OSHA Lead Standards Compared: 1926.62 vs 1910.1025 (2026 Guide)

Which OSHA lead standard applies, and what changes between them?

Short answer: construction work runs on 1926.62 and general industry on 1910.1025. Both set a 50 µg/m³ PEL and a 30 µg/m³ action level. The two real differences are that construction presumes exposure from twelve named tasks before anyone samples the air, and that the blood lead level forcing a worker off the job is 50 in construction and 60 in general industry. Both return a worker at 40.

Lead is one of a handful of hazards OSHA regulates twice, and the two standards are not a copy with the numbering changed. Section 1910.1025 dates from 1978 and is built for fixed workplaces with stable processes and repeatable sampling. Section 1926.62 was issued in 1993 for work that moves from structure to structure, where the job may be over before a laboratory returns a result. That difference in setting produced a different machine.

Why this matters.
The construction standard’s presumption is the part employers most often miss, and it is the part that decides whether workers are protected on day one. Start torch-cutting a lead-painted structure and you are required to treat the exposure as above 2,500 µg/m³ — fifty times the PEL — with the respiratory protection, clothing, hygiene facilities and biological monitoring that implies, until you have sampled and documented otherwise. There is no grace period while the results come back.

The construction presumption: three tiers of interim protection

Where lead is present and the work is one of the listed tasks, 1926.62(d)(2) requires the employer to treat the employee as exposed at the stated level until an exposure assessment documents otherwise. This is interim protection, and it attaches from the first hour of work.

The blood-lead ladder, and the number that differs

Biological monitoring is what actually governs a lead programme in practice, because it measures the dose that reached the worker rather than the dust in the air. Here the two standards diverge at the most consequential point.

Read the highlighted rows together. A construction worker at 55 µg/dl comes off the job; a general industry worker at the same level does not, unless their three-test average has reached 50. Both return at 40. An employer running one written programme across both kinds of work will get one of the two wrong, and it is normally the construction side that gets under-protected.

What both standards demand once the programme starts

• Engineering and work practice controls first — respirators are what is left after feasible controls, not a substitute for them.
• Respiratory protection under 1910.134, with medical evaluation, fit testing and a written programme.
• Protective clothing provided and cleaned by the employer, with contaminated clothing never taken home — the take-home pathway is how lead reaches workers’ children.
• Hygiene facilities — change areas, showers where feasible, hand-washing facilities, and eating areas kept free of lead.
• Housekeeping — no dry sweeping or dry brushing where vacuuming or other exposure-minimising methods are feasible; no compressed air unless paired with a ventilation system that captures the dust cloud. HEPA filtration for vacuuming.
• Training at initial assignment and at least annually, covering the hazard, the controls, the medical surveillance programme and the removal benefits.
• Signs marking lead work areas — see OSHA safety sign requirements.
• Records retained 40 years or duration of employment plus 20 years, whichever is longer, under 1910.1020.

Frequently asked questions

What is the OSHA permissible exposure limit for lead?

50 µg/m³ as an 8-hour time weighted average, in both 1910.1025 and 1926.62, with an action level of 30 µg/m³. The action level is defined without regard to respirator use, so putting workers in respirators does not switch off the programme duties it triggers.

Which lead standard applies to my work?

1926.62 if the work is construction — demolition, removal, surface preparation for repainting, new construction, alteration, repair, renovation, installation, or the transport, disposal and storage of lead materials on that site. 1910.1025 for general industry. Lead abatement in a factory is still construction work. The OSHA standards index maps every such pairing between the two parts.

What are the lead trigger tasks in construction?

Twelve tasks listed at 1926.62(d)(2) that force interim protection before any air sampling exists, at three presumed exposure levels. The lowest tier presumes exposure above the PEL but no more than ten times it; the middle tier presumes above 500 µg/m³; the top tier presumes above 2,500 µg/m³. The table below sets all three out.

Does general industry have trigger tasks like construction?

No, and this is the single largest structural difference between the two standards. 1910.1025 requires an initial determination of whether any employee may be exposed at or above the action level, but it does not presume exposure from the nature of a task. Construction added the presumption because lead work there is short-duration and mobile, and waiting for sampling results would leave workers unprotected through the job.

At what blood lead level must a worker be removed from lead work?

This is where the two standards genuinely differ. Under construction 1926.62(k)(1)(i), removal is required when a periodic and a follow-up test both show a blood lead level at or above 50 µg/dl. Under general industry 1910.1025(k)(1)(i), the threshold is 60 µg per 100 g of whole blood, or a three-test average at or above 50.

When can a removed worker return to lead work?

When two consecutive blood sampling tests indicate a blood lead level at or below 40. That return figure is the same in both standards, which is what makes the different removal thresholds so easy to miss — the exit door is in the same place, the entrance is not.

What is medical removal protection benefits?

An employee removed from lead exposure keeps their earnings, seniority and other employment rights and benefits as though they had not been removed, for up to 18 months. It is a wage-protection provision, and its purpose is to stop workers from concealing symptoms or declining biological monitoring to keep their pay.

How often must blood lead levels be tested?

In construction, for employees exposed at or above the action level on any day, at least every 2 months for the first 6 months and every 6 months thereafter. Where the last result was at or above 40 µg/dl, at least every 2 months until two consecutive tests come back below 40. Employees removed for an elevated level are tested at least monthly during removal.

What happens after a high blood lead result?

A follow-up test must be provided within two weeks of the employer receiving a result at or above the removal criterion. Removal is triggered by the periodic and the follow-up together, which is why a single high reading does not by itself remove someone — and why delaying the follow-up delays a protection the worker is owed.

Is lead paint removal always regulated?

If lead is present and the work is one of the listed tasks, the interim protection duties attach immediately, whatever the actual air concentration turns out to be. For tasks not on the list, the duty attaches where the employer has any reason to believe exposure may exceed the PEL. Testing the coating first is the only way to establish that lead is not present.

What respirator is required for lead work?

It depends on which presumed-exposure tier the task sits in until sampling replaces the presumption. The top tier — abrasive blasting, welding, cutting and torch burning on lead-coated structures — presumes 2,500 µg/m³, which is 50 times the PEL and demands a very high assigned protection factor. Selection runs through 1910.134; see best respirator cartridges for lead abatement.

Does the lead standard cover take-home exposure?

Yes, indirectly and seriously. Both standards require change areas, prohibit removing contaminated clothing from the workplace except by employees designated to launder it, require the employer to provide and clean protective work clothing, and require showers where feasible. Take-home lead poisoning of children in workers’ households is the hazard those provisions exist to prevent.

Is there an action level trigger for medical surveillance?

Yes, and construction sets two. Under 1926.62(j)(1)(i) initial biological monitoring is owed to anyone exposed at or above the action level on any single day, and under (j)(1)(ii) the full surveillance programme attaches at more than 30 days in any consecutive 12 months. General industry has only the second trigger, at more than 30 days per year — so a one-day construction exposure earns a blood test that the same exposure in a factory would not.

Can compressed air be used to clean up lead dust?

No, unless it is used together with a ventilation system that effectively captures the dust cloud. Both standards also prohibit dry sweeping and dry brushing where vacuuming or other methods that minimise exposure are feasible. HEPA filtration is the required standard for vacuuming.

Does OSHA require lead training?

Yes, for every employee subject to exposure at or above the action level and for anyone exposed to lead compounds that can cause skin or eye irritation, at initial assignment and at least annually thereafter. The training has to cover the specific hazards, the engineering and work practice controls, the purpose and description of the medical surveillance programme, and the medical removal provisions including the benefits.

How does the lead PEL compare to current health guidance?

Poorly. The 50 µg/m³ PEL and the removal thresholds date from 1978 for general industry and 1993 for construction, and were set against a blood-lead understanding that public health guidance has since moved well below. Several states operate lower thresholds under state plans. The PEL is a legal floor, not a health-based target — the same gap described in how Table Z and the PEL math work.

What records must be kept for lead exposure?

Exposure monitoring records for at least 40 years or the duration of employment plus 20 years, whichever is longer, and medical surveillance and medical removal records for the same period, under 1910.1020. Medical removal records must identify each removal, the reason, and whether the removal was due to an elevated blood lead level.

Does a negative air sample end the interim protection?

It ends the presumption for that task, provided the employer performs and documents an exposure assessment showing the employee is not exposed above the relevant level. Until that documentation exists, the presumption governs — and the burden of producing it sits with the employer, not with the inspector.

Further reading on this site

• best respirator cartridges for lead abatement — filter selection against the presumed-exposure tiers above.
• how Table Z and the PEL math work — why a 1978 PEL is a legal floor rather than a health target.
• the four asbestos work classes of 1926.1101 — the other construction health standard that presumes hazard from the work rather than the air.
• Tyvek vs Tychem coveralls — the protective clothing side of the hygiene requirements.
• how to choose a half mask respirator — facepiece selection for the lower tiers.
• when does OSHA require a respirator — the general trigger test across Subpart Z.
• how to use chemical paint strippers safely — the alternative to mechanical removal, and its own hazards.
• OSHA bloodborne pathogens standard — the other Subpart Z standard built around biological monitoring and records that outlive employment.
• best respirator cartridges for spray painting — relevant where spray painting with lead paint puts the job in Tier 1.
• OSHA HazCom program requirements — the labelling duties that run alongside the lead-specific signs.
• OSHA standards index — every 29 CFR section indexed, with the general industry vs construction crosswalk.