Cal/OSHA has updated the standards for lead exposure in the Construction and General Industry Safety Orders, with the new regulations taking effect on January 1, 2025. The information below pertains to our clients in General Industry.
What do employers need to know?
CDMS wants to inform our clients that Title 8 §5155 and §5198 of the General Industry Safety Orders have been updated for the first time in decades. The revisions significantly lower the lead exposure thresholds, and employers who might not have been subject to the lead requirements earlier might find themselves now required to take additional measures to safeguard their employees.
If you have any concerns, CDMS recommends that you conduct air monitoring now to determine if employee exposure levels are above the 1/1/2025 threshold limits and would trigger further actions.
The new standards are comprehensive and consider several exposure factors.
The Permissible Exposure Limits (PEL), Time-Weighted Averages (TWA), Blood Lead Levels (BLL) have all been updated.
For General Industry Safety Orders, Section 5155, Airborne Contaminants:
- Lower the PEL for lead (metallic) and inorganic compounds, dust and fume, as Pb (lead) calculated as an 8-hour TWA, from 0.50 to 0.10 micrograms per cubic meter of air.
- Lower the PEL for lead chromate, as Pb (lead) from 0.02 to 0.01 micrograms per cubic meter of air.
For General Industry Safety Orders, Section 5198, Lead:
- Adding and defining the terms “altering or disturbing,” “blood level” and “high efficiency particulate air (HEPA)” filter.
- Adding and defining the term “presumed significant lead work (PSLW).”
- Requiring respiratory protection, protective clothing and equipment, medical surveillance, training, and warning signs for lead, when employees perform PSLW.
- Lowering the BLL at which specified employees must be offered medical examinations and consultations at least annually from 40 to 20 micrograms per cubic meter of air.
- Increasing the frequency of BLL testing when their BLL is at or above 10 micrograms per deciliter and requiring a response plan when an employee’s BLL is at or above 10 micrograms per deciliter.
Employers have a duty to train their employees
As required by section 3203 (Injury, Illness, and Prevention Program), the employer shall establish and implement a system for communicating workplace hazards in a language and manner readily understandable by employees, including provisions designed to encourage employees to inform the employer of lead exposure hazards at the worksite without fear of reprisal.
CDMS’s Role:
CDMS continues to provide and update training and plan development to our California clients. CDMS can also assist with any air monitoring activities that are required. For those who have written IIPPs, now might be a good time to review your current policy and include information regarding protection from lead exposure. If you would like an assessment of your current plan, or questions about Title 8 §5155 and §5198, please reach out to service@cdms.com.
