1910.1025(e): Lead Exposure Control Methods
Where workers are exposed to lead above the PEL for more than 30 days a year, employers must use engineering and work practice controls on the Table I schedule unless shown infeasible, adding respirators if controls are not enough. For exposure above the PEL for 30 days or less a year, engineering controls must cut exposure to 200 micrograms per cubic meter, then any mix of controls may keep it at or below 50 micrograms per cubic meter.
Key takeaways
- 1910.1025(e) is part of OSHA's general industry standards (29 CFR Part 1910).
- OSHA cited it 96 times in the last 3 years, in 57 inspections, with $180,552 in current penalties.
- Most citations: PA (14), TN (13), MI (10).
- Related part: 1910.1025(e)(3) Compliance program (39 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1910.1025(e) ("Methods of compliance") is one requirement inside 1910.1025 Lead, an OSHA general industry standard (Part 1910). It includes 26 sub-paragraphs. The official text below is copied word for word from the Electronic Code of Federal Regulations (eCFR). The numbers, injury cases and training on this page show how OSHA enforces it on real job sites.
Official text
(e) Methods of compliance — 96 citations
(1) Engineering and work practice controls. Open (e)(1) 30 citations
(i) Where any employee is exposed to lead above the permissible exposure limit for more than 30 days per year, the employer shall implement engineering and work practice controls (including administrative controls) to reduce and maintain employee exposure to lead in accordance with the implementation schedule in Table I below, except to the extent that the employer can demonstrate that such controls are not feasible. Wherever the engineering and work practice controls which can be instituted are not sufficient to reduce employee exposure to or below the permissible exposure limit, the employer shall nonetheless use them to reduce exposures to the lowest feasible level and shall supplement them by the use of respiratory protection which complies with the requirements of paragraph (f) of this section. Open (e)(1)(i) 28 citations
(ii) Where any employee is exposed to lead above the permissible exposure limit, but for 30 days or less per year, the employer shall implement engineering controls to reduce exposures to 200 µg/m3, but thereafter may implement any combination of engineering, work practice (including administrative controls), and respiratory controls to reduce and maintain employee exposure to lead to or below 50 µg/m3. 2 citations
| Industry | Compliance dates: 1 (50 µg/m 3) |
|---|---|
| Lead chemicals, secondary copper smelting | July 19, 1996. |
| Nonferrous foundries | July 19, 1996. 2 |
| Brass and bronze ingot manufacture | 6 years. 3 |
| 1 Calculated by counting from the date the stay on implementation of paragraph (e)(1) was lifted by the U.S. Court of Appeals for the District of Columbia, the number of years specified in the 1978 lead standard and subsequent amendments for compliance with the PEL of 50 µg/m3 for exposure to airborne concentrations of lead levels for the particular industry. | |
| 2 Large nonferrous foundries (20 or more employees) are required to achieve the PEL of 50 µg/m3 by means of engineering and work practice controls. Small nonferrous foundries (fewer than 20 employees) are required to achieve an 8-hour TWA of 75 µg/m3 by such controls. | |
| 3 Expressed as the number of years from the date on which the Court lifts the stay on the implementation of paragraph (e)(1) for this industry for employers to achieve a lead in air concentration of 75 µg/m3. Compliance with paragraph (e) in this industry is determined by a compliance directive that incorporates elements from the settlement agreement between OSHA and representatives of the industry. | |
(2) Respiratory protection. Where engineering and work practice controls do not reduce employee exposure to or below the 50 µg/m3 permissible exposure limit, the employer shall supplement these controls with respirators in accordance with paragraph (f). 5 citations
(3) Compliance program. Open (e)(3) 39 citations
(i) Each employer shall establish and implement a written compliance program to reduce exposures to or below the permissible exposure limit, and interim levels if applicable, solely by means of engineering and work practice controls in accordance with the implementation schedule in paragraph (e)(1). Open (e)(3)(i) 23 citations
(ii) Written plans for these compliance programs shall include at least the following: Open (e)(3)(ii) 10 citations
(A) A description of each operation in which lead is emitted; e.g. machinery used, material processed, controls in place, crew size, employee job responsibilities, operating procedures and maintenance practices; 3 citations
(B) A description of the specific means that will be employed to achieve compliance, including engineering plans and studies used to determine methods selected for controlling exposure to lead; 2 citations
(C) A report of the technology considered in meeting the permissible exposure limit; 1 citations
(D) Air monitoring data which documents the source of lead emissions;
(E) A detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc.; 1 citations
(F) A work practice program which includes items required under paragraphs (g), (h) and (i) of this regulation; 2 citations
(G) An administrative control schedule required by paragraph (e)(5) of this section, if applicable;
(H) Other relevant information.
(iii) Written programs shall be submitted upon request to the Assistant Secretary and the Director, and shall be available at the worksite for examination and copying by the Assistant Secretary, Director, any affected employee or authorized employee representatives.
(iv) Written programs must be revised and updated at least annually to reflect the current status of the program. 6 citations
(4) Mechanical ventilation. Open (e)(4) 20 citations
(i) When ventilation is used to control exposure, measurements which demonstrate the effectiveness of the system in controlling exposure, such as capture velocity, duct velocity, or static pressure shall be made at least every 3 months. Measurements of the system's effectiveness in controlling exposure shall be made within 5 days of any change in production, process, or control which might result in a change in employee exposure to lead. Open (e)(4)(i) 18 citations
(ii) Recirculation of air. If air from exhaust ventilation is recirculated into the workplace, the employer shall assure that Open (e)(4)(ii) 2 citations
(A) the system has a high efficiency filter with reliable back-up filter; and
(B) controls to monitor the concentration of lead in the return air and to bypass the recirculation system automatically if it fails are installed, operating, and maintained. 1 citations
(5) Administrative controls. If administrative controls are used as a means of reducing employees TWA exposure to lead, the employer shall establish and implement a job rotation schedule which includes: 2 citations
(i) Name or identification number of each affected employee;
(ii) Duration and exposure levels at each job or work station where each affected employee is located; and 1 citations
(iii) Any other information which may be useful in assessing the reliability of administrative controls to reduce exposure to lead.
Source: eCFR, text current as of 2026-10-15. Read all of 1910.1025.
Where and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 3 |
| 2024 | 30 |
| 2025 | 33 |
| 2026 | 30 |
Top states: PA (14), TN (13), MI (10), FL (9), NJ (8)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| SHOOTERS WORLD, LLC | TAMPA, FL | $46,340 |
| NYRSTAR CLARKSVILLE INC. | CLARKSVILLE, TN | $17,500 |
| BLUE TRAIL RANGE | WALLINGFORD, CT | $10,938 |
| A. STUCKI COMPANY | FREMONT, NE | $10,050 |
| THE BUICK RESOURCE RECYCLING FACILITY | BOSS, MO | $9,794 |
Free toolbox talk
A 5-minute crew talk on 1910.1025(e), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Enforcement of the engineering and work practice control provisions of the lead standard, 1910.1025(e)(1). (2004-05-11)
- Stay-of-enforcement of lead standard for brass and bronze ingot manufacturing. (1997-12-31)
- Enforcement criteria for lead monitoring requirements of recirculated air. (1982-09-17)
- Powered air-purifying helmets are personal protective equipment, not engineering controls. (1981-08-13)
Related parts of this rule
- 1910.1025(e)(3) Compliance program 39 citations
- 1910.1025(e)(1) Engineering and work practice controls 30 citations
- 1910.1025(e)(1)(i) 28 citations
- 1910.1025(e)(3)(i) 23 citations
- 1910.1025(e)(4) Mechanical ventilation 20 citations
- 1910.1025(e)(4)(i) 18 citations
- 1910.1025(e)(3)(ii) 10 citations
- 1910.1025(e)(4)(ii) Recirculation of air 2 citations
Get your crew competent
Trainers on Black Belt Safety: Marc Harvey, Dana Reyes
Trainers and suppliers: feature your business on this rule for $25/month.
Frequently asked questions
What is required when lead exposure is above the PEL more than 30 days a year?
Engineering and work practice controls, including administrative controls, to reduce exposure per Table I, unless shown not feasible.
What if controls are not enough?
They must still be used to reduce exposure to the lowest feasible level and be supplemented by respiratory protection under paragraph (f).
What about exposure 30 days or less per year?
Engineering controls must reduce exposures to 200 micrograms per cubic meter, then any combination of controls may be used to reach 50 or below.
About this page
Sources
- 29 CFR 1910.1025 (eCFR), text current as of 2026-10-15
- U.S. Department of Labor enforcement data: OSHA inspections, citations and accident records, copied nightly; data as of 2026-10-21
3-year window. Federal OSHA only; state-plan rules are not counted. Plain-language text is a summary, not legal advice; the official text controls. Black Belt Safety is not part of OSHA or the Department of Labor.