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Thirty
Thought-Starters on Ceiling Void Dust in Homes
By Elizabeth O'Brien,
Coordinator, The LEAD Group Inc., and Manager, Lead Advisory Service (LAS)
- Q (QUESTION): Where does the
dust in ceiling voids come from?
A (ANSWER): There are numerous ways for dust to get
into ceiling voids, including:
- Air pollution comes through gaps
in tiles and tin roofs and moves in through any other entry point under eaves, etc. Any
residue from any source of air pollution can enter the roof void, for example, from
vehicle and air traffic emissions, industrial activities such as mining, smelting, paint-,
plastic-, metal-manufacturing or recycling, coal-, wood- or oil-burning, incineration,
cremation, fires, dust storms, aerial spraying, paint removal from auto repairers or large
structures such as bridges.
- Combustion particles come
through gaps in chimneys or vents from the living space, some of which have been vented
into the ceiling void (instead of to the outside) for example, coal gas (town gas) burners
used up until the 1950s (See "Ceiling Dust Removalist Case Study").
- Combustion particles from, for
instance, cigarette smoking, gas stoves, oil or kerosene heaters, can move into the void
through ceiling fan extraction vents, ceiling roses and wall vents.
- Paint removal dust particles,
plaster dust, brick dust etc can enter the void from renovations or demolition in the
building or in a neighbouring building. Insulation purposely placed in the void can add to
the dust load especially if it degrades easily eg cellulose fibre.
- Degradation of the roofing
material eg asbestos cement, slate, fibreglass, galvanized iron, can add to the ceiling
void dust load.
- Decaying biological matter such
as nests, bodies and faeces of the 64 pests found (according to Dr Cullen ex-WorkCover
NSW) in ceilings eg birds, rats, mice, possums, insects etc can be present as dust, fur or
feathers. Moulds and lichens can also grow in ceilings or on roof tiles, leaving spores.
- Residues of pesticides used to
control the above could have been purposely sprayed or laid in the ceiling void.
- Debris left in the void by
workers, eg sawdust, roof paint chips, building materials, lead washers used on corrugated
roofs, PVC cabling, wire; or by accident, eg roof tile fragments from hail damage,
charcoal from fires.
2.
Q: What is in ceiling void dust? A: A large range of contaminants arising from the
above activities can be present,
including:
- Heavy metals -
lead,
mercury, cadmium, arsenic, antimony, beryllium, chromium, selenium, barium, molybdenum,
nickel, thallium, vanadium
- Radioactive metals -
plutonium,
uranium, thorium, potassium-40
- Other metals
- zinc, copper,
iron, aluminium, sodium, calcium, silicon, magnesium, titanium, potassium, manganese,
phosphorus, tin
- Fibres
- asbestos,
fibreglass, synthetic mineral fibres, cellulose, wool, rockwool
- Organic compounds -
DDT,
organochlorines, termiticides, dioxins, PAHs (poly aromatic hydro-carbons),
nitro-PAHs
- Biological matter
- animal
faeces, carcasses, feathers, fur, plant spores, bacteria, lice, cockroaches and other
insects, fungi
- Fallout of other persistent
hazardous air pollutants
- components of cigarette smoke, diesel emissions,
woodsmoke,
sulphur, ash from incinerators and coal- or coke-burning.
3. Q: What are the usual amounts of these contaminants in ceiling dust?
A: There is insufficient data to allow
anything but general statements to be made. Most ceiling dust studies have been done to
determine the contribution that a lead or copper smelter, lead mine, or paint
manufacturers makes to the lead in the ceiling dust, but some testing has also been done
in Sydney, Port Kembla and Adelaide to determine the effect of vehicle traffic. Most
studies have only assessed the lead in ceiling dusts (exceptions are noted in the tables
below) as lead is the most studied toxic substance. This is not necessarily a bad thing,
as lead is widely regarded as a good "marker" contaminant ie if you measure the
lead in air, water, dust, soil, sediment, wastewater, waste oil, solid waste, blood etc
and find it to be at a high level, chances are that other contaminants will be present.
4. Q: Why is
lead a good "marker" contaminant? A: Measuring the lead in a contaminated
substance is useful because:-
- Firstly, lead itself is toxic
and therefore knowing the lead content immediately tells you something about the potential
risk involved.
- Secondly, at the points at which
lead is most likely to be dispersed into the environment (ie during the mining and
smelting of base metal ores and during the life of certain uses of lead (eg in petrol,
paints, plastics and chemicals) lead always occurs in combination with other toxic
substances. Examples are:-
- Base metal ores such as silver,
lead, zinc and copper ores all contain lead and typically also contain mercury, cadmium,
arsenic, thallium, beryllium, antimony, selenium, etc.
- In cities or wherever there is
leaded petrol in use or previously in use, there will also be fallout of emissions from
diesel vehicles, gas vehicles, jet-fuelled planes and non-leaded petrol vehicles (eg
Nitro-PAHs, fine particulates).
- As well as containing lead,
paints can contain chromium, asbestos, DDT, mercury, arsenic, barium, etc - all these
contaminants become fallout when paint is sanded, burned, chipped or chalking.
- Particulate pollution from
combustion processes other than in vehicles and smelters, will nearly always contain lead
because lead is found in so many fuels eg, coal, wood, waste (as used in incinerators),
crude oil, waste oil (the lead content will be higher if the oil is from an engine run on
leaded petrol).
5. Q: How does
ceiling void dust get into the living spaces of homes? A: See the factsheet Lead
Safe: Lead in Ceiling Dust by the Lead Reference Centre (LRC - within the NSW EPA)
which mentions, among other things, water damage to ceilings which may cause ceilings to
crack or collapse.
6. Q: What
is a "safe" or "acceptable" level of lead in ceiling dust? A:
Jason Bawden-Smith, lead assessor of JBS Environmental, answers this question with the
following statement on his analysis reports:
"Ceiling Dust Biohazard
Levels (parts per million)
Low biohazard <300 ppm [300 mg/kg (milligrams per kilogram)]
Moderate biohazard 300 - 2000 ppm
High biohazard 2000 + ppm
"Ceiling
dust only poses a health risk to occupants, especially pre-school children, if the lead
dust is accessible, that is:
- Enters the living areas through
holes or cracks in the ceiling;
- When disturbed during removal or
other work activities;
- If the roof void is used as a
room or attic.
"Health risk is also
related to the amount of dust present."
To give
some idea of how much lead needs to enter the living areas of a house for there to be a
contamination problem, another lead assessor (Graeme Waller of Graeme Waller and
Associates) informed a ceiling dust removalist that just 2 tablespoons of ceiling dust
with a concentration of 2,800 ppm (2,800 mg/kg) would contaminate a room and just 2 cups
of the same dust would contaminate a whole house. Graeme uses an "acceptance
criteria" of 1 mg of lead per square metre of floor - anything above this is
"contaminated". A third lead assessor, Fred Salome of CTI Consultants, also
prefers the United States standards that have been set for floor wipes inside a home. If
the ceiling void is going to become a floor (for instance in an attic room) then the dust
should be vacuumed to give any chance of complying with the clearance level of 1mg of lead
per square metre. According to Fred, if the ceiling dust is going to be disturbed (eg when
a ceiling is demolished) then the dust should be vacuumed because ceiling dust is always
contaminated, and testing it is an unnecessary expense. The NSW EPA's publication Significant
Risk of Harm from Contaminated Land (released April 1999) advises that an appropriate
expert be consulted in relation to dust on contaminated land.
7. Q: Does
it make a difference that the lead in ceiling dust is always found in combination
with other contaminants? A: "Yes" it is significant that lead is always
found with other contaminants in ceiling dust because some contaminants are synergistic ie
the effect of the two together is greater than the sum of the effects of each on its own.
Mercury and lead are synergistic for example. In a study by Schubert, Riley and Tyler ("Combined
Effects in Toxicology a Rapid Systematic Testing Procedure: Cadmium, Mercury, and
Lead", Journal of Toxicology and Environmental Health, 4: 763-774, 1978) male
rats were injected with an LD1 (lethal dose for one) of lead ie, the amount of lead that,
when injected into 100 male rats would, on its own, normally kill only one of the rats.
When an LD1 of lead was injected in combination with an LD1 of mercury, all of the
rats died. This is called the LD100 (lethal dose for 100). Thus LD1 lead + LD1 mercury =
LD100 lead with mercury.
8. Q: How
much lead is in ceiling void dust in Sydney? A: See tables below:
Levels of
Heavy Metals in Sydney Ceiling Dusts, that have been reported to The LEAD Group's advisory
service between June 1995 and June 1999
Suburb or Area of Sydney |
Ceiling Dust Lead Levels
mg/kg |
Annandale |
2,800 - 3,300 |
Balmain |
3,400 - 20,000 |
Beverly Hills |
194 |
Botany |
841 |
Cabarita |
3029 (as tested by JBS, same house was 2200 as tested by
Woodward-Clyde) |
Darling Point |
2,280 |
Earlwood (childcare centre) |
1,500 with a loading of 740 mg/m2 |
Eastern Sydney hail area |
1,620 (reported by resident) 500 5,000 (for 80 houses,
reported by lead assessor) |
Erskineville |
4,000 |
Five Dock |
1,900 |
Inner Sydney |
1,000 2,000 (reported by lead assessor) |
Kensington |
1250 |
Middle Cove |
390 |
Milperra |
200 |
Mosman |
1,142 |
Rosebery |
883 |
Rozelle |
12,000 (half a ton of dust) |
Russell Lea |
1,353 |
Surry Hills |
1,117 |
Sydenham: Sydney Aircraft Noise Insulation Project (SANIP) |
2,000 (average) in homes tested by environmental consultant |
Other Relevant Dust
Levels (mg/kg) |
Dulwich Hill |
55 cadmium, 57,000 zinc in
ceiling dust |
Manly |
2,500 lead in demolition
dust on leaves in neighbour's garden |
Woolloomooloo Fingerwharf |
10,000 lead in wall void
dust |
Published
Results for Heavy Metals in Sydney Ceiling Dusts
Reference: |
No. of buildngs |
Area of Sydney |
Age of buildings |
Lead concentration range in mg/kg |
Bawden-Smith (1992) |
49 |
Balmain |
1986 to 1842 |
Range 500 5300, mean 2,300 |
Whicker et al (1997) |
11 |
Campbelltown |
1995 to 1917 |
Range 165 2490, mean 822 |
Woodward-Clyde (1999) |
4 |
Concord |
Not stated |
Range 893 - 6,890 |
References
to the table of ceiling dust results:
Bawden-Smith,
Jason (1992) Environmental Lead Contamination - The Mort Bay [section of Balmain] Pilot
Study, Masters Thesis, Applied Science in Environmental Studies, University of NSW,
Sydney, Australia.
Whicker, C.L.;
Hayes, W., Khoo, C.S. and Bhathal, R.S. (1997) Heavy Metals in Ceiling Dust of Some
Sydney Houses, New South Wales, Australia, in "Journal and Proceedings of the
Royal Society of NSW", Sydney, Australia, Vol.130 Parts 3-4, 65-78.
Woodward-Clyde
(1999) Remediation Action Plan, Dulux Cabarita, Sydney, Australia]
Notes: The
Woodward-Clyde report noted that homes assessed in the area had a ceiling dust lead
loading of around 35 mg/m2. The Whicker study also published ceiling dust levels of copper
(range 57 - 517 mg/kg, mean 150 mg/kg) and zinc (range 97 - 3664 mg/kg, mean 1027 mg/kg).
9. Q: Is
ceiling void dust a health risk and who could determine this? A: Looking at the above
list of what can be in ceiling dust and at the table showing what has been measured to be
in ceiling dusts in Sydney, the precautionary principle would indicate that we must assume
ceiling void dust is a health risk until proven otherwise, especially considering the
following points:-
- In particular, lead assessors
and the Senior Environmental Health Officer at South Eastern Sydney Public Health Unit
concur that ceiling dust, if disturbed or falling into living spaces, is a health risk,
due to the lead alone. The risk is that current or future resident young children will
pick up the lead dust off the floor and other surfaces and their hand-to-mouth activity
will provide the pathway for lead poisoning. For adults, the more usual pathway for lead
poisoning is inhalation, so it is safe to assume that there is a lead health risk for any
adult breathing in large amounts of ceiling dust, such as roofers or ceiling repairers who
do not use respiratory protection. The lead health risk to these workers would easily be
determined by blood lead testing, which could be carried out by individual workers,
organised by employers, done through GP's or at the Workers Health Centre, or carried out
as a research project by WorkCover Authority NSW (though this is unlikely with the
WorkCover redundancy program in full swing).
- It would seem that the most
pressing research need to answer the health risk question in relation to other health
risks from ceiling dust in Sydney is to look at the particulates issue (especially fine
particulates (PM10) and ultra-fine particulates (PM2.5)). Ceiling dust is variously
described as "like talcum powder" or "like flour" or, "you'd be
amazed at the haze inside ceiling voids on a windy day!" The Whicker study referred
to above, found that around 20% of the mass of ceiling dusts around Campbelltown was in
the particle range of less than 53 microns [which is approximately the width of a human
hair]. The lead concentration in this particle range was higher than for larger particles.
According to a new brochure from The Australian Lung Foundation, called Wood Smoke, Air
Pollution and Your Health:
"When you
breathe in high levels of air-borne particles from burning wood, motor vehicle exhausts or
industrial emissions, your health can be seriously affected. People who already suffer
from conditions such as asthma, chronic bronchitis, emphysema or heart disease are
especially at risk. So are the very young and very old. Each year in Australia, lung
disease and ill-health resulting from air pollution, lead to 9 million lost days of work
or social activity, and cause about 1000 preventable deaths."
- Increased cancer risks due to
cadmium and arsenic as have been found around the Boolaroo lead smelter, should also be
investigated.
- The possibility of asbestos
fibres from in situ or since-removed asbestos cement roofs would seem to be a special
health risk from some ceiling dusts. Asbestos is not a cumulative poison and even a single
exposure should be avoided if at all possible.
As for which
government agency is most appropriate for answering the question of whether ceiling dust
is a health risk, this would be either the federal or state health or occupational health
and safety agencies. See the "Ceiling Dust Removalist Case Study" for the clear
answer from WorkCover NSW that exposure to ceiling dust (either by breathing it in,
ingesting it or absorbing it through the skin) should be avoided. Anyone who observes a
worker who has failed to protect himself from ceiling dust exposure is entitled to report
the incident to WorkCover NSW (phone 131 050). Public Health Regulations may have
something to say about ceiling dust. The National Occupational Health and Safety
Commission (NOHSC - previously Worksafe) can write a standard or code of practice for,
say, handling ceiling dust, but NOHSC cannot ensure that the code is followed. It would be
up to the state agency to take it up.
10. Q: Is
ceiling void dust an environmental problem and who controls this? A: When ceiling dust
is permitted to escape from the void and enter the living space, or the outside of the
building, there will then be opportunities for it to contaminate air, soil, street-dusts,
sewage and stormwater. Councils have a mandate to control pollution of air, soil and
stormwater, but council staff need evidence that it's happening (eg be called out and
attend the site at the time) and evidence that the dust etc being dropped in gutters etc
is contaminated. It is a violation of the Clean Waters Act to pollute waters at all, or to
put something in a position where it might pollute stormwater. The NSW Environment
Protection Authority (EPA) controls licences for waste facilities and the EPA has licensed
the Australian Refined Alloys (ARA) secondary lead smelter in Alexandria (phone 9516 5099)
to accept ceiling dust waste, as the lead in the dust can be recycled. Building debris
needs to be separated out from the dust as it harms the ARA equipment.
11. Q: When
should ceiling void dust remain undisturbed? A: The factsheet Lead Safe: Lead in
Ceiling Dust advises "The dust in your roof void does not pose a risk if
ceilings, cornices and ceiling roses are in good repair. In fact, the dust is better left
untouched if there is no leakage into living spaces."
12. Q:
When should ceiling void dust be removed? A: The same factsheet, Lead Safe: Lead in
Ceiling Dust advises "Some home maintenance or renovation activities may disturb
dust and increase the risk of contaminating your living areas. These include:
- Demolishing ceilings or cavity
walls
- Installing insulation or new
electrical wiring
- Working in the ceiling cavity
for any reason
"Water
damage may cause ceilings to crack or collapse
"Assume
dust in pre-1970 houses contains lead unless tests prove otherwise
"Have
lead dust removed from your house
"Do-it-yourself
ceiling dust removal is not recommended - it's dirty and dangerous and requires special
equipment. Hire a professional."
13. Q: Is
there any government requirement that ceiling dust must be removed? A: No, there is
only the above
advice from the NSW Environment Protection Authority and in the following circumstances:-
- For houses in the Sydney Noise
Insulation Project (SANIP) area, the project management (federal government agency) took
advice from the environmental consultancy DASCHEM (Melbourne) that required that ceiling
dust was removed in every house prior to house demolition and prior to installation
of insulation. "All other building work resulting in penetrations to ceilings and/or
walls is to be carried out after the dust removal had been completed", according to
the Procedures Used in the Sydney Aircraft Noise Insulation Project (these
specifications are only for the purpose of SANIP though the ceiling dust contractors who
worked on SANIP tend to still use them).
- "With the introduction of
the Integrated Development Assessment Legislation in 1998, all NSW councils were obliged
to review their standard conditions for DA's [Development Applications]", so in the
case of work to be carried out which requires a DA, for instance, in the Southern Sydney
Regional Organisation of Councils (SSROC) area, member councils are "strongly
encouraged to adopt the conditions [Reference: SSROC - Standard Environmental
Conditions for Development Applications] in as near to the current form as possible to
encourage cross-regional consistency." The "Instructions for Use" section
of the reference quoted above and below warns: "Under no circumstances should any of
these conditions be placed on a DA without consideration as to whether they apply to the
development proposed." Relevant SSROC standard conditions for residential properties
(and all other properties) undergoing demolition/remediation include:-
- "13 Demolition and disposal
of materials incorporating lead paint
Prior to demolition of buildings constructed
before 1970, the applicant shall submit a Work plan prepared in accordance with Australian
Standard AS2601 - 1991, Demolition of structure by a person with suitable expertise
and experience. The Work Plan should outline the identification of any hazardous
materials, including surfaces coated with lead paint, method of demolition, the
precautions to be employed to minimise any dust nuisance and the disposal methods for
hazardous materials
.
"Hazardous dust must not be allowed to escape from the site. The use of fine mesh
dust proof screens or other measures is recommended. Any existing accumulations of dust
(eg; ceiling voids and wall cavities) must be removed by the use of an industrial vacuum
fitted with a high efficiency particulate air (HEPA) filter. All dusty surfaces and dust
created from work is to be suppressed by a fine water spray. Water must not be allowed to
enter the street and stormwater systems. Demolition is not to be performed during high
winds, which may cause dust to spread beyond the site boundaries.
"All contractors and employees directly involved in the removal of hazardous dusts
and substances shall wear protective equipment conforming to Australian Standard AS1716
Respiratory Protective Devices and shall adopt work practices in accordance with the
requirements of WorkSafe's Control of Inorganic Lead at Work (NOHSC: 102(1994) and
NOHSC: 2015(1994)).
"All lead-contaminated materials are to be disposed of in accordance with the EPA's
requirements.
- "14 Lead contaminated
material post-removal requirements
Following demolition activities, soil must be
tested by a person with suitable expertise, to ensure the soil lead levels are below
acceptable health criteria for residential areas. Full certification is to be provided to
Council prior to final inspection."
14. Q:
What are the occupational health and safety protocols for ceiling dust extraction? A:
These vary from
government agency to government agency:-
-
As mentioned above, if ceiling
dust is to be removed as a result of a DA involving demolition in which a council officer
determines that a condition such as SSROC's Standard Condition 13 is required, then
respiratory devices would be worn and work practices from WorkSafe's Control of
Inorganic Lead at Work would be adopted.
-
According to the Procedures
Used in the Sydney Aircraft Noise Insulation Project [SANIP] (which
specifications are only for the purpose of SANIP), in addition to the respiratory device
being worn (after the worker is trained in its use), the following specifications are used
during ceiling dust removal:-
-
All employees directly involved
in the removal shall wear disposable overalls fitted with hoods and must at all times keep
their suits fully on and in good condition;
-
Personal monitoring of all
employees directly involved with the removal conforming to AS3640 Workplace Atmospheres
method for sampling and Gravimetric Determination of Inspirable Dust;
-
The entire ceiling space and
bagged wastes are to be sprayed with a PVA solution applied by an airless spray prior to
removal from the ceiling space:
-
Personal decontamination
procedures are to be followed and will involve spraying down of disposable suits with the
PVA solution in the ceiling space, and washing hands and face with clean water outside the
building with all waste water directed to sewer;
-
All employees involved in dust
removal shall adopt good hygiene practices and ensure hands and faces are thoroughly
washed before leaving the site and prior to smoking or eating;
-
All employees entering the
ceiling space within 1 hour of dust removal shall wear approved respiratory protection
conforming to AS1716;
15. Q: What
special equipment is needed to safely remove ceiling dust? A: The advice from the NSW
EPA, SSROC, SANIP, Illawarra Public Health Unit, North Lake Macquarie Environmental Health
Centre and Broken Hill Environmental Lead Centre is consistent in recommending the use of
industrial HEPA vacuum equipment.
16. Q:
What are the potential health risks to people carrying out ceiling dust removal? A:
The NSW EPA's factsheet, Lead Safe: Lead in Ceiling Dust warns "Watch out for
electrical wires and take care not to fall through the ceiling. See the answer to Q 9
above and the Ceiling Dust Removalist Case Study for the advice of WorkCover NSW.
17. Q: What are
the potential health risks to people working in ceiling voids or cutting into ceilings if
the dust is not first removed? A: Much the same as the health risks to the ceiling
dust removalist.
18. Q: What are
the potential health risks to residents when ceiling dust is removed? A: Adults would
presumably only have a one-off exposure to dust in the air on the day if they were present
during dust removal or soon after and before the dust had settled. People living with
constant exposure to ceiling dust due to holes in the ceiling, may have a more significant
exposure. Young children on the other hand, are at risk of ingesting the dust that settles
after removal, due to their hand to mouth activity and close contact with the floor.
19. Q:
What are the government requirements regarding disposal of ceiling dust? A: The NSW
EPA Pollution Line officer I spoke to on 29.4.99 said "Theres no problem
legally with putting leaded building and demolition waste in the municipal waste bin
so a contractor could not be fined for putting ceiling dust in the
householders rubbish bin it is solid waste class 1 which is what most
of the landfills that accept domestic garbage are categorized as. If the householder
doesnt want the dust or debris in their bin then it should be included in the quote
for the job that the contractor takes it to a landfill it is charged by
weight." One ceiling dust removalist, John Mercer of Australian Lead Services, said
he was shocked to hear that the waste dust could be put in the garbage. He said a better
policy is needed.
20. Q: Can
the lead in ceiling dust be recycled? A: Yes, the ARA secondary smelter in Alexandria
is licensed to accept ceiling dust in order to recycle the lead out of it. Sydney
ceiling dusts have a mineable level of lead in them.
21. Q: When
and why did the ceiling dust extraction industry begin? A: As far as I know, the first
ceiling dust removal project took place in Port Pirie, South Australia in the early 1990's
due to the high levels of heavy metal in the dust resulting from the lead smelter. In
Sydney, the first ceiling dust removalist probably set up his business in 1995, having
designed and built his own truck mounted vacuum equipment. The industry began purely in
response to the demand from householders who were made aware of lead in houses through
media reports. Various extraction companies have come into the field from a range of
related industries such as installation of thermal insulation, air-conditioner ducting, or
noise insulation, cleaning and attic-conversions.
22. Q: How
big is the ceiling dust extraction industry in Sydney? A: There are now more than twenty
companies who do ceiling dust removal in Sydney.
23. Q: How
many houses have had their ceiling dust extracted? A: A conservative estimate would be
5000, over half of which were paid for by the Federal Government in the SANIP.
24. Q: What
are the government requirements regarding licensing of ceiling dust contractors? A: None.
25. Q: What
do you need to do to set yourself up as a ceiling dust removalist? A: At this point in
time (June 1999) - nothing but have a telephone number, an able bodied worker and an
industrial vacuum cleaner. If you deal with cluey clients, they will want you to convince
them that you are looking after your own health, the health of residents and the
environment, have a truck-mounted HEPA vacuum cleaner, and do follow-up clearance testing
of the floors inside the house. John Mercer of Australian Lead Services said
"non-HEPAs should be completely outlawed" Hes heard from lead assessors
and others in the field that only companies who use HEPA filters will get referral work.
26. Q: How
would licensing of ceiling dust removalists help the home-owner? A: Householders are faced
with the problem of determining whether a ceiling dust removalist is going to do a decent
job and not leave a whole lot of dust in the ceiling void or leave their home more
contaminated than it was (in the living area). Licenses would ensure that at least the
contractor could have their license taken away if they consistently did a bad job. With
the usual requirement that licensed contractors be insured, the householder would have
some way of claiming the cost of clean-up and testing, if the job was botched.
27. Q: Could
ceiling dust removalists be licensed by the EPA, WorkCover, or Department of Fair Trading
(DoFT)? A: I asked DoFTs Home Building Unit Manager this question and was advised by
Michael Carroll, for the Director General, that ceiling dust removal work "does not
require to be licensed under the Home Building Act 1989", administered by
DoFT. DoFT
"would not propose recommending any changes to the Legislation in that regard",
for example to necessitate licensing of ceiling dust contractors. Failing the setting up
of licensing of ceiling dust removalists, DoFT may still have a role to play in
"professionalising" the industry, for instance, ensuring contractors have
insurance and work to certain standards. WorkCover could license them, along with lead
paint removalists, lead soil removalists and lead contaminated carpet cleaners, but no
steps have yet been taken to do so. Regulations would need to be developed, as they were
to allow licensing of asbestos contractors. Gary Rhyder from WorkCover NSW has commented
"
with the move away from prescriptive legislation to performance based
legislation employers must adopt a risk management approach to safety. This approach
requires employers to develop specific procedures to address risks, and I am advised that
this approach would continue to be preferred by WorkCover." One ceiling dust
contractor who used to be an inspector for the equivalent body to WorkCover in New
Zealand, said that the approach in New Zealand is not so much " leave it up to
the contractor and step in when they do something wrong, but more, lets
train the contractor and tell them how to do it right in the first place." The
EPA is very disinclined to license contractors but the Lead Reference Centre (the lead
policy and lead education section of the NSW EPA) is keen to work with DoFT and TAFE
(Technical and Further Education) to develop training and other requirements for ceiling
dust contractors.
28. Q: What
do government departments do when they need to employ ceiling dust contractors? A: In the
absence of a licensing system, but with the need to set minimum standards for ceiling dust
removal work, various government departments have responded by putting out tenders and
then creating a list of approved contractors for example:
-
The Sydney Aircraft Noise
Insulation Project (SANIP), a federal government project, has resulted in one ceiling dust
removal company being on a list of approved contractors for SANIP work and 5 other ceiling
dust removal companies being sub-contracted by approved contractors on the SANIP list.
-
The Broken Hill Environmental
Lead Centre project (part of the NSW Health Department) has approved of 3 companies to
carry out lead removal work in the lead mining town of Broken Hill but most of the ceiling
dust work is sub-contracted by the three companies, to Nobac Cleaning Pty Ltd.
-
The Hunter Region office of the
NSW Department of Public Works and Services (Hunter DPWS) has accredited 6 companies to
carry out ceiling dust removal work around the lead zinc smelter in Boolaroo, in a
remediation program being managed by the North Lake Macquarie Environmental Health Centre
(part of the NSW Health Department). Hunter DPWS specifies in the contracts, the
procedures to be used for the ceiling dedusting.
Other
government departments are still overcoming the problem, for example:
-
The NSW Roads and Traffic
Authority (RTA) manages the issue of dust escaping from for instance houses being
demolished to build motorways, by following the NSW Government's Environmental Management
Systems Guidelines. The environmental management plan would then be site-specific and the
RTA undertakes to use best environmental practice.
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The federal Department of
Community Services (DoCS) has asked directors of childcare centres to undertake a lead
audit to determine the need for lead remediation activities such as ceiling dust removal,
but it is left up to the childcare centre management to determine an appropriate
contractor.
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The Illawarra Public Health Unit
(part of the NSW Health Department) investigated having HEPA vacs available for people to
borrow to carry out their own ceiling dust removal work around the copper smelter in Port
Kembla. The factsheet Lead Safe: Lead in Ceiling Dust by NSW EPA, advises
"Do-it-yourself ceiling dust removal is not recommended - it's dirty and dangerous
and requires special equipment. Hire a professional." The Illawarra Public Health
Unit (PHU) later decided to allow residents to borrow the industrial HEPA vacs for dust
removal only inside the house and they "recommend" hiring a professional for
removal of ceiling dust.
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The NSW Department of Housing
carried out a lead project in Glebe housing estate including ceiling dust removal, and
will be carrying out such work following the hail damage in south eastern Sydney, but no
contractors have yet been approved in this process.
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Another NSW government
department in charge of renovating Sydney train stations has done what the public does: -
ring up the Lead Advisory Service for referral to contractors on the list developed by the
service.
29. Q: Is
Standards Australia currently writing or planning to write a standard on ceiling dust
removal, including WHEN to remove dust and how to test it? A: Standards Australia is
not currently writing a standard and there is no committee set up to do so. A letter was
sent on 7th June 1999 to ask if a standard was planned but to date a reply has not been
received.
30.
Q: Is there an industry association for ceiling dust removalists and
what does it say about standards and licensing? A: [This answer was revised in
July 2005] Yes, The LEAD Group mentored the development of the Australian Dust Removalists
Association (ADRA) which began in 1999 and was incorporated as an association on
17 November 2000. See www.adra.com.au for their Code
of Practice and Contact Details of Member Companies to find an ADRA member near you. If
there is no ADRA member near you, try to find a contractor who will remove ceiling dust by
looking in the phone book or local newspaper ads and let them know about ADRA so that ADRA
can determine if they comply with the Association's criteria for membership and invite
them to join if compliant. Potential new members of ADRA should contact the Treasurer
Doug Mill on (02) 9415 2077.
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