National Environmental Management Act, 1998 (Act No. 107 of 1998)

Environmental Management Plan : Department of Labour

Chapter 4 : Environmental Management Policies

4.4. Lead Regulations

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The Lead Regulations, originally promulgated in 1991, are currently under revision. These regulations apply to every employer at a workplace where lead is produced, processed, used, handled or stored in a form in which it can be inhaled, ingested or absorbed by an employee. The regulations provide a prescribed level of lead exposure above which no employee should be exposed to.

 

It provides that no employer should permit work in an environment that exceeds the prescribed exposure limits for lead. It is the duty of every employer to ensure that every employee exposed to lead is adequately and comprehensively informed and trained at the commencement of their employment and periodically thereafter at intervals as may be recommended by the safety committees.

 

In addition, the regulations make provision for the supply of protective equipment by the employer and the employees abiding by such instructions for the wearing of the protective equipment and the undertaking of medical examinations. Provision is also made that the employee should also abide by operation procedures for the prevention of lead being released into the environment. Instructions regarding the disposal of waste material containing lead and the cleaning of any site at which lead or material containing lead has been used, handled or processed should be followed. The adherence to instructions regarding environmental, housekeeping and personal hygiene practices should also be followed as provided by the regulations.

 

Monitoring procedures with regard to airborne lead must be carried out in accordance with these regulations, and should be done by an approved inspection authority. Every employer is responsible for controlling the exposure of persons to lead in the working environment by applying the following measures where appropriate:

lead and materials containing lead used at the workplace which are liable to release airborne lead, shall be limited; and
emissions to atmosphere shall comply with the provisions of the Atmospheric Pollution Prevention Act (Act 45 of 1965).

 

In addition, it is the responsibility of the employer to ensure that all workplaces are kept in a clean state and free of lead waste and, when lead is accidentally spilled or airborne lead is accidentally released into the workplace, corrective measures must be taken immediately before any work is continued. The cleaning of such accidental release must be carried out by vacuum cleaning or by some other means that ensures that lead dust neither escapes nor is released into the air in such a manner that it contaminates any workplace or the environment.

 

In respect of the packaging, transport and storage of lead, employers should ensure that all lead materials are properly contained and are controlled to prevent the spread of contamination by lead from the place where work is being carried out, and that the containers or the vehicles in which such materials are transported are clearly marked, identifying the contents as lead.

 

With regard to the disposal of lead the employer should:

as far as possible, recycle all waste which contains lead, but not into non-lead production processes;
ensure that all collected lead dust, swarf and other waste is placed into containers that will prevent the escape of lead dust during handling;
ensure that all lead sludge, not for recycling, is placed in properly sealed containers to prevent spillage;
ensure that all such waste is disposed of only on sites specifically designated for this purpose in terms of the Environmental Conservation Act, (Act 73 of 1989), in such a manner that it does not cause a hazard inside or outside the premises; and
give written instructions and appropriate training to the drivers of vehicles carrying such waste, on the action to be taken in the event of accidental spillage of lead waste.