Lead processes and lead risk work

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Exposure to Lead
What is a Lead Process
What is Lead Risk Work?
Managing risks of lead exposure in lead processes
Air and health monitoring
Notifications
Record keeping
Further information

Exposure to Lead

Everyone absorbs some lead from the food they eat and the air they breathe. There are however, some work-related or non-work related activities that are more likely to result in you having a higher levels of lead in your body than the general public. Hobbies can include shooting and fishing. There are also a range of work activities that can also expose you to lead.

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.

Take home lead

People who work with lead or have a lead related hobby can put their families at risk of exposure.
Lead-contaminated dust from your workplace can attach to your clothes, shoes, hair, skin, work gear and other personal items, which can readily transfer into your vehicle and onto surfaces in your home. This transfer is known as take-home lead.

Some lead-related work can also put neighbouring properties at risk of exposure. It’s essential to prevent the spread of airborne dust and fumes when working with buildings, materials, paint and soil containing lead.

Visit SA Health's Lead exposure from workplaces page for more information

What is a Lead Process?

Workplace activities which are described as lead processes and likely to expose people to lead include:

exposure to lead dust or lead fumes arising from manufacturing or handling of dry lead compounds such as from dry lead pigments, lead UV stabilisers
dry machine grinding, discing, buffing or cutting lead by power tools
manufacturing, handling or recycling batteries containing lead, or pasting or casting lead
repairs to radiators or vehicle exhaust systems
spraying molten lead metal or alloys
melting or casting lead or alloys containing lead, such as lead dampcourses, trophies, yacht keels, leaded brass
recovering lead form its ores, oxides or other compounds by thermal reduction process
dry machine grinding, discing, buffing or cutting by power tools lead or lead alloys
hand grinding and finishing lead or lead alloys containing more than 50% by dry weight
removal of lead paint from surfaces by dry sanding, buffing or grit blasting (including the removal of waste resulting in handling waste containing lead)
welding, cutting or cleaning the surface of metal coated with lead or lead paint through the application of electric arc, oxyacetylene, oxy gas, plasma or a flame, such as in demolition and maintenance work
fire assay involving lead
melting lead metal or alloys containing >50% by weight of lead
manufacturing or testing detonators or other explosives containing lead
exposing people to lead dust or lead fumes arising from firing weapons at an indoor firing range
foundry processes
spray painting with lead paint (> 1% lead by dry weight).

SafeWork SA 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.

What is 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:

5 μg/dL (0.24 μmol/L) for a female of reproductive capacity
20 μg/dL (0.97 μmol/L) in other cases.

Identifying 'Lead risk work'

PCBUs must assess every lead process in their workplace to determine if it constitutes ‘lead risk work’. To assess a ‘lead process’ the PBCU must have regard to the following:

Past biological monitoring results of workers
Airborne lead levels
The form of lead used
The tasks and processes required to be undertaken with lead
The likely duration and frequency of lead exposure to lead
Possible routes of exposure to lead
Any information about incidents illness or diseases in relation to the use of lead at the workplace.

The PCBU must not take into account the effect of using PPE on the health and safety of workers.

If you can’t determine if lead risk work is being carried out in a lead process, you are to assume it includes lead risk work, until such time as it can be proven that it is not.

Managing risks of lead exposure in 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.

Containment of lead contamination

Employers must ensure so far as is reasonably practicable, that contamination by lead is confined to the lead process area at the workplace. This involves enclosing or isolating the lead process area so that lead fumes or dust cannot spread outside that area.

Housekeeping and cleaning

Employers and workers must 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 swept when dry as this will raise lead dust into the air where it can be inhaled or cause further contamination to other surfaces.

Dispose of contaminated rags and filters in line with safe work procedures.

Eating, drinking and smoking

The business must ensure that workers do not eat, drink, chew gum or smoke in a lead process area. They must also ensure workers do not wear / take contaminated clothing into 'clean areas' including eating and drinking areas and that those areas cannot be contaminated with lead. Workers must ensure they clean hands thoroughly before eating and drinking.

Shower and change facilities

Adequate washing, showering and toileting facilities must be provided for lead-exposed workers so they can wash thoroughly before work breaks and shower at the end of their shift. This includes the ability for workers to remove clothing and equipment that is likely to be contaminated with lead and wash their hands and faces before entering an eating or drinking area at the workplace. Have separate areas designated for clean clothing and another area for contaminated work clothes.

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).

Laundering, disposal and removal of personal protective equipment

Businesses must ensure that personal protective equipment that is likely to be contaminated with lead dust—

is sealed in a container before being removed from the lead process area; and
is disposed of on the completion of the lead process work at a site equipped to accept lead-contaminated equipment; and
if it is not reasonably practicable to dispose of the personal protective equipment that is clothing—
- is laundered at a laundry, whether on-site or off-site, equipped to launder lead-contaminated clothing; or
- if it is not practicable to launder the clothing, is kept in the sealed container until it is re-used for lead process work; and
if it is not reasonably practicable to dispose of the personal protective equipment that is not clothing—
- is decontaminated before it is removed from the lead process area; or
- if it is not practicable to decontaminate the equipment in the lead process area, is kept in the sealed container until it is re-used for lead process work.

The person must ensure that a sealed container is decontaminated before being removed from the lead process area and take all reasonable steps to ensure that clothing contaminated with lead-dust is not removed from the workplace unless it is to be laundered in a manner as described above or disposed of.

Safe work procedures

PCBUs 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.

Induction and training

PCBUs need to provide any worker who is likely to be exposed to lead an induction prior to commencing work with information and training on:

the hazards of lead, including sources of exposure, routes of entry into the body and possible harm to health
the control measures used to minimise the risk to health and safety, including correct operation of equipment, other engineering controls and written safe work procedures
the correct use of methods used to minimise the contamination of other workers and the workplace by lead
the importance of personal hygiene and decontamination procedures
the purpose and significance of workplace lead dust monitoring and sharing of the results
the correct care and use of personal protective equipment and clothing, including its limitations
purpose and benefits of work scheduling and job reassignments (to reduce the amount of time a worker is exposed to lead).
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.

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.

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.

Respirators

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.

Lead workers who need to wear face-fitting respirators for their protection should be clean-shaven. 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.

Air monitoring

In a work area where there is a risk of workers being exposed to a hazardous level of lead, employers are required to conduct air monitoring.

There are two types of air monitoring:

personal monitoring - monitors the amount of lead in the workers breathing zone (a 300mm radius around the head). The results of personal monitoring are compared with the national Workplace Exposure Limit (WEL) for lead (currently 0.05 mg/m³, 8 hour TWA).
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 cannot be used to verify compliance with WELs.

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 standards (AS 1715 and AS 1716)

Health monitoring

If a business determines that the lead process is ‘lead risk work’, they must provide an effective health monitoring program to workers.Biological monitoring is intended to detect increasing lead levels in workers before symptoms of ill health occur. The business must pay all expenses relating to health monitoring.

Health monitoring for lead involves biological monitoring in the form of:

the measurement of lead in blood for workers
a medical interview with a registered medical practitioner with experience in health monitoring.

The health monitoring must be supervised by a registered medical practitioner with relevant experience. 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 Health monitoring for registered medical practitioners guide | Safe Work Australia.

Monitoring schedule

Blood lead removal levels

The Work Health and Safety (Blood Lead Removal Levels) Variation Regulations 2019 established a number of changes which came into effect on 1 July 2019. They included:

the frequency that a PCBU must arrange biological monitoring of workers who carry out ‘lead risk work’
mandate a worker’s immediate removal from carrying out ‘lead risk work’ at certain blood lead levels
determine the threshold at which a PCBU may allow a worker to return to ‘lead risk work’.

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.

If work has been identified as lead risk work after a worker commences the work, the health monitoring schedule is:

as soon as practicable after the lead risk work is identified;
one month after the first monitoring

Frequency of biological monitoring

The frequency at which health monitoring is conducted is represented in the table below.A registered medical practitioner or the regulator may recommend more frequent biological monitoring.

PCBU must undertake biological monitoring:	Females of reproductive capacity	*Females not* of reproductive capacity**	Males
If BLL is >10 ug/dL	Worker should be removed from lead-risk work⁺	-	-
If last BLL was 5-10 ug/dL	6 weeks after last BLL test	-	-
If last BLL was <5 ug/dL	3 months after last BLL test	-	-

If last BLL was <10 ug/dL	-	6 months after last BLL test	6 months after last BLL test
If last BLL was 10-20 ug/dL	-	3 months after last BLL test	3 months after last BLL test
If last BLL was >20 ug/dL	-	6 weeks after last BLL test	6 weeks after last BLL test
If BLL is >30 ug/dL	-	Worker should be removed from lead-risk work⁺⁺	Worker should be removed from lead-risk work⁺⁺

The PBCU must pay all expenses associated with biological and health monitoring.

Health Monitoring reports

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 and kept confidential.

The health monitoring report must include a number of key elements. A health monitoring report form template is contained within the guide for registered medical practitioners to use.

Removing a worker from lead risk work

Any worker with a raised blood lead level above the prescribed limited needs to be removed from that work until their blood lead level reduces to an acceptable level. This duty applies even if there is no recommendation of a registered medical practitioner to do so.

The prescribed limits differ between males and females, and if the female is of reproductive capacity. They are:

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

A PCBU must also remove a worker from carrying out lead risk work as a result of health monitoring, if:

a registered medical practitioner who supervised the monitoring recommends that the worker be removed from carrying out the work
or there is 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.

Returning a removed worker to lead risk work

If a worker has been removed from lead-risk work, a registered medical practitioner with experience in health monitoring must determine whether the blood lead level is low enough for that worker to return to lead-risk work. A worker who has been removed, may only return to that work when:

the confirmed blood lead level is less than:
- 20µg/dL (0.97µmol/L) in the case of females not of reproductive capacity and males;
- 5µg/dL (0.24µmol/L) in the case of females of reproductive capacity; and
the worker is certified as fit to return to a lead-risk job by the registered medical practitioner.

There is no requirement for the PCBU to notify the regulator of the worker's return to work.

Notifications

Learn about the requirement for notification SafeWork SA of health monitoring for lead risk work here. https://www.safework.sa.gov.au/notify/lead-risk-work

Notifications relating to Lead Risk Work

Notification of Lead Risk Work

PCBUs undertaking lead risk work must notify SafeWork SA of the activities within 7 days of the work commencing or when the work is determined to be lead risk work. This applies even if the work is short-term, such as abrasive blasting of lead paint from a structure.

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.

Notifications can be made here.

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. Email the Work Environment Team on SWSAWorkEnvironment@sa.gov.au.

Notification of Worker Removed from Lead Risk Work

PCBUs must provide SafeWork SA with a copy of the health monitoring report relating to any worker carrying out lead risk work as soon as practicable after obtaining a report which contains:

test results that indicate the worker has reached or exceeded the relevant blood lead level for that person
- 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
or the registered medical practitioner who supervised the monitoring recommends that the worker be removed from carrying out the work
any advice that the test results indicate the worker may have contracted a disease, injury or illness as a result of carrying out the lead risk work
any recommendation that the PCBU take remedial action, including that the worker can continue to carry out lead risk work
or 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.

Notifications can be made here.

Record keeping

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.