Important Updates for Lead Professionals: New EPA Dust-Lead Standards and Regulations

On November 12, 2024, the U.S. Environmental Protection Agency (EPA) announced significant revisions to the dust-lead hazard standards (DLHS) and dust-lead clearance levels (DLCL). These changes aim to better protect children and adults from lead exposure and align with the latest science and court rulings. As a lead professional, it is essential to understand how these updates affect your responsibilities.

Key Highlights of the New EPA Rule

1. Revised Standards for Lead in Dust:

   • Dust-Lead Reportable Level (DLRL) (formerly DLHS):

     • Hazardous lead dust is now considered to be at any reportable level as analyzed by an EPA-recognized laboratory.

   • Dust-Lead Action Level (DLAL) (formerly DLCL):

     • New clearance levels for lead in dust:

       • Floors: 5 µg/ft²

       • Window sills: 40 µg/ft²

       • Window troughs: 100 µg/ft²

2. New Definitions and Compliance Requirements:

   • The updated rule now bases the DLRL strictly on health factors and the DLAL on safety, effectiveness, and reliability.

   • The definition of "abatement" has been revised to require action when dust-lead levels meet or exceed the DLAL, rather than the previous DLHS threshold.

3. Effective Dates:

   • The rule takes effect on January 13, 2025.

   • Compliance with the revised standards is required by January 12, 2026.

4. Electronic Submissions Required:

   • Beginning January 13, 2025, all applications, payments, and notifications must be submitted electronically via the EPA’s Central Data Exchange (CDX) system.

Implications for Lead Professionals Firms Conducting Lead-Based Paint Activities:

• Risk Assessors and Inspectors:

  • Compare dust sampling results for floors and window sills to the DLRL (any reportable level).

  • Ensure post-abatement dust sampling results meet the new DLAL levels (5/40/100 µg/ft²).

  • Include EPA-required language in abatement reports if post-abatement dust-lead loadings fall between the DLRL and DLAL.

• Abatement Projects:

  • Firms may need to conduct additional cleaning to meet the stricter clearance levels.

  • Follow the new definition of "abatement" to recommend actions at or above the DLAL threshold.

Firms Conducting Renovation, Repair, and Painting (RRP) Activities:

• Perform optional dust-lead clearance testing when applicable.

• Compare post-renovation dust sampling results to the revised DLAL standards.

• Reclean and retest any areas where results exceed the action levels until clearance is achieved.

General Requirements for All Firms:

• Stay informed of state and local lead-based paint program updates, which must meet or exceed EPA’s standards.

• Be prepared for potential increases in abatement and cleaning demands due to the stricter standards.

Additional Updates

• Target Housing Definition:

  • Now includes zero-bedroom dwellings if a child under six years old resides or is expected to reside.

• Child-Occupied Facilities:

  • Consistently defined as facilities where children under six years old are present.

Next Steps for Compliance

1. Understand the New Standards:Familiarize yourself with the updated DLRL and DLAL thresholds and how they impact your work.

2. Update Procedures and Training:Ensure your staff is trained to comply with the new standards and uses EPA-recognized laboratories for analysis.

3. Transition to Electronic Submissions:Prepare to submit all documentation via EPA’s CDX system by the January 2025 deadline.

4. Monitor State and Local Requirements:Check for additional requirements from your state, territory, or Tribal lead program.

For more information, visit the EPA’s website on Lead Hazard Standards and Clearance Levels. If you have any questions, contact the National Lead Information Center at 1-800-424-LEAD [5323].

Together, we can help reduce lead exposure risks and create safer environments for all.