Although published in October 1994 the Standard was substantially completed in 1991. Final ratification was delayed due to action in the Federal Court on the question of sex discrimination in setting differing requirements for women who are of reproductive capacity, pregnant or breast feeding than for others.

This matter was resolved in November 1993 when the Court ruled that Worksafe had a duty to clearly indicate the health affects for all workers who may be exposed to lead and to set appropriate health and safety standards.

Because of this delay the standard is out of date on the permissible occupational exposure level of lead-in-air, and the definition of lead paint.

Atmospheric Lead Exposure Levels

The standard sets the maximum level of lead in air permitted to he inhaled by workers over a normal 8-hour working day at the current exposure standard of 150 µg/M³. This is the figure listed in "Exposure Standards for Atmospheric Contaminants in the Occupational Environment' last reviewed in 1991.

The standard requires medical removal from lead-risk jobs if the PbB exceeds 50 µg/dL, and for all pregnant or breast-feeding employees regardless of PbB.

It defines a lead-risk job as one that might cause the PbB to rise above 30 µg/dL (less for some women). The Code of Practice gives a correlation between PbB's of 30 µg/dL and exposure to lead-in-air concentrations of 30 µg/M³.

No direct linear correlation exists between lead exposures and PbB. The actual compound of lead, its bioavailability and particle size and the exposed person's metabolic system impact on this relationship.

Nevertheless it is clear that workers inhaling lead levels approaching the permissible exposure standard of 150 µg/M³ may readily end up with PbB's well in excess of the limits set for medical removal. According to US OSHA legislation the permitted exposure level (PEL) is 50 µg/M³, one third of the Australian limit. US law (under the current Title X legislation) also defines an Action Level (intended to he a warning signal to employers that a job is approaching the PEL) of 30 µg/M³.

At the Action Level monitoring of lead-in-air concentrations, employee training and medical surveillance of employees (ie. monitoring PbB's) become compulsory. The US Action Level is equal to the Australian figure defining a lead-risk job.

An exposure standard of 150 µg/M³ is inconsistent with the objective of preventing elevated blood lead levels in workers, and we urge Worksafe to revise the exposure standard for lead downwards to a figure of 50 µg/M³ at the earliest opportunity.

Definition of Lead Paint

The standard contains a schedule of "lead processes" which includes "Machine sanding or buffing of paint (with more) than 1% of lead". Because of this, the same figure of 1% lead content has been included in the new draft Standard Guide to lead paint management – Industrial Applications.

However sanding or buffing paint is not the same as removing paint by abrasive blast cleaning or power grinding. Abrasive blast cleaning is the commonly preferred method of removing lead paint from steel. Lead-in-air levels of 50 µg/M³ can be exceeded when blast-cleaning paint with 0.06% lead.

US studies have shown that lead paint removal workers recorded higher PbB's (and lower life expectancies) than general lead-industry workers. Lead paint removal has been identified as a major cause of lead poisoning among workers and OSHA regards a lead-containing paint to be one containing any amount of lead.

In 1991, the Australian NH&MRC limit for lead in paint was 0.5% for domestic use. This figure was lowered to 0.25% in March 1992 and in 1997 will be further lowered to 0.1%.