how to control it.”
Where the task genuinely needs to happen, control it properly.
Where it doesn't, design it out.
Don't confuse eliminating one task with eliminating the site's silica risk
This is an important distinction. A NON-DRILL edge-protection system does not make a construction site silica-free. There may be cutting, grinding, drilling, demolition, excavation and dozens of other activities taking place elsewhere on the project. Nor does using NON-DRILL remove the project team's responsibility to identify and manage respirable crystalline silica risks arising from those activities. What it can do, in a suitable application, is much more specific:
remove the need to drill new concrete fixings for the edge-protection posts.
We think that is a stronger claim because it is precise.
It also reflects the way good risk management actually works. Large improvements often come from removing a series of unnecessary hazardous tasks rather than pretending one product solves an entire site-wide problem.
Earlier design gives the project more options
This is where the silica conversation connects with a bigger NON-DRILL principle. By the time someone is standing beside finished concrete asking where the handrail posts should go, the project may have very few options left.
The reinforcement is fixed. The precast panels are manufactured. The lifting points and ferrules are already located. Access is required now. Drilling can become the path of least resistance simply because nobody asked the connection question earlier.
But if the temporary edge protection is discussed during design or constructability planning, the team may be able to use a suitable connection that already exists or incorporate one into the structure.
That means the project's silica strategy begins before the drilling method is chosen, not afterwards.
For us, that is the broader lesson.
Don't just improve the control around a hazardous task. Ask whether good design can remove the task.
The same principle applies to the SWMS
This also makes the Safe Work Method Statement more meaningful. A SWMS should describe the method the project actually intends to use. If concrete drilling is part of the edge-protection installation, then the hazards and required silica controls associated with that work need to be reflected in the methodology.
If the engineered connection removes the drilling activity from that installation, the work method is different. The point is not to make the SWMS shorter for the sake of having less paperwork. It is to make the work itself simpler. That is an important distinction. A safer method should drive the paperwork. The paperwork should not be used to make an avoidable method appear safe.
Compliance is a system, not a sticker
Silica provides another good example of why we use this phrase. You cannot manage silica risk by buying one compliant piece of equipment. You have to understand the material, the work method, the task, the exposure pathway and the controls.
Temporary edge protection is much the same. The posts, rails, connections, supporting structure, installation sequence, engineering, inspections and conditions of use all form part of the system. The interesting opportunity occurs when those two conversations meet.
If changing the edge-protection connection can remove a silica-generating drilling task, then the connection decision has affected more than the handrail. It has improved the work method.
Sometimes the safest drilling control is no drilling. There will always be construction activities where concrete must be cut, drilled or otherwise processed. When that work is necessary, it needs to be properly assessed and controlled. But construction teams should be just as interested in the activities that don't need to happen.
If temporary edge protection can be connected using a suitable existing or planned structural connection, introducing another drilled fixing may add a task without adding value. That's why our starting question at NON-DRILL is simple:
Before we manage the dust from drilling this edge-protection connection, can we engineer the drilling out?
Sometimes the answer will be no. When the answer is yes, we think it is worth taking seriously.