How to Prepare for Cal/OSHA New Stricter Lead Regulations

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Lead… the Silent Killer.

Inorganic lead is a malleable, blue-gray, heavy metal that occurs naturally in the earth. Often known as the silent killer, lead poisoning can develop when ingested and inhaled into the body. Ingestion occurs via contaminated clothing and various surfaces as well as by hands when eating, drinking, and smoking. Inhalation, the most common route of entry into the body, occurs by breathing in lead-containing dust and fumes. 

Depending on the level of exposure, the effects can be acute or chronic. Unfortunately, symptoms may not be noticeable until the damage is already done. Almost every organ in the body, including the brain and central nervous system, can be negatively impacted by lead poisoning. Lead poisoning symptoms in adults include:

  • Decreased cognitive abilities

  • Lack of concentration

  • Memory loss

  • Irritability

  • Headaches

  • Fatigue

  • Muscle and joint pain

  • Renal impairment and kidney disease

  • Gastrointestinal effects

  • High blood pressure

  • Anemia

  • Death

Primary Industries Most at Risk of Lead Exposure

The primary industries where employees are most at risk of overexposure involve manufacturing, construction, maintenance, remediation, and recreation. Specific examples of common lead exposure within these industries include:

  • Manufacturing – Lead-acid batteries, lead and ceramic glaze, crystal glass, cable production, paint and ink, and smelting

  • Construction – Renovation, demolition, and disposal of lead-contaminated material, abrasive blasting, and steel welding

  • Maintenance – Soldering, plumbing, and installing lead-containing structures

  • Remediation – Spill and/or clean-up of contaminated material, lead abatement

  • Recreation – Firing ranges, armories, gunsmithing

New Cal/OSHA Lead Exposure Regulations

Cal/OSHA’s Aggressive Updates for Occupational Exposure to Lead

Due to the severity of lead poisoning and the high potential for exposure in multiple industries, the California Occupational Safety and Health Administration (Cal/OSHA) updated its lead exposure regulations to lower the permissible exposure limit (PEL) and action level (AL) for lead in the workplace.

As of February 2024, Cal/OSHA lowered the state’s PEL for lead from 50 micrograms per cubic meter to 10 micrograms per cubic meter as an eight-hour time-weighted average. Cal/OSHA also reduced the AL for lead from 30 micrograms per cubic meter to 2 micrograms per cubic meter as an eight-hour time-weighted average. The goal, of course, is to maintain employees’ blood lead levels below the PEL. It is expected that these new requirements will go into effect on January 1st, 2025. 

Action Plan for Lead Compliance

As a result of this change, numerous regulatory requirements will be triggered resulting in a lot of work ahead for many employers. The action plan for Cal/OSHA’s Lead Standard compliance is as follows:

  1. Air Monitoring

    • First, conduct air monitoring in affected areas to determine exposure levels.

  2. Written Compliance Program

    • Next, based on findings, there may be a need to develop a written compliance program which includes:

      • Instituting hygiene and housekeeping practices

      • Implementing appropriate engineering controls such as ventilation and dust control

      • Establishing proper work procedures

      • Training

      • Assigning the correct personal protective equipment (PPE) such as respirators

    • Routine exposure monitoring and medical surveillance may be required as well.    

With less than six months to meet regulatory requirements, this may seem like a daunting task. However, prevention is key when dealing with lead, so do not take a chance on the health of your employees.

KERAMIDA has the experience, expertise, and resources available to assist you with meeting the 2025 deadline. Our team of industrial hygienists is ready to perform the necessary air monitoring, develop procedures and programs, provide training, and recommend industry-specific best management practices for companies in need. Schedule a time to talk with one of our Industrial Hygiene specialists through our quick response form or call (800) 508-8034 to speak with one of our experienced professionals today. 

Author

Andrew Tirmenstein, CSP, CHMM
Senior Project Manager, Risk, Health and Safety Services
ISO 45001 & ISO 14001 Auditor
KERAMIDA Inc.

Contact Andrew at atirmenstein@keramida.com.