Managing lead-based paint removal

Background

Lead is absorbed into the blood stream where it will circulate before it is slowly excreted in the urine and stored in the bones.  The body can get rid of the lead naturally over time, but the levels of lead may increase if exposure to lead enters the body faster than it takes for it to leave the body.

Lead can stay in the bones for years without causing any health effects, but if the level of lead absorbed into the body gets too high, it can cause both immediate and long-term health effects.

Early signs and symptoms of high lead levels in the body can include:

• headaches
• tiredness
• irritability
• nausea

Continued exposure to lead can cause more serious symptoms including:

• kidney damage
• nerve damage
• brain damage
• lead palsy
• death

A developing unborn child is particularly at risk from exposure to lead, especially in the early weeks of pregnancy.

Solid lead presents little or no risk to people. It is when lead is processed, producing lead dust, fumes or mist, that exposure to lead becomes a health risk.

Exposure can occur through:

• breathing in of airborne lead-containing dust, fume or mist
• ingestion during eating, drinking or smoking when hands have been contaminated with lead

Paint with a high lead content, more than 1% by dry weight of lead metal, was used on many buildings and structures built before1970. These painted surfaces may have since been covered by non-lead based paint.

Lead-based paint can present a health risk if it has deteriorated, becoming powdery or flaky, or when sanding or buffing of lead-based paint produces lead dust.

Employees and their families, building occupants, and people in neighbouring buildings may be at risk of exposure if the lead-based paint removal process is not properly managed.

Employer duties

Employers must, so far as is reasonably practicable, eliminate any risk associated with exposure to lead. If the risk cannot be eliminated, they must reduce the risk, so far as is reasonably practicable, according to the hierarchy of control set out in Part 4.3 of the OHS Regulations. This includes any risks associated with dust generated from lead-based paints.

The paint removal contractor, as a self-employed person or the employer of the persons undertaking the work, will typically have the primary duty to control the risks of exposure to lead dust during lead-based paint removal. Where applicable, the builder, or other persons in management and control of the workplace, will also have responsibilities to ensure the paint removal contractor provides and maintains a safe system of work for the lead-based paint removal.

Where the building or structure was built before 1970 or if there is concern that lead-based paint is present, the paint should be tested to check if the paint is lead-based or to confirm that lead is not present. 

Home owners who engage a contractor to undertake painting works should inform the painting contractor of the location of lead-based paint if known.

Lead exposure standard

Employers must ensure employees and contractors are not exposed to an airborne concentration of lead dust, mist or fumes above the exposure standard of 0.05mg per cubic metre.  This is the maximum airborne concentration of lead that a person may be exposed to in their breathing zone, averaged over an 8 hour work day and 40 hour work week.

Lead process and lead-risk work

Specific duties under the OHS Regulations apply to all workplaces where lead processes are undertaken. Lead processes are specific activities that involve a high risk of lead exposure, such as:

• machine sanding or buffing of surfaces coated with paint containing more than 1% by dry weight of lead metal
• spray painting with lead paint containing more than 1% by dry weight of elemental lead
• using a power tool, including abrasive blasting and high pressure water jets, to remove any surface coated with paint containing greater than 1% by dry weight of lead metal
• the handling of waste containing lead resulting from that removal

If performing a lead process is reasonably likely to cause an employee’s blood lead level (BLL) to reach a certain threshold, that process is lead-risk work.  The levels for determining lead-risk work are:

• 0.97 µmol/L (20 µg/dL) or
• 0.24 µmol/L (5 µg/dL) for female employees of reproductive capacity

Not all lead processes will be lead-risk work.  The nature of the work and the controls in place, including personal hygiene will determine whether a lead process becomes lead-risk work.

Health monitoring for lead-risk work

Health monitoring includes a medical examination and biological monitoring.  If a lead process is identified as lead-risk work, employers must arrange health monitoring for employees who will be engaged in the work, before they start.  They must also arrange follow up biological monitoring for employees, within a month of the work starting, and ongoing at regular intervals.

Information, instruction and training

Employers must:

• inform job applicants of the health risks and toxic effects of lead exposure, as well as the requirements for medical examinations and biological monitoring
• ensure that before employees first start work in a lead process, inform them of the need for and details of medical examinations and biological monitoring
• provide employees with information, instruction and training on the hazards and risks of lead based paint removal and the controls in place to reduce the risk of exposure

Control measures for lead-based paint

If the paint is lead-based (more than 1% by dry weight of lead metal), the employer must control the risk of lead exposure associated with the lead paint removal process. They must eliminate or reduce the risk, so far as is reasonably practicable by applying the hierarchy of controls set out in Part 4.3 of the OHS Regulations.

Hierarchy of control

The following list describes the hierarchy of control from the highest level of protection and reliability through to the lowest and least reliable protection.

Cleaning

Clean the area where the lead process is carried out regularly and ensure the cleaning methods used do not create additional risks. For example, use wet cleaning methods or dry cleaning with a Class M or H vacuum cleaner with HEPA filtration to remove lead-containing dust.  Ensure all waste from the lead based paint removal process is contained and disposed of securely.

Eating and drinking area

Ensure that persons do not eat, drink, chew gum or smoke or carry food, drink, gum or materials used for smoking in the lead process area.

Provide an eating and drinking area that, so far as reasonably practicable, cannot be contaminated with lead from the paint removal process.

Changing and washing facilities

Provide and maintain changing and washing facilities for employees that will:

• minimise secondary lead exposure from contaminated clothing
• minimise ingestion of lead
• avoid the spread of lead contamination

Washing and changing facilities need to be appropriately located within the workplace where a lead process is carried out. Employees should not be required to walk back through the lead processing area after changing into clean clothes.

Review the control measures

Review, and if necessary, revise any measures implemented to control risks associated with exposure to lead when required by the Regulations.

Consult with employees and health and safety representatives

Consult with employees, and any health and safety representatives, on matters related to health or safety that directly affect, or may directly affect them, such as changes to lead processes.

Employee duties

Employees engaged in lead processes have specific legal duties.

In an area where the lead removal process is undertaken, employees must not:

• eat
• drink
• chew gum
• smoke
• carry food, drink, gum or materials used for smoking

Employees must:

• remove any lead contaminated clothing and equipment before entering an area designated for eating and drinking
• wash their hands and face after leaving the lead removal area and before eating, drinking or smoking