Lead in Construction - Cal/OSHA

Since January 1, 2025, California's construction lead standard has used limits far below federal OSHA's. The permissible exposure limit dropped from 50 to 10 micrograms per cubic meter of air. The action level — the point where air monitoring and blood testing start — dropped from 30 to 2. This Cal/OSHA Lead in Construction Toolbox Talk covers what changed in Title 8, Section 1532.1, why the jobs a crew has always done now cross the line, and the California-only step of telling Cal/OSHA before the work starts.

Where the boundary of this talk sits#

This talk covers California's lead numbers and the duties they trigger. How lead harms the body and how it gets carried home belong to the lead exposure talk; recognizing lead paint belongs to the lead paint awareness talk; respirator fit and use belong to the respiratory protection talk.

The anchor#

Here is the distinction that carries this whole talk: California did not add a new hazard in 2025, it moved the line — the exposure limit is now a fifth of the federal one and the action level is fifteen times lower — so the scraping, sanding, and torch work a crew has done safely "for years" was only safe measured against numbers that no longer apply in California; in California, "it's just a little lead dust" is a guess calibrated to the old rule.

The new numbers#

Section 1532.1 sets:

• Permissible exposure limit (PEL): 10 µg/m³ as an 8-hour time-weighted average. Federal 29 CFR 1926.62 is 50.
• Action level: 2 µg/m³ as an 8-hour time-weighted average, without regard to respirators. Federal is 30.
• Abrasive blasting (Section 1532.1(c)(1), Exception): until January 1, 2030, workers doing abrasive blasting may be exposed up to 25 µg/m³ as an 8-hour TWA — a temporary allowance while the industry catches up.

The amendment was filed April 8, 2024, and became operative January 1, 2025.

Trigger tasks: presume it's high until you prove it isn't#

Section 1532.1(d)(2) lists trigger tasks — work that is presumed to expose employees above the PEL until the employer performs an exposure assessment and determines actual exposure. The rule sorts them into three levels, each applying where lead-containing coatings or paint are present. Level 1, presumed above the PEL but not more than 10 times it: manual demolition of structures such as drywall, manual scraping, and heat gun work. Level 2, presumed above 10 times but not more than 50 times the PEL: manual sanding, power tool cleaning, grinding, or sanding with dust collection, and spray painting with lead paint. Level 3, presumed above 50 times the PEL: abrasive blasting, welding, torch cutting, torch burning, rivet busting, lead-containing mortar or lead burning, power tool cleaning, grinding, or sanding without dust collection, cleanup with dry expendable abrasives, and moving or removing abrasive blasting enclosures.

Until the assessment is done, the employer must provide the protections the rule lists, including appropriate respiratory protection, protective clothing and equipment, change areas, eating facilities or areas, regulated areas, blood lead testing, and training — plus shower facilities for Level 3 tasks. With the PEL at 10, very few of these tasks will measure below it without real controls.

Tell Cal/OSHA 24 hours ahead#

This is the step federal OSHA does not have. Under Section 1532.1(p), when work is planned that includes any of the trigger tasks in (d)(2), the employer must give written notification to the nearest Cal/OSHA district office. The information must reach Cal/OSHA at least 24 hours before the work starts. It may be sent by letter, fax, or email, or by telephone followed by written confirmation; in an emergency, notice may be phoned in any time before the work starts, with the written notice sent within 24 hours. The rule has three exceptions: less than 100 square feet or 100 linear feet of material disturbed; torch cutting or welding lasting no more than 1 hour in a shift; and coatings with less than 0.5% lead (5,000 ppm by weight, or 1.0 mg/cm²). A crew that shows up Monday to torch-cut painted steel should know that notice went in by Friday.

Blood testing: earlier and more often#

Under Section 1532.1(j), blood lead testing starts before a worker is assigned to work where exposure is, or is reasonably expected to be, at or above the action level — which is now 2 µg/m³. Testing then runs at least every 2 months for the first 6 months and every 6 months after that. It goes back to at least every 2 months for anyone whose last result was at or above 10 µg/dL but below 20 — until two consecutive results at least 30 days apart are below 10 — and at least monthly for anyone at or above 20 µg/dL.

Medical removal: lower triggers, protected pay#

Section 1532.1(k) requires temporary medical removal from lead exposure when a worker's blood lead level is at or above 30 µg/dL. Since January 1, 2026, removal is also required when the last two blood lead results are at or above 20 µg/dL, or when the average of all results in the last 6 months is at or above 20 µg/dL. A removed worker can return when two consecutive tests at least 30 days apart are both below 15 µg/dL. During removal, the worker is entitled to medical removal protection benefits for up to 18 months.

For comparison, the federal construction standard removes a worker at 50 µg/dL and allows return below 40.

Hygiene still matters most at the end of the day#

Section 1532.1(i) requires employees exposed to lead to wash their hands, exposed arms, and face before entering eating areas, before eating, drinking, smoking, or applying cosmetics, and at the end of the shift. Change areas with separate storage for work clothing and street clothes, and clean eating areas, are required for employees exposed above the PEL. Showers are required for employees exposed above 50 µg/m³, without regard to respirators.

Where the duty sits#

8 CCR 1532.1 carries the California duty: (b) action level 2 µg/m³; (c) PEL 10 µg/m³, with 25 µg/m³ for abrasive blasting until 2030; (d)(2) trigger tasks and interim protection; (i) hygiene; (j) blood testing; (k) medical removal and benefits; (p) 24-hour notice to Cal/OSHA. For contrast, federal 29 CFR 1926.62 uses a PEL of 50, an action level of 30, and removal at 50 µg/dL.

What can go wrong?#

• A painter scrapes and heat-guns old trim the way he always has, with no respirator, because "we never needed one."
• Torch cutting on painted steel starts Monday and nobody sent the Cal/OSHA notice.
• A worker's blood lead is 22, then 24, and nobody removes him because he's "under 30."
• A crew eats lunch on the tailgate without washing.
• Work clothes go home in the truck with the family's laundry.

How do we manage this properly?#

• Treat trigger tasks as over the limit — until an exposure assessment proves otherwise.
• Send the notice — to the Cal/OSHA district office at least 24 hours before trigger work.
• Test blood before assignment — and on schedule after, more often at 10 and 20 µg/dL.
• Remove at the California triggers — 30, or two results at 20, or a 6-month average at 20.
• Wash before eating and at shift end — hands, arms, and face.
• Keep lead at work — change areas, separate storage, and no work clothes in the family laundry.

Before you start#

Ask whether today's work disturbs any lead-containing coating, and whether it is a trigger task. If it is, confirm the Cal/OSHA notice went in at least 24 hours ago, the exposure assessment status, and that respirators, protective clothing, wash water, and a clean eating area are on site. Check who is due for blood testing.

Talk it over#

• Which tasks on this job could disturb lead paint?
• When was your last blood lead test, and do you know the result?
• Where do you wash before lunch, and where do your work clothes go at the end of the day?

The bottom line#

California moved the lead line in 2025: a PEL of 10 µg/m³ and an action level of 2, far below federal OSHA. Trigger tasks are presumed over the limit until measured, and Cal/OSHA gets written notice 24 hours before they start. Blood testing starts earlier, removal happens at lower levels — 30 µg/dL, or 20 on repeated tests — and pay is protected for up to 18 months. Wash before eating, and keep lead at work.

Frequently asked questions about the Cal/OSHA lead standard#

What is California's lead exposure limit in construction?

Since January 1, 2025, Section 1532.1 sets the permissible exposure limit at 10 µg/m³ as an 8-hour time-weighted average and the action level at 2 µg/m³. Abrasive blasting has a temporary limit of 25 µg/m³ until January 1, 2030. The federal construction PEL is 50.

Do we have to notify Cal/OSHA before lead work?

Yes, for trigger tasks. Section 1532.1(p) requires written notification to the nearest Cal/OSHA district office when work is planned that includes any task listed in subsection (d)(2), and the information must reach Cal/OSHA at least 24 hours before the work begins. Letter, fax, and email are accepted, and a telephone notice must be followed by written confirmation. There are exceptions for less than 100 square feet or 100 linear feet of material, for torch cutting or welding of 1 hour or less in a shift, and for coatings with less than 0.5% lead. Federal OSHA has no equivalent pre-job notice for lead.

When does a worker have to be removed from lead exposure in California?

At a blood lead level of 30 µg/dL or more. Since January 1, 2026, a worker is also removed when the last two blood lead results are at or above 20 µg/dL, or when the average of all results in the past 6 months is at or above 20 µg/dL. The worker can return after two consecutive tests at least 30 days apart are both below 15 µg/dL, with medical removal protection benefits for up to 18 months.

Download the Cal/OSHA lead in construction toolbox talk PDF#

Download this Cal/OSHA Lead in Construction Toolbox Talk as a printable PDF in English and Spanish, and review it before any trigger task starts.

Related toolbox talks#

• Lead Exposure
• Lead Paint Awareness
• Respiratory Protection
• Personal Hygiene

Sources#

• Cal/OSHA, Title 8 CCR §1532.1 — Lead ((b) action level 2 µg/m³; (c)(1) PEL 10 µg/m³, abrasive blasting 25 µg/m³ until January 1, 2030; (d)(2) trigger tasks, three presumed exposure levels, interim protection including showers for Level 3; (i) hygiene, showers above 50 µg/m³; (j) blood lead testing schedule; (k) medical removal at 30 µg/dL and, from January 1, 2026, two results or six-month average at 20 µg/dL, return below 15 µg/dL, benefits up to 18 months; (p) written notice received at least 24 hours before trigger tasks, emergency phone notice, exceptions for under 100 sq ft/100 linear ft, torch work up to 1 hour, and under 0.5% lead; amendment operative 1-1-2025): https://www.dir.ca.gov/title8/1532_1.html
• OSHA, 29 CFR 1926.62 — Lead (federal: action level 30 µg/m³, PEL 50 µg/m³, medical removal at 50 µg/dL, return below 40 µg/dL): https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.62

Written by FieldSafetyTalk's safety professional — a CSP, ASP, CHST and OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.

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