OSHA Advanced Notice of Proposed Rulemaking for Lead Standards

NSPCA URGENT UPDATE: Make Your Voice Heard

August 10, 2022

The U.S. Department of Labor announced June 28, 2022 that OSHA has published an Advance Notice of Proposed Rulemaking (ANPR) to revise its standards for occupational exposure to lead. OSHA has signaled intent for major changes to the OSHA Lead in Construction and General Industry Standards, and is seeking comments from stakeholders by October 28, 2022.


Expected Proposed / Final Rule for Construction

Based upon information discussed in the ANPR, the questions asked, and increasing data on health effects related to low-level chronic exposures, NSPCA expects the following key changes or similar:

Medical Surveillance

  • Blood Lead Level (BLL) limits of 10-20 micrograms per deciliter (μg/dL).
  • New triggers for initial BLL testing
  • Increased testing frequency (monthly or bi-monthly) if certain levels are exceeded
  • Removal of zinc protoporphyrin (ZPP) testing

Medical Removal
At 20-30 μg/dL, one high BLL above the threshold and/or repeated elevated values

Return to Work
2 BLLs, taken 2 weeks apart, below 15 μg/dL

Permissible Exposure Limit (PEL)

  • 10 – 20 μg/m3 as 8-hour time weighted average (TWA)
  • Action Level at ½ the PEL, 5-10 μg/m3 as 8-hour time weighted average (TWA)

Questions for Employers / Opportunities for Comment

OSHA will accept comments through October 28, 2022 and has put together a list of over 60 specific questions on which it is seeking input. The brief comment period signifies rapid movement from ANPR to the final rule.

NSPCA will provide a response on behalf of our membership consolidated by our Technical Advisor Alison B. Kaelin. We intend to provide information to OSHA regarding:

  • Abrasive blast cleaning and other surface preparation methods
  • Containment
  • Ventilation
  • Work practices we currently use
  • Types of exposures we experience
  • Our recommendations regarding proposed levels

We need your help to make sure YOUR opinions are represented.

Please provide us with your answers to the OSHA questions (and any available backup data) so that we can consolidate and summarize your answers and respond to OSHA. We will not identify any individual companies or persons; we will instead provide general references, such as “from a New York industrial painting company.”

Download the OSHA questionnaire here.

Complete and return the form to Alison at abkaelin@comcast.net.

Submit no later than October 14, 2022 to allow time for compilation.

Contact Alison with questions via email or (412) 841-7260.

Thank you for your time and contributions. NSPCA values your input.

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National Steel Painting Contractors Association

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165 Warsaw St.
Depew, New York 14043

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