Review of OECD Declaration on Risk Reduction for Lead

LEAD Action News

LEAD Action News Volume 7 No 4, 2000, ISSN 1324-6011
Incorporating Lead Aware Times ( ISSN 1440-4966) and Lead Advisory Service News ( ISSN 1440-0561)
The journal of The LEAD (Lead Education and Abatement Design) Group Inc.

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Review of OECD Declaration

REFERENCE 6: Resolution of the Organisation for Economic Cooperation and Development (OECD) Council Concerning the Declaration on Risk Reduction for Lead. OECD Document number: C(96)42/FINAL (adopted by the Council at its 869th Session on 20 February 1996 [C/M(96)4/PROV]).

THE COUNCIL

I. NOTES the Declaration on "Risk Reduction for Lead" adopted by the Governments of OECD Member countries at the meeting of the Environment Policy Committee at a Ministerial level on 19-20 February 1996 (the text of the Declaration is reproduced in the Annex to this Resolution). Comment – I had to ask 5 staff members within Environment Australia over a period of three months in 1999 as no one I spoke to could tell me whether Australia was a signatory to the OECD Lead Declaration.

II. RECOGNISES that the support and publicity to be given by Member Governments to the Declaration will be an important factor in its authority, efficiency and success… Comment – not done. The publicity given to the Declaration by the Australian government was such that The LEAD Group, with all of its network connections and information, did not know the declaration existed until three years after it was signed. If it weren't for the Assistant Director General of the NSW EPA directing us to the website, we might never have known.

III. INSTRUCTS the Environment Policy Committee to review the progress made by Member countries and to assess the need for further action in conformity with paragraph 9 of the Declaration…. Comment – Australia’s input to the review of progress made since 1992 was submitted towards the end of 1998. The review omitted to respond with any relevant information to most of the items requested. For example, for the question: "Are there programmes or activities within your country to measure blood lead levels in specific populations, such as children or workers, or in the population in general?" the answer should have been:
"There are no programmes to measure blood lead levels in children (except in some smelting and mining towns) or the general population. Workers generally risk losing their job if they even ask for a blood lead test (except in smelters and some mines). One activity that falsely reported the NHMRC target as having been met was the Report on the National Survey of Lead in Children. Results were not reported such as to be directly comparable to the NHMRC target but nevertheless the target was clearly not achieved. The NHMRC target was for all Australians (with the exception of occupational exposures) to have a blood lead level less than 15 µg/dL (0.72 µmol/L) by 1998. The Report made no comment on the result that 1.7% of the 1-4 year old children tested had a blood lead level equal to or greater than 0.73 µmol/L (results for 0.72 µmol/L were not reported). Instead the Report re-wrote the NHMRC target, claiming only that the target "was that, by 1998, 90% of Australian children should have blood lead levels below 0.49 µmol/L". The incidental result of achieving the actual NHMRC target of zero children equal to or above 0.72 µmol/L was expected to be that 90% of children would be below 0.48 µmol/L. It is false to claim that achieving 92.7% below 0.49 µmol/L is equivalent to 90% below 0.48 µmol/L – the true result most likely was below 90% so even the expected incidental result was not achieved. Yet the Report concludes on page 69: "This [NHMRC] target has already been surpassed." Even if the figures had been reported correctly, their statistical significance is in doubt as there were 4,000 blood lead results in the study design yet only 1,575 results were obtained. This experience confirms that Australia needs a second blood lead survey with adequate sampling of at-risk groups, and accurate reporting against the actual goal of having all Australians below 0.48 µmol/L (since it is too late to achieve the first target by 1998)". Instead of the above correct answer, mimicking the false report, the Australian input to the OECD Lead Declaration review, even after initially stating that the "first target… [was] a reduction of lead in all Australians to less than 15 µg/dL", in the very next paragraph says: "The NHMRC’s first target of having 90% of children under the lead limit by 1998 was met ahead of schedule." Having taken the care to say "the lead limit" instead of reporting the level used (0.49 µmol/L) it is possible to imagine that the person who wrote Australia’s input was aware of the deception being perpetrated. Alternatively, they were just not precise enough to be writing such an important review. In another question on data obtained etc from monitoring "lead levels in environmental media, such as air or soil, food or drinking water" not one item of data is given in the answer and food and drinking water are not mentioned at all. The answer wrongly states the standard for lead in air as 50 µg/m³ averaged over one day. Luckily, the correct standard (0.5 µg/m³ averaged over a one year period) is given on the next page of Australia’s input, where again, only air is discussed in answer to another broad question on lead in humans and environmental media.

ANNEX

DECLARATION on Risk Reduction for Lead

THE GOVERNMENTS OF OECD MEMBER COUNTRIES,¹

1 The mention of "Governments’ is deemed to also apply to the European Communities.

… Having regard to the conclusions of the meeting of the United Nations Commission on Sustainable Development in May 1994 concerning the health impact to humans exposed to lead in gasoline, and encouraging further efforts to reduce exposure of humans to lead in gasoline (UN Economic and Social Council Official Records, 1994, Supplement No. 13, pp 32-34);…

Recognising the willingness of industry to share their experience in the sound management and prudent use of products containing lead including development of alternative solutions;

… DECLARE THAT THEY WILL:

… (2) Give highest priority to actions which address the risk of exposure from food and beverages, water, air, occupational exposure and other potential pathways in accordance with Annex I; Comment – not done. As the Australian input to the review of this declaration states "Although the [1994-6 lead education] campaign has now wound down, the issue still generates a lot of public interest, rating as the second most frequently asked after topic with the Department’s Community Information Unit." Despite this public interest and the signing of the OECD declaration, Australia does not seem to give lead the "highest priority" or indeed much priority at all.

(3) Continue to review lead levels in the environment and exposure to lead of sensitive populations (such as children and pregnant women) and of high risk populations (such as certain groups of workers) using the results to evaluate the effectiveness of national programs in reducing risks from exposure to lead and to identify priorities and opportunities for future actions; Comment – not done. It’s easier to avoid reviewing lead levels if you fail to monitor them in the first place – this seems to be the policy in Australia.

(4) Promote and maximise the use of environmentally sound and economically viable collection and recycling programmes for lead and lead containing products in order to reduce the release of lead to the environment from waste streams; … Comment – recycling of lead and lead containing products (like light bulbs) and lead contaminated wastes (like paint chips, ceiling dust and sump oil) does not seem to be a priority of any Australian government. NSW EPA is possibly the best-placed and motivated to have the best practice in terms of waste and recycling generally. Unfortunately, NSW EPA set a policy on certain lead wastes being exempt from classification on the basis of levels of lead and other contaminants. Instead, if a lead contaminated waste is removed from a house, childcare centre or educational institution it is automatically classified as "solid waste" rather than industrial or hazardous which it may otherwise have been classified as. If the federal government can do no more than to point out (as in the "6 Step Guide to Painting your Home") that waste policies vary from one area to another, then perhaps the International Lead Management Center or the OECD could inspire greater efforts?

FURTHER DECLARE THAT THE OECD SHOULD:

… (9) Review progress by Member countries in pursuance of this Declaration three years after adoption and assess the need for further action; … Comment – not done. The review done by Environment Australia was appalling in not answering most questions and including at least a page (out of the six pages) of vehicle emissions information irrelevant to lead. It in no way assessed the need for further action.

Annex I

a. Progressively phase-down use of lead in gasoline except where needed for essential or specialised uses for which there are no practical, viable alternatives; Comment – the phase out date as it stands at the moment is 1st Jan 2002, embarrassingly slow for a developed country and behind many developing countries such as China and the Philippines. Western Australia banned leaded petrol as of 1st Jan 2000, and Queensland looks like the next state to achieve a ban by 1^st March 2001.

b. Eliminate exposure of children to lead resulting from products intended for use by children (eg, toys, cribs, crayons); Comment – in the period when the US Consumer Product Safety Commission has recalled well over 100 different consumer items due to lead content, the Australian government has recalled 4 products. Lack of testing would seem to be the key once more.

c. Eliminate exposure to lead from food packaging (eg, for cans, by phasing down use of lead solder in existing canning lines, not using lead solder in new canning lines, or where these are not practical, using functional barriers to prevent lead migration; for wine-bottle capsules, substituting other materials); Comment – lead soldered food cans are still produced in Australia for ham etc and some leaded cans are imported. Lead capsules are still manufactured and allowed to be imported into Australia.

d. Phase down the use of lead in paint and rust-proofing agents except in cases of essential or specialised uses for which there are no practical alternatives; Comment – one phase has taken the allowable lead content of domestic paint to 0.1% but the US level of 0.06% seems not to have been considered.

e. Restrict exposure to lead from the leaching of lead from ceramic ware and crystal ware used for food and beverages (eg, by effective production and process controls); Comment – labelling of these products would also be essential as there is no process control that will help you if you leave alcoholic beverages stored in leaded containers. A severely lead poisoned couple were hospitalised in Sydney recently due to drinking a health drink grown in a ceramic pot. An education campaign is required as long as people still have these items in their homes.

f. Restrict the use of lead shot in wetlands and promote the use of alternatives to lead sinkers in shallow waters; … Comment – not done by the federal government despite a recommendation from ANZECC (Australian New Zealand Environment and Conservation Council) in 1996 that lead shot in wetlands should be banned within 4 years. The Victorian government plans to ban lead shot in certain areas by 2003. An officer in the Animal and Plant Health Service of the Department of Primary Industries in Queensland told me that there is a ban on metal being present in meat. This has led to a virtual ban on lead shot for mustering cattle etc - only hard plastic is now used. The same officer was under the mistaken impression that lead shot was banned from sale in Australia. Australian manufacturers of alternatives to lead sinkers have had to go to the US to market their product with any hope of success due to the Australian government’s lack of support on this issue.

j. Establish strategies, including public information programmes, to abate significant exposures arising from the historic use of lead-containing materials in buildings. Comment – there has only been public information programmes of the scantest kind since this declaration was signed, and only on paint abatement. There is no federal government support available for lead abatement with the exception of ceiling dust removal in the Sydney Aircraft Noise Insulation Project that is now winding down and appears not to have been repeated around any other major airport in Australia. The fact that a recent case occurred of a woman reaching a blood lead level of 64 µg/dL after her tankwater reached 50 times the acceptable NHMRC lead level in a house with lead flashings on the roof, would seem to indicate that neither the lack of lead testing (of humans or environmental media), nor the lack of strategies to abate significant exposures is helping the Australian people to achieve the NHMRC goal of all Australians below 10 µg/dL.

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 Issues Paper
Review of NHMRC Strategy
Review of Ros Kelly’s Lead Roundtable
Review of NSW Lead Management Action Plan
Review of NSW Parliamentary Select Committee
Review of OECD Declaration

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