4.4 Lead

Part 4.4 of the regulations covers workplaces with 'lead processes'.

Division 1 - Introductory matters

4.4.1 This part of the regulations only applies to workplaces where a lead process is undertaken.

4.4.2 What is a lead process? The regulations list the situations which are defined as 'lead processes':

  1. where a person at work is exposed to lead dust or lead fumes (either from the manufacture or handling of dry lead compounds);
  2. any work, including manufacture, with batteries containing lead involving manipulation of dry lead compounds or the pasting or casting of lead;
  3. anything to do with breaking up or dismantling of batteries containing lead, including sorting, packing and handling of any of the battery parts;
  4. spraying with molten lead metal or alloys with more than 5% by weight of lead metal;
  5. melting or casting of lead alloys containing more than 5% by weight of lead metal at a temperature more than 450ºC;
  6. recovery of lead from its ores, oxides or other compounds by a thermal reduction process;
  7. dry machine grinding, discing, buffing or cutting by power tools of lead with more than 5% by weight of lead metal;
  8. machine sanding or buffing of surfaces coated with paint with more than 1% by dry weight of lead metal;
  9. a process in which electric arc, oxy-acetylene, oxy gas, plasma arc or a flame is applied, for the purposes of welding, cutting or cleaning, to the surface of metal that is coated with lead or paint with more than 1% by dry weight of lead metal;
  10. radiator repairs if exposure to lead dust or lead fumes may occur;
  11. fire assays, if lead is used;
  12. hand grinding and finishing of lead or alloy with more than 50% by weight of lead metal;
  13. spray painting with lead paint with more than 1% by dry weight of elemental lead;
  14. melting of lead metal or alloy with more than 50% by weight of lead metal if the exposed surface area of the molten material is more than 0×1 square metre and the temperature of the molten material does not exceed 450ºC;
  15. use of a power tool, including abrasive blasting and high pressure water jets, to remove any surface coated with paint with more than 1% by dry weight of lead metal and the handling of waste containing lead resulting from that removal;
  16. a process that exposes a person to lead dust or lead fumes arising from the manufacture or testing of detonators or other explosives that contain lead;
  17. a process that exposes a person to lead dust or lead fumes arising from the firing of weapons at an indoor firing range;
  18. foundry processes involving—
    1. the melting or casting of lead alloys with more than 1% by weight of lead metal in which the temperature of the molten material is greater than 450ºC; or
    2. the dry machine grinding, discing, buffing or cutting by power tools of lead alloys with more than 1% by weight of lead metal;
  19. a process at a workplace determined by the Authority to be a lead process in accordance with regulation 4.4.4. 

4.4.3 Females taken to be of reproductive capacity Because lead is particularly toxic to the unborn child, a female employee working in a lead process is to be treated as being 'of reproductive capacity', unless she provides the employer with a written statement advising the contrary.

4.4.4 The Authority may determine any process to be a 'lead process' but only if it believes the health of employees is at risk due to blood or airborne lead levels.

4.4.5 Medical examinations and biological monitoring

Where required under this part of the regs, medical examinations must be conducted by a registered medical practitioner to monitor the person's health in order to identify changes in health status due to exposure to lead.  Also, where required, biological monitoring, consistingof testing of the venous blood, must be conducted by a pathology service accredited by NATA under the supervision of a registered medical practitioner to determine the amount of lead in the blood (with certain limits).

Division 2 - Duties of Employer 

The employer in workplaces with lead processes has a range of duties.

Subdivision 1 - Provision of Information (4.4.6 & 4.4.7)

The employer must provide information (information, instruction and training; MSDSs and labels) to both job applicants and employees about the health risks and toxic effects associated with lead exposure and the need for, and content of medical examinations and biologicals monitoring.

Subdivision 2 - Control of risks associated with lead processes (4.4.8 - 4.4.16) 

The employer must:

  • Control the risks associated with the lead processes according to the hierarchy of control, that is if reasonably practicable, eliminate the risk followed by substitution, isolation, engineering controls or a combination of these.  If a risk still remains, then the employer must use administrative controls to eliminate the risk, and if a risk STILL remains, only then can appropriate personal protective equipment (ppe) be used.
  • Review, and if necessary, revise  the risk control measures in a number of circumstances:
    • before any changes to the lead process or systems of work;
    • if a worker is removed due to high lead blood levels (or likelihood) under reg 4.4.23
    • after occurance of any notifiable incident under Part 5 of the Act that involves exposure to lead
    • if for any other reason the risk control measures do not adequately control the risk
    • after receiving a request from a health and safety rep
  • Consult with the OHS rep/s
  • Monitor the airborne concentration of lead dust, lead mist or lead fumes and ensure the exposure standard is not exceeded (the current exposure standard is TWA: ppm 0.15 mg/m3, STEL: ppm - mg/m3) and provide the results of this monitoring to any worker who has been or may be exposed to lead dust, mist or fumes
  • Ensure that any contamination by lead is contained to an area where a lead process is carried out
  • Ensure that areas where lead processes are carried out are kept clean, where practicable using cleaning methods that do not create a risk to people in the vicinity of the areas, and do not create the potential to spread the lead contamination
  • Prohibit eating, drinking, chewing gum or smoking (or carrying smoking-related materials) in any lead processing area
  • Provide appropriate facilities (for eating, changing, washing, etc),
  • Provide protective clothing and equipment, and ensure its safe removal and laundering or disposal

Subdivision 3 - Lead-risk jobs (4.4.17 - 4.4.28)

The employer must:

  • Identify lead risk jobs and notify these to the Victorian WorkCover Authority in writing
    Lead-risk jobs are defined as jobs involving a lead process in which the blood level of the worker is reasonably likely to exceed 1.45 µmol/L; or 0.48 µmol/L for female employees of reproductive capacity 
  • Provide medical examinations and regular biological monitoring of workers in lead risk jobs
    (note that the 'trigger levels' - at which a timetable of monitoring is required - are 1·45 µmol/L for females not of reproductive capacity and all males and 0·48 µmol/L for females of reproductive capacity. If the level of lead in the blood exceeds 2·41 µmol/L for females not of reproductive capacity and all males; ·97 µmol/L for females of reproductive capacity; or 0·72 µmol/L for females who are pregnant or breast feeding, the worker must be removed from that job. Further tests must be carried out prior to returning a worker to a lead-risk job)
  • Provide these results to the workers, and keep records of these for 30 years
  • Provide information (results of monitoring and the medical report) to WorkSafe if any person has been removed from a lead-risk job - as soon as is reasonably possible.

Division 3 - Employee Duties

  • Employees must not eat, drink, chew gum, smoke or carry materials used for smoking in any area where a lead process is carried out
  • Employees who have been in a lead process area must remove any lead contaminated clothing and equipment they have used before entering an area designated for eating and drinking
  • Employees who have been in a lead process area must wash their hands and face after leaving the area and before eating, drinking or smoking.

The full text of the regulations can be viewed and downloaded from the Victorian Legislation and Parliamentary Documents website -  click on Victorian Law Today, then on Statutory Rules, and then on "O" to find the Occupational Health and Safety Regulations.

See WorkSafe's Your Guide to the Lead Regulations [pdf]

Last amended June 2015

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