Alliance Preparing Guidance for Laws on Lead in Paint
By IISD’s SDG Knowledge Hub, June 30, 2020
The Global Alliance to Eliminate Lead Paint (Lead Paint Alliance) has published Frequently Asked Questions (FAQs) to support the process of developing laws to address lead in paint. Feedback on the document is being accepted through 3 July 2020.
The document highlights that lead paint is a major source of childhood lead exposure, but more than 100 countries still lack binding legal limits on lead in paint. The FAQs on lead paint are targeted at government representatives, industry, and civil society organizations.
The publication provides information about the Model Law and Guidance for Regulating Lead Paint, which helps countries enact new or modify existing laws to establish a single regulatory limit on the total lead content in paints. It also suggests steps for establishing a lead paint law, based on the experiences of countries that have adopted such laws.
The FAQs detail recommended compliance tools in the Model Law, including:
- requiring manufacturers and importers to have paint tested for lead content by third-party accredited laboratories using internationally recognized test methods;
- requiring manufacturers and importers to provide a declaration of conformity, which demonstrates compliance with a lead paint regulation;
- identifying the government agency with enforcement authority, and detailing enforcement responsibilities; and
- prohibiting paint that exceeds the legal limit, failure to cooperate with government inspections, failure to provide declarations of conformity or providing false declarations, and attempts to influence a third-party laboratory’s test results.
If countries lack a laboratory to conduct accredited, third-party testing, manufacturers and importers can send paint samples to other countries for testing.
The Model Law does not address disposal, but it underscores the importance of ensuring that legal frameworks provide for management and disposal in an environmentally sound manner.
The FAQs also address: the health, environmental, and economic impacts of lead exposure; the reasoning behind setting a lead limit of 90 ppm in paint; non-lead alternatives; paint reformulation costs; timing of lead paint phase-out, including allowing reasonable time for manufacturers to change paint formulations and production processes; paint testing requirements and methods; and disposal.
The Lead Paint Alliance is a voluntary initiative to prevent children’s exposure and minimize occupational exposure to lead paint and to phase out the manufacture, import, and sale of paints containing lead. The UN Environment Programme (UNEP) and the World Health Organization (WHO) act as Co-Secretariats, and the US Environmental Protection Agency (EPA) chairs the Alliance's Advisory Council. As of March 2020, the Alliance had 20 governments, 45 NGOs, six academic institutions and 23 industry organizations as partners.
UNEP is accepting feedback on the FAQs through 3 July 2020. [Lead Paint Alliance Frequently Asked Questions]