- Changes to blood lead removal levels
- Work activities
- Assessing lead processes
- Safe work procedures
- Induction and training
- Air and health monitoring
- Controlling risk of lead exposure
- Removing a worker from lead risk work
- Record keeping
- Further information
Everyone absorbs some lead from the food they eat and the air they breathe. However, if you are exposed to lead at work, it is more likely that you will have higher levels of lead in your body than the general public.
Exposure to lead has the potential to cause adverse health effects to exposed workers. The removal of lead from paint and petrol within Australia has significantly reduced background levels and concerns for some workers previously exposed to inorganic lead at work. However, workers continue to be subject to chronic exposure to lead in a number of industries. Lead can be inhaled through dust or fumes or swallowed through eating contaminated food.
Health problems from exposure to lead can be prevented by implementing exposure controls to minimise a worker's exposure to lead.
Changes to blood lead removal levels
The Work Health and Safety (Blood Lead Removal Levels) Variation Regulations 2019 have been made and will come into operation on 1 July 2019, with a two year transitional period for the new blood lead levels. This change reduces the notification levels of the allowable blood lead levels in workplaces, as agreed nationally.
The amendments relate to blood lead levels:
- contained in the definition of ‘lead risk work’ under regulation 394
- that determine the frequency that a PCBU must arrange biological monitoring of workers who carry out ‘lead risk work’
- that mandate a worker’s immediate removal from carrying out ‘lead risk work’
- that determine the threshold at which a PCBU may allow a worker to return to ‘lead risk work’.
Lead risk work means work carried out in a lead process that is likely to cause the blood level of a worker carrying out that work to be more than:
For the period up to and including 30 June 2021
- 10 μg/dL (0.48 μmol/L) for a female of reproductive capacity
- 30 μg/dL (1.45 μmol/L) in other cases.
From 1 July 2021
- 5 μg/dL (0.24 μmol/L) for a female of reproductive capacity
- 20 μg/dL (0.97 μmol/L) in other cases.
Some of the workplace activities exposing people to lead include:
- dry machine grinding, discing, buffing or cutting lead
- manufacturing or recycling lead-acid batteries
- repairs to radiators or vehicle exhaust systems
- melting or casting lead or alloys containing lead, such as lead dampcourses, trophies, yacht keels, leaded brass
- removal of lead paint from surfaces by dry sanding, heat or grit blasting
- demolition involving oxy-cutting of structural steel primed with lead paint
- fire assay involving lead
- handling lead compounds causing lead dust, such as from dry lead pigments, lead UV stabilisers
- spray painting with lead paint (> 1% lead by dry weight).
Assessing lead processes
PCBUs have a primary duty of care to ensure, so far as is reasonably practicable, that workers and other people (such as premises neighbouring your workplace) are not subjected to risks arising from lead exposure.
PCBUs must assess every lead process in their workplace to determine if it constitutes lead risk work. If you can’t determine if a process includes lead risk work, you should accept that it does until such time as it can be proven otherwise.
We can decide that a process carried out at a workplace is a lead process if we are satisfied that it creates a risk to the health of a worker, having regard to blood lead levels or airborne lead levels in the workplace. Our decision is a reviewable decision.
Safe work procedures
Employers should develop and implement safe work procedures for activities where workers are or may be exposed to lead. For example, coatings and metals should be checked for lead before starting activities such as welding, grinding, and drilling.
Some activities require detailed, step-by-step safe work procedures on how to perform the work safely. For example, if lead is found in a coating, a detailed safe work procedure is required on how to remove the coating before work begins.
A risk management process is outlined in the Workplace Health and Safety Regulations. This process includes:
- identifying hazards (both general and for lead risk work)
- assessing risk and deciding on control measures
- implementing control measures
- monitoring and reviewing the effectiveness of control measures.
You must notify us of any lead risk work within 7 days of the risk determination or if a determination in unable to be made. This applies even if the work is short-term, such as abrasive blasting of lead paint from a structure.
You must also advise us in writing of any changes to the information provided in this notification, either before or as soon as practicable after becoming aware of the change.
Emergency services organisations must notify us as soon as is practicable if lead risk work was determined to be carried out in the course of a rescue or administering first aid.
Induction and training
PCBUs need to provide any worker who is likely to be exposed to lead, induction prior to commencing work and, at least annually after that, information and training on:
- the potential health risk and toxic effects associated with lead exposure
- the control measures used to minimise the risk to health and safety
- the correct use of methods used to minimise the contamination of other workers and the workplace by lead
- the correct care and use of personal protective equipment
- the need for, and details of, a health monitoring program.
The induction and training provided must be commensurate with the risk identified by the assessment process and be provided in a manner appropriate to the workers in the workplace, in particular, those of non-English speaking backgrounds.
Air and health monitoring
In a work area where there is a risk of workers being exposed to potentially hazardous level of lead, employers are required to have an effective health protection program as well as conduct air monitoring.
Monitoring frequency must be increased for any worker involved in an activity or process that is likely to significantly change the nature of or increase the duration or frequency of worker’s lead exposure.
There are two types of air monitoring:
- personal monitoring - monitors the amount, or level of lead in the workers breathing zone (a 300mm radius around the head). The results of personal monitoring are compared with the national exposure standard for lead, which is based on personal exposures
- static monitoring - provides data on the lead concentration in specific areas of a process or plant and may be used to assess the effectiveness of engineering controls. The results of static monitoring may not be comparable with the exposure standard which is based on personal exposure.
To interpret a report involving air monitoring and the applied controls, you will need a good understanding of:
- the appropriate use of the hierarchy of controls
- exposure standards and their use
- industrial ventilation
- respiratory protective equipment standard (AS 1716)
- how to select respiratory protection (AS 1715).
Health monitoring is intended to detect increasing lead levels in workers before symptoms of ill health occur.
Health monitoring for lead involves:
- the measurement of lead in blood for workers who are exposed to inorganic lead
- a medical interview with a registered medical practitioner with experience in health monitoring.
The medical consultation element of health monitoring provides an opportunity for individual counselling in relation to the health effects of lead.
Safe Work Australia has lead health monitoring guides for workers, PCBUs and medical practitioners.
For a worker who is to start work in a lead risk job, the health monitoring schedule is:
- health monitoring before the worker starts work
- blood lead monitoring one month after starting work.
For a worker who already works in a lead risk job, the health monitoring schedule is:
- blood lead testing within one month after the risk assessment shows that a job is a lead risk job
- health monitoring as per the schedule in the Work Health and Safety Regulations 2012 (SA) (reg 407).
PCBU must keep records of all health monitoring activities and provide workers with a copy and explanation of their health monitoring test results. Health monitoring records must be kept for 30 years.
A health monitoring report form template is contained within the guide for registered medical practitioners to use.
Controlling risk of lead exposure
PCBUs should follow the hierarchy of risk control to manage the risk of lead exposure. Where possible implement the highest order risk controls.
PCBUs should eliminate the use of the lead substance or process that creates a health risk to workers with a substance or process that is less hazardous.
- use aluminium radiators with plastic tanks instead of copper-core radiators with soldered tanks
- implement lead free paint processes
- use a calcium based stabilizer instead of lead based, for UV light and heat.
If the hazard cannot be eliminated, there are a number of control options that can be used alone, or in combination, to prevent or minimise lead exposure.
Substitution involves replacing the hazard with one that presents a lower and more manageable risk.
The concentration of lead can be reduced or a different form of lead can be used that is less readily absorbed.
For example, if there is no substitute for lead-based solder, an oxyacetylene torch should be substituted for one with a cooler flame such as propane or LPG. This will decrease the risk of lead fume exposure.
Before substituting materials, make sure that the new material does not contain another product that is just as hazardous or more hazardous than lead. Check the product's safety data sheet for help identify potential hazardous components.
Isolation refers to isolating or separating the hazard from the person, or the person from the hazard.
Sometimes lead-containing materials cannot be avoided and are required for, or provided by, the production process. The most effective method of controlling dust and fumes from lead-containing materials is to totally enclose the task or process that produces lead contamination. This will eliminate or minimise lead exposure for all workers.
An example of an isolation control for the radiator repair industry is the use of a sand blast or bead blast machine to clean the remaining solder from the header plate. In these systems, tiny glass beads or sand is projected in a stream of compressed air at the header plate to blast the surface clean.
Partially enclosing or segregating a task or process may reduce lead exposure for some workers but not all workers.
Engineering controls are developed by reviewing the production process in order to find ways to minimise and, if possible, eliminate the amount of lead contaminant being released into the atmosphere. In some situations, it may be possible to consider modifying processes to reduce the amount of lead fume or dust generated.
Engineering control options include local exhaust ventilation, robotics and even temperature regulation to reduce fume.
All workers are responsible for ensuring tools and equipment, including exhaust systems, are working properly and well-maintained. Workers should report equipment problems and failures immediately.
Administrative controls involve minimising exposure to a risk through the use of procedures or instruction.
These may include worker education and training, personal hygiene rules regarding hand washing and eating and drinking as well as cleaning and housekeeping, safe work procedures, maintenance of equipment, work scheduling and implementation of a health protection program.
Education and training
Workers who may be exposed to lead require adequate training and instruction on the following:
- hazards of lead, including sources of exposure, routes of entry into the body and possible health effects
- correct operation of equipment and other engineering controls
- written safe work procedures
- proper use, maintenance and limitations of PPE and clothing
- importance of personal hygiene and decontamination procedures
- purpose and significance of workplace lead dust monitoring and health monitoring and results
- purpose and benefits of work scheduling and job reassignments (to reduce the amount of time a worker is exposed to lead).
The amount of time that a worker is exposed to lead can be reduced through job rotation and varied work assignments. Changes to work schedules can reduce exposure by:
- limiting the amount of lead absorbed
- allowing the body time to naturally get rid of any lead that has been absorbed
- allowing work with high lead levels to be undertaken when there are fewer workers in the work area.
Employers and workers should ensure that work areas are kept clean and free of lead dust. Surfaces should be cleaned with water, wet mops, wet rags, and vacuums with high efficiency particulate air (HEPA) filters to prevent lead dust from contaminating work clothes and tools. Surfaces should not be wiped or or swept when dry as this will raise lead dust into the air where it can be inhaled and cause further contamination to other surfaces.
Dispose of contaminated rags and filters in line with safe work procedures.
Shower and change facilities
Adequate washing, showering and change facilities must be provided for lead-exposed workers so they can wash thoroughly before work breaks and shower at the end of their shift. Have separate areas designated for clean clothing and another area for contaminated work clothes. Separate the two areas with shower and washing facilities.
Other personal hygiene items to include in wash facilities are:
- nail brushes
- paper towel or air dryers (no reusable towels)
- soap dispensers (not soap bars).
A worker must not eat, chew gum or smoke in a lead process area. Eating and food preparation and storage areas must be isolated from work areas. Do not wear / take contaminated clothing into 'clean areas' including food preparation areas. Clean hands thoroughly before eating and drinking.
Personal protective equipment (PPE)
When other control measures are not technically possible, are impractical, or do not provide adequate protection, PPE such as respirators and properly fitting coveralls must be used.
Personal protective equipment is worn as the final barrier between a worker and the hazard.
The requirements under WHS for PPE as a control follow, as the least effective control measure the implementation of its use requires consultation, planning and a number of considerations.
Employers are required to provide the necessary equipment and worker training on the proper use of such equipment. Workers must use and maintain PPE to minimise lead exposure.
Any clothing (including boots) and other PPE used during lead work must be cleaned separately from other clothing and must not be taken home for laundering.
If respirators are required, they must:
- be matched for the work task and the degree of risk
- be properly fitted for the individual worker
- tested to ensure adequate protection from exposure to lead
- regularly cleaned
- properly stored to prevent lead contamination
- have filters inspected and replaced regularly and according to the manufacturer's instructions.
There are two main types of air-purifying respirators:
- particulate respirators, which filter out thermally and mechanically generated particles, and
- gas respirators, which only filter out certain gases and vapours.
Combined particulate and chemical filter respirators are commonly used in atmospheres where impurities are mixed, such as in spray painting where there are both solvent vapours and particulate paint mist.
There are three classes of particulate filters suitable for filtering finely divided solid or liquid particles, or both from inhaled air:
- Class P1 – intended for use against mechanically generated dust particles
- Class P2 - intended for use against both mechanically and thermally generated particles
- Class P3 – intended for use against all particles.
Class P1 and Class P2 filters usually, but not exclusively, incorporate a half facepiece. Class P3 respirators comes only as a reusable type. The mask is a full face or ‘gas mask’ and is fitted with a large canister filter, fitted to the mask or worn separately on a belt with a connecting hose. It provides the highest level of protection of any filter respirator but heat and discomfort levels are high.
Lead workers who need to wear respirators for their protection should be clean-shaven. Beards, beard stubble and even large moustaches diminish the efficiency of filter respirators by 90% or more. If lead workers are not clean-shaven, they must wear a respirator, which provides air at a positive pressure such as a PAPR or a supplied air hood.
Removing a worker from lead risk work
Any worker with a raised lead level above the prescribed limited needs to be removed from that work until their bodies can get rid of excess lead.
If you remove a worker from carrying out lead risk work as a result of health monitoring, you must notify us if:
- for the period up to an including 30 June 2021, the worker’s blood lead level is, or is more than:
- 50 μg/dL (2.42 μmol/L) for females not of reproductive capacity and males
- 20 μg/dL (0.97 μmol/L) for females of reproductive capacity
- 15 μg/dL (0.72 μmol/L) for females who are pregnant or breastfeeding
- from 1 July 2021, he worker’s blood lead level is, or is more than:
- 30 μg/dL (1.45 μmol/L) for females not of reproductive capacity and males
- 10 μg/dL (0.48 μmol/L) for females of reproductive capacity
- the registered medical practitioner who supervised the monitoring recommends that the worker be removed from carrying out the work
- there’s an indication that a risk control measure has failed and, as a result, the worker’s blood lead level is likely to reach the point where they would be removed from carrying out lead risk work.
A worker who has been removed from lead risk work may only return to that work when:
- the confirmed blood lead level is less than:
- 40mg/dL (1.93 µmol/L) - for males and females not of reproductive capacity
- 10mg/dL (0.48 µmol/L) - for females of reproductive capacity, including females who have ceased their pregnancy and are not breast feeding, and
- the worker is certified as fit to return to a lead-risk job by the authorised medical practitioner.
If lead risk work is carried out at your workplace you must:
- keep a copy of the notification you provided us for the period that the lead risk work is carried out
- ensure a copy of the notification is readily accessible to a worker who is likely to be exposed to lead, as well as their health and safety representative.
Respiratory Protection Equipment (REP) - SafeWork SA
Working with lead - Work Safe Queensland
Exposure standards for atmospheric contaminants in the occupational environment - Safe Work Australia
Australian Standard 3640-2004 Workplace atmospheres-method for sampling and gravimetric determination of inhalable dust