Lead Paint Law Development and Implementation in the Central and Eastern European RegionEECCA
HEJSupport joined the International Pollutants Elimination Network (IPEN) in organizing the involvement of a group of non-governmental organizations in the regional workshop for Central and Eastern Europe on lead paint law development and implementation. The workshop was hosted by UNEP and WHO in Tbilisi, Georgia and was held on June 27-28, 2022.
During the workshop, a joint NGO presentation was made to highlight the main achievements and challenges on the way toward lead paint elimination in the region. NGOs from Armenia, Georgia, Azerbaijan, Moldova, Kazakhstan, Kyrgyzstan, Russia, Tajikistan, Ukraine and Uzbekistan shared the results of their work on lead paint monitoring in their countries.
In addition, the discussion included recommendations for strengthening national legislation on lead paint. The recommendations include the following key points.
1. Regulatory developments are an important but not the final step towards lead paint elimination. Implementation, enforcement, and control are needed to ensure meaningful achievements. For this, it is crucial to focus on the following key issues:
– capacity building and awareness-raising activities targeting all relevant stakeholders, including governmental officials, policymakers (parliamentarians), paint manufacturers, retailers, workers, including workers in the construction industry, NGOs, and the general public (consumers);
– capacity building and technical support should be provided to the national laboratories to ensure that they are capable enough to conduct lead paint testing and share the results which are reliable; Accreditation of national laboratories for lead testing in paints is crucial to ensure the reliability of data generated.
– nationally approved methodology on lead paint testing should be developed and approved by the national body on standardization to ensure market quality control;
– market control of all paints sold at the national level should be conducted on a regular basis to ensure compliance with the existing national regulations or to empower the development/revision of the regulations;
– data generated as a result of the market control should be compared with the requirements of the national regulation as well as with the globally recognized lead paint limit of 90 ppm;
-activities addressing the illegal trade of paints should be conducted to eliminate lead-based paints from the market; cooperation and coordination between countries and regions are needed;
– data collection conducted by NGOs during lead paint monitoring should be supported to ensure broad coverage of national paint markets in various countries.
2. Though the price of lead-free pigments may go up by about 10% or more, it is essential to continue working with paint manufacturers to encourage them to invest in innovations that exclude the use of lead-based pigments in paint manufacturing. It is also crucial to ensure access to lead-free paints, which is now limited in many countries of the region.
3. In many countries, the approval process of the draft regulations or the revised versions of the already existing regulations on the safety of paints is slow and inefficient. It results in the delay of phasing out lead-based paints and the continuation of lead exposure to people, including children. The work with parliamentarians and public hearings will help address this problem and facilitate the adoption and entry into force of the national legislations regulating lead in paints.
4. To minimize expenses of paint testing it is important to use XRF devices to conduct initial screening of lead in paints. Such devices should become broadly accessible and affordable in countries, especially for use by customs services.
5. It is important to set up a globally accepted minimum threshold of lead content in paint at the level of 90 ppm to ensure equal safety for everyone in all countries and regions regardless of the level of regulatory developments in countries.
6. Developing a technical regulation on the management of waste containing lead, including paints, is important to address the issue of sound waste management. This is a significant problem for all countries and regions.
7. Labeling lead in paint is essential to ensure consumers’ right to know and minimize exposure. The existing labels are voluntary based, and not all of them are third-party verified and thus are not reliable or trustworthy. Applying the GHS requirements to paints is crucial but does not disclose chemical content in paints. The obligatory labelling of lead in paint based on laboratory testing results provided by accredited laboratories with third-party verification is important.
8. It is essential to develop Guidelines on minimizing the risk of purchasing lead-based paints without conducting laboratory analysis. For example, the guidelines should include an algorithm for the technical evaluation of products. It should explain that during the official product registration process, paint formulation is required to understand which product component may contain lead. The responsible authority should require a safe alternative if such a component is revealed. In addition, it is important to require product safety data sheets with annexes. Analysis of the annexes to the safety data sheet where product health effects are listed will help determine if health risks associated with lead exposure are listed. Often suppliers do not provide annexes to the safety data sheets about the hazardous properties of products which complicates the analysis of whether toxic chemicals, including lead, are present. In addition, water-based paints as alternatives to oil-based paints should be prioritized.
9. Lead paint is one out of 8 Issues of Concern (IoCs) under the Strategic Approach to International Chemicals Management (SAICM). Though substantial achievements have been made in addressing lead in paint, more work is required to ensure the sustainability of the results in all countries and regions. Thus, it is important to continue the work on Lead in Paint as an issue of concern under the new global strategy on sound chemicals and waste management beyond 2020 that is currently under the consideration of the international community.