What California Employers Need to Know About the 2025 Cal/OSHA Lead Standard Changes

Cal/OSHA tightened their controls on occupational exposures to lead in the state earlier this year, lowering the Permissible Exposure Limit concentration from 50ug/m3 of lead as an 8-hour time-weighted-average down to 10 ug/m3 TWA. A sharp reduction occurred with their corresponding Action Level for lead, which decreased from 30 ug/m3 to 2 ug/m3 when considered an 8-hour time-weighted average.

This aggressive strategy has been praised by some and criticized by others, but it is the law for all California employers—both industry and construction. The new rules, which took effect on January 1, 2025, are designed to reduce the blood-lead concentrations of workers in the state below 10 ug/dl (or 10 Micrograms per Deci-liter), which will improve overall worker health and limit deleterious effects on their reproductive systems.

The controls being applied within the new rules are primarily tried-and-true; they would all be considered typical or textbook cases. They involve air monitoring for lead, wiping sampling surfaces, biological monitoring that tests the employee's blood for lead, tighter work restrictions for impacted employees, and improved housekeeping and hygiene measures. New emphasis is being placed on oral exposure (perhaps by eating with dirty hands) and biological monitoring, which better assesses a worker's total exposure than air monitoring, which fails to capture oral and, if applicable, dermal exposures.

Instead, the changes relate to typical controls being applied with much lower threshold triggers than they were in the past. This means employers will need to navigate these changes, considering their operations in a holistic and integrated manner. Employers impacted by these changes are encouraged to review their current operations against the new requirements and ensure they are working within the appropriate framework specified by regulators. The new Cal/OSHA lead standard revisions are detailed and specific, which is helpful. However, the frequency of air monitoring, for example – or the requirements related to the provision of uniforms and employee showers have changed recently, and California employers need to be aware.

At AssuredPartners, we endeavor to help our clients prioritize employee safety and protect the environment in the communities they serve. Our organization's partnership is based on promoting strategies that lead to long-term success, and we strive to provide specific, actionable advice to our clients. For more information on this topic or any other workplace safety and health concern, contact your designated AssuredPartners representative to access our nationwide network of risk control professionals.

Further Reading:
California Code of Regulations, Title 8, Section 5198. Lead.
California Code of Regulations, Title 8, Appendix B to Section 5198 Employee Standard Summary
Cal/OSHA Passes Aggressive Update to Lead Regulation - Advocacy - California Chamber of Commerce