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  • Cal/OSHA clarifies lead exposure prevention guidance for the construction industry

    Contributed by FSM Staff

    OAKLAND, CA -- Cal/OSHA has clarified its lead exposure prevention guidance for the construction industry regarding employers’ requirements on protections for employees conducting dry abrasive blasting.

    Cal/OSHA’s amended lead standards for the construction industry (California Code of Regulations, Title 8 Section 1532.1) went into effect on January 1, 2025.  Subsection (d) of the regulation requires employers to perform exposure assessments for employees who may be exposed to lead on the worksite, to determine their employees’ actual exposure. This includes employees who conduct dry abrasive blasting. Until the employer performs the assessment and determines actual employee exposure, the maximum amount of time an employee can conduct dry abrasive blasting is limited to five hours per day, and after January 1, 2030, the amount of time must be limited to 2 hours per day.

    Once the employer has performed the required exposure assessment, there is no limit on the maximum amount of time an employee may conduct abrasive blasting, but the employer must ensure employee exposures are below the permissible exposure limit, taking into consideration the protection provided by respirators I used by employees.

    The permissible exposure limitII for abrasive blasting is 25 micrograms of lead per cubic meter of air until January 1, 2030. After January 1, 2030, the permissible exposure limit is 10 micrograms per cubic meter.

    For example, if employees are correctly using respirators with a protection factor of 1,000 at all times, air concentrations III of lead up to 25,000 micrograms per cubic meter are permitted for abrasive blasting until January 1, 2030. A protection factor of 1,000 would reduce air concentrations of lead at 25,000 micrograms per cubic meter to a concentration of 25 micrograms per cubic meter inside the respirator. Starting January 1, 2030, the maximum air concentration allowed for abrasive blasting will be 10,000 micrograms per cubic meter for employees correctly using a respirator with a protection factor of 1,000 at all times.

    The protection provided by respirators is listed in Table 1 of Section 5144, Respiratory Protection. Below is a copy of the table.


    I The protection factors assigned to respirators are only valid if used in accordance with section 5144.
    II The permissible exposure limit is measured as an eight-hour time-weighted average concentration.
    III Air concentration measured as an eight-hour time-weighted average.


    Section 5144 Table 1 - Assigned Protection Factors 1


    Type of respirator 2

    Quarter mask

    Half mask

    Full facepiece

    Helmet/hood

    Loose-fitting facepiece

    1. Air-Purifying Respirator

    5

    310

    50

     

     

    2. Powered Air-Purifying Respirator (PAPR)

     

    50

    1,000

    425/1,000

    25

    3. Supplied-Air Respirator (SAR) or Airline Respirator

     

     

     

     

     

    Demand mode

    10

    50

     

     

     

    Continuous flow mode

     

    50

    1,000

    525/1,000

    25

    Pressure-demand or other positive-pressure mode

     

    50

    1,000

     

     

    Self-Contained Breathing Apparatus (SCBA)

     

     

     

     

     

    Demand mode

     

    10

    50

    50

     

    Pressure-demand or other positive-pressure mode (e.g., open/closed circuit)

     

     

    10,000

    10,000

     

    Notes

    1. Employers may select respirators assigned for use in higher workplace concentrations of a hazardous substance for use at lower concentrations of that substance, or when required respirator use is independent of concentration.

    2. The assigned protection factors in Table 1 are only effective when the employer implements a continuing, effective respirator program as required by this section, including training, fit testing, maintenance, and use requirements.

    3. This APF category includes filtering facepieces, and half masks with elastomeric facepieces.

    4. The employer must have evidence provided by the respirator manufacturer that testing of these respirators demonstrates performance at a level of protection of 1,000 or greater to receive an APF of 1,000. This level of performance can best be demonstrated by performing a Workplace Protection Factor (WPF) or simulated WPF study or equivalent testing. Absent such testing, all other PAPRs and SARs with helmets/hoods are to be treated as loose-fitting facepiece respirators, and receive an APF of 25.

    5. These APFs do not apply to respirators used solely for escape. For escape respirators used in association with substances covered by substance-specific standards in Title 8, Division 1, Chapter 4, Subchapters 4, 7, and 18, employers must refer to the appropriate substance-specific standards. Escape respirators for other IDLH atmospheres are specified by subsection (d)(2)(B).

    About Cal/OSHA’s Lead Standards
    On February 15, 2024, the Occupational Safety and Health Standards Board approved updates to Cal/OSHA's Lead Standards (California Code of Regulations, Title 8, Sections 1532.1 (for the Construction Industry) and 5198 (for General Industry)). The updated regulations became effective on January 1, 2025.

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