June 30, 2022

OSHA to Revise Lead Standards

An advance notice of proposed rulemaking (ANPRM) published by OSHA on Tuesday begins the rulemaking process for the agency to revise its standards for occupational exposure to lead. OSHA’s ANPRM stems from recent medical research findings that adverse health effects in adults can occur at lower blood lead levels than those required by the agency’s current standards. Under current OSHA lead standards, the medical removal level is ≥60 µg/dL in general industry and ≥50 µg/dL in construction, and the blood lead level required for an employee to return to lead-exposed work after being medically removed is <40 µg/dL. A discussion of the health effects of lead exposure in the Federal Register notice announcing the ANPRM states that blood lead levels as low as 5 µg/dL “have been associated with impaired kidney and reproductive function, high blood pressure, and cognitive effects attributed to prenatal exposure.” Research has also shown that adults with blood lead levels of 5-19 µg/dL performed more poorly on neurocognitive and neuropsychologic assessments than adults with levels below 5 µg/dL.

OSHA’s ANPRM seeks input from the public and stakeholders on reducing the current blood lead level triggers in the medical removal protection and medical surveillance provisions of its current lead standards for general industry and construction. The agency is also asking for comments related to how current ancillary provisions in the standards could be modified to reduce workers’ blood lead levels. Another area OSHA seeks input on is whether it should consider reducing its current permissible exposure limit of 50 µg/m3 of lead over an eight-hour time-weighted average or its action level of 30 µg/m3. The PEL was established in 1978 with the adoption of OSHA’s lead standard for general industry.

Comments on OSHA’s ANPRM are due by Aug. 29. Further details about the ANPRM can be found in the agency’s press release, and instructions for submitting comments can be found in the Federal Register.