Crystalline Silica – the new asbestos
"If you don’t measure it accurately, the problem doesn’t exist."

Facts
The Applicant's intention is to truck a Carcinogenicity Category 1 product through Cambridge uncovered, this product may cause cancer if inhaled (contains crystalline silica).
The Applicants (Fulton Hogan/RS Sands) claim that the silica content of the sand from this quarry is between 7-16%. However, this statement is blatantly false and misleading. A simple search for 'silica content of concrete sand' or 'silica content for quarry sand' reveals that the actual silica content is typically 70% or more. Providing such inaccurate information raises serious concerns about the validity of the entire application. If the health and safety data is incorrect, it calls into question the credibility of the rest of the application as well
The MSD (Material Safety Data - ex MSDS) will contain the following which is required by law and Worksafe NZ. However, the Applicant is not even providing the draft, nor is the MSD/ MSDS ever mentioned as part of their submission (deliberate omission as they do not want you to know the truth).
As a comparison, Winstone's provide this information as per the following link for their MSD which confirms the product type:
https://winstoneaggregates.co.nz/assets/Uploads/resources/Sand-SDS-v2.pdf

The Applicant should disclose their product is:
- Carcinogenicity Category 1 product 
- H 350 May cause cancer if inhaled (contains crystalline silica)
- H372 Causes damage to organs by inhalation through prolonged or repeated exposure if inhaled (silicosis and effects to the lungs)
P260 - Do not breathe dust
The sand contains respirable dust present which may contain crystalline silica
P281 - Use personal protective equipment as required
The dust from this product is considered a target organ toxicant due to the presence of crystalline silica, which primarily affects the lungs when inhaled.
The dust resulting from this product does contain crystalline silica. Crystalline silica inhaled in the form of quartz or cristobalite from occupational sources is carcinogenic to humans (IARC Group 1). Crystalline Silica triggers 6.7A classification (confirmed carcinogen). 





































Worksafe NZ has quarrying at the top of the list for Silicosis so Fulton Hogan even contradicts Worksafe NZ, Health NZ and all the other worldwide organization including the WHO (World Health Organization).
https://www.worksafe.govt.nz/topic-and-industry/dust/silica-dust-in-the-workplace/#lf-doc-55260
https://www.worksafe.govt.nz/topic-and-industry/dust/silica-dust-in-the-workplace/
https://www.tewhatuora.govt.nz/for-health-professionals/clinical-guidance/diseases-and-conditions/accelerated-silicosis





















Respirable crystalline silica (RCS) is a hazardous substance found in materials like sand with high silica (quartz), stone, concrete, and mortar. When these materials are handled, crushed, or extracted, they release fine, invisible RCS dust into the air. Silica dust is a hot topic now in Australia who are far more experienced, sadly New Zealand is very much behind. This dust poses a significant health risk, as prolonged exposure can lead to a condition known as silicosis—a potentially fatal disease that permanently damages the lungs. Often called the "new asbestos," silicosis is not well known but has severe consequences, including the risk of kidney disease. While undisturbed sand may not pose a significant risk, any activities that generate RCS dust create serious exposure hazards. For more information and recent court cases related to RCS silica, one can search "RCS Silica" or check the Videos section of a relevant website.

Given the well-documented dangers of respirable crystalline silica (RCS), this misinformation is not only irresponsible but borders on negligence. The Applicant appears to be falsifying the silica content to downplay its risks, thus avoiding the need to manage it properly. Additionally, the Applicant is refusing to provide the proposed Safety Data Sheet (SDS). It's also concerning that Fulton Hogan does not make the MSDS for their other sand quarries available on their website. In New Zealand, MSDS (also referred to as Safety Data Sheets or SDS) are required to be accessible to both employees and customers when hazardous substances are involved, in accordance with the Health and Safety at Work (Hazardous Substances) Regulations 2017.

Fulton Hogan's paid consultant, PDP (Pattle Delamore Partners), provided an air quality assessment as so-called "independent experts," but they are contracted and paid by Fulton Hogan (the Applicant) and have a history of working with them to push through consents, which calls their independence into question. For PDP to claim they do not know the silica content of the sands/products completely undermines the credibility of their report. How can they be considered dust experts if they don’t even know what’s in the dust or that concrete sand is high in silica? Moreover, PDP placed silica at the bottom of their air report, despite the fact that silica is classified as a Category 1 Carcinogen—the highest risk level. This omission significantly weakens the reliability of their findings.





























What they are doing is miscalculating the silica percentage and using incorrect dust monitoring equipment and locations so that silica is not properly detected. PDP placed silica at the bottom of their report, despite it being classified as a Category 1 Carcinogen, which should be at the top of the list for priority.

Every reputable sand and concrete company in the Waikato is aware of the Alkali-Silica Reactivity (ASR) issues with Waikato sand and its effects on concrete. This makes it implausible for Fulton Hogan to misrepresent the silica percentage—refer to the 'Resources' section of this website.

We strongly encourage Fulton Hogan & Stevenson employees to research “silicosis in quarrying” or “silicosis in roading.” There is already a known Fulton Hogan employee suffering from silicosis, raising serious health and safety concerns. Upon reviewing Fulton Hogan's website, it became clear that they do not provide Material Safety Data Sheets (MSDS) for their products, unlike their competitors, who include SDS for products like sand.

In a recent South Island consent process, Fulton Hogan successfully removed conditions that required trucks to be covered, eliminated most of the dust monitoring equipment, and reduced reporting requirements for RCS. These actions are nothing short of irresponsible and dangerous to human and animal health, if not outright malicious. More information on this can be found here: [Fulton Hogan appeals conditions over operating new quarry](https://www.odt.co.nz/star-news/star-districts/star-selwyn/fulton-hogan-appeals-conditions-over-operating-new-quarry). 

The saying goes, "If you don’t measure it accurately, the problem doesn’t exist."
As silicosis is a chronic disease, there is no cure and once the damage is done it cannot be reversed.
The New Zealand Government made a correction to a 2018 statement, strengthening their position based on new findings around dust. They also reference the World Health Organization (WHO), which we trust far more than the Applicant and their paid so-called "experts."


















This is the HAPINZ report the NZ Government are referring to:
https://www.ehinz.ac.nz/projects/hapinz3/key-findings-from-hapinz/
Key items from this report:
106 deaths by wind-blown dust 
If there was no air pollution (ie PM2.5 or NO2 from human-made sources) in New Zealand, then about 3,300 deaths would have been avoided in 2016.  This represented about 11% of all deaths in New Zealand in 2016.

Additional reading / links: (also refer the large Video section of this website)
https://lungfoundation.com.au/wp-content/uploads/2023/09/Silicosis-Pamphlet_Mining_updated.pdf
https://www.theguardian.com/australia-news/2019/aug/17/the-next-asbestos-what-you-need-to-know-about-silica
https://www.quarrymagazine.com/2020/08/27/the-impact-of-new-rcs-exposure-standards-on-quarrying-operations/
https://www.health.ny.gov/environmental/workplace/lung_disease_registry/silicosis_road.htm
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1448352/
https://breathefreelyaustralia.org.au/wp-content/uploads/2019/05/road_worker_fact_sheet-AIOH-V2.pdf
https://www.breathefreely.co.nz/wp-content/uploads/2020/06/road_worker_fact_sheet-nzohs-1.pdf
https://pubmed.ncbi.nlm.nih.gov/35468208/
https://www.bellrock.com.au/crystalline-silica-the-new-asbestos/
https://winstoneaggregates.co.nz/assets/Uploads/resources/Sand-SDS-v2.pdf
https://www.torhoermanlaw.com/silicosis-lawsuit/silicosis-lawsuit-settlement-amounts/
https://www.worksafe.govt.nz/topic-and-industry/dust/silica-dust-in-the-workplace/#lf-doc-55260
https://www.hse.gov.uk/quarries/silica.htm
https://lungfoundation.com.au/wp-content/uploads/2023/09/Silicosis-Pamphlet_Mining_updated.pdf
https://www.lung.org/lung-health-diseases
/lung-disease-lookup/silicosis/learn-about-silicosis
https://genesenvironment.biomedcentral.com/articles/10.1186/s41021-021-00193-3

Silicosis with animals:
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10424253/
https://www.mdpi.com/2306-7381/9/6/251
https://respiratory-research.biomedcentral.com/articles/10.1186/s12931-016-0478-5

MSD from Fulton Hogan for one of their other products, they know all about silica and silicosis! The silica content for the below is significantly less than this Application.
https://www.fultonhogan.com/wp-content/uploads/2021/06/LQ1ZN-QUARRY-PRODUCTS-%E2%80%93-GRANITE-SILTSTONE-AND-GREYWACKE.pdf