As an industry leader in environmental consulting, Citadel EHS has extensive experience in dealing with environmentally regulated materials. We aim to keep you informed and prepared for upcoming changes to ensure your workers and subcontractors stay safe and your construction projects run smoothly, on budget, and on time.

We want to inform you about an upcoming change to lead regulations that will significantly impact construction project processes, costs, and staffing for sites containing lead materials—particularly for renovations of buildings built before 1979 and new construction of healthcare and industrial facilities.

Key Changes Effective January 1, 2025

Cal-OSHA is enforcing stricter limits on worker exposure to airborne lead, which will lead to additional requirements for many projects:

• The Permissible Exposure Limit (PEL) will decrease from 50 µg/m³ to 10 µg/m³.
• The Action Limit (AL) will lower from 30 µg/m³ to 2 µg/m³.

With these reductions, more workers will exceed the exposure thresholds, even for tasks that previously met limits. As a result, employers will need to perform more frequent exposure monitoring and increase regulatory compliance efforts, including medical monitoring, respiratory protection, and additional training. Contractor insurance costs and requirements will also increase.

Changes in Training and Certification Requirements

Currently, much construction involving lead-containing paints and coatings does not exceed the PEL, allowing non-hazardous materials trades to handle this work using workers with lead awareness training, typically a 2-hour session.

However, with the new PEL and the increased number of workers exceeding the PEL, a lesser-known provision of the Cal-OSHA lead standard will apply: workers wo are exposed at or above the PEL are required to have California Department of Public Health (CDPH) training and certification as Workers or Supervisors.

• Certified Lead Workers must complete a 24-hour training course and work under a certified Lead Supervisor.
• Lead Supervisors require a 40-hour course plus certification, including a CDPH exam.
• Both roles must fulfill bi-annual continuing education and pay certification fees.

So, what was achievable with a worker with 2 hours of training on December 31, 2024 will in many cases require at least 3 days of training, plus certification, on January 1, 2025.

Impact on Project Scope and Costs

As compliance requirements expand on January 1, 2025, many non-hazardous materials  contractors may no longer accept lead-related work, shifting this responsibility to hazardous materials contractors. This change will increase project complexity, costs, and the need for specialized labor to meet the new Cal-OSHA standards.

In summary, these new regulations mean more extensive safety measures, training, and project planning for any work involving lead materials.

Citadel EHS as Your Partner in Compliance and Safety

At Citadel EHS, we understand the complexities of these regulatory changes and their impact on your operations. Our team of experts is here to help you navigate these updates, ensuring your business remains compliant and your workers are protected. With our extensive experience and commitment to environmental safety, Citadel EHS is your trusted partner in managing lead-based paint regulations and workplace safety standards.

Contact us today to learn more about how we can support your compliance efforts and safeguard your workforce. Together, we can create a safer, healthier environment for everyone.