Lead at Work

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The regulations do not apply to work with materials or substances containing lead where, because of the nature of the work, lead cannot be inhaled, ingested or absorbed, e.g. handling finished pottery products which contain lead. They do apply to any type of work activity, e.g. handling, processing, repairing, maintenance, storage, disposal etc. which is liable to expose employees.

Employees must provide a suitable and sufficient assessment to identify the significant risks of exposure to lead and the steps that need to be taken to control the risks of exposure and record those findings as soon as possible after the assessment.

Significant exposure will have to satisfy one these three conditions:

1. Exposure exceeds half the occupational exposure limit for lead; or
2. There is a substantial risk of the employee ingesting lead; or
3. If there is a risk of an employee’s skin coming into contact with lead alkyls or any other substance containing lead in a form, e.g. lead naphthenate, which can also be absorbed through the skin.

Where a significant hazard is evident then the employer must:

• Issue employees with protective clothing
• Monitor lead-in-air concentrations
• Place the employees under medical surveillance

The risk assessment can be supported by the supplier, including information contained in relevant safety data sheets for the lead-containing products.

• Other control methods to prevent exposure will include:
• Providing sufficient general ventilation and where necessary respiratory equipment and local exhaust ventilation equipment (LEV) used where the exposure risk is from airborne lead dust or fumes.
• Fully enclose to prevent access to the process or partially enclose with LEV to reduce contaminants getting airborne.
• Reduce employee numbers and the time employees are exposed, including non-essential employees
• Reduce employee numbers and the time employees are exposed, including non-essential employees.
• Food and drink must not be consumed in any area where lead work processes are being carried out. Washing of hands is essential before eating, drinking or smoking and before leaving the workplace. Changing of contaminated clothes should take place before entering eating and social areas.
• Both employer and employees should take such steps as are reasonably practicable to prevent lead contamination from spreading beyond the workplace or storage area.
• Provide a safe storage for lead to be used or removed from site.
• Waste lead and dust should be taken by an approved collector to facilitate recycling.
• Those under medical health surveillance will need to be monitored for lead levels in their blood and appropriate action taken to protect them. This will be advised by the medical practitioner which may include suspension of the employee until levels return to a safe level.

It is the employer’s duty to provide and maintain adequate records showing details of risk assessments, information and training, precautionary measures taken, medical surveillance, control measures and other personal protective equipment provided.

An initial medical assessment should be completed so soon as is practical before a person starts work where a significant hazard to lead exposure is evident. In any event not later than 14 working days after first exposure. Periodic employee medical assessments are required thereafter and records to be kept on personnel files.