Blood lead tests: what employers must arrange
Short answer: every employee exposed to airborne lead above the occupational exposure limit must be under the medical surveillance of an occupational medicine practitioner, with blood lead tests at intervals set by each result. The Lead Regulations, 2001 also set removal and return levels, which are lower for women who are capable of procreation.
The Lead Regulations, 2001 (Government Notice R. 236, Government Gazette 23175, 28 February 2002) came into operation on publication and replaced the Lead Regulations of 1991. Medical surveillance is covered by regulation 8, and the phase-in of its removal and return levels ended on 30 June 2005. Draft replacement regulations were published for comment on 1 March 2024, but the 2001 regulations remain the law until they are repealed.
Who must be under medical surveillance
Regulation 8(1) requires medical surveillance by an occupational medicine practitioner when:
the employee is exposed to an airborne lead concentration exceeding the OEL, which is 0,15 mg/m³ for lead other than tetra-ethyl lead and 0,10 mg/m³ for tetra-ethyl lead;
the employee is exposed to tetra-alkyl lead; or
an occupational medicine practitioner certifies that the employee should be under medical surveillance.
Your lead air monitoring results therefore largely decide who needs blood lead tests.
What must be tested, and how often
At the start: an initial examination immediately before or within 14 days after the person starts work, covering medical and occupational history, clinical examinations and, for lead other than tetra-alkyl lead, blood lead and haemoglobin (regulation 8(2)(a)).
Months three and six: blood lead is repeated during the third and the sixth month after the person starts (regulation 8(2)(a)(iii)).
After that: Annexure A sets the maximum interval by the last result: 12 months under 20 µg/100 mℓ, 6 months from 20 to 39, 3 months from 40 to 59, and at the practitioner's discretion at 60 and over.
Women capable of procreation: all blood lead measurements at three-monthly intervals (regulation 8(2)(b)(i)).
ZPP option: where zinc protoporphyrin (ZPP) in blood is monitored at intervals not exceeding two months, only annual blood lead measurements are required. A ZPP value of 10 µg ZPP/g haemoglobin or more means blood lead must be measured (regulation 8(2)(a)(iii) and (f)).
Tetra-alkyl lead: urinary lead is measured immediately, then under Annexure B at least every 6 weeks below 120 µg/ℓ and weekly from 120 to 149 µg/ℓ.
Removal and return levels
Removal: a blood lead result of 60 µg/100 mℓ or more must be repeated. If the repeat, corrected for haematocrit against a standard value of 43 % for men and 38 % for women, is above 60 µg/100 mℓ, the employee is certified unfit for work where they are exposed to lead. The practitioner may also certify an employee unfit below 60 µg/100 mℓ (regulation 8(2)(d)).
Removal, women capable of procreation: removal from lead work when her blood lead exceeds 40 µg/100 mℓ, her urinary lead exceeds 75 µg/ℓ, or she falls pregnant (regulation 8(4)(a)).
Return: regulation 8(3) sets the conditions for going back: written certification of fitness by the practitioner; blood lead less than 50 µg/100 mℓ; a ZPP value less than 6 µg/g haemoglobin; or urinary lead less than 130 µg/ℓ.
Return, women capable of procreation: only when her blood lead is less than 30 µg/100 mℓ or her urinary lead is less than 65 µg/ℓ or, after removal for pregnancy, when she is no longer pregnant (regulation 8(4)(b)).
Tetra-alkyl lead: a urinary lead result of 150 µg/ℓ or more is repeated, and a repeat above 150 µg/ℓ means the employee is certified unfit (regulation 8(2)(e)).
Investigation: each removal must be recorded and investigated (regulation 8(5)).
Keeping blood lead down, and keeping records
Adequate control: regulation 11(1) regards control of exposure to ingestible lead as adequate if blood lead is less than 20 µg/100 mℓ, or, for lead alkyls, urinary lead is less than 120 µg/ℓ.
Hygiene: no one may smoke, eat, drink or keep food or beverages in an area not specifically designated for it, or use compressed air to blow lead particles off surfaces (regulation 15(1)).
Employees' duties: employees must obey your lawful instructions on reporting for medical surveillance and notifying the occupational health practitioner of a pregnancy (regulation 5).
Records: medical surveillance records must be kept for at least 40 years (regulation 10(f)). Others may see them only with the employee's formal written consent (regulation 10(c)).
A quick self-check
Compare your air monitoring results with your medical surveillance list. Everyone exposed above the OEL, and everyone working with tetra-alkyl lead, must be on it.
Check that new starters had the initial examination, and blood lead tests in months three and six.
Check each employee's next test date against the Annexure A interval for their last result.
Confirm that women capable of procreation are tested every three months and know to report a pregnancy.
Review removals: was each one recorded and investigated, and was each return certified in writing?
How Qualitas can help
Qualitas Occupational Consulting is a Department of Employment and Labour Approved Inspection Authority and a SANAS-accredited (ISO/IEC 17020) inspection body for asbestos, lead, noise and hazardous chemical agents. Our lead monitoring measures employees' exposure to airborne lead against the OEL, so you and your occupational medicine practitioner know who must be under medical surveillance. Where blood lead results are rising, it shows which tasks and controls to fix first, in a report written for management, SHEQ teams and auditors.
Not sure what your site needs? Start with our free Compliance Gap Analysis, request a quote, or call or WhatsApp 082 649 6599.
This article summarises the Lead Regulations, 2001 (Government Notice R. 236, Government Gazette 23175, 28 February 2002) for general guidance. It is not legal advice; refer to the regulations for the full requirements.
Christo de Wet is a SAIOH-registered occupational hygienist with 15 years' experience and the founder of Qualitas Occupational Consulting.
Comments