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• Exposure to Lead
• What is Lead Risk Work?
• Managing risks of lead exposure
• 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.

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.

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).

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 assume that it does until such time as it can be proven otherwise.

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.

Notifications

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. Learn about the required notifications of lead risk work here.

Managing risks of lead exposure

PCBUs must manage the risks associated with lead exposure and follow a risk management process. 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.

In implementing control measures, a PCBU should follow the hierarchy of risk control to manage the risk of lead exposure. Where possible implement the highest order risk controls.

Eliminate

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.

For example:

• 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.

Substitute

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 to help identify hazardous components.

Isolate

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.

Partially enclosing or segregating a task or process may reduce lead exposure.

Engineering controls

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.

Administrative controls

Administrative controls involve minimising exposure 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 monitoring program.

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.

Work scheduling

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.

Good housekeeping

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 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.

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.

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).

Eating areas

A worker must not eat, chew gum or smoke in a lead process area. 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.

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 and health monitoring

In a work area where there is a risk of workers being exposed to a hazardous level of lead, employers are required to have an effective health monitoring 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 workers’ lead exposure.

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

Biological monitoring is intended to detect increasing lead levels in workers before symptoms of ill health occur.

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.

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

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.

Further information

Self assessment tool - SafeWork SA

Respiratory Protection Equipment (RPE) - SafeWork SA

Fact Sheet  - Dangers of take-home lead from workplaces and hobbies - SA Health

Exposure standards for atmospheric contaminants in the occupational environment - Safe Work Australia

Health monitoring for lead (inorganic) | Safe Work Australia

Health monitoring for registered medical practitioners guide | Safe Work Australia

Health Monitoring Guidance - Workers - Final.pdf (safeworkaustralia.gov.au)

Australian Standard 3640-2004 Workplace atmospheres-method for sampling and gravimetric determination of inhalable dust