Consultant in Chemical Technology
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GUIDELINES FOR LEAD CONTAINING PAINTS.

ACTION LEVELS

A).

B).
C).
D).
E) .
F) .
G) .
H)

,>0.15% soluble lead “Contains Lead. Should not be used on articles likely to be sucked or chewed by children”. Note this is a Chip2 requirement but NOT an EC risk phrase. Independent of other EC Phrases.
>0.5% <10% total lead chromate CHIP requirement “T” R61,33
>10% lead chromate CHIP requirement “T” R61,33,40
>0.5% <25% total lead CHIP requirement “T” R61,33
>25% total lead CHIP requirement “T” R61,20/22,33
>1.0% total lead - “Contains Lead”. SAPMA label requirement
>5% Sol lead on NV “LEAD PAINT” OHS Act, Lead regulation, label requirement
>0.6% lead on paint “LEAD PAINT” OHS Act, "WARNING" "CONTAINS LEAD. DRIED FILM OF THIS PAINT MAY BE HARMFUL IF EATEN OR CHEWED."click for regulation


LABELS

Note in the UK lead usage is controlled by the Safety at Work Act - Lead regulations. This is in line with the South African OHS Act - Lead regs.
By quoting a preparation as >1% lead, this shows that it is subject to the CHIP requirements.
A paint with < 1% but >0.5% lead would not be subject to the lead regs. but would still be subject to the CHIP requirements.
Note that the presence of chromate has probably a greater effect than lead on labelling requirements!

Paints and similar materials having a total lead content in excess of 0.15 % calculated on the total material as supplied will carry the legend:-

"CONTAINS LEAD. SHOULD NOT BE USED ON SURFACES LIABLE TO BE CHEWED OR SUCKED BY CHILDREN".

GOVERNMENT GAZETTE, NO. 30891 28 MARCH 2008 OHS ACT - DECLARATION OF LEADED PAINT AND SIMILAR SURFACE COATING MATERIALS CONTAINING LEAD OR COMPOUNDS AS GROUP 1 HAZARDOUS SUBSTANCES

Paints and similar materials having a total lead content in excess of 0.6 % calculated on the total material as supplied must bear, on the main panel of their label, the signal word

"WARNING" "CONTAINS LEAD. DRIED FILM OF THIS PAINT MAY BE HARMFUL IF EATEN OR CHEWED."

These products must also bear on their label the following additional statement or its practical equivalent:

Do not apply on toys and other children's articles, furniture, or interior surfaces of any dwelling or facility, which may be occupied or used by children.
Do not apply on exterior surfaces of dwelling units, such as window sills, porches, stairs, or railings, to which children may be commonly exposed,
Keep out of reach of children.

This is in addition to any phrases allocated for other components.

Paints and similar materials having a total lead content greater than 0.5% on the total weight of the material as supplied.

The “toxic” icon and the above phrase. along with the phrases
R20/22 Harmful by inhalation and if swallowed.
R33 Danger of cumulative effects
R61 May cause harm to the unborn child
S45 In case of accident or if you feel unwell seek medical advice. Show this label if possible.
S53 Avoid exposure - obtain special instructions before use.
In addition to any phrases allocated for other components.

 Those materials having a soluble lead content greater than 5% on the non-volatile content of the material will, in addition to therequirements given above, must also carry the legend. "LEAD PAINT"

The above covers the minimum for the lead content. The following should be added, as appropriate, for paints.

R11 or R10 flammability warning(s) & icon as applicable.
S23 Do not breathe spray.
S28 After contact with the skin, wash immediately with plenty of a recognised skin cleaner or soap & water
S43 In case of fire use water fog, foam or powder - do not use water jets. - as applicable.