Ask the Expert Question-and-Answer Archive

by Ron Joseph

May, 2001

Regulations Covering Lead Content in Paint

Q. I work in the library for the Fabricators and Manufacturers Association. A member is looking for information on the reporting responsibilities and regulations that would be involved if they supply a customer with paint with a lead content that is more than .06%. This member is involved with coil coating. Before he makes a committment to his customer, he wants to know what kinds of reporting activities will be required and what agencies he might be reporting to. He has tried to find this information from his paint vendors and from various EPA websites, but has found no answers. Can you tell me what agencies or associations or magazines that may be able to help with providing an answer? I have tried some searching on the web and industry magazines. Some contacts have not responded. If you know of any person or agency or if you have handled this type of inquiry before, I would very much appreciate being able to give him a lead. Thank you for your time and effort in this matter.

A. Thanks for your question. Unfortunately, I can only give you some background, but not help you completely. To the best of my knowledge in the late 1970's, I think 1979 to be precise, OSHA published some guidelines concerning the lead content in paints. I worked for a corporation that chose to essentially eliminate lead as a pigment in its coatings. The major reason for going to so-called lead-free pigments was to protect our painters from potential lead poisoning. At much the same time, OSHA also chose this low value to protect consumers, especially those who apply architectural paints to their homes. As you well know, many babies and small children, especially those who live in old apartments on the East Coast are known to have lead in their systems, even though the new paints are essentially, if not totally lead-free.

With regard to reporting requirements, again to the best of my knowledge these are provided on the MSDS of the paints themselves. I have not heard of reporting requirements for finished products, but that does not mean that there are none.

Here are some things you might pursue:

All of the large paint manufacturers, such as Sherwin-Williams, PPG, DuPont, etc. have health, safety and environmental departments that keep abreast of these issues. Sherwin-Williams is headquartered in Cleveland, OH and their research labs are in the A.W. Steudel Center in South Chicago. PPG is in Pittsburgh, PA, and DuPont is in the Philadelphia area.

As far as OSHA is concerned, I believe you would be looking for regulations that go back to the late 1970s or early 1980s. Since these predate the Internet it is possible that you won't find them on the web.

Finally, there are dozens of industrial hygiene, safety and toxicology consultants listed on the web who might be able to assist you further.

When you get the answers to your questions can you PLEASE send them to me so that everyone who comes to this site can benefit from your research.

Thanks in advance, and I hope this will help you.

Best wishes,