Inorganic lead (lead) is used in Australian workplaces in a variety of products, including solders, batteries, radiation shielding and ammunition. It was used extensively in lead paints and lead fuels before these products were banned, and may still be present in some workplaces.
Exposure to lead can cause adverse health effects. Evidence links lead exposure to:
- cardiovascular disease
- kidney damage
- effects on the nervous system, including difficulty concentrating, hearing loss, loss of balance, tremors
- behavioural changes like aggression, anxiety and depression
- reduced fertility, and
- birth defects and developmental delays in children.
Lead can accumulate in the body over time, depositing in the bones and teeth. This ‘body burden’ can become a risk later in life as the body ages and bones demineralise, releasing stored lead into the blood stream.
Managing risks associated with lead
If you are a PCBU, you have duties under the model WHS Regulations to manage the risks to health and safety associated with using, handling, generating or storing lead at a workplace. Failure to manage these risks is a breach of the model WHS laws.
The best way to control a risk is to eliminate it completely—that is, by removing the risk from the workplace. If that is not possible you must minimise risks, so far as is reasonably practicable.
The model Code of Practice: Managing risks of hazardous chemicals in the workplace provides a four-step risk management approach to managing the risks of hazardous chemicals, including lead. More information on Identifying, assessing and controlling hazards is also available.
When choosing control measures, PCBUs must consider the hierarchy of control and choose the control that most effectively eliminates the hazard or minimises the risk. This can be a single control or a combination of different controls that provide the highest level of protection that is reasonably practicable.
Change to allowable blood lead levels
Lead risk work is any work that will likely cause blood lead levels of a worker to exceed 20 µg/dL (0.97 µmol/L), or 5 µg/dL (0.24 µmol/L) for females of reproductive capacity.
This is a reduction from previous blood lead levels of 30 µg/dL (1.45 µmol/L) and 10 µg/dL (0.48 µmol/L) for females of reproductive capacity.
A transitional period of two years applies for these new levels and your local WHS regulator will have more information on how this will work in your state or territory.
Lead processes and lead risk work
Due to the severity of health effects caused by exposure to lead, and the abundance of lead in workplaces and the environment, Part 7.2 of the model WHS Regulations specifies that PCBUs are required to identify lead processes or lead risk work.
While extensively defined in Regulation 392 of the model WHS Regulations, a lead process in general is any work that exposes a worker to:
- lead particulates, lead dust or lead fumes, for example grinding, sanding or welding
- molten alloys containing lead
- lead included in batteries or parts of batteries, and
- lead based spray paint, including any abrasive blasting or water jet treatment of surfaces coated in lead based paint.
A PCBU must ensure, so far as is reasonably practicable, that:
- contamination by lead is confined to a lead process area at the workplace
- these lead process areas are kept clean and steps are taken to prevent any persons from eating or drinking in the process area, and
- an eating and drinking area is provided that is free from lead contamination.
Other important duties required when lead is used or present at a workplace include:
- a PCBU’s provision and maintenance of changing rooms, and washing, showering and toilet facilities to minimise lead contamination and exposure
- information about the health risks and toxic effects associated with exposure to lead is provided to workers before they start the lead process, and
- steps taken to minimise workers’ exposure to lead when handling contaminated PPE and ensure that contaminated PPE is disposed of appropriately.
PCBU’s have a duty to assess each lead process carried out by the business and determine if it is lead risk work. Any worker carrying out lead risk work must be given information about the process before they start. They must also be provided information about health monitoring.
A PCBU must ensure that health monitoring is provided to workers undertaking lead risk work before the worker first starts the work and one month after.
Health monitoring must be carried out by or under the supervision of a registered medical practitioner with experience in health monitoring.
Health monitoring must include:
- demographic, medical and occupational history
- physical examination, and
- biological monitoring.
Health monitoring can be used to help identify whether existing control measures are working effectively or whether more effective control measures should be implemented. Health monitoring must never be used as an alternative to putting in place effective control measures.
The Health Monitoring for Exposure to Hazardous Chemicals – Guide for persons conducting a business or undertaking provides further information on health monitoring, and guidance on meeting your requirements as a PCBU.
Biological monitoring for lead is conducted by taking a blood sample and measuring the blood lead level.
Biological monitoring starts before the worker commences the work, one month after starting and must continue at regular intervals depending on previous results, gender and reproductive capacity.
For females not of reproductive capacity and males, biological monitoring must be conducted:
- 6 months after the last test if the last result showed a blood lead level of less than 10 µg/dL (0.48 µmol/L)
- 3 months after the last test if the last results showed a blood lead level of 10 µg/dL (0.48 µmol/L) or more but less than 20 µg/dL (0.97 µmol/L), or
- 6 weeks after the last test if the last results showed a blood lead level of 20 µg/dL (0.97 µmol/L) or more.
For females of reproductive capacity, biological monitoring must be conducted:
- 3 months after the last test if the last result showed a blood lead level of less than 5 µg/dL (0.24 µmol/L)
- 6 weeks after the last test if the last results showed a blood lead level of 5 µg/dL (0.24 µmol/L) or more but less than 10 µg/dL (0.48 µmol/L).
The testing frequencies and blood lead levels were implemented in 2018. A transitional period of two years applies and your local WHS regulator will have more information on how this will work in your state or territory.
Amendments have been made to the model WHS Regulations that lower the threshold at which a worker is removed from lead risk work. A worker must now be removed from lead risk work if their blood lead levels exceed:
- 30 µg/dL (1.45 µmol/L) for females not of reproductive capacity and males (down from 50 µg/dL (2.42 µmol/L)), and
- 10 µg/dL (0.48 µmol/L) for females of reproductive capacity, or those who are pregnant or breastfeeding (down from 20 μg/dL (0.97 μmol/L) and 15 µg/dL (0.72 µmol/L) respectively).
These removal levels were implemented in 2018. A transitional period of two years applies and your local WHS regulator will have more information on how this will work in your state or territory.
If the medical practitioner supervising the health monitoring recommends it, a worker must also be removed from lead risk work regardless of the blood lead level. The PCBU must notify their WHS regulator if a worker is removed from lead risk work due to the outcomes of health monitoring.
If a worker is removed from carrying out lead risk work because of excessive blood lead levels, the PCBU must arrange for the worker to be medically examined within seven days of removal. The worker may only return to lead risk work if the medical practitioner is satisfied that the worker is fit to return and the worker’s blood lead level is less than:
- 20 µg/dL (0.97 µmol/L) for females not of reproductive capacity and males (down from 40µg/dL (1.93µmol/L)), and
- 5 µg/dL (0.24 µmol/L) for females of reproductive capacity (down from 10 µg/dL (0.48 µmol/L)).
These return to work levels were implemented in 2018. A transitional period of two years applies and your local WHS regulator will have more information on how this will work in your state or territory.
A confidential record of the worker’s health monitoring reports must be kept by the PCBU for at least 30 years. The PCBU must take all reasonable steps to obtain the health monitoring report and provide a copy to the worker as soon as practicable.
Read further information in our Lead (inorganic) health monitoring guidance material.
Monitoring for airborne contaminants
A PCBU must ensure that a worker is not exposed to concentrations of airborne chemicals above the workplace exposure standard. The workplace exposure standard for inorganic lead (eight hour time-weighted average) is 0.05 mg/m3.
The workplace exposure standard for lead was implemented in 2018. A transitional period of two years applies and your local WHS regulator will have more information on how this will work in your state or territory.
More information can be found in:
- Workplace exposure standards for airborne contaminants, which contains key information about how workplace exposure standards are applied under the model WHS Regulations, and
- Guidance on the interpretation of workplace exposure standards for airborne contaminants, which contains further information for businesses.
To comply with the model WHS Regulations, PCBU’s must monitor workers’ exposure to airborne lead if:
- there is uncertainty whether or not the exposure standard has been or may be exceeded, or
- it is necessary to work out whether there is a risk to health.
Records of air monitoring must be kept for a minimum of 30 years and must be made available to workers who are exposed.
In April 2018 the model WHS Regulations and the workplace exposure standard for lead were amended.
The changes include:
- reducing the workplace exposure standard for lead from 0.15 mg/m3 to 0.05 mg/m3
- reducing the blood lead level used to define lead risk work
- reducing the mandated blood lead removal levels
- adjusting the testing frequency of workers, and
- reducing the blood lead levels permitted to return to lead risk work.