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Lead in surface coatings and inks – review of restrictions




As a result of the findings of a post implementation review of the 2007 annotation of the Australian Inventory of Chemical Substances (AICS) of certain lead compounds used in industrial surface coatings and inks, the Director of NICNAS has decided to maintain the conditions of use imposed by the annotations.


On 3 January 2006, fifteen lead compounds used in industrial surface coatings and inks were declared Priority Existing Chemicals for health risk assessment because of the human toxicity of lead, particularly to young children (Table 1). Industrial surface coatings are those not typically used in domestic situations, for example they are used in the painting of factories, bridges, motor vehicles, machinery and equipment, and the coating of materials used in commercial buildings such as window frames.


Table - Lead Compounds Declared for Assessment

Chemical Name

CAS Number

Lead monoxide


Lead chromate


Lead sulfate


Lead molybdate


Lead sulfo-chromate


Lead chromate molybdate sulfate red


Lead chromate oxide


Lead octanoate


Lead 2-ethylhexanoate


Lead oxide


Lead nitrate


Lead naphthenate


Lead peroxide


Lead carbonate (white lead)


Lead chrome 1244



The aim of the assessment was to identify the health hazards of lead compounds and the potential for occupational and public exposure in Australia to be able to determine the risk of adverse effects to workers and the public.


NICNAS completed a Priority Existing Chemicals (PEC) assessment of the fifteen lead compounds in industrial surface coatings and inks, and published a report on 20 September 2007.


Based on the known health effects of lead and availability of alternatives, one of the recommendations in the assessment report was that the declared lead compounds be phased out of industrial surface coatings and inks at concentrations greater than 0.1% in the non-volatile component. It was further recommended that this be achieved through annotation of the Australian Inventory of Chemical Substances (AICS) under section 13 of the Industrial Chemicals (Notification and Assessment) Act 1989 (the Act).


Given the findings of the assessment and that the hazards of lead are well documented, the Director of NICNAS annotated the AICS in 2007 to ensure a staged phase out of the compounds. The objective of the action was to minimise the use of lead compounds and eliminate uses that were not essential whilst giving businesses adequate time to develop non-lead replacements for certain applications. The Director’s action was complementary to a voluntary industry initiative to remove lead compounds from its surface coating products. A complete phase out from industrial surface coatings and inks took effect on 1 January 2009.


A Regulation Impact Statement was not prepared by NICNAS at the time a decision was taken to annotate the AICS. Consequently, a Post-implementation Review (PIR) was required to be undertaken in line with the Government’s best practice regulation process. The Office of Best Practice Regulation (OBPR) determined that the PIR fulfils best practice requirements (OBPR Ref 9256) and published the PIR on their website.


Review process
The review was undertaken from November 2011 to June 2012 and consisted of three web based surveys aimed at:

  • Surface coatings manufacturers and importers,master painters, and
  • workers involved in the manufacture and use of industrial surface coatings.

In undertaking the review NICNAS is grateful to the following for their assistance:

  • the Australian Paint Manufacturers Federation Inc. and its members, particularly DuPont Australia
  • the Australian Council of Trade Unions
  • The Master Painters Association of Victoria
  • NSW Department of Health
  • Queensland Health

Report findings
The PIR concluded that the annotations of 15 lead compounds to phase-out their use in industrial surface coatings and inks had minimal imposts on business while achieving marginal reduction in the risk to workers and the public from lead used in industrial surface coatings and inks, given:

  • a concurrent voluntary industry program to phase out such use meant there was little ongoing introduction; but
  • in some specific sectors, personal protective equipment was inconsistently used and therefore some exposure was possible.

The report proposed on-going assessment and management of associated risks noting the increased scientific concern over appropriate standards for blood lead levels and reports of continuing, though isolated, instances of introductions of lead containing surface coating.


After consideration of the PIR findings, the Director has decided to maintain the conditions of use, with minor rephrasing to make the conditions easier to comprehend. Briefly, listed exceptions which ceased on 31 December 2008 will be removed. These editorial changes do not result in new regulation nor change the current regulatory burden (OBPR Ref 15035).


Post PIR implementation activity
If the proposed use of a chemical annotated under section 13 of the Act does not meet the conditions of use on the AICS, it is deemed to be a new industrial chemical under the definition given in section 5 of the Act. Consequently, a person seeking to introduce an annotated lead compound contrary to the published conditions of use must notify NICNAS prior to the introduction. NICNAS would then assess the risks and make recommendations to risk management agencies to control those risks, or set permit conditions as required.


As the PIR report identified possible instances of continuing introductions of lead compounds for use in industrial surface coatings, compliance monitoring activities are proposed for 2013-14 which aim to determine compliance with the conditions of use associated with the introduction of these chemicals.


For further information regarding a new chemicals application please email newchemicals@nicnas.gov.au


For further information regarding compliance activities please email info@nicnas.gov.au

Or telephone NICNAS on (02) 8577 8800.

Review of Existing Chemicals Program

Following the publication of the Final Report and Recommendations from the Review of the Existing Chemicals Program in December 2006, the Strategy for Implementing the Recommendations was approved by the Parliamentary Secretary to the Minister for Health and Ageing in August 2007, after consultation with stakeholders.  An Implementation Steering Group comprising the community, industry and governments has been convened to guide NICNAS in implementing the recommendations.  The Reform to the Existing Chemicals Program will enhance its efficiency and effectiveness, and its responsiveness to the chemical concerns of stakeholders.

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Cosmetics Reform
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Nanotechnology Reform
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Low regulatory concern chemicals (LRCC) Reform Initiative

NICNAS has recently introduced a number of reform initiatives to encourage the introduction of new and safer chemicals based on the criteria set out in the 'Low Regulatory Concern Chemicals (LRCC) Final Report and Recommendations on the outstanding reforms' (published in the November 2007 issue of the Chemical Gazette).

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Legislative Change 2010-11

NICNAS is proposing to amend the Industrial Chemicals (Notification and Assessment) Act 1989 (the Act) and the planned changes cover:

  • The transfer to the Australian Inventory of Chemical Substances (the AICS) of certain chemicals, including those in cosmetic products previously regulated by the Therapeutic Goods Administration. This was to address a regulatory gap in the protection of public health and complete reforms related to cosmetics (which commenced in 2007) and would also facilitate future reforms;
  • Implementation of measures arising from the review of the NICNAS Existing Chemicals Program including:
    • introduction of new assessment processes such that NICNAS can apply the most appropriate assessment approach (information, advisory or regulatory) based on the issue being addressed; and
    • streamlining processes for re-assessment of chemicals on the AICS, otherwise known as existing chemicals.
  • Minor changes to the Act to enhance the administration of the scheme and improve efficiency including removal of the need to publish summary assessment reports and revision of the Schedule to the Act to clarify current arrangements for active ingredients in sunscreens and chemicals which are persistent and bioaccumulative in the environment.

Extensive consultations had taken place in past years on the reforms to cosmetics regulation, and on changes to the existing chemicals program. Consultation on the minor changes was undertaken in two stages in April 2010 and July 2010. The latter round was based on a revised proposal which took into account submissions to the April 2010 consultation.  

Click here to find out more about the proposed 2010-11 legislative changes >>