Key Changes in the 2025 Cal/OSHA Lead Regulations:

Reduced Permissible Exposure Limit (PEL): 

The current PEL of 50 micrograms per cubic meter of air (μg/m3) will be lowered to 30 μg/m3, over an eight hour time weighted average TWA.

Lowered the action level (AL) from 30 μg/m³ to 2 μg/m³.

• Expanded Medical Surveillance: Employers will be required to provide more frequent blood lead level testing for workers, starting at lower thresholds. This will enable earlier intervention and prevention of lead poisoning.
• Lowered BLLs Blood Lead Levels numbers
• Medical removal protection (MRP) is triggered by a blood lead level (BLL) of 30 micrograms per deciliter, down from 50 micrograms per deciliter in the current rule
• Enhanced Engineering Controls: Stricter requirements for engineering and work practice controls to minimize airborne lead dust and fumes. This includes more robust containment, ventilation, and decontamination procedures.
• Increased Training & Notification: Employers must provide comprehensive training on lead hazards and controls. They must also notify workers, their families, and nearby communities about lead abatement activities.
• Protecting Children in Schools: The new regulations will mandate lead testing and abatement in pre-K through 12th grade school facilities, ensuring children are not exposed to lead paint, pipes, or other building materials.

There are a few key reasons why it has taken Cal/OSHA so long to implement and enforce the new lead safety regulations that will take effect in 2025:

1. Extensive Scientific Review and Stakeholder Input

Updating occupational exposure limits for a hazardous substance like lead requires a thorough, evidence-based approach. Cal/OSHA has spent years reviewing the latest research on the health effects of lead, as well as gathering feedback from employers, labor unions, environmental groups, and public health experts. Ensuring the new regulations are grounded in science and address the needs of diverse stakeholders has been a lengthy but necessary process.

2. Resistance from Industry Groups

Understandably, some industry groups have pushed back against the proposed reductions in permissible exposure limits and the added compliance requirements. Businesses have raised concerns about the costs and operational challenges of implementing more stringent engineering controls and medical surveillance programs. Cal/OSHA has had to navigate these political and economic pressures to develop regulations that balance worker/public protection with reasonable implementation timelines.

3. Coordination Across State Agencies

Updating the lead safety standards has required close collaboration between Cal/OSHA, the California Department of Public Health, the Department of Toxic Substances Control, and other relevant state agencies. Aligning the regulatory changes across these different entities and jurisdictions has added complexity and slowed the rulemaking process.

4. Ensuring Adequate Resources and Enforcement Capacity

Effectively implementing and enforcing the new lead regulations will require a significant investment of resources – for training inspectors, developing compliance assistance materials, and building out laboratory testing capabilities. Cal/OSHA has had to carefully plan and budget for these operational needs to ensure the revised standards can be properly implemented and enforced starting in 2025.

While the lengthy timeline has been frustrating for many, the end result will be a substantially strengthened regulatory framework to protect workers, children, and communities from the severe health consequences of lead exposure. The additional time has allowed Cal/OSHA to develop a comprehensive, evidence-based set of requirements that will have a meaningful, long-term impact.