Updated Lead Exposure Regulations in California

California is enhancing workplace safety with new lead exposure regulations approved by the California Occupational Safety and Health Standards Board (Cal/OSHA) on February 15, 2024. These updated standards went into effect January 1, 2025, and aim to significantly reduce occupational lead exposure and improve safety protocols across various industries. Titan Environmental is here to help make sure these new regulations are properly adhered to, whether you are a local business, large corporation, or government agency.

Updated Regulations

The updated regulations for Construction and General Industry (Title 8, Sections 1532.1 and 5198) introduce several critical adjustments:

• Reduction to Action Level (AL) – Action level means employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 2 micrograms per cubic meter of air (2 μg/m3) calculated as an 8-hour time-weighted average (TWA). [Previously the amount was 30 μg/m3]
• Reduction in Permissible Exposure Limit (PEL) – The employer shall ensure that no employee is exposed to an airborne concentration of lead greater than 10 micrograms per cubic meter of air (10 μg/m3) calculated as an 8-hour time-weighted average (TWA) period. The 8-hour TWA shall be calculated in accordance with the appendix to section 5155. [Previously the amount was 50 μg/m3]

Additional Key Provisions

Exposure Assessment and Monitoring

Employers must assess employee exposure levels to determine appropriate protective measures. If an assessment is not conducted, interim protections must be provided, including respiratory protection, protective clothing, medical surveillance, training, and warning signs. The frequency of exposure monitoring depends on exposure levels.

Medical Surveillance and Removal Conditions

Employers must implement a medical surveillance program for employees exposed to or above the Action Level (AL). Medical exams and procedures must be provided at no cost to employees and conducted at reasonable times and locations.

Blood Testing

Blood testing requirements include pre-assignment testing before employees begin work in areas where lead exposure is likely, as well as testing every two months for the first six months, then every six months thereafter. Medical removal is required if an employee’s blood lead level (BLL) reaches any of the following thresholds:

• BLL tested above 30 µg/dL
• Two consecutive BLL test results above 20 µg/dL
• An average BLL over six months greater than 20 µg/dL

Employees can only return to work once their BLL drops below 20 µg/dL, with the six-month average also below 20 µg/dL.

Workplace Hygiene

Employers must implement general hygiene measures for all employees exposed to lead at or above the new AL, which is four times lower than the current federal standard. These measures include:

• Changing areas
• Eating facilities
• Employee training
• Hygiene practices
• Protective clothing/equipment
• Respiratory protection
• Restricted access to regulated areas
• Showers available
• Exposure monitoring records kept for 40 years, or for the duration of employment plus 20 years, whichever is longer

Impacted Industries

The updated regulations will affect a wide range of industries in California, including:

• Automotive
• Construction
• Fabrication (metal work/welding)
• Manufacturing (batteries, construction materials, etc.)
• Scrap Processing
• Smelting/Melting

Titan Environmental can help ensure that your business or government facility is in compliance with these new regulations. If you have any questions, or would like to have one of our experts consult on any construction, fabrication, or manufacturing processes, please contact us today.