OSHA Requests Comments on Lead Exposure Standards

Posted on 8/22/2022 by Roger Marks and Lee Ann Coniglione

OSHA is considering a rulemaking to revise its standards for workplace exposure to lead, based on medical findings made since the Standard for lead was established in 1978. OSHA has requested public comments on the possibility of lowering the blood lead level (BLL) for medical removal and the BLL for returning to lead-exposed work in its general industry and construction regulations.  

Recent medical findings have shown that adverse health effects can occur at levels lower than the current medical removal level in OSHA’s regulations. Lead exposure can affect the reproductive, cardiovascular, neurological, respiratory, and immune systems.

The comment period for this Advanced Notice of Proposed Rulemaking (ANPRM) has been extended until October 28, 2022.

OSHA Requests Comments on Lead Exposure Standards

Current OSHA Standards for Lead in General Industry 

Employers covered by the Lead Standard must implement engineering controls, work practices, and (when needed) respiratory protection to reduce employees’ exposure below the permissible exposure limit (PEL) of 50 micrograms per cubic meter of air (μg/m3).

Under the current OSHA Standard for lead in general industry (29 CFR 1910.1025), OSHA requires covered employers to determine whether employees are exposed to lead at or above the action level of 30 micrograms per cubic meter of air (μg/m3), averaged over eight hours.

If employees are (or may be) exposed to lead at or above the action level, the employer must institute a medical surveillance program.  This includes regularly sampling the level of lead and zinc protoporphyrin (ZPP) in employees’ blood.

If testing shows that an employee’s blood lead level is at or above a specific threshold, the employee must be removed from the work that exposes them to lead. The regulations also designate a blood lead level for safely returning employees to work.

The regulations also include rules for providing additional personal protective equipment as well as basic housekeeping measures such as cleaning surfaces and vacuuming.

In addition, the standard requires employers to provide change rooms and showers for employees with exposures above the PEL and enforce certain hygiene practices (e.g., no eating or drinking in areas with exposures above the PEL). 

What Industries Could the Rule Affect?

A change to OSHA's lead exposure regulations for general industry will impact workplaces in which employees are exposed to lead at or above the permissible exposure limit and/or action level.

Workers in general industry may be exposed to lead during the manufacturing, repair, or recycling of goods that contain lead, such as lead-acid batteries, lead bullets, plumbing fixtures and pipes, leaded glass, radiators, and more.

Data collected shows four main industry categories in which workers demonstrate elevated blood lead levels:

  • Manufacturing. Includes battery manufacturing, nonferrous metal rolling, drawing, extruding, and alloying; ship and boat building, automotive electrical and electronic equipment manufacturing; and fabricated metal products manufacturing.
  • Construction, Includes highway, street and bridge construction.
  • Services. Includes shooting ranges and automotive, mechanical, and electrical repair and maintenance.
  • Mining. Includes mining of lead and zinc ore.
According to a 2016 study by NIOSH, more than 90% of adults who showed elevated blood lead levels were exposed at work.

Department of Defense Action on Lead Exposure  

Following a study of lead exposure at firing ranges completed in 2013, the Department of Defense determined that the current OSHA standards for lead exposure were not protective enough for workers in these facilities. DOD subsequently lowered its medical removal and return-to-work triggers for blood lead levels in military and civilian personnel.

OSHA published a Fact Sheet to help employers protect workers from lead hazards at indoor firing ranges in 2018.

State Actions on Lead Exposure

In 2018, Michigan lowered the blood lead level at which an employee is required to be removed from exposure. California OSHA has held advisory meetings to discuss the possibility of lowering its medical removal triggers and return-to-work threshold for lead. Reductions to these levels have been proposed in Washington as well.

Lead Safety Training

OSHA requires annual training for employees exposed to lead at or above the current action level (29 CFR 1910.1025(l)(1)). The Lead Safety Online Course provides training for employees, developing employee awareness of the hazards of lead in the workplace, routes of exposure, and protective measures.

Tags: lead, lead exposure, new rules, osha, workplace safety

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