To: Boating Industry Association (BIA) Ltd Members
Subject: Industry Feedback Sought – Safe Work Australia Proposed Lead WHS Regulatory Changes
Response Deadline for Member Input to BIA: Friday, 14 August 2026
Executive Summary
Safe Work Australia (SWA) has released a national consultation paper proposing significant revisions to Part 7.2 (Lead) of the model Work Health and Safety (WHS) Regulations.
These proposals aim to align Australian standards with stricter European Union (EU) directives. If adopted, they will lower the thresholds that trigger mandatory medical surveillance, worker removal from job sites and workplace compliance duties.
The BIA is preparing an industry submission to highlight operational realities, costs, and potential workforce disruptions across boat yards, maintenance facilities, refit workshops, and servicing operations. We will be calling for a proportional approach rather than ‘catch all’ and raising other matters such as the issue of availability of health monitoring providers as a practical barrier to the shortened testing window; especially for businesses in regional and remote locations where access to occupational health provides is already limited.
Overview of Key Proposed Changes
- Broadening the Definition of a “Lead Process”
- The Proposal: SWA proposes replacing the narrow list of traditional lead processes with a catch-all definition covering any work activity likely to expose a worker to lead.
- Marine Impact: Common boatyard and maintenance tasks—such as scraping/sanding legacy paints or primers, servicing vessel lead ballast, soldering, handling battery banks, or using laser ablation—could automatically trigger full lead compliance duties (e.g., dedicated washing/changing amenities, strict containment and specialized cleaning protocols).
- Lowering Thresholds for Mandatory Health Monitoring
- The Proposal: Lowering the Blood Lead Level (BLL) defining “Lead Risk Work” from 20 μg/dL20 𝜇g/dL to 10 μg/dL10 𝜇g/dL, or alternatively requiring mandatory health monitoring (baseline and follow-up testing) for all workers undertaking lead-related work. Note: μg/dL𝜇g/dL Stands for micrograms per decilitre and is the standard for reporting blood lead levels.
- Marine Impact: Substantially more shipwrights, boat builders, and those working in maintenance, service and repair would require formal medical surveillance, with employers likely bearing all direct testing and administrative costs. Follow-up testing timeframes may also be shortened from 4 weeks to 2 weeks.
- Halving the Removal Level for Affected Workers
- The Proposal: Lowering the threshold that requires an employer to immediately remove a worker from lead risk tasks from 30 μg/dL30 𝜇g/dL down to 15 μg/dL15 𝜇g/dL (7.5 μg/dL7.5 𝜇g/dL
- for females of reproductive capacity).
- Marine Impact: Halving the removal limit means technicians could be stood down or reassigned much earlier, creating potential delays in refit and repair schedules and key operational bottlenecks.
Member Feedback Request
To ensure our submission accurately represents the recreational marine sector, please share your thoughts on the following:
- Operational Scope: Which activities in your business involve potential lead exposure (e.g., anti-fouling removal, ballast work, soldering, battery handling)?
- Financial & Administrative Burden: What impact would mandatory baseline/regular blood monitoring for relevant workers have on your business operations and costs (this could include the availability of ‘health monitoring providers’ near to you)?
- Workforce Disruption: How would lower worker-removal thresholds affect your yard’s scheduling, workforce availability, and project delivery times; this should include the workforce participation effect if the practical outcome is a barrier to women from areas such as ballast, keel and batter work?
- Practical Guidance vs. Regulation: Would non-regulatory guidance (e.g., marine-specific codes for controlling dust/fumes) be more effective for your workplace than broader regulatory mandates?
How to Provide Input
The SWA Discussion Paper is available HERE.
To support BIA in its Submission on behalf of industry, please send your comments, case studies, or operational data to the BIA Advocacy & Policy team by 5:00 pm, Friday 14 August 2026. If you send your own Submission, please share it with BIA to help ensure consistency across the sector.
- Email: neil@bia.org.au
- Phone: 0418 279 465
