Lead-based Paint Removal

Background

Lead-based paint, commonly used on many pre-1970s buildings and structures, can contain lead levels greater than 1%. Work involving sanding, buffing or removing paint with lead levels greater than 1% by dry weight is regulated under Part 4.3 of the OHS Regulations as a ‘lead process’, with specific duties for employers undertaking this work.

WorkSafe has identified that employers and self-employed persons are undertaking unsafe lead-based paint removal. Issues that have been identified include:

• Employers not having procedures in place to ensure lead paint is identified prior to the commencement of works.
• Failure to identify the lead process as lead-risk work.
• Failure to notify WorkSafe prior to commencing lead-risk work.
• Not informing employees of the presence of lead and the potential risks – particularly to female employees of reproductive capacity.
• Undertaking lead-based paint removal from an old residential building without appropriate controls, including personal protective clothing.
• Workplaces not having adequate decontamination facilities for workers.
• Failure to clean and decontaminate lead removal areas at the completion of works.
• Employers not having a blood testing program in place for employees prior to commencing removal of lead-based paint.
• Failure to arrange health monitoring for employees when undertaking lead-risk work.

Safety issues

Lead can stay in bones for years without causing any health effects. However, high levels of lead in the body can increase the risk and cause immediate and long-term health issues.

Exposure to lead should be minimised for female workers, especially before and during pregnancy. Unborn children are particularly at risk, as lead stored in the bones can be released into the bloodstream during pregnancy, becoming a source of exposure for the developing child.

Failure to clean and decontaminate a lead-based paint removal area could result in children and toddlers on site picking up small lead paint chips and put them in their mouths.

Early signs of high lead levels

• headaches
• tiredness
• irritability
• nausea
• stomach pains
• anaemia.

Serious symptoms from continued exposure

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

Recommended ways to control risks

Employers must control lead exposure risks using a hierarchy of control. They should first try to eliminate the risk. If that’s not possible, they should reduce it by:

• Substituting dry removal processes for wet methods such as chemical paint stripping products or power tools fitted with on tool water suppression. Note: When using chemical stripping products, the SDS for the chemical must be reviewed and controls implemented accordingly.
• Building an enclosure, where practicable, or isolating the lead-based paint removal area from unprotected workers.
• Using powered tools fitted with dust extraction systems attached to a Class M or H vacuum cleaner – and ensure workers are trained in the correct removal techniques (including maintaining the dust extraction system) to minimise the generation of airborne dust.
• Rotating employees working in the lead-based paint removal area, where practicable, to reduce exposure time.
• Cleaning the lead-paint removal area, using cleaning methods that do not create additional risks. For example, use wet methods or Class M or H vacuum cleaner instead of dry sweeping.
• Ensuring adequate hygiene facilities, such as a designated decontamination area and wash facilities, are available.
• Providing respiratory protection that is appropriate for the level of contamination, disposable coveralls, gloves and impervious safety shoes.

Legal duties

Employers must also eliminate any risk associated with exposure to lead, so far as is reasonably practicable. If elimination is not reasonably practicable, employers must reduce the risk so far as is reasonably practicable, by:

• identifying whether a lead process is ‘lead-risk work’
• using the hierarchy of control to ensure any risks associated with exposure to lead are controlled so far as reasonably practicable
• reviewing risk control measures when required
• keeping the lead process area clean
• providing washing and changing facilities
• providing an appropriate eating and drinking area that cannot be contaminated with lead from any lead process
• providing for the laundering or disposal of protective clothing and work clothing that is likely to be contaminated with lead dust
• arranging medical examinations and biological monitoring as required
• providing supervision, instruction, information and training to enable employees to work safely with lead.

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.

Employers have a duty to provide job applicants who apply to work in a lead process with information about the health risks and toxic effects associated with lead exposure, as well as the need for and details of required medical examinations and biological monitoring.

Employee duties

Employees have a general duty to take reasonable care for their own health and safety, and that of others who may be affected by their work. They also have a duty to cooperate with their employer’s efforts to make the workplace safe.

Employees also have specific duties at workplaces where lead processes are carried out. They must:

• not eat, drink, chew gum or smoke in a lead process area
• not carry food, drink, gum or materials used for smoking in any area where lead processes are being undertaken
• remove any lead contaminated clothing and equipment they have used, before entering an area for eating and drinking
• wash their hands and face after leaving a lead process area before eating, drinking or smoking.

An employee’s exposure to lead can be further minimised by using the control measures their employer provides, such as:

• wearing personal protective clothing (such as a respirator and dust-coat) when required
• storing food, drink, chewing gum and tobacco away from the lead process area
• washing and changing into clean clothing before going home
• attending all scheduled medical appointments.