A message from the Marina Industries Association (MIA).
Safe Work Australia (SWA) has released a national consultation paper, Protecting workers from exposure to lead (July 2026), proposing significant changes to Part 7.2 (Lead) of the model Work Health and Safety (WHS) Regulations. The proposals are directly relevant to marina, boatyard and shipyard operators whose businesses undertake vessel refit, repair and maintenance, and the MIA has prepared a submission on behalf of industry.
What is being proposed
The consultation paper canvasses three main areas of change. In each case SWA sets out options ranging from prescriptive regulation through to supporting guidance:
A broader definition of “lead process”. SWA proposes replacing the current list of defined lead processes with a wider “catch-all” covering any activity reasonably likely to expose a worker to lead. For marine businesses, common tasks such as removing legacy antifouling and topside coatings, servicing lead ballast, soldering and handling battery banks could be drawn into the definition.
Lower thresholds for mandatory health monitoring. Options include reducing the blood lead level that defines “lead risk work”, or requiring baseline and follow-up blood testing for all workers undertaking lead work. The follow-up testing window may also be shortened from about one month to two weeks.
Reduced action and removal levels. The blood lead levels that trigger early action, or that require a worker to be removed from lead risk tasks, may be lowered – with a lower level again for females of reproductive capacity.
The MIA position
The MIA strongly supports SWA’s objective of protecting workers from the harmful effects of lead, and acknowledges that lead is a hazardous substance with no known safe level of exposure. MIA say their central concern is that the regulatory response be calibrated to actual risk. Occupational lead exposure in the marina, boatyard and shipyard sector has reduced significantly over recent decades and continues to decline, and the response should reflect that reduced and declining risk.
In summary, the MIA’s submission takes the following positions:
MIA support broadening the definition of lead process (Option 1(a)) on the express condition that a clear, indicative list of lead processes is retained and supported by marine-specific guidance. They say they do not support removing the list entirely.
MIA support guidance to help duty holders assess when health monitoring is required, but do not support mandatory health monitoring for all workers undertaking lead work. Any reduction in the blood lead level defining lead risk work should be introduced only on a staged transition.
Where action or removal levels are reduced, MIA recommend a staged transition matching the European Union timeline (to 2028–2029) rather than an abrupt change.
Across all three issues, the MIA’s clear preference is for a proportionate, risk-based and guidance-led response, and MIA have offered to co-develop marine-specific guidance with Safe Work Australia.
Why this matters for members
The reduction in lead exposure across the sector has been driven by the transition away from lead-based marine coatings, the broader environmental phase-down of lead, and the routine use of modern controls such as containment, wet methods, local exhaust ventilation, HEPA cleaning and personal protective equipment. Lead-based paints were fully abolished in 2010 following a staged phase-down that began in 1965, and the legacy-coating exposure pathway continues to diminish with each refit cycle.
A response that is too broadly framed risks imposing significant cost and administrative burden on marina, boatyard and shipyard businesses – the overwhelming majority of which are small enterprises in regional and coastal communities – without a corresponding safety benefit. Access to occupational health physicians, occupational hygienists and pathology services is already limited in many regional and remote locations, making a universal monitoring mandate and a shortened testing window impractical for members a considerable distance from the nearest provider.
Have your say
The MIA welcomes member input on our draft submission. If you would like to review the MIA draft or offer any comments, please send these to Chris Stone at by Wednesday 19 August 2026.
Members are also welcome to lodge their own submission directly with Safe Work Australia. The consultation paper and survey are available on the SWA Consultation Hub.
Read the SWA paper & make a submission
Read the MIA’s Proposed Submission
