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Lead-contaminated dust from chipped or peeling lead-based paint is one of the most common causes of elevated blood lead levels in children. Infants and children are especially vulnerable to lead paint exposure, because their growing bodies absorb more lead than adults and their brains and nervous systems are more sensitive to the damaging effects of lead. Lead dust can be generated when lead-based paint deteriorates or is disturbed.

On June 21, 2019, the Environmental Protection Agency (EPA) and the Department of Housing and Urban Development (HUD) announced that there will be changes to the lead standard decreasing allowable lead dust levels on floors and windowsills.  This marks nearly two decades since the EPA and HUD has issued a tougher, more protective standard aimed at protecting children from the effects of lead exposure in housing and child-occupied facilities constructed before 1978.   

Since the EPA set standards for lead in dust in 1991, multiple studies have shown health effects exist at lower blood levels than previously thought.  Through the Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health Impacts (Lead Action Plan), the EPA final rule changed the dust-lead hazard standards to 10 µg/ft2 and 100 µg/ft2 on floors and windowsills, respectively.  This represents a significant reduction from current allowable levels of 40 µg/ft2 for floors and 250 µg/ft2 for windowsills.

The more protective dust-lead hazard standards are consistent in their current application, applying to inspections, risk assessments, and abatement activities in pre-1978 housing and certain schools, childcare facilities and hospitals across the country.

The standard change, while not officially announced, will likely coincide with acceptable workplace lead dust levels.  A 2003 OSHA interpretation on lead-contaminated dust on workplace surfaces related to the Lead-in-Construction Standard (CFR 1926.62) specially mentions EPA HUD’s lead-in-dust floor level. This interpretation specifically addressed evaluating cleanliness of change rooms, storage facilities and lunchrooms/eating areas where the lead-in dust level is recommended.   One would have to presume the new lead dust standard will apply to this segment of OSHA and be welcomed by its workers.

Standard changes will officially take place 180 days following the date of publication in the Federal Register.

If you have any questions regarding the EPA and HUD lead regulations, or need assistance with lead-based paint management, please contact me at (919) 459-5257 lrockefeller@ei1.com.