Cal/OSHA has completed several significant occupational health rule-makings over the past year and has outlined an active agenda through 2027. Below is a summary of key regulatory updates and proposed changes that may affect your operations.

Recently Completed Rulemaking (2024–2025)

1. Respiratory Protection – Fit Testing (§5144 Appendix A)

Effective June 24, 2024, Cal/OSHA adopted new quantitative fit testing protocols. The revised method shortens the testing sequence from eight exercises to four, while maintaining the same equipment and procedures. The changes align with federal OSHA Appendix A.

2. Lead Standards (§1532.1, §5155, §5198)

Effective January 1, 2025, California significantly lowered occupational exposure limits for lead in construction and general industry:

• Action level reduced to 2 µg/m³
• Permissible Exposure Limit (PEL) reduced to 10 µg/m³
• Medical removal triggered at 2 tests ≥ 20 µg/dL or 1 test ≥ 30 µg/dL
• Return-to-work level lowered to 2 tests < 15 µg/dL

Employers with potential lead exposure should ensure monitoring, medical surveillance, and compliance programs reflect these new thresholds.

3. Indoor Heat Illness Prevention (§3396)

Effective July 23, 2024, heat illness prevention requirements were expanded to indoor workplaces. The regulation mirrors the outdoor heat standard and includes requirements for water, cool-down areas, assessment and control measures, acclimatization, emergency response procedures, training, and a written Heat Illness Prevention Plan.

4. Silica – Countertop Fabrication (§5204)

Permanent regulations took effect February 2, 2025. The rule requires wet methods, high-level respiratory protection (1,000 APF), housekeeping controls, and medical removal protections regardless of measured exposure levels. Enforcement focus remains high due to ongoing silicosis cases associated with engineered stone fabrication.

Planned and Ongoing Rule-making (2025–2027)

Cal/OSHA’s rule-making agenda includes several additional topics that may impact employers:

1. First Aid Kits (§1512 & §3400) – Proposed updates would require kit contents to be determined by a physician or comply with ANSI/ISEA Z308.1-2021, with weekly inspections and hazard-based evaluation of additional supplies.
2. Heat Illness Prevention (AB 2243) – Revisions under consideration include mandatory distribution of Heat Illness Prevention Plans to employees and expanded acclimatization protections.
3. Wildfire Smoke (§5141.1) – Proposed revisions may lower the Air Quality Index threshold for mandatory respiratory protection for farmworkers and adjust respiratory program requirements.
4. Permissible Exposure Limits (PELs) – A proposed reduction of the Trichloroethylene (TCE) PEL from 25 ppm to 0.2 ppm is under review to address cancer risk concerns.
5. Workplace Violence – General Industry (§3343) – Rulemaking required by SB 553 would formalize workplace violence prevention program requirements for general industry employers, similar to existing healthcare standards.
6. Process Safety Management – Refineries (§5189.1) – Proposed revisions would expand applicability to facilities producing renewable fuels by removing the word “petroleum” from the regulation.
7. Opioid Reversal Medications – Proposed requirements would mandate that certain employers maintain opioid reversal medications onsite and provide employee training.
8. Healthcare-Specific Rule-making – Additional regulatory efforts are underway addressing:

• Surgical plume exposure
• Workplace violence prevention enhancements (including weapon detection requirements)
• Hazardous drug handling standards
• Firefighter respiratory protection technology development

9. Naturally Occurring Asbestos (NOA) – Separate construction-specific rule-making is being developed to address exposures to naturally occurring asbestos.

Next Steps for Employers

Given the volume and scope of regulatory activity, we recommend:

• Reviewing written programs for heat illness, respiratory protection, lead, and silica compliance
• Evaluating exposure monitoring and medical surveillance practices
• Monitoring draft regulations and advisory committee updates
• Preparing for expanded workplace violence prevention requirements

Citadel EHS continues to monitor Cal/OSHA developments closely and can assist with program updates, exposure assessments, training, and compliance planning.

If you have questions regarding how these changes may affect your organization, please contact our team.