29 CFR 1910.1025: OSHA Lead in General Industry

Regulatory citation: 29 CFR 1910.1025, Lead (General Industry)

What Is the OSHA Lead Standard for General Industry?

Section 1910.1025 covers occupational exposure to lead outside construction and agriculture. It applies to operations such as battery manufacturing, smelting, foundries, soldering, firing ranges and recycling of lead products. The standard sets airborne limits and requires monitoring, controls, respirators, protective clothing, hygiene facilities, medical surveillance, medical removal and training.

Why Lead Exposure Matters

Lead is absorbed by breathing dust and fume or by swallowing it from contaminated hands and food. It builds up in the body and can harm the nervous system, kidneys, blood and reproductive system. Workers can also carry lead dust home on clothing.

Core Obligations

1. Keep Exposure Below the Limits (1910.1025(b) and (c))

The permissible exposure limit (PEL) is 50 micrograms per cubic meter of air (µg/m³) averaged over an 8-hour period. For shifts longer than 8 hours, the limit is 400 divided by the hours worked that day. The action level is 30 µg/m³, measured without regard to respirator use.

2. Monitor Exposure (1910.1025(d))

Employers must make an initial determination of whether any employee may be exposed at or above the action level. Samples must be full-shift personal samples covering at least 7 continuous hours. Where exposure is at or above the action level but at or below the PEL, monitoring is repeated at least every 6 months. Above the PEL, it is repeated quarterly. Monitoring can be reduced or stopped after two consecutive measurements, at least 7 days apart, fall below the relevant level. Employees must be told their results in writing within 15 working days.

3. Use Controls and a Written Compliance Program (1910.1025(e))

Where exposure is above the PEL for more than 30 days a year, engineering and work practice controls must reduce it to the PEL where feasible. Where exposure is above the PEL for 30 days or fewer a year, engineering controls must at least reduce it to 200 µg/m³. A written compliance program is required and must be revised at least annually. Mechanical ventilation must be checked at least every 3 months and within 5 days of a process change that could affect exposure.

4. Provide Respirators and Protective Clothing (1910.1025(f) and (g))

Respirators must be used under a program that meets 29 CFR 1910.134, with HEPA filters on air-purifying respirators. Full facepieces are required where lead causes eye or skin irritation. Where exposure is above the PEL or irritation is possible, protective clothing must be provided at no cost. It must be supplied clean and dry at least weekly, and daily for employees exposed above 200 µg/m³.

5. Keep Surfaces Clean and Provide Hygiene Facilities (1910.1025(h) and (i))

Surfaces must be kept as free as practicable of lead. Compressed air may not be used to clean floors and other surfaces. Where exposure is above the PEL, employers must provide clean change rooms with separate storage, showers at the end of the shift, filtered lunchrooms and handwashing. Food, drink, tobacco and cosmetics are banned in those work areas.

6. Provide Medical Surveillance (1910.1025(j))

Medical surveillance is required for employees exposed at or above the action level for more than 30 days a year. Blood lead and zinc protoporphyrin sampling is done at least every 6 months. It increases to every 2 months for anyone at or above 40 µg/100 g of blood, until two consecutive results are below that level, and monthly during medical removal. Employees with results at or above 40 µg/100 g must be told in writing within 5 working days. Prophylactic chelation is prohibited.

7. Remove Workers With High Blood Lead (1910.1025(k))

An employee must be removed from exposure when a periodic test and a follow-up test both show 60 µg/100 g or more. Removal is also required when the average of the last three tests, or of all tests over the prior 6 months if longer, is 50 µg/100 g or more, unless the last test was at or below 40 µg/100 g. The employee can return after two consecutive results below 40 µg/100 g. Earnings, seniority and benefits must be maintained for up to 18 months for each removal.

8. Train, Post Signs and Keep Records (1910.1025(l) to (n))

Training must be given to everyone exposed at or above the action level and repeated at least annually. Warning signs must be posted in each work area where the PEL is exceeded. Exposure and medical records must be kept for at least 40 years or the duration of employment plus 20 years, whichever is longer.

Common Compliance Approaches

Separate Clean and Dirty Areas

Design the route from the plant floor through change rooms and showers so work clothing never reaches the lunchroom or the parking lot.

Track Blood Lead Trends

Plot each worker's results over time. A rising trend is a signal to check controls and work habits before the removal criteria are reached.

Example: Lead Controls in Practice

A battery recycling plant monitors its grid casting operators and finds exposures of 80 µg/m³. It posts warning signs, issues respirators with HEPA filters and provides daily clean coveralls, change rooms and showers. Its written compliance program schedules new local exhaust hoods. One operator's blood lead reaches 62 µg/100 g, and a follow-up test two weeks later confirms 61. The plant moves him to a low-exposure job at full pay and retests him monthly until two results come back below 40.

Related regulations: OSHA lead in construction, OSHA respiratory protection, OSHA access to exposure and medical records.

Note: Construction work with lead is covered by 29 CFR 1926.62. In July 2025 OSHA proposed changes to the respirator provisions of this standard. Hearings were held in August 2026. No final rule had been issued as of October 2026. State plan states may set stricter rules.

Frequently Asked Questions

What is the difference between the action level and the PEL?

The action level of 30 µg/m³ triggers monitoring, medical surveillance and training. The PEL of 50 µg/m³ is the legal limit, and exceeding it triggers controls, respirators, protective clothing, hygiene facilities and signs.

How often is blood lead tested?

At least every 6 months for covered employees. Every 2 months for anyone at or above 40 µg/100 g, and at least monthly during medical removal.

Does a removed worker lose pay?

No. Medical removal protection keeps earnings, seniority and other rights and benefits in place for up to 18 months for each removal.