Document qdV3m1OwnBDOr5nKEzQv0LNZx
LABOUR OFFICE
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INTERLAB GENEVE
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Dear DV;. Kehoe>
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Tfrhaannk you ;fpi\youn letter of 22 October concerning legislation ' :
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. The question pft&e use of lead-containing paints for the internal i i painting of'buildings; has: been a matter for international`.regulation
since 1921,.when the Yfrite Lead (Painting) Convention wasadopted' by the,
W.5
International iLdbodr 'Conference* . This Convention prohibits`the use. of white lead and sulphate of lead and-all products containing these, pigments
in the internal'painting of buildings, with certain exceptions;MTThe,most
important exception is that the; use`of white pigments containing a v
maximum"of `2 per cent, of'lead expressed; in terms of metallic lead; is ,
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permitted. ,Although this Convention only covers the use of white lead and sulphate of lead and therefore leaves open the possibility of the, use of other lead colours, the use of lead paint in the internal paintingMf buildings has been practically abolished in the countries which have .. . ratified the Convention. In certain countries, the legislation specific
ally extends the prohibition to all lead-containing paints.
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~ Since 1921, when this Convention was adopted; a considerable amount;.
of legislation has been enacted in the twenty-seven countries whioh have':,
ratified the Convention and also in many .other countries. There is no
documentation in the Office on the existence of more extensive provisions
than those contained in the Convention, but as the primary concern of the
Office with regard to Conventions is to. survey the compliance of national
legislation with the Convention, the, existence of such provisions is not
excluded. . -.7' /
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7,. ;.
, As far as I know, there is no Australian Commonwealth legislation in
existence in this field.and we have no documentation on existing or pro
posed. State legislation.. However, I am endeavouring to collect such l
information for you.
i
, In'order to provide you without delay with .basic documentation, I am
sending you under separate cover the study "White Lead", published by the
Office in 1927. This study contains the text of the Convention on pages
404 - 405. I am also forwarding under separate cover a number of laws
and regulations published in the Legislative Series, as per the attached
list.-
-tv . v
..
r . Robert A. Kehoe, University of Cincinnati, The Kettering Laboratory, ' College /of Medicine, ! Bden Avenue,
2
I am further enclosing a complete list of relevant legislation in oountries which have sent in reports on the application of the Convention, as well as the legislation of certain other countries.
Finally, I am. sending you herewith an extract from a report on the application of the Convention which shows the situation in countries which have not ratified the Convention,
With regard to recent legislation, I am endeavouring to obtain relevant documentation and will transmit information to you as it becomes available. Please let me know if there are specific details or aspects on which you would like to receive existing legislation.
With kind regards. Yours sincerely.
Aage Grut Chief of the Industrial Hygiene Division
KB 98?r00
oop<J5-(,
P Legislative Series
Argentine Australia Austria Belguim
Bulgaria Chile Cuba
1924 -- Arg. 1
Germany
1925 -- 1931 --
1932 --
1923 1928 1947
1926 1927 1927 1928 1980 1940
-- r --
--
-
Austral. 1 Austral. 5 Austral. 3
Aus. 1 Aus. 1 Aus. 3
United Kingdom
Greece
Bel. 2
Bel. 7 Bel. 9
India
Bel. 0 Bel. 3
Mexico
Bel. '2"''MAwngs'Morocco
1920 -- Ger 4-6 1921 -- Ger. 1 1930 -- Ger. 4
1926 -- G -B .11 1927 -- G.B. 4
193^ -- Gr. 2 1937 -- Gr. 1 1938 -- Gr. 4 1937 - Ind. 5 ex h au s t **
1931 - Mex. 1
1931 -- Mor. 2
1932 -- Bulg. 2
1932
Bulg. 3
Netherlands 1933 - Neth. 4
193^
Neth. 2.
1926 - Chile 2
1927
Chile 2-.
1931 - Chile 1
1934 - Cuba 13
1935
Cuba 8
Norway Poland
1929 - Nor. 1
1927 1930
1935
Pol. 7 Pol. 0 Pol. 4
CzechoslavkjLa 1924 - Cz. 1
Finland
1927
Fin. 1
1929 -- Fin. 1
France
1930
Fr. 13
193^ -- Fr. 9
Rumania
1930 - Rum. 2
1933
Rum. 2
Spain Sweden
1931 mm Sp. 4 -
1926 mm Swe. 1 1949 mm Swe. 5
Switzerland 1942 - Switz. 2
4. Venezuela 1945 _ Ven. 1 1947 - Ven 2
Uruguay
1937 -- Ur. l,*or pu l :::!ed
KIT 0012387
N15307.01
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13. White Lead (Painting) Convention, 1921
101
13. Convention concerning the use of white lead in painting This Convention came into force on 31 August 1923
Countries
Date of
registration of ratification
Reports received
Afghanistan
Argentina
Austria Belgium
Bulgaria Chile
Colombia . Cuba Czechoslovakia Estonia Finland France Greece Hungary1
Latvia Luxembourg
Mexico Netherlands
Nicaragua Norway Poland Rumania Spain Sweden Uruguay Venezuela Yugoslavia
12. 6.1939 26. 5.1936 28. 1.1949 12. 6.1924 7.12.1948 19. 7.1926 29.11.1948
6. 3.1925 15. 9.1925 2. 4.1949
20. 6.1933 7. 7.1928 30. 3.1949
31. 8.1923 26.12.1948 8. 9.1922 6. 4.1929 26.10.-1948
19. 2.1926 -9.12.1948 22.12.1926 4. 1.1949
4. 1.1928 9. 9.1924
16. 4.1928 19.11.1948 7. 1.1938 3.12.1948
15.12.1939 27.12.1948 12. 4.1934
11. 6.1929 3. 2.1949 21. 6.1924 13.12.1948
4.12.1925 20. 6.1924 27.11.1923 2.12.1948
6. 6.1933 23.12.1948 28. 4.1933 30. 9.1929
* Conditional ratification registered.
Lis t o p Le g is l a t io n a n d Ad min is t r a t iv e Re g u l a t io n s , e t c .
Argentina.
Act No. 9,688 of 11 October 1915 concerning industrial accidents.
Act No. 11,317 of 30 September 1925 regulating the employment of women and young persons (L.S. 1924, Arg. 1).
Decree of 11 July 1927 concerning prohibition of the use of white lead in the agencies subordi-
' 'nated to the Ministry of Public Works. ", Municipal Order of 30 December 1927 (Buenos
Aires), prohibiting the manufacture, sale and use of paints with a lead base.
Austria.
/
* Order of 8 March 1923 issued under 74 (a) of
the Industrial Code and issuing regulations
for the protection of the life and health of
; persons employed in painting, varnishing and
decorating carried on by way of trade (L.S.
1923, Aus. 1 D).
/
Order of 4 February 1928 of the-Minister of
Social Affairs respecting' the notification of
bases of lead poisoning'due to painting work
in building, varnishing and artistic painting
(L.S. 1928, Aus. 1).
Federal Act of 3 July 1947 respecting labour
. inspection. /'
Belgium. /
. Act of, 30 March 1926 concerning the use of white lead and other pigments containing lead (L.S. 1926, Bel. 2 A).
Act of 24 July 1927 concerning compensation r/ for injury caused by occupational diseases
(L.S. 1927, Bel. 7).
Royal Order of 16 September 1926 to regulate the purchase, sale, transport and use of white lead and other white compounds containing lead intended for trade purposes (L.S. 1926, Bel. 2 B).
Ministerial Order of 16 September 1926 in pur suance of 2, 4, 5 and 7 of the Royal Order to regulate the purchase, sale, transport and use of white lead and other white compounds containing lead (L.S. 1926, Bel. 2 D).
Royal Order of 17 September 1926 concerning the use in painting of white lead, other white pigments containing lead and white pigments the lead content of which in the metallic state exceeds 2 per cent. (L.S. 1926, Bel. 2 C).
Royal Order of 15 November 1927 to supplement the Royal Order of 16 September 1926 to regulate the purchase, sale, transport and use of white lead and other white compounds containing lead intended for trade purposes (L.S. 1927, Bel. 9).
Royal Order of 31 October 1928 prohibiting the employment of young persons under eighteen years of age and women in painting work involving the use of white lead and other white lead pigments (L.S. 1928, Bel. 6).
Royal Order of 14 April 1930 laying down special Regulations for the application of paint by the compressed-air spraying gun or pneu matic painting (L.S. 1930, Bel. 3).
General Regulations of 11 February 1946, relating to the protection of workers.
Chile.
Decree of 30 April 1926 to approve the Regu lations respecting industrial hygiene and safety (L.S. 1926, Chile 2).
Regulations of 21 April 1927 respecting occupa tional diseases (L.S. 1927, Chile 2).
Legislative Decree No. 178 of 13 May 1931 to ratify the Labour Code (L.S. 1931, Chile 1).
Decree No. 655 of 25 November 1940 ( 234 and 245) to issue new Regulations concerning industrial hygiene and safety.
Cuba.
Legislative Decree No. 215 of 16 May 1934 to prohibit the use of white lead in painting (L.S. 1934, Cuba 13).
Legislative Decree No. 105 of 25 July 1935, amending the above Decree (L.S. 1935, Cuba 8).
Finland.
Act of 1 March 1929 prohibiting the use of white lead and sulphate of lead in certain kinds of painting (L.S. 1929, Fin. 1 A).
Order of 1 March 1929 concerning the implement ing of the Convention.
Decision of the Ministry of Social Affairs dated 22 June 1929 laying down detailed provisions concerning the use of white lead in painting (L.S. 1929, Fin. 1 B).
Resolution of the Council of State of 14 March 1919 specifying the trades and branches thereof which must be deemed to be specially dangerous, and issuing detailed Regulations concerning the employments liable to injure the health of children and young persons or, to hinder their physical development (L.S. 1924, Fin. 6, Appendix 1).
; Sanitary Regulations of 24 September 1929 for
workers emnloved irt rm.int.infr work in wtiink
CD GO QO
N15307.
the use of white lead, sulphate of lead and products containing those pigments is neces sary. Factory Inspection Act of 4 March 1927 (L.S. 1927, Fin. 1). Decision of the Council of State of 4 March 1927 concerning the application of the above Act.
France.
Decree of 10 July 19-13, as amended, respecting general protective and hygiene measures applying to all undertakings concerned (Ar ticle 8a, 8b, 8c).
Decree of 8 August 1930 respecting the use of white lead and sulphate of lead in painting work (L.S. 1930, Fr. 13 B).
Order of 4 December 1934, in pursuance of the Decree of 8 August 1930, to determine the text of the notice pointing out the dangers of lead poisoning and the measures to be taken to avoid them.
Order of 4 December 1934 to determine the text of the recommendations for the medical examinations made in pursuance of the Decree of 8 August 1930.
Order of 23 July 1947, as amended on 31 July 1948, to determine the conditions under which showers must be provided for personnel engaged in unhealthy or unclean work.
Decree of 23 August 1947 respecting special measures in regard to the protection of workers engaged in painting or varnishing by means of spraying (Title I).
Act No. 48-1106 of 10 July 1948 concerning the sale and the use of noxious substances in industrial operations, superseding the provi sions of Chapter IV ( 78 to 80) of Book II of the Labour Code concerning special provi sions for the use of lead compounds in painting work.
Greece.
Royal Decree of 17 December 1921 respecting the prohibition of the use of white lead, red lead, litharge and of all other compounds of these oxides in the painting of buildings, ships, etc. (L.S. 1921, Gr. 2 B).
Act No. 2654 of 6 August 1921 respecting the prohibition of the use of white lead, red lead and litharge in the building industry and other work (L.S. 1921, Gr..2 A).
Ministerial Order No. 7059 of 1922 exempting certain products from the prohibitions pro vided for in Act No. 2654.
Act No. 2994 for the ratification of the interna tional Convention concerning the use of white lead in painting.
Act No. 6011 of 29 January 1934 (promulgated on 6 February 1934) to amend Act No. 2654 (L.S. 1934, Gr. 2).
Act No. 6080 of 1934 respecting the prohibition of certain organic colouring matters.
Luxembourg.
Act of 5 March 1928 approving the Conventions adopted by the International Labour Confe rence in the course of its first ten sessions (1919-1927).
Mexico.
Political Constitution of the United States of Mexico of 1917.
Federal Labour Act of 18 August 1931 (L.S. 1931, Mex. 1).
Regulations of 24 October 1934 concerning industrial hygiene.
Netherlands.
Decree of 25 September 1933 (L.S. 1933, Neth. 4) to promulgate the text of the Labour Decree of 1920 (L.S. 1920, Neth. 8), as last amended by the Royal Decree of 12 July 1933.
Nonuay.
A ! of 24 May 1929 partially prohibiting the use of white leads, etc., in painting (L.S. 1929 Nor. 1).
Royal Decree of 6 December 1929 concerning t he putting into force of the above Act.
Regulations concerning the use of white lead, etc., in painting, issued under 6 of the Act of 24 May 1929.
Poland.
Decree of the President of the Republic of 30 June 1927 concerning the manufacture, importation and uso of white lead, sulphate of lead and all other lead compounds (L.S.
. 1927, Pol. 7). Ministerial Decree of 13 September 1930 con
cerning the health and safety measures which are obligatory in the preparation of paints and pastes containing white lead, etc., and in painting work involving the use of such paints and pastes (L.S. 1930, Pol. 6). Order of the Minister of Social Welfare, dated 3 October 1935, in agreement with the Minis ters of Industry and Commerce, the Interior, War, Finance, Agriculture and Agrarian Reform, Communications and Posts and Tele graphs, respecting the occupations prohibited for young persons and women (L.S. 1935, Pol. 4). Ministerial Decree of 25 November 1937 relating to conditions for the manufacture and appli cation of lead.
Sweden.
Workers' Protection Act of 29 June 1912 (B.B., 1913, Vol. VIII, p. 84).
Act of 19 February 1926 to prohibit in certain cases the employment of workers in painting work in which lead colours are used (L.S. 1926, Swe. 1).
Decree of the Royal Department of Labour and Social Welfare of 30 June 1926 concerning the form to be used for reports on cases of lead poisoning in the painting industry.
Royal Decree of 10 December 1926 concerning the payment of the expense of medical exa mination of working painters, examined in accordance with the above-mentioned Act.
Uruguay.
Resolution dated 3 March 1937 to regulate the use and manipulation of lead and its deriva tives with a view to reducing lead poisoning (L.S. 1937, Ur. 1).
Argentina. There are no new develop ments report for the period under review.
Copies <$ the report have been communi cated to the'General Confederation of Labour and the Argentine Association of Production, Industry and Commerce.
Austria. The revert repeats the infor mation previously giVen. Statistical data on occupational disease were submitted to the Office.
Copies of the report hav&vbeen commu nicated to the Federal ChambeSpf Industry, the Austrian Chamber of Labour and the Austrian Federation of Trade
Belgium. There are no cases for ^hich the use of white lead, sulphate o'f leadysqr <a*hir -produoto-'oenta^ni-ng thooo 1 pigrmynro
HdeB/AMcD
-Additions to list of legislation concerning the use of white lead
ALGERIA
Order relating to the prohibition of the use of whit lead, sulphate of lead and linseed oil containing lead in the painting of buildings. Dated 24 March 1950.
AUSTRALIA - New South Wales
Lead Regulations under the Factories and. Shops
Act, 1912-1948. Dated $
1950.
BULGARIA Act of 1917 respecting the health and safety of workers, as amended. (L.S. 1952, Bulg.3)
Order No. 15599 of 80 September 1952, laying down the measures to be taken for the handling and the use of lead and its compounds and alloys in trades
and factories and in industrial establishments and undertakings (L.S. 1952, Bulg. 2 0)
Order No. 13.600 of 20 September 1932 prohibiting the use of white lead and sulphate of lead in certain painting operations (L.S. 1932, Bulg. 2 A)
CANADA - Alberta
Regulations relating to the use of lead and benzol and of mercury, 1941.
Manitoba;
Regulations relating to the use of lead and. benzol. Dated 6 May 1941, amended in 1947.
Ontario:
Regulations 80/46 concerning the use of lead and benzol, 1946.
NSW ZEALAND
Lead Process Regulations, 1950-
o0oi] 2 3 o i)
N15307.03
2
CZECHOSLOVAKIA
Act of 12 June 1924 issuing regulations for the protection of the life and health of persons employed in painting, varnishing and decorating (L.S. 1924, Cz. 1).
Government Order No. 41 of 1938 concerning provisions for the protection of the health and safety of unskilled workers.
EGYPT
Ministerial Order of l4 May 1953- concerning the protection of workers against occupational diseases caused by lead or its compounds.
FRANCE
Decree No. 48.-1901 of 11 December 1948 to issue public administrative regulations concerning special measures of hygiene, applicable in undertakings in which persons are exposed to the risk of lead poisoning.
Order of 12 December 1948, in pursuance of the Decree No. 48-1901, fixing the text of the notice pointing out the dangers of lead poisoning and the precautions to be taken to avoid them.
Order of 12 December 1948, establishing the list of industrial employmentsi covered'by Decree No. 48-1901 of 11 December 1^48.
Order of 12 December 1948, establishing the text of the instructions for raedica.1 examinations carried out in virtue of Decree 48-1901 of 11 December 1948.
Decree No.48-2034 of ~j>0 December 1948, to issue public administrative regulations concerning the prohibition of the use of white lead, sulphate of lead and linseed oil with a lead content in the painting of buildings.
FRENCH EQUATORIAL AFRICA
Order No. 2813 to prohibit the use of white lead and sulphate of lead in painting, 1951
HE 0012331
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K2 E-3E.LAKDS
Act ot 2 July 1934, to Is;:cue safety provisions the oerformance ,)f work in general end safety in factories and workplaces in particular (L.S. 1934> Neth.8)
for
Order of 8 August l>p>' > to issue public asniuiBtrative regulations concerning safety .ceacures for work involving the use of white lead.
8 v/SDlSN
Aoyal notification (No.210) of 6 hay I949, to prohibit the employraent of workers in painting operations with lead colours.
.loyal Notification (No. 11) of o ,,,ay Igig, concerning the medical examination for the prevention of certain occupational diseases (including lead poisoning) (L.S; 13^9, Sue.p).
hoyal Notification of 0 hay 1949 (No. 218) concerning reimbursement for nedlcal examination for ths prevention of certain occupational fiseases
7LN1ZUNLA
Labour Act of 21 October 1947 (L.d . ly'+J, 'fen.2), to amend the Act of lb July Igpo (L.S. Igpb, hen.2) as amended in 1945 (L.S. 1945, Ven.l) .
KC 00129S2
Convention (?^i0 13) concerning the U3e of white lead In painting', 1Q21
In a certain number of countries, which have not ratified the Convention, certain legislative provisions exist for the protection of the workers, or certain categories of workers, against some of the risks of lead poisoning in painting.
In the German Federal Republic the protection of painter workers against lead poisoning is dealt with by an Order of 27 May 1930. The Order is in accordance with the Convention, since the period for which exceptions were allowed has elapsed. In 'ew Zealand regulations under the Health Act I92O and the Factories Act 19^6 provide for the protection of persons employed in lead processes (Lead Process Regulations, 195). The provisions of the Articles 1, 5 I) 5 Til (s.) and 7 of the Convention are not covered by the Regulations. Article 3 of the Convention is covered by s. 3^ of the Factories Act, 19^6. Switzerland possesses in the Order respecting the prevention of lead poisoning in the manufacture and use of paint of 19 May lb42 rsgulat&ons for the protection of workers against this poisoning. The notification of cases of lead poisoning la required under the accident insurance orders*
However, the provision of Article 7 of the Convention, concerning statistics with regard to lead poisoning among working painters is not covered by the Regulations.
K? 001
N15307.04
'U-
In th Unitsa Kingdom the Lead taint (Protection Ag&inot poisoning) Act, 1925 and the Lend ?aiat Acgulntione, 1517 under this Act, rank provisions for the protection against; lead.... poisoning, The Act specifies that section 66 of the factories Act, 1937*`concerning the notification of occupational diseases (including load poisoning) applies to persona employed In painting buildings. Hie term "young persons" used in the Lead faint (Protection Against Poisoning} Act, 1925 means, according to section 152 of the factories Act, 1937# persons over l*r years hut not older than 18 years. However, c o bs provisions of the head Paint Regulations do not apply to persons who are occasionally employed in or in connection with painting of buildings for m aggregate period not exceeding c5 normal working days in a calendar year and vhests ordinary employment dose not include the painting of buildings, Chis exception la not foreseen in the Convention.
In Indonesia, the 'V.hlte Lsad Ordinance, Ho. 509 of 21 December 1931 deCU with the protection against the dangers resulting from the use of whits lead as a raw material, but the legislation is not sufficient to allow ratification of the Convention.
iith regard to the specific provisions of the Convention, one or more of these provisions are found in the legislation of several countries.
0012304
Various approaches have boon made In the sense of /*rt. 3 (1) of t'no convention* rtthe employment of tmlas under eighteen years 02* ago and or all women shall bo prohibited in any painting wat of an Indus trial character involving the use of white lead or sulphate ot lead or other products containing these pigments*'.
In Drasll,this provision Is applied under the even stricter regulation, which prohibits the employment of young persons under 10 yearn of age and of women on work with load 02' its compounds.
In Ecuador, male young persons under the age of 15 years and girls and women may not be employed in the manufacture of white lead, red load and other poisonous pigments, and also the handling of paint, enamel or varnish containing salts of load or arsenic.
Various countries (Burma, Bgypt, India, Italy and nyria) prohibit the employment of women and young persons in the manu facture of lead compounds, but the prohibition is not extended to the use of these substances in painting.
In Portugal, certain operations with white lead are prohi bited for women? they do not, however, include painting. The em ployment of boys under 16 and of girls under 13 years lo prohi bited for work with risks from lead. In Ireland, young persons under 13 nay not be employed in operations involving the risk of lead poisoning.
0012395
In cic&ragua, young persons under 1*3 r not be employed in industrial painting work in which toxic rs&teriala or products are used, while women are excluded from employment in work specified as dangerous for their physical welfare.
In other countries a general clause prohibits the employ ment of young persons under IS and of women in work that is declared unhealthy. This is the case in Albania, Bolivia, Costa Kica, Japan and Turkey; a similar provision for persons under 1j and for women exists In Guatemala end Panama.
article 5 II (b) of the Convention, concerning overalls to be worn by painters during the whole of the working period is covered in a general way by the factory legislation in Albania and Brasil, while the latter country prescribes measures for cloakrooms with individual lockers for clothes not wra during work and for washing facilities, (Article 5 II to) and 5 II (a) of the Convention).
The provision', of Article 3 III (a) is satisfied In those countries where lead poisoning is taken up in the list of notifiable occupational diseases. This is ths case, in addition to the countries which ratified the Convention. to the satis faction of the Committee of Experts, in Brasil, Ceylon, the German federal Republic, India, Iraq, Pakistan, Switzerland the United Kingdom and in various states and provinces of Australia, Canada and the United States.
0012396
The provision of Article 3 III (b) concerning the medical examination or worker* on request of the competent Authority, is found In nany countries as a condition of employment in unhealthy occupations, or is covered by compulsory periodical medical examination of all workers, or of certain categories of workers, in which workers exposed to the risk of lead poisoning generally are included.
Particular difficulties for ratification of the Convention are found in Australia, Canada and the united States , where the matter of health protection comas in the jurisdiction of the constituent states or provinces. Several of these etatee and provinces possess regulations concerning the use of whits lead in. painting.
syyscT aivm t o is s c tassavA?io?ig
IW ilnaror*\Y
The Government Repreeentatlve of Afghanistan stated that appropriate provisions for the application of the Convention are to be included in the labour and Employment Act, which is in preparation. A Government Representative of Argentina stated that the situation in hln country vias due to the federal type of Government, but that as a result of the recent revision of the Constitution it was possible to take the necessary legisla tive measures.
r 0022397
<*
9
The Government or Mexico declared that detailed regulations were in preparation. In various reports the Government indicated that thee regulations were declared unconstitutional, and that new regulations are being drafted, but that the Convention as ratified had, in any ease, fore of lav under the Constitution. As regards Article 5 HI (&), the Government of Uruguay explained that medical examination of cases of lead poisoning srre carried out by the National Insurance Bank, end that necessary steps will be taken for periodical examination.
K? 0012398
<laiven
Afghanistan
Argentina Austria Belgium ByXg&ria Chile Colombia Cuba C a echpalovakla Estonia
- inland franco =Are sea Hungary0
Latvia .Uixeiilbourg iaxlee .""Otlierl&ndo Nicaragua lorw&y Aol&nd Rumania bpain Afscien Uruguay Aanssaiela
'Jugoslavia
12.6.1939
26.5.1936
12.6.1924
19.7-1926 6.3.1925 15.9.1925 20.6.1953
7 *? n 0*3i"! ( * t .c ^g As 31.0.1921
0.3.1922
5.A.lOpo
'74 0 * -A Jn*. r5-, CX-O 22*12.12^6
/'" t' a *A1. *Jj*^y ** Cf%5 9.9.1921 16.4.192a
7.1.1938
13.12.1939 19.A.1934 II.6.1919 21.6.1924
4.12.192? '0.6.1924 27.1: 0J'0.7j v.O j^J CO h It'?-'
50. -329 :.:
l5 t'7