Chemical name: Chromic acid (H2CrO4), lead(2+) salt (1:1) Final regulatory action has been taken for the category: Industrial Final regulatory action: The chemical is Severely Restricted Use or uses prohibited by the final regulatory action: Order No 004 effectively prohibits the use of lead chromates as intentional ingredients in paints, and it effectively prohibits the import and manufacture of paints that contain lead chromates as intentional ingredients (as pigments). Order No 004 does not prohibit or restrict any other uses of lead chromates. Use or uses that remain allowed: Any other use of lead chromates, other than those related to their use as ingredients in paints and coatings, remain allowed. However, based on a review of import data, current national usage of lead chromates, are estimated to be minor. The final regulatory action was based on a risk or hazard evaluation: Yes Summary of the final regulatory action: On 21 September 2017, the Ministry of Environment, Nature Protection and Sustainable Development (MINEPDED) promulgated Order No 004, modifying and supplementing the list of chemical substances in Decree No. 2011/2581/PM of August 23, 2011, regulating harmful and/or dangerous chemical substances. Order No 004 added “Paint formulations with a concentration of Lead compounds greater than 90 ppm” to the “List of harmful and/or dangerous chemical products and substances prohibited from manufacturing and importing.” Order No 004 also added “Paint formulations with a concentration of Lead compounds equal to or greater than 90 ppm” to the List of harmful and/or dangerous chemical products and substances subject to prior authorization. This Regulatory Action Severely Restricted the Use of Lead Chromates Whenever lead chromates are intentionally used as pigments in paints, the concentration of lead compounds in the paint product will, almost always, be substantially greater than 1,000 ppm (typically above 10,000 ppm). Order No 004 prohibits the manufacture and import of paints with a concentration of lead compounds greater than 90 ppm. This limit mirrors the limit adopted by the United States and other countries. Its intent is to effectively ban the intentional use of any lead compound as an ingredient in paint, including lead chromates, while permitting the possibility of some, unintentional, de minimis, lead contamination. Order No 004, therefore, effectively prohibits the use of lead chromates as intentional ingredients in paints. See e.g. Toolkit for establishing laws to eliminate lead paint, Paint Basics, Module A-3; Page 14, 2021 Update, Global Alliance to Eliminate Lead Paint, https://wedocs.unep.org/bitstream/handle/20.500.11822/37030/PAINT.pdf?sequence=3&isAllowed=y The reasons for the final regulatory action were relevant to: Human health Summary of known hazards and risks to human health: The report: How Cameroon Decided to Ban Lead Paint. As noted above, a detailed description of Cameroon’s risk evaluation, including background information and references to the studies, findings, and other country experiences that the risk evaluation relied upon can be found in the report: How Cameroon Decided to Ban Lead Paint, which is being submitted together with this Notification. Cameroon’s decision to ban lead paints imposed a severe restriction on lead chromates. When the United States and other countries adopted legally binding limits on the lead content of paint, they did so because of the adverse health effects that are caused by from human exposures to lead from paints that contain lead pigments and/or other leaded ingredients. The U.S.’s first ban on lead paints for home use was based on a 1976 risk evaluation prepared by a committee of the U.S. National Academy of Sciences titled Recommendations for the Prevention of Lead Poisoning in Children. (https://nap.nationalacademies.org/download/18520) The U.S.’ 1976 risk evaluation
The U.S. 1977 decision to impose a 600 ppm limit on the total lead content of paints was designed to prevent the use of lead compounds (including lead chromates) as intentional ingredients in paints. Cameroon’s decision to impose a 90 ppm limit reflects current recommendations based on the wider availability of cleaner raw materials and more precise analytical methods. If a 600 ppm regulatory limit was sufficient for the U.S. to prevent the intentional use of lead chromate pigments in paints sold and used in that country in 1978, a 90 ppm regulatory limit was more than sufficient to prevent the intentional use of lead chromate pigments in paints sold and used in Cameroon after 2017. Evidence of health effects in children of “low-level” Lead Exposures Young children, especially those under six years of age, are particularly vulnerable to lead exposure and lead exposure can cause adverse, irreversible lifelong effects. Even low-level exposures to lead can interfere with a child’s brain development and cause neurological disorders or deficits. These lead to a reduction in the child’s intelligence, learning ability and school performance, and lifelong earnings; and it can also cause increased anti-social behavior and incarceration rates. Exposure to lead early in life can alter gene expression and cause an associated increased risk of disease later in life. There is no level of exposure to lead in children that is known to be without harmful effects. Key references (including references therein): The Joint FAO/WHO Expert Committee on Food Additives (JECFA), Lead (addendum), approved by the Seventy-third meeting, held in Geneva, from 8 to 17 June 2010 (pages 381-497) World Health Organization. (2010). Childhood lead poisoning. Lanphear, B. P., Hornung, R., Khoury, J., Yolton, K., Baghurst, P., Bellinger, D. C., ... & Roberts, R. (2005). Low-level environmental lead exposure and children’s intellectual function: an international pooled analysis. Environmental health perspectives, 113(7), 894-899. Jusko, T. A., Henderson Jr, C. R., Lanphear, B. P., Cory-Slechta, D. A., Parsons, P. J., & Canfield, R. L. (2008). Blood lead concentrations< 10 μg/dL and child intelligence at 6 years of age. Environmental health perspectives, 116(2), 243-248. Bellinger, D. C. (2008). Very low lead exposures and children's neurodevelopment. Current opinion in pediatrics, 20(2), 172-177. U.S. Department Of Health And Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry (2007). Toxicological profile for lead. Gilbert, S. G., & Weiss, B. (2006). A rationale for lowering the blood lead action level from 10 to 2 μg/dL. Neurotoxicology, 27(5), 693-701. Evidence of acute and chronic toxicity of lead Lead is known to cause a wide range of health impacts in both children and adults. At high levels of exposure, lead can severely damage the brain and kidneys in adults or children and ultimately cause death. Other health impacts in children include colic, constipation, anaemia, and depression of the central nervous system that may result in coma, convulsions and death. Additional health impacts in adults include adverse hematological effects such as anemia, altered thyroid hormone levels, weakness in fingers, wrists, or ankles. Lead exposure also causes small increases in blood pressure, particularly in middle-aged and older people. In pregnant women, high levels of exposure to lead may cause miscarriage. High-level exposure in men can damage the organs responsible for sperm production. Key references (including references therein): World Health Organization. (2010). Childhood lead poisoning. U.S. Department Of Health And Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry (2007). Toxicological profile for lead. Toxicological Information. Cameroon’s evaluation of the health risk from exposure to lead from lead paint considered information about lead’s toxicity including:
Evidence of children’s exposure to lead from lead paint Lead paint is a significant source of exposure to lead for children. Painted surfaces weather, wear, and deteriorate over time. When a surface coated with lead paint deteriorates, leadcontaminated dust and paint fragments will be released and enter the nearby indoor and/or outdoor environment. Preparing surfaces coated with lead paint prior to repainting can cause a high risk of exposure. Prior to repainting old painted surfaces, painters often sand or scrape the surface. This releases a high amount of lead dust and paint fragments into the surrounding environment. When a young child plays on the floor (or near ledges) in a home where household dust is contaminated with leaded paint fragments, or when a young child plays outdoors in an area where the soil is contaminated with leaded paint fragments, the child is likely to get some of this contaminated dust or dirt on her or his hands. Children engage in normal hand-to-mouth behavior such as sucking on their hands; eating dust and dirt; putting small objects in their mouths; and/or chewing on a surface. If the dirt on their hands is contaminated with fragments of old lead paint; or it they put a fragment of old lead paint directly into their mouth; or if they chew on a surface coated with old lead paint, they will ingest fragments of old lead paint. And this can happen repeatedly. The lead in the old paint fragments can be absorbed from the child’s gastrointestinal tract and enter their bodily tissues. Gastrointestinal absorption of lead is enhanced in childhood. Up to 50% of ingested lead is absorbed by children, as compared with 10% in adults. Children are also more likely to have nutritional deficiencies that result in increased absorption of lead. Key references (including references therein): U.S. Department Of Health And Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry (2007). Toxicological profile for lead. World Health Organization. (2010). Childhood lead poisoning. Gaitens, J. M., Dixon, S. L., Jacobs, D. E., Nagaraja, J., Strauss, W., Wilson, J. W., & Ashley, P. J. (2009). Exposure of US children to residential dust lead, 1999–2004: I. Housing and demographic factors. Environmental Health Perspectives, 117(3), 461-467. Evidence of exposure to lead from paint in adults, including workers Adults can also be exposed to lead from paint in home environments. In addition, workers can be exposed to lead from lead paint during various stages of its life cycle. A worker, for example, may be exposed to lead during the manufacture of lead paints, or may be exposed from inhalation during spray-painting with lead paints. Workers are also often exposed to lead from lead paint when preparing to repaint an old surface that was previously coated with lead paint, either in a residential or industrial setting. Blando, J. D., Antoine, N., & Lefkowitz, D. (2013).
Lead-based paint awareness, work practices, and compliance during residential construction and renovation. Journal of environmental health, 75(9), 20-27. Virji, M. A., Woskie, S. R., & Pepper, L. D. (2008). Task-based lead exposures and work site characteristics of bridge surface preparation and painting contractors. Journal of occupational and environmental hygiene, 6(2), 99-112. The Potential for Future Lead Exposure in a Substantial Number of Cameroon’s Young Children. The risk evaluation considered the U.S. experience in reaching its conclusion that the continued, widespread sale and use of lead paints in Cameroon would result – in later years – in substantial numbers of Cameroon’s young children being exposed to lead from lead paints. As is discussed in the attached report, How Cameroon Decided to Ban Lead Paint, data contained in the U.S. 2011 American Health Homes Survey provides good evidence that the U.S.’ experience of children’s ongoing exposures to lead from lead paints can be adapted to prevailing conditions in Cameroon and used to demonstrate this. Socioeconomic Considerations The evaluation noted that good, cost-effective substitutes for all leaded paint ingredients are available. It also noted that in the countries that recently banned lead paints, the end-users experienced very little, if any, increase in the cost of the reformulated paints. Conclusions The conclusions that were drawn from the evaluation include:
And more specifically,
Regulatory Action Based on the risk evaluation, the Ministry of Public Health concluded that a ban on lead paints can be achieved at a very low socioeconomic cost, and that no sector of Cameroon’s society will suffer meaningful harm. The Ministry conveyed this conclusion to the Environment Ministry, the Industry Ministry, the President of the National Assembly, and the President of the Republic. Following consultations between the relevant Ministries (Health, Environment, Industry and Trade); the National Standard Agency (ANOR), the Presidents of the National Assembly and the Presidency of the Republic, it was agreed that there was an urgent need to enact a regulatory measure. The Environment Ministry, based on its mandate, promulgated Order No 004 which bans lead paint by limiting the concentration of lead to no more than 90 ppm in all paints manufactured, imported, marketed, and used in Cameroon. Expected effect of the final regulatory action in relation to human health: The expected effect of the final regulatory action is reduced risk to human health, by the avoidance of the human exposures to lead from the lead paints that would, otherwise, continue if lead paints were allowed to be sold and used. Most of the expected beneficial effects will not occur immediately. There is usually a delay of several years between the time a surface is coated with lead paint and the time that fragments of that lead paint accumulate in the surrounding dust and soil, or otherwise become available for ingestion by young children. Date of entry into force of the final regulatory action: 21/09/2017 |