Paint study

In April 2023, the Ghana Environmental Protection Agency (Ghana EPA), Ghana Standards Authority (GSA) and Environmental Youth Action Network (EYAN) jointly conducted a study with LEEP to determine the lead content of paints available to purchase in Ghana.

The four organisations tested paints manufactured in and imported to Ghana to identify brands non-compliant with the GSA’s lead paint standard, and to indicate the extent to which paint is a source of lead exposure in the country.

The research team bought 59 samples of solvent-based paints, water-based paints, spray paints, and tints (also known as colourants) intended for home use from stores in Accra and Kumasi. They visited 36 hardware and paint stores to ensure all main brands were included. Where available, white, yellow, and red colours from each brand were purchased. If these colours were not available, similar colours were purchased. 

24 brands were purchased in the study. 42 of the samples were from 16 locally manufactured brands and the other 17 were from eight imported brands. Three of the samples were from spray paints, nine were from tints, eight were from water-based paints and the remaining 39 were from solvent-based paints.

All paints were analysed by a laboratory at the University of Wisconsin, USA for lead content based on dry weight using inductively coupled plasma atomic emission spectrometry. The laboratory is accredited by the American Industrial Hygiene Association (AIHA) and it participates in the Environmental Lead Proficiency Analytical Testing program (ELPAT). The laboratory’s analytical methods and certifications are consistent with those recommended by the World Health Organisation for measuring lead in paint.

Results summary

The results showed that six out of the 59 samples (10%) and five of the 24 brands (four locally manufactured and one imported) contained hazardous levels of lead (greater than 90 ppm, the maximum level recommended by the WHO and UNEP). This result shows that Ghana is one of the leaders in its region on lead paint reduction.

Four of the lead paints were solvent-based paints made in Ghana, and two were imported spray paints. Five of the lead paints were yellow colours and the other was a red colour, indicating that lead pigments are likely the source of the lead.

Of the five lead paint brands, our market research found one to be “medium” popularity, and the others to be “low” popularity in Ghana (these are qualitative indicators based on our initial market research). However, the imported spray paint brand appears to have very large total international sales. LEEP has found lead paint from the brand being sold in Ghana, Senegal, Angola, Rwanda and Niger. We estimate that the manufacturer produces 28 million litres per year (although only a proportion of this amount will have been lead paint). 28 million litres is equivalent to LEEP’s current estimate for the total volume of all paint manufactured in Zimbabwe.

Of the paints that did have high lead, they were many times higher than the recommended 90 ppm limit. All of the lead paints had a lead content greater than 600 ppm, and the highest lead content detected was 94,000 ppm, which is over 1,000 times the recommended limit.

Lead content of the 59 samples of solvent-based paints. 90 ppm is the maximum limit recommended by the WHO and UNEP.

A previous paint study in Ghana conducted by IPEN in 2013 found that six out of 18 (33%) samples had greater than 90 ppm lead. Five out of these had more than 600 ppm, and three had more than 10,000 ppm. The highest lead content detected was 42,000 ppm. The 2023 LEEP results are not directly comparable with the 2013 IPEN results, because the majority of the paints sampled were different. The results, however, are suggestive of a general decline in the levels of lead paint in Ghana over the last decade.

Regulation

Current regulation requires all solvent-based paint manufactured in Ghana to have a maximum lead content of 90 ppm. All manufacturers of products made by an industrial process (including paint) in Ghana must obtain a licence from the GSA (Ghana Standards (Certification Mark) Rules 1970, Rule 1). Failure to do so can be punished by a fine or imprisonment (Rule 8). The GSA should only award a licence to manufacturers who comply with Ghana Standards (Ghana Standards Authority Act 2022, Section 35 (1)). In late 2022 the Ghana Standards Authority revised the lead paint limit in Ghana Standard 180:2022 (Paints and Varnishes – Specification for Oil Paint) from 600 ppm to 90 ppm, effective from 14 February 2023 (the date it was gazetted). Taken together, these regulations therefore require that all solvent-based paint manufactured in Ghana should have a maximum lead content of 90 ppm.

The GSA’s work on the new standard was undertaken before LEEP started working in Ghana. The new lead limit in GS 180:2022 complies with the ECOWAS Standard ECOSTAND 092:2022.

The Ghana EPA is currently pursuing further regulation to enforce the 90 ppm limit on lead in paint. Among other things, this will ensure the regulation includes imported paint sold in Ghana, which is not covered by the Ghana Standards (Certification Mark) Rules 1970, and water-based paint, which is not covered by GS 180:2022.

Manfacturer engagement

LEEP has contacted all of the manufacturers of the high lead paints identified in the study. This included making a separate in-person trip to the country where the manufacturer of the imported spray paints is headquartered.

To date, LEEP has received responses from the two largest manufacturers, who together produce four of the six lead paints identified in the study. They report to LEEP that they have reformulated to lead-free paint. LEEP plans to confirm this in follow-up testing.

The manufacturers that report switching to lead-free include the manufacturer of the imported spray paints with an estimated annual international production of 28 million litres. The manufacturer informed LEEP that its paints being sold in some geographic markets (such as Europe) were already entirely lead-free, and that it switched to lead-free for all of its other paints four months after LEEP first contacted it. We are gathering further information to determine to what extent the manufacturer’s switch to lead-free (if correct) can be attributed to LEEP’s advocacy.

LEEP will continue to engage with the two other lead paint manufacturers who have not yet confirmed their transition to lead-free.

Acknowledgements

LEEP thanks the excellent teams at Ghana EPA, GSA and EYAN for their commitment to and partnership on this project.

The Ghana EPA, GSA, EYAN and LEEP teams that carried out the paint study.

Appendix

The following table shows the lead concentrations of the paints tested in the study:

Lead concentrations of paints tested.