OSHA Reopens Comment Period on Lead Standards Overhaul — August 21 Deadline for Employer Input
OSHA reopened the public comment period on its proposed lead standards revision following ACCSH review. Employers in construction and general industry had until August 21, 2026, to submit comments on changes to respiratory protection requirements under 29 CFR 1910.1025 and 1926.62.
On July 22, 2026, OSHA published a Federal Register notice reopening the comment period on its proposed revisions to the lead standards for both construction and general industry. The reopened comment period — which closes August 21, 2026 — follows a review by the Advisory Committee on Construction Safety and Health (ACCSH), which examined the proposed changes and issued recommendations that are now available in the public rulemaking docket.
For employers in construction, manufacturing, remediation, and other industries where workers may encounter lead, this is a critical window. The proposed rule (Docket No. OSHA-2025-0022) would change how companies manage respiratory protection for lead — and the comment period represents employers' opportunity to shape the final outcome.
Update, September 22, 2026: The reopened comment period closed on August 21, 2026, and OSHA's related deregulatory hearings began August 19. OSHA has not published a final rule, so the current lead standards remain fully enforceable. The guidance below is retained for readers tracking the rulemaking.
Why OSHA Is Revising the Lead Standards
OSHA's lead standards for general industry (29 CFR 1910.1025) and construction (29 CFR 1926.62) are among the oldest substance-specific health standards still in effect. The general industry standard dates to 1978, while the construction standard was established in 1993. Since then, extensive medical research has demonstrated that adverse health effects occur at blood lead levels well below the current triggers for medical removal and return-to-work provisions.
Two separate rulemakings are in play, and employers should not conflate them. In June 2022, OSHA published an Advance Notice of Proposed Rulemaking (ANPRM) under Docket No. OSHA-2018-0004 focused primarily on whether to lower the blood lead level triggers for medical removal; that effort has not advanced to a proposed rule. Separately, on July 1, 2025, OSHA published a Notice of Proposed Rulemaking (NPRM) under Docket No. OSHA-2025-0022 that would revise the lead standards' substance-specific respirator requirements to better align them with 29 CFR 1910.134, with the initial comment period extended through November 1, 2025.
After consulting ACCSH on April 1 and May 19, 2026, OSHA reopened the NPRM's comment period for an additional 30 days to ensure broad stakeholder participation in response to the committee's input.
What the Proposed Rule Would Change
The July 2025 NPRM focuses primarily on updating respiratory protection requirements under the lead standards for both general industry and construction. Here are the key proposed changes:
Updated Respirator Provisions
Under the current standards, the lead-specific respirator tables impose requirements that go beyond — and sometimes conflict with — OSHA's general Respiratory Protection Standard (29 CFR 1910.134). The NPRM proposes to:
- Permit half-mask respirators with appropriate eye and face protection where the standards currently require a full-facepiece respirator
- Remove the HEPA-filter-only requirement, allowing any NIOSH-approved particulate filter suitable for the exposure
- Delete duplicative training paragraphs already covered by 1910.134
OSHA also said it was considering — but not proposing — removing the provisions that let employees request a powered air-purifying respirator (PAPR). Respirator selection would still follow the assigned protection factors in 1910.134.
What the Lead NPRM Does Not Do
The lead NPRM does not change medical evaluation requirements for respirator users. A separate OSHA proposal (90 FR 28463, Docket No. OSHA-2025-0021) would remove the 1910.134(e) medical evaluation requirement for employees who wear only filtering facepiece respirators or loose-fitting PAPRs; that proposal is being considered in OSHA's August deregulatory hearings alongside the lead changes, but it is a different docket with its own record. Medical evaluations would remain required for tight-fitting air-purifying, supplied-air, and self-contained breathing apparatus users under either proposal.
Alignment Across Standards
The proposed changes would harmonize respiratory protection requirements across the lead standards and OSHA's general respiratory protection framework, reducing the number of conflicting or redundant provisions employers must navigate.
Current Lead Exposure Limits and Triggers
For context, the current OSHA lead standards set the following limits — which remain unchanged under the current proposal:
| Requirement | General Industry | Construction |
|---|---|---|
| Permissible Exposure Limit (PEL) | 50 µg/m³ (8-hr TWA) | 50 µg/m³ (8-hr TWA) |
| Action Level | 30 µg/m³ (8-hr TWA) | 30 µg/m³ (8-hr TWA) |
| Medical Removal Trigger | ≥ 60 µg/dL blood lead | ≥ 50 µg/dL blood lead |
| Return-to-Work Level | < 40 µg/dL blood lead | < 40 µg/dL blood lead |
OSHA's 2022 ANPRM explored lowering the medical removal triggers based on newer research, but the 2025 NPRM is limited to respiratory protection modernization. Whether OSHA will advance the blood lead level rulemaking remains an open question — making the record on this round important for employers who want to influence the scope of any final rule.
The ACCSH Review and What It Means
OSHA is required to consult with ACCSH — its advisory committee on construction safety — before finalizing any standard that affects the construction industry. The committee reviewed the proposed lead standard revisions and submitted recommendations, which OSHA has placed in the public rulemaking docket at regulations.gov.
The reopened 30-day comment period exists specifically so that stakeholders can review and respond to ACCSH's input. This is a procedural step, but it carries real significance: comments submitted during this window will directly inform OSHA's final rulemaking decisions on the construction lead standard.
The Bigger Picture: Deregulatory Hearings in August
This lead standards comment period is part of a broader deregulatory initiative under Executive Order 14192, "Unleashing Prosperity Through Deregulation." OSHA has scheduled virtual public hearings beginning August 19, 2026, covering proposed changes to respiratory protection and chemical exposure standards for 16 toxic substances — lead among them.
The hearings will examine proposals to:
- Allow modern respirator types across multiple substance-specific standards
- Remove mandatory medical evaluations for certain low-burden respirator types
- Streamline compliance requirements to reduce employer costs while maintaining worker protections
- Potentially eliminate provisions OSHA considers outdated or redundant
Employers who have a stake in lead exposure compliance should consider both the written comment record (closed August 21) and the hearing process as complementary avenues for input.
What Employers Should Do Now
With the comment period closed and a final rule pending, employers with lead-exposed workers should take the following steps:
1. Audit Your Current Lead Compliance Program
Review your existing lead exposure controls, monitoring schedules, respiratory protection program, and medical surveillance practices. Understanding your current baseline is essential before commenting on — or preparing for — regulatory changes.
2. Review the Proposed Rule and ACCSH Recommendations
Read the proposed rule text through the Federal Register and review ACCSH recommendations in the public docket. Focus on how the proposed respiratory protection changes would affect your operations, costs, and worker safety outcomes.
3. Track the Docket After the August 21 Close
The comment period closed August 21, 2026. Comments filed under Docket No. OSHA-2025-0022 at www.regulations.gov remain public, and OSHA must consider them when drafting any final rule. Watch the docket for post-hearing submissions and for OSHA's final rule notice.
4. Evaluate Your Respiratory Protection Program
Even before the rule is finalized, consider whether your respiratory protection practices are aligned with OSHA's general standard (29 CFR 1910.134). Employers whose lead programs already follow 1910.134's selection, fit-testing, and medical evaluation framework may find the transition straightforward. Those relying on the lead standards' older respirator tables should begin evaluating how half-mask options and broader filter choices would fit their exposure assessments.
5. Continue Full Compliance with Current Standards
The proposed rule is not yet final. Until OSHA publishes a final rule, the existing lead standards — including all current PELs, medical removal triggers, and respiratory protection requirements — remain fully enforceable. OSHA continues to inspect and cite under the lead standards, and lead exposure remains a recurring citation area in construction and manufacturing.
6. Monitor the Deregulatory Hearing Record
Track the record from OSHA's August 19 deregulatory hearings, which will provide additional insight into the agency's direction on chemical exposure standards. For operational planning guidance, BlueHive's 2026 OSHA Changes white paper provides an overview of 2026 OSHA regulatory changes affecting employers.
Industries Most Affected
Lead exposure is not limited to a few sectors. Workers across multiple industries face lead hazards that would be directly affected by these proposed changes:
- Construction — demolition, renovation, and removal of lead-painted structures; lead pipe installation and repair
- Manufacturing — battery production, lead smelting and refining, electronics soldering
- General industry — firing ranges, radiator repair, lead-containing product handling
- Remediation — hazardous waste sites, environmental cleanup of lead-contaminated properties
- Maritime — shipbreaking, painting, and maintenance involving lead-based coatings
Employers in these industries should pay particular attention to how the proposed respiratory protection changes and the potential future revision of exposure limits could affect their compliance obligations and costs.
Key Dates to Track
| Date | Action |
|---|---|
| July 22, 2026 | OSHA reopens comment period on lead standards (91 FR 46027) |
| August 19, 2026 | OSHA deregulatory public hearings began (virtual) |
| August 21, 2026 | Comment period closed — Docket No. OSHA-2025-0022 |
| TBD | OSHA publishes final lead standards rule |
Sources
- OSHA Lead Standards Proposed Rule — Federal Register (July 22, 2026)
- OSHA Lead Standards Rulemaking Background
- Lead Standard — General Industry (29 CFR 1910.1025)
- Lead Standard — Construction (29 CFR 1926.62)
- CDC/NIOSH Lead Information for Employers
- OSHA Lead NPRM — Federal Register (July 1, 2025, 90 FR 28277)
- OSHA Lead Standards Topic Page
- Federal Register Notice — OSHA Deregulatory Hearing Schedule (June 3, 2026)
- OSHA ACCSH Advisory Committee
- OSHA Respiratory Protection Standard (29 CFR 1910.134)
- BlueHive — 2026 OSHA Changes: What Has Taken Effect, What Is Coming
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Frequently Asked Questions
The reopened comment period closed on August 21, 2026 (91 FR 46027). Comments were submitted electronically through the Federal e-Rulemaking Portal at regulations.gov under Docket No. OSHA-2025-0022; OSHA has not yet published a final rule.
OSHA's July 1, 2025 proposed rule (90 FR 28277) would revise the substance-specific respirator provisions in 29 CFR 1910.1025 and 1926.62 to align them with the general Respiratory Protection Standard (29 CFR 1910.134) — for example, by permitting half-mask respirators with appropriate eye and face protection instead of requiring full facepieces, removing the HEPA-filter-only requirement, and deleting duplicative training paragraphs. It does not change the PEL, action level, or blood lead triggers.
OSHA reopened the comment period to give the public an opportunity to review and respond to recommendations made by the Advisory Committee on Construction Safety and Health (ACCSH), which reviewed the proposed lead standard revisions for construction.
The current OSHA permissible exposure limit for airborne lead is 50 micrograms per cubic meter of air as an 8-hour time-weighted average. The action level triggering monitoring and medical surveillance is 30 µg/m³. Medical removal is required at blood lead levels of 60 µg/dL in general industry and 50 µg/dL in construction.
Written comments were accepted electronically at www.regulations.gov under Docket No. OSHA-2025-0022 through August 21, 2026. All comments become part of the public record, and employers can still review the docket and ACCSH recommendations there while awaiting a final rule.
