Lead in Paint
The World Coatings Council is a contributing member of the Lead Paint Alliance (LPA, formerly the Global Alliance to Eliminate Lead Paint), an organization established under the United Nations Environmental Program (UNEP) and the World Health Organization (WHO).
Since its inception in 2010, and with its reorganization in 2015, the LPA has been working to engage national governments, industry and non-governmental organizations in establishing restrictions on lead use in paints that pose public health and environmental risks, especially to children.
The long-standing policy of the World Coatings Council supports the UN’s Lead Paint Alliance “Model Law,” as a useful starting point for both government and industry to collaborate on developing restrictions that ensure widespread and verifiable compliance. The continued advancement of LPA objectives, aided by the publication of the UN Model Law, detailed documentation of current effective restrictions and the Frequently Asked Questions (FAQs), as well as a useful “toolkit” to help policymakers increase awareness and advance required restrictions.
As the LPA continues its efforts to address lead use in paint and coatings, the World Coatings Council also anticipates working with other LPA partners to assist in industry implementation efforts to ensure widespread and verifiable compliance.
Challenges: A Reasonable Lead Standard
As many raw materials for paint come from the earth, it is unlikely that paint formulas can be completely lead-free. However, with careful and selective raw material sourcing, manufacturers can formulate paint at very low levels and in conformity with the 90 ppm — the limit espoused in the UN Model Law.
Paint and coatings that have specialized uses or enhanced performance characteristics may find it more difficult to meet the 90-ppm limit. These products are typically “Industrial” or “Specialty” coatings that are not intended for consumer use. Anti -fouling marine coatings are a good example. These coating systems are applied to ships and offshore structures in both sea and freshwater environments to protect the structure from deterioration. Cuprous oxide (Cu2O) is the active ingredient in the majority of anti-fouling coatings available on the market today. Cuprous oxide is produced from recycled scrap copper that often contains lead (from solder). The World Coatings Council, through its Antifouling Coatings Committee, developed the following advocacy statement that addresses this issue:
Marine anti-fouling coatings are widely used to keep ship hulls free from fouling organisms, such as barnacles, algae, or mollusks. This prevents excessive drag on the hull allowing ships to maintain efficiency and consume less fuel while in motion. (See: International Maritime Organization (IMO) Anti-Fouling Systems). The growth of such organisms also allows the spread of invasive species into sensitive marine ecosystems. (See: IMO Biofouling)
Anti-fouling coatings use a number of soluble pigments, usually minerals and metals to control the properties of the coating. These raw materials are supplied to manufacturers and may contain traces of other substances, such as lead.
Lead should not intentionally be used in marine anti-fouling coatings. However, Cuprous oxide (Cu2O) is used as an active ingredient in the majority of anti-fouling coatings available on the market today. Cuprous oxide is produced from recycled scrap copper that often contains lead (from solder). While the industry is working to develop effective coatings with lower lead levels, these are not widely available. Thus, the level of lead in recycled scrap copper suggests that copper-based marine anti-fouling coatings would not be able to consistently meet a 90-ppm lead limit at this time.
One example of a marine coatings limit is 600 ppm total lead (See “Performance Specification: Paint System, Anticorrosive and Antifouling, Ship Hull“, U.S. Department of Defense, April 9, 2013). In addition, the European Union (EU) evaluated and approved a limit of 1200 ppm residual lead contamination in cuprous oxide which often comprises less than 50% by weight in marine antifouling coatings, generally resulting in less than 600 ppm lead in the marine anti-fouling coating.
This statement was accepted and supported by the United Nations Environment Programme (UNEP) and the UN Lead Paint Alliance. It is available on the UNEP website under “Answers to Questions about Lead Paint and Lead Paint Laws (FAQs).“ This FAQ can be viewed as a template for addressing other coatings categories that may not be able to reach 90ppm for technical reasons.
Other elements of the Model Law contain compliance mechanisms such as test methods and a reasonable conformity assessment.
The World Coatings Council supports current efforts of the LPA to assist in the expansion of the number of regions or countries in restricting lead use in paint by virtue of a universal, consistent and reasonable model regulation with reasonable compliance mechanisms.
For more information on the LPA and efforts to seek restrictions on decorative paints see: