A Comprehensive Guide to the Updated Cal/OSHA Lead Standards

Author: Courtney Hansen, Associate at NV5

NV5 is committed to monitoring forthcoming revisions to the Lead Standard, making sure clients stay informed about potential impacts on their business and lead monitoring programs.  To that end, the California Division of Occupational Safety and Health), better known as Cal/OSHA, recently released the second 15-Day Notice of proposed modification to the existing Lead Standard (Construction – 1532.1, General Industry – 5198). The review process started in April 2023 with intent to vote on the final draft in February 2024.

The initial 15-Day Notice period ran from July 7th to July 24^th, 2023. Subsequently, there have been various alterations between the first and second notices.

Below is comprehensive list of the items that have been changed or added to the standard proposed in the second notice. Some modifications impact both the Construction Standard and the General Industry Standard, while others are specific to either one. Excluded from the list below are minor adjustments in phrasing, document organization, or additional definitions that do not affect compliance actions.

The current proposed lead exposure limits are an Action Level of 2 µg/m³ and a Permissible Exposure Limit (PEL) of 10 µg/m³.

Construction 1532.1 and General Industry 5198

• Section (f)(3)(A) regarding respiratory protection:
  • 1^st notice – barred the use of filtering facepieces.
  • 2^nd notice – allows the use of filtering facepieces as long as they are N100, R100, or P100.
• Section (g)(1) regarding protective work clothing:
  • 1^st notice – required gloves and face shield or vented goggles.
  • 2^nd notice – states to use “as needed” gloves, face shields, vented goggles, or other protection equipment in accordance with General Industry Safety Orders (GISO) Article 10.
• Section (i)(2)(C) regarding change areas:
  • 2^nd notice – adds requirement for employers to ensure employees do not enter personal vehicles wearing protective clothing.
• Section (j)(2)(E) regarding elevated blood lead level response:
  • 2^nd notice – adds an exception that a written blood lead level response plan and training are not required when a blood lead level at or above 10 µg/dl is detected only in an employee’s initial blood lead testing.
• Section (m)(1)(E) regarding signs:
  • 2^nd notice – adds requirement for signage to be in a language understandable by employees.

Construction 1532.1

• Section (i)(3)(A) regarding showers:
  • 1^st notice – required employers to provide showers to employees whose airborne exposure to lead is above the PEL (10 µg/m³).
  • 2^nd notice – requires employers to provide shower when exposure is above 50 µg/m³.
• Section (j)(1)(A) and (B) regarding blood lead testing and medical surveillance program:
  • 2^nd notice – adds an additional exception that initial blood lead testing and participation in a medical surveillance program is not required for employees who are not exposed above the Action Level (2 µg/m³) for 15 or more days within 12 months and not exposed on any day above 20 µg/m³ 8-hour TWA.
• Appendix C – Medical Surveillance Requirements Section I, subsection D:
  • 2^nd notice – adds requirement to include in written medical opinion from PLHCP any recommended follow-up blood lead testing and medical examinations.

General Industry – 5198

• Section (e)(1)(B) regarding compliance methods:
  • 2^nd notice – adds a statement that where engineering controls cannot reduce lead exposure to at or below the PEL, respiratory protection shall be implemented to reduce exposure to the lowest level feasible.
• Section (e)(1)(c) Table 1:
  • 2^nd notice – adds a section for the Separate Engineering Control Airborne Limits (SECALs) for lead acid battery recycling applied through a phased-in system with an initial limit of 50 µg/m³ and brought down to 30 µg/m³ after 5 years.
• Section (j)(1)(A) regarding medical surveillance program:
  • 2^nd notice – adds an additional exception that participation in a medical surveillance program is not required for employees who are not exposed above the Action Level (2 µg/m³) for 15 or more days within 12 months and not exposed on any day above 20 µg/m³ 8-hour TWA.
• Section (j)(3)(A) regarding medical examinations:
  • 2^nd notice – adds two exceptions that employees under the following conditions are not required to participate in medication examinations and consultations.
    • Employees who are not exposed to lead above the Action Level for 30 or more days within 12 months, and who is not exposed on any day above 10 µg/m3 as an 8-hour TWA.
    • Employees who are not exposed above the Action Level (2 µg/m³) for 15 or more days within 12 months and not exposed on any day above 20 µg/m³ 8-hour TWA.

For assistance, please contact us at 562.495.5777 or reach out to Courtney Hansen, Associate at NV5, via email at Courtney.Hansen@NV5.com.