Cal/OSHA Occupational Lead Exposure Prevention for the Construction Industry

Under the California Labor Code and the California Occupational Safety and Health Act, all employers in California are legally required to provide and maintain a safe and healthy workplace for employees.

The California Code of Regulations, title 8, section 1532.1 Lead (T8 CCR 1532.1), is Cal/OSHA's occupational health standard for lead exposures in the construction industry. Its purpose is to protect employees who may be exposed to lead while performing construction work. Cal/OSHA has a separate standard for lead exposures in General Industry – T8 CCR 5198.

The California Lead in Construction regulation emphasizes an increase in the use of protective measures such as substitution, engineering controls and administrative controls, with the goal of providing greater protection for employees from the hazards of lead exposure. Thus, 1532.1 establishes requirements that are more protective than existing federal regulations.

Who Must Comply with this Standard?

The T8 CCR Section 1532.1 regulation applies to all construction work:

  • Where an employee may be occupationally exposed to lead.
  • Excluded from coverage in the general industry standard for lead by T8 CCR 5198 subsection (a)(2).

Construction work is defined as work for construction, alteration and/or repair, including painting and decorating, including:

  • Demolition or salvage of structures where lead or materials containing lead are present
  • Removal or encapsulation of materials containing lead
  • New construction, alteration, repair, or renovation of structures, substrates, or portions thereof, that contain lead, or materials containing lead
  • Installation of products containing lead
  • Lead contamination/emergency cleanup
  • Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed
  • Maintenance operations associated with the construction activities described in T8 CCR 1532.1 subsection (a)

Worker Exposure

Workers in the construction industry may come into contact with lead when they demolish or salvage buildings with lead or lead-containing materials, remove or encapsulate lead-containing materials, build new buildings with lead or lead-containing materials, or install products containing lead. There are also construction-related activities that may expose workers to lead, such as the transportation, disposal, storage, or containment of lead or materials containing lead on construction sites, and the maintenance operations associated with construction activities.

Who is Most at Risk?

Workers involved in the types of work listed below could be at risk of lead exposure and include:

  • Iron work
  • Demolition
  • Painting and painting-prep
  • Lead-based paint abatement
  • Heating and air conditioning maintenance and repair
  • Electrical
  • Carpentry
  • Renovation
  • Remodeling
  • Plumbing

Plumbers, welders, and painters are among those workers most exposed to lead.

T8 CCR Section 1532.1 lists certain tasks that may likely result in exposures to lead above the Permissible Exposure Limit (PEL) and, in some cases, exposures more than 50 times the PEL. These tasks are known as trigger tasks and are described in the Glossary section of this guide.

Workers at the highest risk of lead exposure are those involved in Level 3 trigger tasks, which include:

  • Using lead-containing mortar
  • Lead burning
  • Tasks where lead-containing coatings or paint are present:
    • Rivet busting
    • Power tool cleaning, grinding or sanding without dust collection systems
    • Cleanup activities where dry expendable abrasives are used
    • Abrasive blasting enclosure movement and removal
    • Abrasive blasting*
    • Welding
    • Torch cutting
    • Torch burning

*To limit employee exposure to lead, the maximum amount of time an employee can conduct dry abrasive blasting is limited to 5 hours per day, except that after January 1, 2030, the amount of time must be limited to 2 hours per day.

Other operations, where lead-containing coatings or paint are present, with the potential to expose workers to lead include Level 1 and 2 tasks, such as:

  • Manual demolition of structures (e.g., dry wall)
  • Manual scraping
  • Heat gun applications
  • Manual sanding
  • Power tool cleaning, grinding or sanding with dust collection systems
  • Spray painting with lead paint

November 2024