LEAD Group Submission re: the Australian federal government’s proposed lead Workplace Health and Safety (WHS) regulations, due 26th February 2016

by Elizabeth O’Brien, The LEAD Group.

By making a submission I hope that once the federal requirements change, State and Territory WHS Authorities will soon become much more pro-active in lead exposure prevention and that the medical system becomes much better able to manage lead-affected past and future painting contractors, pistol instructors and other workers exposed to lead.

This text is from a link from one of the links in the Invitation to make a submission email:

“In particular Safe Work Australia seeks views on options for:

1. setting levels of lead in workers’ blood (blood lead levels) to identify:
• trigger points to commence mandatory health monitoring of workers undertaking lead risk work
• workers who need to be removed from lead risk work, and
• when those workers may be returned to lead risk work.
2. setting a maximum concentration of lead in air for workplaces” [https://submissions.swa.gov.au/SWAforms/lead/pages/form]

In this submission I propose the trigger point (timing) of initial mandatory health monitoring (that is, blood lead testing and a standard medical appraisal including, as a minimum, blood pressure monitoring, kidney and liver function, presence of cataracts, hearing, reaction time, IQ, balance and memory testing) of workers undertaking lead risk work as: prior to starting lead risk work or ASAP if health monitoring was not done prior to commencing lead risk work.

I also propose that repeat blood lead testing (and blood pressure testing if elevated in the first test and re-assessment of any other lead-related health issues found in the pre-lead-work medical appraisal) occurs within two weeks of starting lead risk work, and then monthly unless the blood lead level rises above 5 ug/dL.

Then I propose that all occupational blood lead results are notifiable to the state or territory Health Department as well as to the WHS Authority in each jurisdiction. This will require Safe Work Australia to recommend blood lead notification of all results to the Health and WHS Authorities in the various jurisdictions so they are motivated to change their notification regulations.

I propose too that if a worker’s blood lead level is above 5 ug/dL, this would trigger the workplace being investigated by a WHS Inspector, the Inspector’s orders being mandatorily followed and blood lead testing frequency would revert to fortnightly until the blood lead level returns below the NHMRC Public Health Reference Level of 5 ug/dL.

I propose a blood lead level of 10 ug/dL as the level at which workers need to be removed from lead risk work (to give more time for improvements in the lead-safety of the workplace and re-training in worker safety protocols) until the blood lead level falls below 2.5 ug/dL, when the worker may be returned to lead risk work.

Although I have no proposed appropriate maximum concentration of lead in air for workplaces (because that’s a whole science on its own and it can only be derived after the “blood lead removal level” is set, I do however suggest that Australia follows US OHS lead guidance whereby they have determined a maximum dust wipe lead level in work areas and mess rooms. Whilst air lead monitoring may make sense (and already be happening) when the lead risk work is at a fixed location, for contractors or those working outside dust wipe lead is much more easily measured. Dust wipe samples can be obtained simply by the worker themselves or a Safety Officer being trained in how to collect dust wipe samples and posting them to a lab, or just by buying a LEAD Group Kit which includes the instructions for doing that. With a LEAD Group Kit, the purchase price includes receiving a report with recommendations on abatement of any lead hazards found at the workplace. and which can be set after the “blood lead removal level” is set. This proposed dust wipe lead level in the Australian WHS Lead Requirements, once set, would trigger further clean-up of the workplace and further engineering or other controls to reduce the creation or settling of lead dust and of “take-home” dust.

Finally, I propose that medical practitioners who wish to undergo training in management and prevention of occupational lead exposure, be supported in doing so, and listed, once trained, online, so that lead-exposed workers and their GPs can easily locate a specialist to assist the worker and prevent the further lead poisoning of their co-workers and families.

Yours Sincerely
Elizabeth O'Brien
Lead Advisor/Case Manager, The Lead Education and Abatement Design (LEAD) Group Inc. (environmental health charity)
www.lead.org.au
Manager, Lead Safe World Project (LSWP) – a collaboration between NGOs and businesses with products or services which help to create lead-safety locally and further afield
www.leadsafeworld.com
Lead Results Interpreter, LEAD Group test kit results interpretation service
www.leadsafeworld.com.au/solutions/lead-group-diy-sampling-lab-analysis-lead-test-kits
and LEAD Group test kit advice-via-Skype service, re: type of samples and where to collect them from, for a LEAD Group kit
PO Box 161 Summer Hill NSW 2130 Australia
Ph +61 2 9716 0014