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QUESTION: Does a crane with >1% Pb paint imported from China obey the relevant Australian regulations/law on lead? 07/12/09 Shanghai Province, China, People's Republic of

Dear sire/Ma'am who might concern,

I am engaged in machinery manufacturing in Shanghai China, and I found a crane were applied lead-containing (>1% Pb) topcoat, but which has been shipped to AU. Clearly there was no lead-free requirement in my contract documentation and specifications, but I still worry about whether my product will obey the relevant regulations/law on lead. If it does, how can I perform a reparation in this case? What procedure shall be followed with it?

Best Regards

Wenbo

EMAIL TWO Cc: Stephen Zaluzny, NICNAS Sent: Tuesday, December 08, 2009 8:50 PM

Subject: Does a crane with >1% Pb paint imported from China obey the relevant Australian regulations/law on lead?

Dear Stephen,

Could you please give us some advice in this case hopefully?

We wonder those:

1. Whether AU gov .has a special requirement about the lead-containing paints applied for the imported objects i.e. cranes an other industrial applications? If it does, what regulation should be followed? I just know a AU standard AS 4361.1-1995 Guide to lead paint management-industrial Applications (Lead-containing paint is in excess of 1% by weight of dry film).

2. We have another crane applied lead-containing paints, fortunately we found it before shipping. What methods could be taken to resolve the lead problem? What procedure could be recommended in AU like this case? e.g. total coating removal and replacement, or over coating with a lead-free paint?

You know, we want correct this lead issue even though no special lead-free requirement in our contract. We always behave environmental with our high quality product in the worldwide, thus we need your farther suggestion in this special case.

Your responding is highly appreciated.

Best Regards

Wenbo

EMAIL THREE Sent: Tuesday, December 08, 2009 6:28 PM

Ma'am,

Thank you so much. I am looking forward to hearing your news from Stephen Zalusny soon. You know, I cannot wait to know the detailed regulations on lead in paint in Australia about my case.

Thanks again.

Best Regards

Wenbo

ANSWER: Dec 8 2009

Dear Wenbo,

from my understanding of the new Australian policy on lead compounds in paint, the ban on lead compounds in paint, as of 1st January 2010, does not apply to imported painted objects - it only applies to paint imported or manufactured in Australia. So a lead-painted crane is not covered by the ban as far as I am aware. I am copying this reply to Stephen Zalusny at the National Industrial Chemicals Notification and Assessment Scheme (NICNAS) in case I have a misunderstanding of the ban.

If so, perhaps Stephen would be kind enough to reply to both of us.

Yours Sincerely

Elizabeth O'Brien

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