THE sheer number of poorly trained medical advisors assessing the health of mining workers is one factor the CFMEU believes contributed to the startling re-emergence of black lung disease.
Since December 2015, 11 cases of black lung disease, a condition previously believed to have been eradicated, have been detected in Queensland coal mine workers.
An independent review - the Sim Review - conducted by Monash University and released last week pointed to a possible further 18 cases, but these required confirmation.
The review also handed down 17 recommendations geared at fixing the respiratory components of the coal mine workers health scheme, the failings of which contributed to the disease's re-emergence.
In total there are 237 Nominated Medical Advisors - made up of general practitioners and occupational physicians - registered to conduct coal workers' health assessments.
In the opinion of the CFMEU, this is almost 30 times too many.
While the Sim Review recommended "there should be a smaller pool of doctors undertaking the health assessments", the mining union said this pool should be no greater than eight.
The union also believes the doctors need to be appointed independently of mining companies and that they should be funded by a mining industry levy, rather than by individual mining companies.
But the report also pointed out there was no formal system for vetting or training these 237 doctors, 30 of whom operate from Mackay and 16 from Rockhampton.
From 256 lung function test samples, the reviewers assessed they found the appointed doctors conducted 40% incorrectly, and that 41% of the tests carried out properly were then interpreted incorrectly.
When it came to chest x-rays, the Sim Review found 18 of 248 sampled showed signs of possible black lung disease.
These 18 had been missed by the original radiographers, the review found.
The CFMEU said this should reveal the need for all doctors and radiographers assessing coal workers to be trained and experienced to international standards.
It also called for all radiologists to be trained in the 'B-reader program'.
The program was introduced in the US to ensure consistency in the way coal miners' x-rays were read.
A Department of Natural Resources and Mines spokesperson said it would consider all feedback provided by the CFMEU and then respond to the union in time.
The CFMEU believe there are almost 30 times too many doctors (Nominated Medical Advisors) conducting coal workers' health assessments.
Mackay: 30 NMA's are registered
Sunshine Coast: 14
Gold Coast: 9