March 16, 2023

Cal/OSHA Proposes Revisions to Lead Standards

California’s Occupational Safety and Health Standards Board, the standards-setting agency within Cal/OSHA, has proposed regulations to lower the action level and permissible exposure limit for airborne lead in construction and general industry. The agency proposes to lower the action level from 30 µg/m3 as an eight-hour time-weighted average to 2 µg/m3 as an eight-hour TWA, and to lower the PEL for lead, calculated as an eight-hour TWA, from 50 µg/m3 to 10 µg/m3. This proposal is intended to maintain employee blood lead levels (BLLs) below 10 µg/dl, the notice published by Cal/OSHA (PDF) explains. Existing regulations aim to maintain BLLs below 40 µg/dl.

Cal/OSHA also seeks to reduce exposure to lead through the oral route and to expand requirements for blood lead testing of employees who work with lead. Proposed revisions to existing requirements that address these concerns include establishing general hygiene requirements when employees are exposed to lead, rather than when they are exposed to lead above the PEL, as well as increasing the frequency of blood lead testing for employees whose BLLs are at or above 10 µg/dl, compared to existing requirements that call for testing of individuals whose BLLs are at or above 40 µg/dl. Cal/OSHA’s proposal would also require monthly blood lead testing for each worker whose airborne exposure to lead is above 500 µg/m3 as an 8-hour TWA, regardless of respirator use.

“The proposed amendments are needed to adequately protect employees who have occupational exposure to lead,” Cal/OSHA’s notice states. “[R]ecent evidence demonstrates that even at exposure levels well below those currently allowed by the existing regulations, harmful health effects can occur.”

The Occupational Safety and Health Standards Board is accepting written comments on the lead proposal until 5 p.m. local time on April 20, 2023. The board will also hold a public hearing in Sacramento, California, beginning at 10 a.m. on April 20. Instructions for submitting written comments and attending the hearing via video conference, teleconference, or livestream can be found in the Cal/OSHA notice (PDF).

The text of the proposed regulation is available as a PDF. For more information, see the Occupational Safety and Health Standards Board webpage on lead.

Related: An advance notice of proposed rulemaking published by federal OSHA in June 2022 began the rulemaking process for the agency to revise its standards for occupational exposure to lead.