LEAD Action News vol 9 no 4, September 2009 ISSN 1324-6011 Incorporating Lead Aware Times (ISSN 1440-4966) & Lead Advisory Service News (ISSN 1440-0561) The journal of The LEAD (Lead Education and Abatement Design) Group Inc. Editor-in-Chief: Evan Whitton

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Why you should have your ceiling dust removed before you take advantage of the Australian government’s Energy Efficient Homes Package: Insulation Program

Link re: lead dust removal

By Anne Roberts and Elizabeth O’Brien, The LEAD Group Inc. Written 4th August 2009, Updated 14th May 10

This initiative by the Federal Government Department of the Environment, Water, Heritage and the Arts (DEWHA), to reduce energy use by households is commended. However, The LEAD Group urges the Department to advise householders to have ceiling dust removed before insulation is installed.  This is typically going to be the only way that installers will be forced to comply with state OH&S regulations by having a risk management plan which includes safe removal of ceiling dust prior to insulation installation.

We also recommend that the Department’s directions to insulation installers include guidelines on the removal of ceiling dust, in accordance with guidelines set out by WorkCover NSW (see below).

What the Insulation program was about

The Federal Government’s ceiling insulation program provided a rebate of up to $1,600 for home owners, and up to $1,000 for landlords or renters.

[Update: The rebate was reduced to $1,200 on 1st November 2009 and suspended on 19th February 2010, with a replacement program to be brought in by 1st June 2010 announced by the then minister in charge, Peter Garrett. Greg Combet, the minister in charge of cleaning up the scheme, confirmed on 22nd April 2010 that the rebate scheme that was due to resume on June 1. would now not proceed because of safety concerns.]

The million homes already insulated could be subject to inspections and possible replacement of insulation so this factsheet is still relevant to insulators and some homeowners / tenants.

The Allan Hawke report which reputedly sank the Insulation rebate program: stated in part:

A key function in managing a program like the HIP [Home Insulation Program] lies in identifying risks and putting in place mechanisms for their mitigation and management, including as risk profiles changed. Insulation installation requires people to work in hazardous and confined areas such as ceiling spaces, which has inherent risks and the elimination of all risks is an unreasonable expectation.]

The package does not “exclude” what is referred to (in the above letter from DEWHA to the Global Lead Advice Service) as the “simple vacuuming up of residual debris, such as dust and leaf litter in the ceiling space.”

On the other hand, neither does the package contain a recommendation that ceiling dust be removed before insulation is installed.

Use of the word “simple” in relation to the removal of ceiling dust is interesting. There is no acknowledgment in the Environment Department’s letter nor in information to householders that any ceiling dust, particularly in an Australian house built before 1970, will, without exception - none has been found so far - contain at least some lead dust particles, and probably a great many, if the house is anywhere near a busy road.

(Since the phase-out of leaded petrol in Australia in 2002, the rate of addition of lead to ceiling spaces has fallen markedly.)

The Federal Government’s “Competency requirements for registration on the Installer Provider Register,” June 2009, do not specify training in ceiling dust removal. There is no requirement stated that dust removal be carried out by a trained, competent dust removal contractor, using correct equipment.

The only such group of contractors in Australia are the members of The Australian Dust Removalists Association, (ADRA) - see www.adra.com.au

The Competency requirements for registering with the Federal Government as an Installer are as follows:

“Organisations and individuals on the Installer Provider Register must ensure that they (if an individual), and each individual they engage (whether employed or through a sub-contracting arrangement) to install ceiling insulation:

has the competency detailed in Section 1 below (Occupational Health and Safety Training)

and

satisfies either (a) or (b) below:

the requirements detailed in one or more of Sections 2, 3 or 4 below or are supervised by an individual who satisfies the requirements for individuals listed above, and who signs off their work on the Work Order Form.

“Section 1 - Occupational Health and Safety Training (to be completed by all persons installing ceiling insulation) [This is a one-day course]

“Individuals supervising installation of ceiling insulation must also have one or more of the following competencies:

“Section 2 - Trade Specific Competency

“Be a licensed builder, electrician, carpenter, bricklayer, plasterer, painter or plumber (or equivalent, if no licensing requirements exist) in the relevant State or Territory.

“Note: it is recommended that tradespeople without insulation experience consider undertaking insulation specific training; or

“Section 3 - Insulation Specific Competency

Have achieved a statement of attainment from a Registered Training Organisation, against the BCG03 or CPC08 Training Package relating to insulation installation…or

“Section 4 - Prior industry experience

“Be an individual who has: experience and skill in installing ceiling insulation as a result of relevant work experience over a significant period of time (at least 2 years); and an understanding of the relevant Australian Standards and the Building Code of Australia.”

What the requirements for the registration of insulation contractors should include

There is no indication whether the one-day course referred to in Section 1 above deals with removal of ceiling dust or even the hazards of ceiling dust. These courses very likely don’t.

Only NSW WorkCover, out of all the Australian States (in Victoria, the authority is called “WorkSafe”) has written a fact sheet on ceiling dust containing lead. NSW WorkCover also has a fact sheet on the hazards of insulation installation, among them lead and ceiling dust. All state and territory Occupational Health and Safety regulations require that the employer identify hazards prior to work beginning, and that they have a Hazard Management Plan to ensure safe work conditions for their employees.

The NSW fact sheet on a code of practice for the Control of Hazardous Substances states that:

“Contractors and workers involved in the cleaning, repairing, or demolition of ceilings should be aware of the information contained within this guidance note.”

By not making it a condition of the rebate that ceiling dust be removed prior to insulation installation (as much to protect the installers as to detox the home for all future residents) and be included as part of the Package, it is currently the case that householders will have to pay extra for ceiling dust removal, or not get it done at all, if they consider they can’t afford it. However, in most cases, non-removal of ceiling dust will make the work of insulation installers non-compliant with OH&S regulations. Note for example, the following statements from NSW WorkCover’s “FACT SHEET: HOW TO SAFELY INSTALL CEILING INSULATION”:

THE HAZARDS

When installing ceiling insulation, you should control the health and safety risks associated with:

• insulation containing synthetic mineral fibres (SMFs) – eg rockwool or glasswool – or other fibres or dust that can irritate the skin, eyes and upper respiratory tract
• hazardous substances – eg asbestos, pesticides, chemicals or lead

PRIOR TO INSTALLATION

If you’re an employer, head contractor or self-employed worker, you must:

• follow the risk management process – ie identity all the hazards, assess their risks and control them

If you are an installer, before you enter the roof cavity to start the installation:

• do a pre-work risk assessment of the roof cavity and advise the building owner of any identified risks that you cannot eliminate or control.
• Only start work once all the above is complete, and you are satisfied that the system of work and working environment is safe and without risk to health.

Now that NSW WorkCover has identified the hazard of leaded ceiling dust for insulation installers Australia-wide, DEWHA is the perfectly placed agency to ensure that all state and territory WorkCover Authorities, similarly create informative factsheets for insulation installers and police the industry in this, it’s greatest growth phase ever. Telling the public about this hazard through the Energy Efficient Homes Package: Insulation Program website and all it’s publications that are being handed out in shopping centres all over Australia, is a sure-fire way to protect householders from the dust as well.

We include here, for the guidance of householders and/or contractors, a link to NSW WorkCover’s GUIDANCE NOTE FOR CEILING DUSTS CONTAINING LEAD and quotes from it:

Note: The Australian Safety and Compensation Council (ASCC) publish exposure standards in the document National Exposure Standards for Atmospheric Contaminants in the Occupational Environment 3rd Edition [NOHSC: 1003 (1995)]. Values for the exposure standards can be found online in the Hazardous Substances Information System (HSIS) database ( www.ascc.gov.au ) and interpretation of these standards can be found in the Guidance Note on the Interpretation of Exposure Standards for Atmospheric Contaminants in the Occupational Environment 3rd Edition [NOHSC: 3008 (1995)].

Safe work procedures

“Contractors and workers involved in the cleaning, repairing or replacement of ceilings are advised to consider the following procedures, in order to minimise health risks from ceiling dust.

These procedures include:

1. Working in ceilings [Information for householders as well as contractors]

• The sealing of any openings between living areas of the dwelling and the ceiling void prior to the commencement of any work to prevent dust entering the living area.
• The use of vacuum cleaners which comply with AS/NZS 3544 Industrial vacuum cleaners for particulates hazardous to health, to prevent the release of lead containing dust while it is being removed.

2. Personal Protective Equipment (PPE) [Information for contractors]

The use of Personal Protective Equipment, including:

1. Respirators complying with AS/NZS 1716 Respiratory Protective Devices and used according to AS/NZS 1715 Selection, use and maintenance of respiratory protective devices. If the results of the risk assessment identify significant chemical contamination, a full-face respirator may be required to provide the needed level of respiratory protection. Note: A respiratory protection program should be set up by management in accordance with AS/NZS 1715.
2. Where respirators relying on facial fit are being used, workers should shave daily as beard and stubble can interfere with the facial fit, which could result in exposure to lead containing dust.
3. Eye protection, complying with AS/NZS 1336 and AS/NZS 1337 whenever full-face respirators are not worn.
4. Disposable coveralls with fitted hood (the type suitable for use in agricultural spraying and asbestos removal work, changed at regular intervals).

3. Decontamination and Personal Hygiene [Information for contractors]

The adoption of thorough decontamination procedures before each work break, including the observance of a high standard of personal hygiene. This can be achieved by:

• provision of soap and adequate washing facilities
• washing of hands before eating, drinking and smoking
• employers providing laundering of work clothes
• placing any used disposable overalls into marked bags, which should be sealed for disposal with other waste
• the containment and disposal of the removed dust and any contaminated clothing, rags and other waste should be in accordance with any NSW Department of Environment and Conservation (NSW DECC) (formerly the NSW EPA) requirements
• after the work has been done, all equipment must be decontaminated and the area cleaned of dust. Use wet methods to dampen down dust material before wiping up, or use industrial vacuum cleaners.

4. Training [Information for contractors]

Workers should be provided with training that includes:

1. the hazards associated with this type of work
2. an understanding of the health risk assessment process
3. an understanding of the results of health surveillance and biological monitoring
4. the selection, use and maintenance of respirators
5. safe work methods
6. acceptable personal hygiene for this type of work

All training should be documented and a register of training kept.

The cost of detoxing a home of ceiling dust. Who will pay it?

DEWHA’s information to home owners is that “the average cost to insulate a home is estimated to be $1,200.” It would be interesting to know if this proves to be the case, leaving the main contractor $400 towards sub-contracting a dust removalist. Not enough! The Australian Dust Removalists Association (ADRA) website states:

“ADRA advises that given today’s current fuel prices and where there is relatively easy access to the job the average cost to vacuum a dust-only ceiling space is approximately $10 per m2 using WORKCOVER specified HEPA filtered equipment by trained staff. The $10 per m2 is for a building of approximately 100m2 and smaller might have a larger charge whereas larger would be less per m2.

“Difficult entry and trussed low pitched roofs, removal of rubble and removal of old insulation, both batts and loose fill would involve extra cost. In cases of small areas, expect there to be a minimum job price.”

As noted above, no ceiling dust tests that we’ve seen in Australia have revealed the absence of lead. We therefore do not recommend testing ceiling dust for lead. It would almost certainly be an unnecessary expense in all but the newest of houses.

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