Action News Volume 7 No 4, 2000, ISSN 1324-6011
Review of NSW Lead Management Action Plan
REFERENCE 4: NSW Lead Management Action Plan (LMAP). Published for the *Interdepartmental Lead Taskforce by NSW Environment Protection Authority, Sydney, November 1994.
* 16 NSW Government Agencies were represented on the Interdepartmental Lead Taskforce:
NB the number of each strategy was assigned by The Lead Group in the original document, the 125 strategies appear as dot points underneath each sub-heading.
3.3 Lead In Air
1. Identification of Problem Areas
Strategy 3. Undertaking source emission inventories. Estimates of emission rates from sites, which produce or incorporate lead products should be undertaken and updated regularly. The information should be included in the State of the Environment Report. Comment the 1997 "State of the Environment Report" on the NSW EPA website www.epa.nsw.gov.au gives a graph of ambient air lead levels over time for the Southern Copper smelter in "Case Study: Air Quality in the Illawarra" but does not list an emission inventory for lead-emitting industry in NSW. Under the heading Waste in Section 2.10.4 Sources of Lead, it says:
"The NSW EPA currently administers 18 pollution control licences listing lead as a pollutant. The permitted levels of emissions vary by company and pollution pathway [you have to buy a copy of the licence to find out the levels knowing the level of emissions that is allowed under the licence does not tell you the actual emissions]. Although there are environmental controls for certain mining and refining activities, an estimated 146 million tonnes of waste and some processing activities that contain residual amounts of metal were exempt from waste regulations."
Under the heading Water and Air in the same section, a 1985 figure is quoted: - 11.4 tonnes of lead was released from municipal incinerators in 1985. The information could not be said to be "updated regularly". As of mid-1999, under the provisions of the NSW Protection Of the Environment Operations Act 1997 (POEO Act), Section 320, people can request emissions data from NSW EPA on any of the facilities that are licensed to emit the particular emission (eg lead to air, lead to water). Unlike an application for information under the NSW Freedom of Information Act, an application under this section of the POEO Act does not require a fee to be paid. The National Pollutant Inventory (NPI) website www.npi.gov.au/ which was first published in December 1999, gives no emission data for lead smelters or any of the major lead product manufacturers as the industry handbooks on NPI reporting were so slow in being finalised by these industries. Of a total of 237 facilities from 23 industry sectors in Australia that did report their lead emissions during FY 1998-9 on the NPI website, 43 facilities are in NSW. The caveat for NPI reporting states that facilities were not required to report for the whole year, but it was only 3 mines that reported for the month of June 1999 while the other 40 facilities gave the annual emission. Multiplying the June 1999 figure by 12 puts Pasminco Broken Hill as the top emitting facility of those listed, with 804 kg/year lead emitted to air. ACI Glass Packaging at Penrith was second with 580 kg/year and Hunter Valley Operations Howick Pit at Ravensworth was third with a multiplied estimate of. Lowes Petroleum was fourth, fifth and sixth with its Depots at Lightning Ridge, Tamworth and Moree emitting 220, 210 and 100 kg/year respectively. All other facilities reported emissions of less than 100 kg/yr including petrol refineries, lead and coal mines, paint factories, brick, steel, plastics and concrete works, and airports and paper mills. Nearly half the reporting facilities reported air emissions of 1.6 kg/yr or less eg maltings, breweries, bakers, lamp manufacturers. One facility only reported emissions to land. Reports of emissions to land and water are not required in all industry handbooks or are not yet mandatory.
The biggest question arising from reading the website is when will the community actually have full data sets for all emissions for whole years with all emitting facilities reporting so comparisons can be made and baseline data established? The strategy was developed 7 years ago how long does it take? Is it working to rely on industry reporting?
Looking at the data provided by NSW EPA on air emissions from other lead sources on the NPI website one can only conclude that we should close all our petrol stations and open more lead mines to get less lead in the air. By comparison to the estimated 804 kg/yr emitted to air by Pasminco Broken Hill Mine, petrol stations in the Sydney Newcastle Wollongong airshed emit 140,000 kg/yr or nearly 175 times the mine. Of course the caveat warns against comparisons of figures determined by different estimation techniques so no such statement can actually be made.
Even our metropolitan lawn mowing emits more lead than the mine (1100 kg/yr). Unfortunately these are the only 2 categories given by NSW EPA, whereas every other state EPA has reported on between 4 and 15 categories. Just comparing service station and motor vehicle lead emissions between the airsheds, we have (see table below).
It is quickly apparent that they were all worked out using different estimation methods and thus the validity of all the data is highly suspect.
When industry air emission figures are all low and the state government figures seem to have been plucked out of the air, it makes you wonder if the community wouldnt have done a better job at measuring and estimating emissions given the millions that have been spent on the NPI.
3.8 Lead In Paint
2. Augmentation of administrative and regulatory control
Strategy 72. Review the Standard for the Uniform Scheduling of Drugs and Poisons to reduce the permissible lead concentration of all paints except zinc based paints as defined by Australian Standards AS 2105 and AS 2204. Comment as mentioned above, one reduction in domestic lead paint content took place in December 1997, from 0.25% to 0.1%.
Strategy 73. Extend the existing prohibitions for the use of First Schedule paints under the Uniform Paint Standard to include industrial buildings and structures, mines and oil terminals, food and drink preparation equipment and utensils and small-scale automotive repair work. Comment this may have taken place but to my knowledge does not include auto paints.
Strategy 77. Adopt under the Commonwealth Trade Practices Act Australian Standard 1647 to control the levels of heavy metals in imported toys. Comment according to the federal consumer affairs section of the treasury, this is not necessary and will not be done.
Strategy 78. Review monitoring surveillance for imported toys to ensure compliance with AS1647. Comment federal consumer affairs have written a report that has not been published or disseminated to the public.
Strategy 79. Direct all Government departments and agencies to use Government Paint Committee (GPC) Specifications for all painting work, to use GPC approved contractors for the removal of First Schedule paints and to comply with the proposed Australian Standard code of practice for the removal of paint containing lead. 79. Direct all Government departments and agencies to use Government Paint Committee (GPC) Specifications for all painting work, to use GPC approved contractors for the removal of First Schedule paints and to comply with the proposed Australian Standard code of practice for the removal of paint containing lead. Comment this has probably not happened as the Lead Advisory Service Australia still receives calls from government officers in charge of organising paint removal on government structures who are unaware of the existence of the Australian Standards on Lead Paint Management or indeed the basic methods of lead-safe paint removal.
The Government Paint Committee has been replaced by the Australian Paint Approval Scheme, which has set up a Paint Contractor Certification Program but only industrial lead and other hazardous paints removal certification has been awarded and only to a handful of companies throughout Australia. So it would be safe to say that with the possible exception of bridge paint removal, government paint removal jobs would fall to non-lead certified painters in the vast majority of cases.
3.9 Lead In Petrol
1. Information and education
To make as many motorists as possible aware of the possibility of using unleaded petrol in pre-1986 vehicles. To make as many motorists as possible aware of the dangers of lead in leaded petrol to children's health.
Strategy 86. Continue to support the Federal Government's "Take the Step" campaign. 86. Continue to support the Federal Government's "Take the Step" campaign. Comment the NSW Government provided minimal support for the campaign.
Strategy 87. Widely distribute the list of pre-1986 vehicles which can use unleaded petrol without engine modification. 87. Widely distribute the list of pre-1986 vehicles which can use unleaded petrol without engine modification. Comment the NSW EPA produced a factsheet in 1994 on trialing unleaded petrol in cars not on the list but this was not reprinted when stocks ran out. During its lifetime from 1996-9, the NSW Lead Reference Centre has been very discouraging of the Lead Advisory Service doing much at all in the way of pro-active distribution of this information eg to car clubs.
2. Augmentation of Administrative and Regulatory Control
Strategy 90. Gain industry agreement to relabel "super" petrol as "leaded" as soon as possible. Comment done.
Strategy 91. Amend the Clean Air Regulations to take account of the use of other possible fuel additives if this becomes necessary. Comment this does not appear to have been done. It is quickly apparent that they were all worked out using different estimation methods and thus the validity of all the data is highly suspect
IMPORTANT REQUEST TO READERS I have written italicised comments after each component in the following government plans regarding consumer products but I would love to hear from you if my comment is wrong or incomplete and will be happy to print a retraction with the good news about what has actually happened, in a later issue of LEAD Action News.
Review of NSW Lead
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Updated 21 November 2013