Working with lead can put your health at risk.
Amendments were made to the WHS Regulation on 1 July 2019. Some of these relate to blood lead levels, with a two-year transitional period to comply with the new requirements. Lead-related amendments involve:
- changes to the definition of lead risk work
- the frequency with which a PCBU must conduct biological monitoring of workers who carry out lead risk work
- reduction in blood lead levels for the immediate removal of workers from carrying out lead risk work
- thresholds at which a PCBU may allow a worker to return to lead risk work
- these requirements are subject to a two year transitional period from 1 July 2019 to 1 July 2021.
Refer to exemption 006/19, gazetted 28 June 2019. Refer to Lead notifications for more detailed information on the changes.
There are many jobs involving lead work, including welding, spray painting, repairing radiators, abrasive blasting and removing lead-based paints.
Exposure to lead can cause headaches, stomach pains and anaemia – or worse, damage to the kidneys, nerves or brain, and even infertility.
Over the past three years more than 30 workers were injured in NSW workplaces as a result of lead risk work.
There are specific laws about working safely with lead. Here we summarise those laws and give you some practical tips.
Talk to your workers
Before anyone begins any lead process, you must give them information about the risks and health effects when working with lead. If it’s lead risk work you must give details about health monitoring and the need for health monitoring.
Control the risks
Make sure all your lead work is restricted to the lead process area and confine lead contamination to that area.
Keep the area clean and make sure the cleaning method does not spread the lead to other areas or create risks to the health of other workers.
Also ensure no-one drinks, eats, smokes or chews gum in the area. A separate dining area, wash basins, shower and toilet facilities should be made available away from the lead work area. Make sure those doing lead work wash their hands and face thoroughly before entering the dining area.
Seal contaminated personal protective equipment (PPE) that is likely to be contaminated before removing it from the lead process area. Where you can:
- dispose of it at a site that accepts lead contamination equipment
- launder and decontaminate it, or
- place it in a sealed container until re-used.
Review control measures
Review your control measures at least every five years, or when circumstances affect (or may affect) the health and safety of a worker. For example, review your control measures when:
- you change your work processes
- a worker is removed from carrying out lead risk work
- we require, or the worker’s health and safety representatives (HSRs) request, it.
Assess your work
Not all work that involves lead is ‘lead risk work’. But if you’re unsure, assume it is and notify us.
For the period up to and including 30 June 2021 ‘lead risk work’ means blood levels at or exceeding:
- 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 ‘lead risk work’ means:
- 5 μg/dL (0.24 μmol/L) for a female of reproductive capacity
- 20 μg/dL (0.97 μmol/L) in other cases.
To determine if a task is ‘lead risk work’, check past medical records, injuries and illnesses. Also check the type of lead you use, the airborne lead levels, how and how much workers are exposed, and examine your work practices. Your assessment should ignore the benefits of PPE.
You have seven days to notify us in writing that the work you are doing is lead risk work –and state the kind of lead process involved. Also notify us if there are any changes to work processes that you previously informed us about.
Keep a copy of the notification and ensure your workers and their HSRs can access it.
In the event of an emergency rescue or first aid incident, emergency service organisations must also notify us.
Get health monitoring for workers
You are responsible for all medical costs associated with any health monitoring performed on workers who do lead risk work.
Health monitoring must be provided both before and again one month after a worker starts lead risk work (or once lead risk work is identified, and again a month later).
The health monitoring must include a demographic, medical and occupational history, plus a physical examination and biological monitoring, unless the practitioner recommends a different type of monitoring.
In consultation with affected workers, choose a medical practitioner experienced in health monitoring.
Give the practitioner your name, the worker’s name and date of birth, and tell them about the work and how long the worker has been doing any of that work already.
Get a health monitoring report after the monitoring is carried out and give a copy to the worker. Make sure it covers:
- the name and date of birth of the worker
- the name and registration number of the medical practitioner
- the name and address of the person who commissioned the health monitoring – eg the employer
- the date of health monitoring
- if a blood sample is take, the date the blood sample is taken,
- the results of biological monitoring that indicate blood lead levels
- the name of the pathology service used to carry out tests
- any test results that indicate that the worker’s blood lead level is too high
- any advice that test results indicate that the worker may have contracted a disease, injury or illness as a result of carrying out the lead risk work that triggered the requirement for health monitoring
- any remedial measures, including whether the worker can continue to carry out the work
- whether medical counselling is required for the worker.
Also give a copy to us, if the report indicates:
- high blood lead levels
- an injury illness or disease
- any remedial action.
Complete this form and send it to us if the worker is no longer able to do lead risk work.
Immediately remove the worker from lead risk work if:
- biological monitoring indicate high blood lead levels
- the practitioner recommends it, or
- the workers blood lead level is likely to become too high because there is an indication that a risk control measure has failed.
If a worker is removed from doing lead work, arrange a medical examination for them (in consultation with them) within seven days and ensure they do not return to their same job until their blood lead levels have reached an acceptable level – and the practitioner is satisfied their fit to carry out lead risk work.
As part of the health monitoring, you must arrange for biological monitoring of all workers involved in lead risk work. The frequency of these biological tests depends on gender, fertility, blood lead levels, the worker’s previous monitoring results, and if the worker carries out any activities that will affect their lead exposure. In some cases, we may determine the frequency of the monitoring.
Keep a confidential copy of all health monitoring reports for at least 30 years and never disclose a worker’s results or report to any other person without their consent (unless permitted by law).
For the specific laws about working with lead, see clauses 392 – 418 of the Work Health and Safety Regulation 2017.
For practical information about notifying us about your lead work and how to have our decisions reviewed, see the guide for applicants for lead notifications.
There are also general health and safety laws that will apply to you in any situation, including when doing lead work.