ILA members continue to deliver reductions in lead exposure ahead of impending new workplace regulatory standards

The European Chemicals Agency Risk Assessment Committee (RAC) has recently completed its review of the science on the health effects of occupational exposure to lead in order to provide advice to the European Commission. This activity is part of an ongoing review to update the EU binding occupational and biological limit values that are now over 30 years old.

It seems that the new EU wide regulatory limits that will be adopted in the next few years, will be substantially lower than those currently in place that allow blood lead levels in workers as high as 70µg/dL… and rightly so.

ILA has long recognised that the current regulatory limits do not provide enough protection for workers across Europe. In 2013 we established our own voluntary blood lead reduction programme that goes beyond regulation. It is based upon the concept of continuous improvement, sharing of best practice through workshops, peer to peer dialogue, annual benchmarking and the establishment of a challenging target. The latest is that no employee in an ILA member company should have a blood lead value exceeding 20µg/dL. We have made it a condition of membership of the Association that companies must enrol in the programme and demonstrate year on year improvements in the management of employee lead exposure.

Reducing employee blood lead levels is not easy and it is complicated by the fact that older long-service employees have stored lead in their bodies from past times, when exposure controls were not as good as they are today. Notwithstanding this, we have seen dramatic reductions in employee lead exposures over the last seven years.

At the beginning of our programme in 2013, nearly 2000 workers – that’s 25% of all workers across our member companies – had a blood lead value exceeding 20µg/dL.

There have been year upon year reductions in these numbers since then. By the end of 2019, approximately 800 workers (representing just over 10% of the current membership workforce) had blood lead levels higher than the target. Hands-on support for our members is an important aspect of the Association’s voluntary blood lead reduction programme. In 2019, I participated in an audit of KCM 2000 Group‘s facility in Plovdiv, Bulgaria to provide input into their workplace lead exposure reduction efforts as they are currently making significant capital investments at the site that will improve lead exposure management. Many companies in our membership no longer have any employees with a blood lead above our voluntary target. By the end of 2018, our programme had delivered a 45% reduction in the number of employees at ILA member companies with a blood lead exceeding the ILA target of 20µg/dL since 2013.

This dramatic improvement has been achieved without drastic reductions in air lead levels measured in facilities and is testament to the fact that an employee’s internal lead level can be reduced without recourse to using prohibitively expensive engineering solutions.

These would be necessary if the current EU binding occupational exposure limit was reduced from 150µg/m3 (the 8-hour total weight average permitted exposure level (TWA PEL)) to the level of 4µg/m3 (8-hour TWA) that RAC postulated. This level postulated by RAC would undoubtably make many facilities uneconomical and further accelerate the damage seen to our sector post-COVID.

Our membership’s focused goal of continually reducing employee lead exposure will no doubt help companies adapt to new prevailing regulatory limits.

Another ILA member H.J. Enthoven & Sons is one of the many who have made it an essential part of their mission:

“HJE is proud to demonstrate a continual reduction in blood lead levels in our workforce… As a member of the International Lead Association, which sets blood lead exposure limits for the industry membership, we take part in the ILA’s biennial blood lead workshops. These are a great opportunity for the industry to come together and share best practice in meeting these critical limits” Mark Ashmore, H. J. Enthoven & Sons

You can read more from Mark, on the many innovative ways they have stepped up to the challenge here.

The collective action encouraged through participation in the ILA workplace lead exposure reduction programme has contributed greatly to enhancing the health and wellbeing of employees that are delivering the closed loop recycling process for lead batteries, and other lead containing products, that is held up by many as the exemplar of a successful circular economy.

In over 30 years of employment in roles in the field of health, safety and latterly regulatory affairs, I have to say that one of my greatest achievements has been the establishment of the ILA employee lead exposure reduction programme. The programme has been embraced by or members and has delivered that rare win-win scenario in which employees, employers and policy makers have all benefited from actions that have improved workplace standards in lieu of having an effective regulatory driver.

Cover image: Campine