OSHA Lead Exposure Limit
What is the OSHA PEL for lead?
For inorganic lead, the OSHA PEL is 0.05 mg/m³ (50 µg/m³) as an 8-hour TWA, with an action level of 0.03 mg/m³. It is set by the lead standard at 29 CFR 1910.1025, not by Table Z-1 [1].
Where the limit sits
- Table Z-1 of 29 CFR 1910.1000 lists "Lead, inorganic (as Pb); see 1910.1025" (CAS 7439-92-1) but gives no number of its own. It sends you to the lead standard [2].
- OSHA's chemical database gives the PEL-TWA as 0.05 mg/m³ with a 0.03 mg/m³ action level. Lead has no OSHA skin notation [1].
What counts as "lead"
- OSHA's definition covers elemental lead, all inorganic lead compounds, and organic lead compounds called lead soaps. Other organic lead compounds are not covered [1].
- Two organic leads have their own Table Z-1 PELs. Tetraethyl lead and tetramethyl lead are each 0.075 mg/m³ (as Pb), with a skin designation [3][4].
Nonferrous foundries
- Large foundries (20 or more employees) must reach the 0.05 mg/m³ PEL through engineering and work-practice controls.
- Small foundries (fewer than 20 employees) only have to reach 0.075 mg/m³ by those controls [1].
Other limits for comparison (all 0.05 mg/m³, as Pb)
- NIOSH REL. NIOSH also aims to keep workers' blood lead below 0.06 mg Pb/100 g of whole blood.
- ACGIH TLV-TWA (1991).
- Cal/OSHA PEL (Section 5198) [1].
The IDLH is 100 mg/m³ [1].
Approach: I checked OSHA's 29 CFR 1910.1000 Table Z-1, the annotated PEL tables and the OSHA Occupational Chemical Database entry for lead. These cover the general industry standard (1910.1025); I did not separately check the construction lead standard.
What's the action level?
The OSHA action level for inorganic lead is 0.03 mg/m³ (30 µg/m³). It sits next to the 0.05 mg/m³ 8-hour TWA PEL in OSHA's lead entry, which points to 29 CFR 1910.1025 [1].
It covers the same substances as the PEL: elemental lead, all inorganic lead compounds, and the organic lead compounds called lead soaps. Other organic lead compounds are not covered [1].
OSHA's entry gives only the number. It doesn't say which duties under 1910.1025 start at the action level. That would come from the text of the standard itself, which I didn't open for this answer.
Approach: I checked the lead entry in the OSHA Occupational Chemical Database, which covers the general industry lead standard. I did not check the construction lead standard.
How does Cal/OSHA compare?
Cal/OSHA is now much stricter than federal OSHA. Since the amendments that took effect January 1, 2025, California's lead PEL is 10 µg/m³ and its action level is 2 µg/m³ (8-hour TWAs). Federal OSHA is still at 50 µg/m³ and 30 µg/m³. That makes California's PEL 5 times lower and its action level 15 times lower.
| Federal OSHA (29 CFR 1910.1025) | Cal/OSHA general industry (T8 §5198) | Cal/OSHA construction (T8 §1532.1) | |
|---|---|---|---|
| PEL (8-h TWA) | 50 µg/m³ (0.05 mg/m³) | 10 µg/m³ | 10 µg/m³ (abrasive blasting: 25 µg/m³ until January 1, 2030) |
| Action level (8-h TWA) | 30 µg/m³ (0.03 mg/m³) | 2 µg/m³ | 2 µg/m³ |
| Scope | Elemental lead, inorganic compounds, lead soaps | Metallic lead, all inorganic compounds, organic lead soaps; excludes construction and agriculture | Construction |
Federal figures are from OSHA's lead entry [1]. California figures are from the official Title 8 texts of §5198 and §1532.1.
Other changes in the California rules
- Medical removal: both sections still require removal when the last blood lead test is at or above 30 µg/dl. From January 1, 2026 they also require removal when either of these is at or above 20 µg/dl:
- When the change took effect: both sections were last amended in a filing dated April 8, 2024 (Register 2024, No. 15), which became operative January 1, 2025.
The OSHA database is out of date for California. OSHA's chemical database still shows the Cal/OSHA PEL for lead as 0.05 mg/m³ (dust and fume, as Pb), with no skin notation. That entry was last updated on June 15, 2023, before the California amendments [1]. The current Title 8 text is the figure to use.
Approach: I checked the OSHA Occupational Chemical Database and the GESTIS international limit values. GESTIS has US limits only from OSHA and NIOSH, with no California entry. Because no Cal/OSHA table is in the datasets, I took California's current limits from the official Title 8 text on the California Department of Industrial Relations site.