Wessam al Jundi

To: 

Mrs. Lisa Young  

HM Coroner's Officer ManagerEngagement and Policy Division – Manufacturing Sector 

RE: Death of Wassam al Jundi - HMC Regulation 28 Report  (ref: 35218597) 

Dear Mrs. Young, 

please see below a statement on behalf of the Agglomerated Stone Manufacturers Association (A.St.A), 
in  response  to  your  enquiry  sent  on  January  10th  2025.  The  statement  can  be  attributed  to 

, director of A.St.A. 

Our  association  A.St.A.  was  formed  in  2010  to  promote  Environmental  Health  and  Safety  standards 
among all members in the engineered stone industry, including the thousands of third-party fabricators 
that fabricate our products and other stone products in their workshops prior to their installation.  

A  critical  safety  issue  in  the  stone  fabrication  industry  is  the  requirement  to  follow  well-established 
regulations and rules to protect workers from overexposure to respirable crystalline silica which can be 
generated  during  fabrication  (e.g.,  cutting,  grinding,  and  polishing)  of  stone  products  that  contain 
crystalline silica.  Regulatory bodies have established regulations and requirements to control silica dust 
and prevent overexposures to employees, and all employers who work on products containing silica must 
follow these standards.   

While many fabricators care about this issue and follow the rules to protect their workers, there remains 
a need for increased compliance and enforcement activities to ensure that all stone fabrications workers 
are safe from respirable silica overexposure in their workplaces.   

Unfortunately,  recent  years  have  shown  an  increase  in  prevalence  of  silicosis  and  other  occupational 
pulmonary diseases among employees of stone fabricators.  Silicosis is prevented through compliance 
with well-established safety regulations and requirements and it is essential that all fabrication employers 
ensure the safety of their employees at all times.   

Many  industry  stakeholders  have  been  working  toward  increasing  awareness,  compliance  and 
enforcement of the safety regulations and requirements in the stone industry. Regulators, have made clear 
and  simple  rules  (such  as  allowing  only  wet  cutting)  or  have  placed  emergency  standards  with 
requirements aimed to improve compliance and increase enforcement.  We and our members have been 
advocating for awareness, placing warning stickers, providing data sheets, creating educational materials 
all aimed to protect workers, and indeed many fabricators have invested behind the necessary equipment 
that allows them to completely protect their employees form this threat.  Importantly, this is a workplace 
safety issue, not a product issue.    

It seems that positively influencing such behaviors requires focused governmental involvement, and we 
are calling to consider the adoption of either clear and easy to follow rules, implement a licensing program 
for  the  fabricator’s  professions  (similar  to  electricians,  plumbers,  and  gas  technicians)  or  of  both.  As 
example for clear rules, we would suggest considering requiring: 

A.St.A. World-Wide 
Agglomerated Stone Manufacturers Association 
Via Brennero 108 - 37015 DOMEGLIARA (VR) - ITALY  
P.I. 03965830239 - C.F. 93080320232 - info@astaworldwide.com 

 
 
 
 
 
 
 a.  That all cutting tasks be performed using wet equipment and that no dry-cutting, dry-grinding or 

dry-polishing be allowed (manual or CNC)  

b.  Wet cleaning methods 
c.  Occupational review of the site and periodic air sampling 
d.  Medical surveillance 
e.  Mandatory training for employees 

As for the proposed licensing program we believe following components should be considered:  

(a)  Worker training required to obtain licenses,  
(b)  Familiarity and implementation of environmental control measures (e.g., air testing) with on-site 

auditing by inspectors or outsourced authorized bodies,  
(c)  Restrictions on fabrication of stone products without a license, 
(d)  Prohibition against dry cutting, dry grinding, and dry polishing, 
(e)  Prohibition to supply to or purchase from an unlicensed fabricator,  
(f)  Appropriate enforcement and penalty provisions.   

We remain at your disposal for any support you might need in this field. 

Sincerely,  

A.St.A. World-Wide 
Agglomerated Stone Manufacturers Association 
Via Brennero 108 - 37015 DOMEGLIARA (VR) - ITALY  
P.I. 03965830239 - C.F. 93080320232 - info@astaworldwide.com

From: 
Sent: Thu Jan 16 2025 17:37:26 GMT
To: 
Subject: RE: Death of Wassam al Jundi - HMC Regulation 28 Report (ref: 35218597)

Good afternoon,

Thank you for forwarding this on. DHSC has no comments or suggestions for this 
document.

Our response to this PFD case suggested that responsibility for the Coroner’s concerns 
sits with HSE. It may be worth forwarding to them.

Kind regards,

DHSC PFD Oversight Team

Quarry House, Quarry Hill, Leeds, LS2 7UE

E:

Department of Health and Social Care

Follow us on Twitter @DHSCgovuk

Engagement & Policy Division 

Deputy Director 

2 Victoria Pl 
Carlisle 
CA1 1 ER  

M: 
E:

18 December 2024  

Dear Mrs Brown,   

Prevention of future deaths report – your investigation into the death of Wessam  
Al-Jundi  

Thank you for your letter and Regulation 28 report made under the Coroners and Justice 
Act 2009 and Regulations 28 and 29 of the Coroners (Investigations) Regulations 2013.  

Firstly, I would like to express my sympathy to the family of Wessam Al-Jundi at the loss 
of their loved one. 

In your report, you outlined matters of concern for consideration by the Health and 
Safety Executive (HSE), as highlighted by the key issues quoted below:   

“Any current surveillance health and safety monitoring is unlikely to achieve a 
satisfactory outcome as the onset of untreatable disease predates the 15 year 
surveillance programmes.”   

“Evidence from photographs and an in-life statement suggest Wessam was working in 
completely unsafe conditions to avoid dust exposure”…..….”there appears to be an 
absence of safe working conditions, with no adequate water suppression systems for the 
dust created, in adequate respiratory personal protection equipment and absent or 
inadequate ventilatory systems.  This is therefore continuing to put the workforce at risk 
of death due to untreatable lung compromise.”  

The Health and Safety at Work etc Act 1974 and the Control of Substances Hazardous to 
Health Regulations 2002 (COSHH) (as amended) provide a robust regulatory framework 
requiring employers to put in place measures to prevent workers being exposed to 
hazardous substances, such as artificial stone dust containing respirable crystalline silica 
(RCS).  

COSHH requires employers to make a suitable and sufficient assessment of the risks to 
health, and to ensure that exposure to substances hazardous to health is either 
prevented or, where this is not reasonably practicable, adequately controlled. Exposure 
to RCS is preventable where adequate control measures are in place to protect 
workers.   

HSE provides a range of free resources and guidance online for employers setting out 
how workers can be protected from exposure to RCS. Suitable control measures include 
combinations of the enclosure and automation of processing equipment, the use of 
water suppression and control of any mist generated, as well as personal protective 
equipment such as respirators (masks).  The effectiveness of controls must be 
maintained, and workers must have been trained and competent to use such controls. 

   
 
 
 
 
         
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 Suitable health surveillance must also be provided for workers liable to be exposed to 
RCS. Where there is a risk of developing conditions such as accelerated silicosis, or 
where there is evidence of significant overexposure to RCS, the timing and performance 
of health surveillance should be adapted. This means chest x-rays being performed well 
before the 15-year time period you refer to, and referral to an occupational lung disease 
specialist being made as appropriate. In May 2024, we clarified these requirements in 
the updated ‘Health surveillance for those exposed to respirable crystalline silica (RCS), 
Supplementary guidance for occupational health professionals’, which is available on 
HSE’s website at https://www.hse.gov.uk/pubns/guidance/g404.pdf.   

HSE works with industry and suppliers to raise awareness of managing the risks of 
exposure to RCS, and works proactively with key stakeholders and trade associations, 
for example, in the construction industry.  We have delivered several national inspection 
campaigns and continue to investigate reported ill-health and concerns about 
inadequate risk management in industries where there is potential for exposure to 
RCS.   

On 7 October 2024, we met with manufacturers of stone products to discuss practical 
solutions businesses and dutyholders can take to protect workers from exposure to RCS 
when working with high silica content stone. We also met with key fabrication 
employers on 25 November 2024. Further workshops are proposed to ensure a broad 
understanding of how engineered stone is being supplied and used to enable us to 
devise further interventions targeting key issues.   

As part of this engagement, we have confirmed the requirements for working high silica 
content stone worktops, and we will shortly be publishing further guidance, aimed at 
installers, their managers and supervisors to remind them of the steps they must take to 
control the exposure risk. We are also working with the Worktop Fabricators Federation 
to support development of their own information leaflet which they can share amongst 
their networks.  

Collectively, this raises awareness of the need for controls when engineered stone is 
being worked. HSE continues to review the latest global evidence to consider what 
additional controls or action may be necessary and it is engaging with occupational lung 
disease clinicians to build understanding of affected workers.  HSE has commissioned 
research to better understand the underlying causes of poor compliance with use of 
controls by employers closest to the problem (e.g. fabricators).   

I understand that you are in contact with our lead investigator who is examining the 
circumstances leading to the death of Wessam Al-Jundi.  They will keep you updated as 
this investigation progresses.  

I hope this confirmation of HSE’s work in this area and our commitment to tackling this 
health risk is helpful to your investigations.   

Yours sincerely  

.

From:
Sent: Fri May 02 2025 16:59:56 BST
To: e
Subject: RE: Death of Wessam al Jundi (ref: 35218597)

OFFICIAL

Dear 

,

Thank you for your email below to the Government Legal Department’s (GLD) central
litigation team.

With sincere apologies, the report contained within (attached) has unfortunately been
subject to delays in reaching the relevant department for consideration within the
Ministry of Housing Communities and Local Government (MHCLG) and confirming any
preceding GLD litigation team involvement in this case.

Please find attached a request for an extension to the 56 day period permitted in order
to issue a formal response.

Also attached is the Health and Safety Executive’s (HSE) response to the report. The
concerns raised within the report relate to working practices and protections which
would fall within the remit of HSE and the regulations its response set out. Policy owned
by MHCLG would not be applicable in addressing these issues and there is
consequently little substantive addition MHCLG could provide to HSE’s response.

We are of course able to provide a formal response explaining the extent of MHCLG’s
policy remit and why this would be a matter for HSE, but wish to highlight this limitation
in case it would mean a formal response and additional delay would be unhelpful to the
coroner’s investigation.

Kind regards

, on behalf of 

, Deputy Director, Construction Products

Reform, MHCLG

(she/her)

Head of Strategy, Communications & Engagement, Construction
Products Reform

Ministry of Housing, Communities & Local Government

Regulatory Stewardship & Reform

WFF Silica Dust – draft ‘state of the art’ positioning statement:  November 2024 

1  Quartz worktops have been headline news since the end of 2023, when first major Australian 
retailers and then the Australian government announced a country-wide silicosis-scare 
product ban.  Australia's government H&S agency, Safe Work Australia, made these findings 
of occupationally-acquired silicosis in a report released in October 2023: 
•  Engineered stone workers develop silicosis at a "disproportionate" rate compared to other 

industries 

•  Most engineered stone workers who developed silicosis were under 35 
•  Engineered stone workers faced a faster disease progression (which means they become 

unwell more quickly) and a higher mortality rate (which means they are more likely to 
die) than silicosis victims in other industries 

•  Overall, the report concluded that "the use of all engineered stone should be prohibited". 

2 

‘Quartz’ is a catch-all term for man-made engineered stone materials, created in factories by 
combining quartz sand, colourings and additives with thermosetting resins to create large-
format slabs which exhibit all the appearance, weight and aesthetics of natural stone.  Quartz 
dominates the UK stone worktops market (70%+ by volume of all stone worktops sold).  The 
main reason is design consistency:  engineered stone slabs deliver a genuine ‘stone’ aesthetic, 
but with all the advantages and consistencies of factory-engineered products.  Colour, texture, 
porosity, patterning and dimensional stability are no longer products of random nature, but of 
precise engineering and considerable research and development.  Quartz is a product with 
which retail showrooms are familiar and consumers are comfortable, and which fabricators’ 
machine minders are confident in processing. 

3  The first point to emphasise is the very distinct and discrete nature of the occupational 
risk.  It exists entirely and exclusively at the point at which the stone is processed by cutting 
and polishing instruments:  preeminently when large-scale stone slabs are cut down and 
finished to meet the precise dimensions and design requirements of the finished worktops.  
Risk can also occur when processing smaller stone pieces and/or in renovation and 
remodelling if worktop removal involves cutting or grinding tools. 

4 

It needs to be understood that consumers, specifiers or installers are not at risk in using these 
products once this fabrication process has been completed.  Respirable silica dust is released 
only when cutting or polishing tools are applied to the material. This issue is not analogous to 
asbestos exposure, or to more contemporary consumer concerns about formaldehyde, fire 
retardants or similar chemicals leaching from consumer products over time and compromising 
indoor air or water quality.    

5  There need be no question of anyone being at risk from existing work surfaces or interior 

features.  There are negligible risks associated with conventional demolition or removal either 
-- provided the worktops are not cut with machine grinding tools.  

6  Any risks from crystalline silica dust occur only when the surface is cut by fast moving 

abrasive tools in the factories or work-places where the worktops are cut, shaped and polished 
prior to installation. The cutting process flings invisibly-small fragments of crystalline silica 
into the air where it can be then breathed into the lungs.   

7 

It is this Respirable Crystalline Silica (RCS) dust that creates the specific Silicosis health risk 
which sparked the Australian ban, and lies behind proposals for similar regulatory 
interventions in parts of the USA. 

 
 
 
 
 
 
 
 
 
 8 

9 

It should be emphasised that both fabrication and enforcement practices in those countries 
have historically been significantly less ‘tight’ than in the UK, which has had the Health & 
Safety at Work Act since 1974.  Australasian, American and Spanish fabricators featured in 
case studies have been characterised by widespread use of dry-cutting, poor factory controls 
and reliance upon natural ventilation.  (see for example, Spain in 2018) 

It is significant in this regard that the first identified UK cases of occupationally-acquired 
silicosis specifically related to worktop fabrication are all associated with poorly-controlled 
workplace environments which (from the victims’ descriptions) did not comply with more 
than the most basic UK regulatory requirements. (Feary et c, 2024: 
https://thorax.bmj.com/content/79/10/979 ) 

10  There are two distinct, but complementary, issues which need to be addressed in a safe 

fabricating workplace.  The first is the risk of exposure to workplace dust in general, and to 
respirable fractions (sub- 5 micron) in particular.  The second is exposure to dust specifically 
containing respirable crystalline silica (RCS) dust, which has been identified as carcinogenic. 

11  The above is important when considering the conventional risk-prevention hierarchy.  The 
first consideration is always substitution with a lower-risk alternative.  In the case of stone 
worktops, substitution is only an option where distinct alternative categories exist.  The 
obvious substitutes for engineered quartz are either the traditional natural stone it largely 
replaced, or the new generation of extra-large-format ceramic tiles.  But both natural stone 
and man-made large-format porcelain/‘sintered stone’ products also create dust when cut.  
And naturally-occurring granites and quartzites may contain as much silica as engineered 
quartz products.   

12  The HSE provides a range of resources and guidance online setting out how workers can be 
protected from exposure to RCS including use of water suppression, equipment enclosure, 
extraction and personal protective equipment, such as respirator masks.  Workers must also be 
trained and competent to use such controls. (See for 
example  https://www.hse.gov.uk/pubns/guidance/st0.pdf; 
https://www.hse.gov.uk/pubns/priced/hsg201.pdf) 

13  The important principle here is the use of ‘proper controls’.  Great Britain has long-

established Workplace Exposure Limit metrics, and it is incumbent upon factory owners to 
manage staff training and production line processes to operate below those limits.  And also 
incumbent upon workers to wear any PPE provided, and to ensure they do nothing to put 
themselves or fellow workers at risk of exceeding the WEL. 

14  The use of water as both a dust suppressant and as a tool lubricant is long established among 
professional fabricators in the UK.  Cutting slabs and upstands to size, creating cut-outs for 
taps, sinks and hobs and polishing cut edges are routinely carried out on large-scale CNC 
machinery, typically using enclosures to reduce workforce exposure and water suppression at 
the cutting or polishing head.  Hand-finishing and polishing is usually carried out wet, with 
the need to control dust-laden mist being met typically by air extraction at point of use, often 
involving further water-wall booths.  Risks to individuals undertaking hand-finishing are 
usually further mitigated by the use of face-fit or positive-pressure RPE. 

15  Different factories will all use different machinery and different processes.  But they are all 

required to operate below the same WEL. 

16  There are no barriers to entry to the market.  Light industrial units (Class B-2) are typically 
suitable for setting up worktop factories;  second-hand machinery is easily available;  major 
brands of engineered stone may require fabricators to make minimum stock investments and 

 
 
 
 
 
 
 
 
 adhere to specified processing requirements, but non-branded raw materials are widely 
available, either sourced direct from overseas suppliers or via UK distributors. 

17  There is no SIC code specific to the manufacture of stone worktops. This makes it impossible 

to identify a specific universe of practitioners, or even estimate the total number of 
organisations carrying out business as fabricators. Artificial stone appears three times in the 
SIC code notes uksic2007webamend8531 (9).pdf: 

•  22.23 Manufacture of builders’ ware of plastic - manufacture of artificial stone (e.g. 

cultured marble) 

•  23.61 Manufacture of concrete products for construction purposes – manufacture of 

precast concrete, cement or artificial stone articles for use in construction 

•  23.69 Manufacture of other articles of concrete, plaster and cement – manufacture of 

other articles of concrete, plaster, cement or artificial stone  

•  Plus there is also the option of registering under cutting and finishing of stone – 23.70. 

18  Because of the growth in the market over the last 20 years (largely driven by the quartz 

worktop manufacturers’ marketing efforts and consistency of product, particularly into new 
homes and the top end of the kitchen market), engineered stone worktops are desirable, 
aspirational products.  Naturally, kitchen showrooms wish to offer them.  They can easily add 
several thousand pounds to the contract value in supplying a new kitchen.   

19  Kitchen showrooms lack the skills, equipment or expertise to process and supply stone 

worktops.  They inevitably sub-contract the template-supply-and-fit process to third-party 
specialist fabricators.  This often extends to the fabricator inviting the end customer to come 
and view the stone slab from which their worktop will be created, and to discuss the detail of 
the fit or the flow of the grain or ‘value add’ options like draining groove details which can be 
incorporated in the factory worksheet.  The end-user’s contract, though, is usually with the 
showroom, rather than direct with the fabricator. 

20  Similarly with interior designers, house-builders or other specifiers:  the role of the fabricator 

is often that of a specialist consultant and sub-contracted supplier. 

21  The combination of a widely-desired, high-ticket aspirational product, the reliance upon 
fabricators for third-party specialist expertise, the comparative lack of experience among 
purchasers and the infrequent or one-off nature of the purchasing decision, together with the 
low cost of entry to the profession, means there is no shortage of ‘worktop fabricators’ in the 
UK.  In many ways, the industry at its present stage of professionalism resembles the double-
glazing industry of a generation ago.  Or the current market for retro-fit solar panels. 

22  In particular, the natural consumer desire to obtain a high-ticket item for the lowest possible 

price creates a natural ‘pull’ for low-cost operators.   

23  The way for a fabricator to reduce the purchase price of the raw materials is governed either 
by quantity (volume-based discounts) or by quality (non-branded product of unproven 
provenance or formulation).  So that leaves building occupancy costs, sunk costs of capital 
equipment and employment costs of workforce.  Of which the costs of creating and 
maintaining a safe working environment, purchasing and maintaining correct protective 
equipment and undertaking appropriate training, safety monitoring and occupational health 
procedures are all (a) invisible to the customer and (b) additional to the costs of producing 
worktops.        

24  If the retail showroom or the housebuilder is the Principal Contractor, they carry a statutory 
duty to ensure their subcontractors are following correct HSE regulations.  Retailers and 

 
  
 
 
 
 
 
 
 
 specifiers should exercise their duty of care by ensuring they buy only from fabricators who 
can demonstrate a commitment to Health & Safety including proper demonstrably effective 
factory controls for dust, ensuring any on site cutting is minimised and the risks of RCS 
managed. 

+ 

+ 

+ 

+ 

25  The industry has explored several ‘what-ifs’ about somehow controlling or regulating the 
market for stone worktops.  As all engineering stone is imported, it would be possible to 
create controls at point of entry, such that the product could only be released either to the 
manufacturer’s licenced UK distribution arm, or to a registered fabrication business.  Selling-
on would need to be accompanied by a provenance certification route, similar to that for 
certificated timber or waste-transfer notes.  

26  The double glazing industry’s code of practice and associated FENSA registration model may 
also be worth exploring.  Especially as FENSA certification is universally required when 
homes come subsequently to be sold.  

27  Because worktop fabricators are usually trade suppliers of business customers, many of the 
approaches being considered by the Federation of Master Builders’ current campaign to 
license the UK building industry might also be appropriate for consideration.