That’s a somewhat controversial title for this post. Where lead exposure “safety” is concerned, my opinion is they’re not doing their job. But that statement requires clarification.

We have a regulatory body for workplace health and safety that develops regulatory models for the states and territories of Australia (except Victoria). This is what Safe Work Australia (SWA) say about their role:

Safe Work Australia is a national policy body representing the interests of the Commonwealth, states and territories, as well as workers and employers. We work to achieve healthier, safer and more productive workplaces through improvements to work health and safety ( WHS ) and workers’ compensation arrangements.

When SWA formulates regulations about workplace health and safety issues, it is a complex process of introducing amended rules, discussion and then deciding whether the changes are justified, much like parliament, where the people with primary voting and indeed veto rights are the employers , and representatives of employers and government agencies. While workers are allegedly represented I have found no evidence of direct worker consultation or representation.

When you look at the decision-making process around lead biohazard management, as an example dear to my heart, there is no evidence that worker safety had any sort of precedence.

Lead exposure management regulations have remained unchanged for over four decades, with the exception of the lowering of the trigger blood lead values for work removal and resumption. This is despite an overwhelming amount of clinical and epidemiological evidence that indicates the basic premise of these actions is incorrect. It is despite the fact that SWA’s own publicly accessible documentation very clearly indicates the basic premise of the regulation is simply wrong.

And yet they continue this abomination in their regulatory model because it best suits the employers. If you know you’re doing harm, what does that say about an organization that refuses to consider change?

I’d like to present an email I sent to the SWA Chemical Policies director after getting a reply that basically did what bureaucrats do, repeat what the organization does instead of answering any specific questions.

Here it is:

I have to apologise for bothering you again, but I have had a prior issue around lead exposure management in lead risk workers that I tried to raise with SWA.

I was pretty naïve at the time, not having any experience with the workplace health and safety mantras, and not understanding how safety had to be cost-acceptable when proposing updated safety regulations.

You would be aware of the fact that lead exposure monitoring and management achieves nothing but excess lead exposure detection , and only IF the employer sees rising blood lead level (BLL) as a failure of exposure limiting processes and does something about it.

I have second-hand information about lead risk workers removing their dust masks because of 50 degree heat, with their faces running with black sweat and of change rooms that were too crowded with lead dust on the floor.

If rising BLL is used as an indicator of degrading environmental safety, or unacceptable worker habits or actions, and as a trigger for investigation and rectification, then I acknowledge its value in exposure monitoring and management.

But nothing is done about the continued bioaccumulation of lead.

SWA documentation makes it pretty clear that whoever composed the document on lead knew about lead bioaccumulation and the very long half-life of lead in bone, as well as the fact that most lead ends up in bone.

But aside from a reference to how  x-ray fluorescence (XFR) spectrometry could possibly be used to measure bone lead and saying XRF wasn’t ready yet (2019), SWA has no alternative to measuring BLL, doing what they’ve been doing for decades, with the occasional adjustment of the trigger levels (now 30ug/dl and 20ug/dl). I would like to provide an update (enclosed) where work by Linda Nie’s group at Purdue University now has portable XRF measurement of bone lead at a point where it can and should be used.

If we don’t measure bone lead and by extension body lead levels, we remain unable to even attempt to manage lead worker’s ever increasing body lead burdens, which WILL cause disease in the future, if not already.

A long-term Monash study of lead workers, mentioned in a SWA document, notes a 7-times higher rate of oesophageal cancer in workers with a BLL of 30ug/dl. When a worker leaves lead risk work, they have a 2-3 fold higher risk of dying of cardiovascular disease at a BLL of 15ug/dl. We also have  gout, high blood pressure, atherosclerosis and a host of other conditions.

SWA knows about this and effectively ignores it as far as the current regulation model is concerned. Lead risk workers’ have a real risk of developing serious disease or death because the true dangers of their lead risk work, aren’t properly addressed.

I accept that any effective way of reducing the bioaccumulation of lead (an inevitable result of exposure)  is worth doing, but it ignores the result of the bioaccumulation.

I’ve neglected the truly devastating effects to children of mothers who have worked as lead risk workers. Lead, like calcium is removed from the body during gestation and during breast feeding.

Doing nothing about managing a worker’s body lead burden can have devastating consequences.

Even if XRF finds it’s way into the model regulations, we are still left with the problem of what to do about the already accumulated lead. Chelation or removal of lead provides a remarkably elegant solution, provided we stick to oral chelators.

I need to point out the US OHSA explicitly forbids using “prophylactic” chelation to remove lead since it interferes with BLL measurements and confuses the results of monitoring. I would like to argue that removing lead that is already present is not prophylactic, but I don’t have the proper bureaucratic mindset.

Nevertheless, the inescapable truth is that if we know the body lead burden of a worker using XRF, and we are hopefully minimising exposure using BLL, we still need to manage body lead levels either by preventing lead being absorbed at all, or by removing it.

Cattle in far north Queensland live on land that is rich in natural lead. As a result they end up having so much lead in their bodies that they are now unfit for human consumption. A few weeks in a feedlot eating an industrial chelating agent leaves them lead-free and fir for consumption.

The station owners needed to produce a cost-effective solution to make their cattle saleable, and they found one. Is it really too hard to look at this for lead-risk workers?

I’ve managed to get a few lead risk workers to volunteer for a trial of 600 mg Ca Na EDTA in an enteric capsule (cost 13 cents per capsule, with occasional trace metal supplementation) daily. The sample size is too small to be meaningful, but what we are seeing is a steady fall in BLL, in spite of continued exposure to lead. The first time something like this was reported was in 1962, so I’m simply repeating something already done 60 years ago, albeit at a much lower dosage (they used 4g Ca Na EDTA daily).

My logic was that it takes time to remove bone lead, so slow and steady minimised any risk, and was probably going to be more effective. I guess we’ll see.

Removing lead with oral chelators is not a new idea. But it’s high time it was considered as a tool to make sure that lead risk workers didn’t carry an awful legacy from their work, all while they were under the protective umbrella of SWA or their state WHS organizations.

I am aware that part of the decision process for formulating updated (and perhaps safer) model regulation is cost-driven, namely the cost of implementation and employers can argue against changes that are deemed to be too costly. In a proper cost-benefit analysis, a costing has to be included for the costs of NOT changing the regulations.

I’m sure you wouldn’t be surprised to learn that I didn’t receive an answer. That’s par for the course when a bureaucrat doesn’t want to answer an awkward question. Ignore it and it will go away.

I’ve talked about the constraints on people in organisations about communication, how hard it is to be a whistleblower and the likely outcomes of speaking up. We know what happens to whistleblowers in Australia and what it says about the claimed openness of our governments agencies.

Nevertheless, it was disappointing, because if SWA as an organization cares more about employer opinions than worker safety, they aren’t doing their stated job. I understand that safety regulations that are too expensive can affect the viability of an industry and unemployed workers aren’t that well off either. When invoking updated safety regulations that would actually reduce employer costs and improve worker safety are blocked because of hubris, indifference and inertia, is SWA doing its job?