December 10, 2024
Understanding California’s Revised Lead Standard Effective January 1, 2025
The Occupational Safety and Health Administration’s (OSHA’s) Lead standard (29 CFR 1910.1025) became effective on February 1, 1979. Since then, Washington, Oregon and federal OSHA have started the rulemaking process to update their lead standards. In 2018, Michigan OSHA became the first state plan program to adopt more stringent blood lead levels for medical removal protection. More recently, the California Department of Industrial Relations’ Occupational Safety & Health Standards Board approved updates to California OSHA’s lead standard. This revised standard will go into effect on January 1, 2025 and will likely have a significant impact on California’s firing range industry.
A summary of the major changes and requirements likely to apply to California shooting ranges and range maintenance companies is listed below. However, employers should review the revised standard in its entirety to better ensure compliance for their operations.
New Terms
Altering or disturbing. Subjecting to a process that may result in the release of lead dust, lead mist, lead fume or other lead particles. Such processes include, but are not limited to, welding, torch cutting, brazing, torch soldering, melting, pouring, spraying, cutting, shredding, crushing, baling, grinding, polishing, machining, drilling, scraping, sanding, abrading, sweeping, raking and shoveling.
Presumed significant lead work (PSLW).
(1) Altering or disturbing material that is:
(A) known to contain lead at a concentration equal to or greater than 0.5% by weight, as a result of material testing or as content listed in a safety data sheet or similar specification sheet; or
(B) reasonably anticipated to contain lead at a concentration equal to or greater than 0.5% by weight. Such materials include, but are not limited to, scrap lead, lead solder, lead bullet fragments and dust, lead sheeting, lead cable housing and lead billets.
(2) Torch cutting any scrap metal.
EXCEPTION: Altering or disturbing material, as specified in this subsection or torch cutting any scrap metal, does not constitute PSLW when the total combined duration of lead exposure resulting from altering, disturbing and torch cutting is less than 8 hours during any 30-day period.
Airborne Lead Dust Exposure Limits
The revised California lead standard lowered the state’s Permissible Exposure Limit (PEL) from 50 micrograms of lead per cubic meter of air (50 µg/mg3) to 10 µg/mg3 as an eight-hour time-weighted average (8-hr TWA) and its Action Level (AL) from 30 µg/mg3 to 2 µg/mg3 as an 8-hr TWA.
Range owners, operators and managers are required to provide their employees with medical examinations, blood lead testing, signage and initial and annual employee training when measured airborne lead dust levels exceed the AL. Engineering (e.g., ventilation, video surveillance, observation windows, control rooms, etc.) and administrative (e.g., worker rotations to limit daily stay time on the range) controls, respiratory protection, written compliance program, protective work clothing and equipment and hygiene facilities (e.g., change rooms, showers, lunchrooms) are required when airborne lead dust exposures exceed the PEL.
Exposure Monitoring
Firing ranges and range maintenance companies must conduct personal airborne lead dust exposure monitoring. The results of this monitoring are independent of respirator use and will be used to determine how much of California OSHA’s lead standard applies to firing range operations. If measured airborne lead dust exposures are recorded to be below the AL, no additional monitoring would be required unless there has been a production, process, control or personnel change which could result in new or additional exposure to lead or whenever the employer has any other reason to suspect a change which may result in new or additional exposures to lead.
If monitoring reveals employee exposure to be at or above the AL, but below 30 µg/m3 as an 8-hr TWA, the employer shall repeat monitoring at least every 12 months. If the exposure monitoring results exceed 30 µg/m3 but below 50 µg/m3, the employer shall repeat monitoring at least every 6 months. If worker exposures are above 50 µg/m3, the employer shall repeat monitoring quarterly. Personal exposure sampling must continue at the above frequencies until at least two consecutive measurements, taken at least 7 days apart, are at or below the corresponding trigger level.
Suggested Airborne Lead Dust Sampling Plan
Indoor and outdoor range owners, operators and maintenance companies are strongly encouraged to conduct the OSHA required airborne lead dust monitoring within their staff’s breathing zone during peak range operations and during range maintenance activities such as trap and target maintenance, lead reclamation, range ventilation filter changes, range cleaning and spent bullet handling.
Interim Protective Measures
Until the employer conducts the required airborne lead dust personal exposure monitoring, they must provide their employees performing , appropriate protective work clothing and equipment (e.g., gloves, full-body coveralls, etc.), medical surveillance (e.g., blood lead testing and medical exams), training and lead signage.
Range owners, operators and maintenance companies required to use these interim protective measures must develop, implement and maintain a written respiratory protection program that includes respirator selection procedures, medical evaluations, training, fit testing and recordkeeping. In addition, all employers falling under these interim protective measures must also conduct the required personal protective equipment (PPE) hazard assessment and related PPE training in accordance with California OSHA regulations.
Medical Removal Protection
The revised California lead standard also lowered the blood lead level (BLL) triggering removal from a lead work area from 50 micrograms per deciliter (50 µg/dL) of whole blood to 30 µg/dL and the return to former work area BLL from 40 µg/dL to 15 µg/dL. Come 2026, range owners, operators and maintenance companies will also need to remove employees from lead work areas when their last two BLLs are at least 20 µg/dL or when the average of all BLLs in the last six months is at least 20 µg/dL. If medical removal occurs, employers are required to document the removals as a “poisoning” on their California/OSHA Log Form 300.
Employee Information & Training
Employees with any occupational exposure to lead must be provided with Appendix A and B of the revised standard. In addition, employers must provide their employees with training covering the methods used to meet the revised standard’s housekeeping and hygiene requirement prior to starting work and at least annually thereafter. A more extensive training program is required when measured airborne lead dust levels exceed the AL.
Technical Assistance Is Available
Indoor and outdoor firing ranges and range maintenance companies are encouraged to contact NSSF’s Compliance Consultant Team should they have any questions related to this revised standard or if they need technical onsite assistance to better ensure compliance with the revised standard.
About the Author
Dale Krupinski is a Certified Industrial Hygienist (CIH) and a Certified Safety Professional (CSP) with more than 20 years of safety and health management experience. His career includes work as an OSHA Compliance Safety and Health Officer at OSHA’s National Office. Dale’s expertise includes OSHA compliance assessments, training and program development in areas including occupational noise, lead management, personal protective equipment, respiratory protection, machine guarding, recordkeeping, ventilation, electrical safety and hazardous substance exposure monitoring. Since 2011, Dale has worked proactively with the shooting range industry to improve occupational safety and health programs. He also provides ranges with technical OSHA citation settlement and related corrective action assistance.
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