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Lead in General Industry: What 29 CFR 1910.1025 Requires and Where It Parts Company With the Construction Standard
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Lead in General Industry: What 29 CFR 1910.1025 Requires and Where It Parts Company With the Construction Standard

OSHA's general industry lead standard removes a worker at 60 micrograms per 100 grams of whole blood. The construction standard removes at 50. What 1910.1025 actually requires.

by iSi Environmental

A plant’s lead program removes a worker from lead work at 60. The contractor doing coating repair in the same building removes at 50. Both numbers are correct, and the ten units between them are where somebody built a program off the wrong standard.

Lead has two OSHA standards, and they are not two versions of the same rule. 29 CFR 1910.1025 governs general industry. 29 CFR 1926.62 governs construction. Paragraph (a)(2) draws the line: the section “does not apply to the construction industry or to agricultural operations covered by 29 CFR part 1928.” Everything else is in, because 1910.1025(a)(1) reaches “all occupational exposure to lead.” Maintenance by plant personnel on plant equipment is general industry, including demolition of process equipment inside an operating facility when plant employees do the work. Alteration, repair or demolition undertaken as a construction activity runs under 1926.62, and the lead in construction post covers that side.

Both standards use an action level of 30 micrograms of lead per cubic meter of air and a permissible exposure limit of 50. They do not share a medical removal trigger. General industry removes at 60 under 1910.1025(k)(1)(i)(A). Construction removes at 50. A facility that assembled its lead program from a contractor’s binder carries a removal trigger set ten units permissive. No air monitoring data will surface that. A blood result landing between the two numbers will.

One notation point before the numbers. 1910.1025 states its blood lead triggers in micrograms per 100 grams of whole blood, written here as µg/100 g. 1926.62, CDC, NIOSH and the lab report that comes back from the draw all state blood lead in micrograms per deciliter, written here as µg/dL. OSHA’s own 2022 rulemaking notice carries a footnote confirming that µg/dL is “essentially equivalent to µg/100g of whole blood,” and this post keeps each source in its own units.

Does the OSHA lead standard for general industry apply to my facility?

If you have occupational exposure to lead and you are not construction or covered agriculture, yes. 29 CFR 1910.1025(a)(1) reaches “all occupational exposure to lead,” and (a)(2) excludes only “the construction industry or … agricultural operations covered by 29 CFR part 1928.” There is no industry list, headcount test or quantity threshold.

Applicability is actually decided by the definition of “lead” at 1910.1025(b), which is narrower than the word suggests: “metallic lead, all inorganic lead compounds, and organic lead soaps. Excluded from this definition are all other organic lead compounds.” Lead oxide in pigment, solder, brass and bronze alloys, lead sheet, battery paste and lead stearate are inside. Tetraethyl lead and other organic lead compounds that are not soaps sit outside this standard, which settles which rule applies rather than whether they are regulated.

What is the OSHA action level for lead, and how is it different from the PEL?

The permissible exposure limit is 50 micrograms per cubic meter as an 8-hour time-weighted average, at 1910.1025(c)(1). The action level is 30 micrograms per cubic meter, at (b), and it is measured without regard to respirator use. The PEL is a limit you may not exceed. The action level is a switch that starts monitoring and medical surveillance programs while you are still legally compliant.

Issuing a half-mask moves neither the action level determination nor the surveillance obligation behind it. Extended shifts change the limit arithmetically: under 1910.1025(c)(2), when an employee works more than eight hours in a day the allowable time-weighted average is 400 divided by the hours worked that day. A 10-hour shift carries a limit of 40 micrograms per cubic meter and a 12-hour shift carries 33. A foundry or blast operation running four-tens gets compared against 50 when the limit is lower.

How often does the general industry lead standard require air monitoring?

Three frequencies, at 1910.1025(d)(6). Below the action level, no repeat is required except under (d)(7). At or above the action level but at or below the PEL, at least every 6 months. Above the PEL, quarterly. To step down a tier or stop, you need two consecutive measurements taken at least 7 days apart below the relevant threshold.

Before any of that comes the initial determination at 1910.1025(d)(2), using the basis provisions at (d)(3). A facility that has never run it has no tier. The provision most often missed after that is (d)(7). Monitoring must be repeated whenever a production, process, control or personnel change may result in new or additional exposure, regardless of where the last result sat. A new abrasive media, a different coating on the same beam, or a captured-exhaust hood down for repair all reopen the question. The step-down rule cuts the other way: one clean sample does not drop a facility out of quarterly monitoring.

How long does an employer have to tell an employee their lead monitoring result?

15 working days. 1910.1025(d)(8)(i) requires the employer to notify each affected employee “within 15 working days after the receipt of the results of any monitoring performed under this section,” either individually in writing or by posting the results in an accessible location. The clock starts when the employer receives the lab report, not when the sample was taken.

A pump that ran on a Tuesday and came back from the laboratory nine days later starts the clock on the day the report landed. Notification is owed to every affected employee, including those whose results sat below the action level.

When does lead exposure require a written compliance program?

When exposure exceeds the PEL for more than 30 days per year. 1910.1025(e)(1)(i) then requires engineering and work practice controls, and (e)(3)(i) requires a written compliance program to reduce exposure to or below the PEL by those controls alone. It must contain the eight elements at (e)(3)(ii)(A) through (H) and be revised and updated at least annually under (e)(3)(iv).

The eight elements are specific, and a generic written program will not satisfy them: a description of each operation in which lead is emitted, the specific means to achieve compliance including engineering plans and studies, a report of the technology considered, air monitoring data documenting the source of emissions, a detailed implementation schedule, a work practice program covering paragraphs (g), (h) and (i), the administrative control schedule required by (e)(5) where one applies, and other relevant information.

When does an employer have to start blood lead testing in general industry?

When employees are or may be exposed at or above the action level for more than 30 days per year, under 1910.1025(j)(1)(i). The baseline frequency is at least every 6 months under (j)(2)(i)(A). It accelerates to at least every 2 months once a result reaches 40 µg/100 g, and runs monthly during any removal period, under (j)(2)(i)(B) and (C).

The trigger is the action level rather than the PEL, and it is counted in days. The 2-month acceleration at (j)(2)(i)(B) continues until two consecutive results come back below 40 µg/100 g, so one lower reading does not restore the 6-month schedule.

Under (j)(2)(ii), when a periodic test shows a blood lead level at or above the removal criterion at (k)(1)(i)(A), the employer must provide a follow-up test within two weeks of receiving that result. Medical examinations run alongside under (j)(3)(i): at least annually for any employee whose blood lead level reached 40 µg/100 g in the preceding 12 months, before first assignment to an area at or above the action level, and on an employee’s report of symptoms, of a desire for advice on lead’s effect on the ability to procreate a healthy child, or of difficulty breathing in a respirator.

At what blood lead level must a general industry employer remove a worker from lead work?

Two triggers. At or above 60 µg/100 g of whole blood on a periodic and a follow-up test, under 1910.1025(k)(1)(i)(A). Or when the average of the last three tests, or all tests over the previous 6 months if that is longer, is at or above 50 µg/100 g, unless the most recent test is below 40, under (k)(1)(i)(B). Construction removes at 50 µg/dL instead.

The averaged trigger at (k)(1)(i)(B) catches a program running on a spreadsheet of single results. An employee can sit in the low 50s for three consecutive draws, never touch 60, and still be removable. If the most recent test is below 40 µg/100 g, the averaged trigger does not fire. Removal under (k)(1) is removal from work having exposure at or above the action level, which transfer to other work can satisfy.

The construction figure is named only to mark the boundary. A general industry employer at 60 and a contractor at 50 on the same site have two correct numbers, and both crews need to know which standard they are under before a result lands in the gap.

What blood lead level lets a removed employee return to lead work?

Below 40 µg/100 g on two consecutive tests, under 1910.1025(k)(1)(iii)(A)(1). One good result does not return anyone. The return threshold is also the same number that triggers two-month sampling under (j)(2)(i)(B) and annual medical examinations under (j)(3)(i)(A), so 40 is the most operationally important figure in the standard.

A program tracking only 60 and 50 misses all three jobs that 40 does, because nothing visible happens at 40 until somebody pulls the records.

Does an employer have to keep paying a worker removed for an elevated blood lead level?

Yes, for up to 18 months per occasion. 1910.1025(k)(2)(i) requires medical removal protection benefits, and (k)(2)(ii) requires the employer to “maintain the earnings, seniority and other employment rights and benefits of an employee as though the employee had not been removed.” That obligation, rather than the air sampling, is usually the largest cost in a lead program.

Personal air sampling and laboratory analysis are a scheduled, budgetable line. Eighteen months of maintained earnings and seniority per occasion, with monthly blood draws under (j)(2)(i)(C) and a replacement needed on the same operation, is a staffing event that arrives with no notice. What triggers it is a laboratory result on a person, not a reading on a pump.

Why is OSHA’s lead removal level so much higher than the CDC blood lead reference value?

Because the two numbers were set 45 years apart and only one has moved. CDC carries a blood lead reference value of 3.5 µg/dL, and the ABLES surveillance program flags 5 µg/dL as elevated. OSHA removes at 60 µg/100 g in general industry. CDC states plainly that “there is currently no known safe level of lead.”

The 3.5 µg/dL figure is the Council of State and Territorial Epidemiologists’ reference value for adults and children above the 97.5th percentile, and the ABLES program uses 5 µg/dL for surveillance. Neither is a workplace limit. CDC puts the health findings on the same page as the regulatory triggers: the National Toxicology Program concluded lead below 10 µg/dL “increases blood pressure, the risk of hypertension, and the incidence of essential tremor.” ACOEM and the California Department of Public Health recommend medical removal at two consecutive blood lead levels between 20 and 29 µg/dL, which is a professional recommendation rather than an OSHA requirement. CDC also characterizes OSHA as considering a blood lead level of 25 µg/dL serious, and that is CDC’s description of OSHA, not a trigger written anywhere in 1910.1025.

The regulatory numbers at (j) and (k) have not moved since promulgation. The amendment history on OSHA’s copy runs from 60 FR 52856 in 1995 to 85 FR 8732 on February 18, 2020, and the later entries are recordkeeping and nomenclature housekeeping. A facility can run a fully compliant federal lead program while carrying employees whose blood lead levels sit an order of magnitude above every current public health reference point.

Does the lead standard set a numeric limit for lead dust on surfaces?

No, and OSHA said so again on September 29, 2025. The duty to keep surfaces “as free as practicable” of lead accumulation “is performance oriented. Therefore, the standard does not identify any specific quantitative levels of lead in dust that satisfies the standard.” OSHA archived its 2003 letter that had pointed to HUD’s 200 µg/ft² figure.

That language comes from a letter of interpretation dated September 29, 2025, signed by Brian Rizzo, Acting Director of the Directorate of Construction, answering the question “What is OSHA’s position on the decontamination level for lead on surfaces?” The letter arose under the construction standard and cites 1926.62(h)(1), (i)(2)(i) and (i)(4)(ii). OSHA tied it to the identical general industry requirements at 1910.1025(h)(1), (i)(2)(i) and (i)(4), so it reads onto a general industry housekeeping and hygiene facility program. A letter of interpretation is OSHA’s stated position, not a regulation, and it amends neither standard.

OSHA withdrew the one number practitioners had, explaining that it “previously recommended the use of HUD’s previous acceptable decontamination level of 200 µg/ft2 for floors in evaluating the cleanliness of change areas, storage facilities, and lunchrooms/eating areas,” but that “maintaining surface lead dust levels at or below a specific concentration, such as the HUD acceptable decontamination level, was not adopted into OSHA’s final rule.” The January 13, 2003 letter recommending the HUD figure was archived because it no longer references HUD’s current level. What remains is a method test: as free as practicable, cleaned by HEPA vacuuming or by methods equally effective. A specification handed to your crew carrying a 200 µg/ft² clearance criterion is a contract term someone wrote, and it should be priced and argued as one.

Is a worker exposed below the lead action level covered by the standard at all?

Partly, and the provision is easy to miss. Training under 1910.1025(l)(1)(ii) reaches every employee exposed at or above the action level “or for whom the possibility of skin or eye irritation exists,” which is not an air-concentration test. Monitoring must also be repeated under (d)(7) on any process, control or personnel change. Medical surveillance under (j) is not triggered.

The skin and eye irritation clause pulls in people a sampling-driven program will never flag: someone handling lead stearate drums, changing bag filters on a dust collector serving a lead operation, cleaning up after a blast job. Training is owed before initial job assignment under (l)(1)(iii) and annually under (l)(1)(iv).

What is the penalty for a lead standard violation in 2026?

Serious and other-than-serious violations carry up to $16,550 each under 29 CFR 1903.15(d)(3) and (d)(4). Willful or repeated violations carry up to $165,514, with a $11,823 statutory minimum for willful, under (d)(1) and (d)(2). Because monitoring, surveillance, training and the compliance program are separate requirements, a single unassessed operation generates multiple citable items.

Those figures are codified. The eCFR text of 1903.15(d), current to October 22, 2026, still reads “penalties proposed after January 15, 2025,” with an amendment history ending at 90 FR 1861, and OSHA’s penalties page carries a January 15, 2026 label over identical amounts. No figure changed.

Do lead requirements differ in Kansas, Oklahoma, Texas, Missouri, Nebraska or Colorado?

No. None of the six has an OSHA-approved State Plan, so federal 1910.1025 applies unmodified with no state overlay anywhere in iSi’s service region. osha.gov also notes that in these states “State and local government workers are not covered by federal OSHA,” which leaves municipal shops doing lead-paint maintenance outside federal enforcement.

OSHA’s list names 22 plans covering both private sector and state and local government employees and 7 limited to state and local government. None of the six appears on either list. Each entry reads the same way, using Kansas as the example: “Kansas is not an OSHA-approved State Plan, and is under federal OSHA jurisdiction which covers most private sector workers within the state.”

Several of the states that adopted lower medical removal triggers are State Plan states. A Wichita or Tulsa facility reading about a lower removal trigger somewhere else has a clean answer: those are State Plan adoptions, and a state with no plan has nothing to adopt them through.

Thirty days a year decides most of the program

The numbers that get quoted in lead conversations are air concentrations. The number that sets the shape of the program is a day count. Exposure at or above the action level for more than 30 days per year starts medical surveillance under 1910.1025(j)(1)(i). Exposure above the PEL for more than 30 days per year starts the engineering control duty at (e)(1)(i) and the written compliance program at (e)(3)(i).

So a facility can hold a single result of 35 micrograms per cubic meter, file the report, and believe the operation is characterized, while the obligation that result creates turns on a count nobody is keeping. How many days a year does that torch run on that coated beam? That answer lives in work orders and production schedules, and it is what converts an air monitoring result into a surveillance program.

What OSHA is working on in the lead standards right now

The obvious assumption is that lead rules are tightening. The agenda says otherwise.

The only live OSHA lead rulemaking is deregulatory and it is about respirators. RIN 1218-AD66, titled simply “Lead,” sits at the Proposed Rule Stage in the current DOL/OSHA agenda. Its abstract, verbatim: “This proposed rule revises some substance-specific respirator requirements to allow different types of respirators to be used under OSHA’s Lead standards and better aligns the standards with OSHA’s Respiratory Protection standard.” Its CFR citations are 29 CFR 1910.1025, 1915.1025, 1917.1, 1918.1 and 1926.62, its priority is “Substantive, Nonsignificant,” and its Executive Order 14192 designation is Deregulatory. The proposed rule appeared at 90 FR 28277 on July 1, 2025, with comments closing September 2, 2025, extended at 90 FR 40547 on August 20, 2025 to November 1, 2025. The agenda lists a public hearing for August 2026 without a specific day, and whether it occurred is not established here.

The rulemaking that would have moved the blood lead triggers has gone quiet. OSHA issued an Advance Notice of Proposed Rule Making titled “Blood Lead Level for Medical Removal” at 87 FR 38343 on June 28, 2022, under docket OSHA-2018-0004 and RIN 1218-AD10, covering 29 CFR parts 1910 and 1926, with comments due August 29, 2022. It asked about the blood lead level at which medical removal should occur. It does not appear in the current Unified Agenda, and the DOL/OSHA agency rule list carries exactly one lead-titled entry, which is the respirator rule above.

For planning purposes, 60 µg/100 g is the number to build against, and OSHA itself opened the question of whether it is the right one four years ago.

What enforcement looks like around a lead program

Neither 1910.1025 nor 1926.62 appears on OSHA’s preliminary Top 10 Most Frequently Cited Standards for FY2026, covering October 1, 2025 through August 31, 2026. The list is 1926.501, 1910.1200, 1910.147, 1926.451, 1926.1053, 1910.134, 1910.178, 1926.503, 1926.102 and 1910.212.

The useful read on that list is position six. Respiratory Protection at 1910.134 is on it, and a lead program failure almost never arrives as a lead citation by itself. The respirators a facility leans on in place of engineering controls under 1910.1025(e)(1)(i) and (f) bring 1910.134’s fit testing, medical evaluation and written program requirements with them. The citable surface around an unassessed lead operation covers monitoring, medical surveillance, training, the written compliance program and the respirator program, each with its own paragraph.

Where this lands in a plant

The self-qualification test runs in three questions. Is the work general industry or construction? Does any material in the operation contain metallic lead, an inorganic lead compound or a lead soap, which is a safety data sheet question rather than a purchase-description question? And has anyone ever performed the initial determination under 1910.1025(d)(2) to decide whether any employee may be exposed at or above 30 micrograms per cubic meter? If that last answer is no, the facility has not started the standard, and neither 30-day counter can be evaluated at all.

The operations that produce surprises are the ones nobody filed under lead: the torch on the old coated beam, the sander in the paint shop, the blast cabinet on legacy equipment, the solder pot running since before anyone currently on site was hired. The welder is not wearing a sampling pump, so the exposure is not on paper, so the 30-day counter was never started.

iSi’s industrial hygiene group has run lead exposure assessments for general industry clients since 2011. If no one at your facility has run the (d)(2) initial determination, or if nobody has checked which removal trigger the lead program on the shelf names, that is a sampling question before it is a paperwork question. Our industrial hygiene group does the personal air monitoring, the exposure assessment and the written lead program build to the eight elements at (e)(3)(ii). Send the operation list and the building age and we will tell you which paragraphs you are actually under. We respond the same day.

Frequently Asked Questions

What are the OSHA lead action level and PEL in general industry?

The action level is 30 micrograms per cubic meter and the PEL is 50 as an 8-hour time-weighted average, under 29 CFR 1910.1025(b) and (c)(1). On shifts longer than 8 hours the limit drops to 400 divided by hours worked, so a 10-hour shift carries a 40 microgram limit.

At what blood lead level is a general industry worker removed?

At or above 60 µg/100 g on a periodic and follow-up test under 1910.1025(k)(1)(i)(A), or when the average of the last three tests is at or above 50 unless the latest is below 40. Construction removes at 50 µg/dL under 29 CFR 1926.62. Return requires two consecutive results below 40.

When does blood lead testing have to start?

When employees are or may be exposed at or above the action level for more than 30 days per year, under 1910.1025(j)(1)(i). Baseline frequency is every 6 months, accelerating to every 2 months once a result reaches 40 µg/100 g and monthly during removal.

Does a removed worker keep getting paid?

Yes. Medical removal protection at 1910.1025(k)(2) maintains earnings, seniority and benefits for up to 18 months per occasion, as though the employee had not been removed.

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