OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 29, 2025

Mr. Patrick Miller
Brodowski, McCurry, Miller & Hoekenschnieder
415-A Church Street, Ste 200
Huntsville, AL 35801

Dear Mr. Miller:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to OSHA's Directorate of Construction for a response. You are seeking a clarification of the term "as free as practicable" regarding lead contamination on surfaces in OSHA's lead standard for construction, 29 CFR §1926.62. This letter constitutes OSHA's interpretation only of the requirements herein and may not be applicable to any question not delineated within your original correspondence. Your paraphrased question and our response are below.

Background: Your request relates to the following requirements in this standard [emphasis added]:

  • 1926.62(h)(1) - All surfaces shall be maintained as free as practicable of accumulations of lead.

  • 1926.62(i)(2)(i) - The employer shall provide clean change areas for employees whose airborne exposure to lead is above the [permissible exposure limit] PEL, and as interim protection for employees performing tasks as specified in paragraph (d)(2) of this section, without regard to the use of respirators.

  • 1926.62(i)(4)(ii) - The employer shall assure that lunchroom facilities or eating areas are as free as practicable from lead contamination and are readily accessible to employees.

You also referenced an existing OSHA letter of interpretation to Frank White, January 13, 2003, which addressed these same requirements of the lead standard and provided recommendations that you believe are now outdated because of the current scientific information regarding lead hazards and more recent federal guidelines for recommended levels of lead dust on surfaces.1

Note: Similar requirements are in OSHA's lead standard for general industry, 29 CFR § 1910.1025, sections (h)(1), (i)(2)(i), and (i)(4).

Question: What is OSHA's position on the decontamination level for lead on surfaces?

Response: The requirement to maintain surfaces "as free as practicable" of lead accumulation is performance oriented. Therefore, the standard does not identify any specific quantitative levels of lead in dust that satisfies the standard. To meet this requirement, the employer must institute a rigorous housekeeping program to keep airborne lead levels below permissible limits and to minimize all exposures to this toxic substance through either inhalation or ingestion.2 This requires the employer to have a regular housekeeping schedule to ensure that surfaces are kept free of accumulations of lead-containing dust that, if disturbed, may become airborne and expose employees to lead. This includes regular cleaning of surfaces in work areas where lead is present, in any changing areas for workers, in any lunchrooms or eating areas, and in break areas, as specified in the Lead standard's paragraphs listed above. The standard uses the term "practicable," as each workplace will have to address different challenges to ensure that lead-surface contamination is kept to a minimum.

The intent of the standard is to maintain surfaces "as free as practicable" from accumulations of lead. This can be accomplished primarily by HEPA (High efficiency particulate air) filtered vacuuming of floors, rafters, and other surfaces, or by methods equally effective in preventing the dispersal of lead into the workplace (e.g., a wet floor scrubber). Re-entrainment of lead dust is an additional source of exposure and one that engineering controls are not generally designed to control. Housekeeping is an exceptionally important provision of the standard as it minimizes hazardous accumulations on surfaces and the re-entrainment of lead dust into the air. Alternative methods to cleaning surfaces may be acceptable if they minimize the likelihood of lead becoming airborne. An example is to encapsulate the lead which may be more effective for difficult areas to keep clean such as rafters or surfaces with deteriorating lead-based paint.

Lastly, OSHA previously recommended the use of HUD's3 previous acceptable decontamination level of 200 µg/ft2 for floors in evaluating the cleanliness of change areas, storage facilities, and lunchrooms/eating areas. Again, the housekeeping requirement is to ensure dust does not build up so much that disturbing it could cause or contribute to employee exposure above permissible limits, but the obligation to keep surfaces free of accumulations is measured by "practicability" since it would be very difficult for employers to determine whether any particular level of accumulation would, if dispersed, result in airborne concentrations over the PEL specified in 29 CFR 1926.62(c)(1). An employer must keep a regular housekeeping schedule adapted to exposure conditions at a particular site. Maintaining surface lead dust levels at or below a specific concentration, such as the HUD acceptable decontamination level, was not adopted into OSHA's final rule.4

Additionally, as requested, OSHA has reviewed its January 13, 2003, interpretation letter that you referenced. We have archived this letter because we determined that it no longer references HUD's current acceptable decontamination level.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To ensure that you are using the correct information and guidance, please consult OSHA's website at www.osha.gov. If you have any further questions, please feel free to contact the Office of Construction Services at (202) 693-2020.

 

Sincerely,

Brian Rizzo, Acting Director
Directorate of Construction

1 See OSHA's letter at https://www.osha.gov/laws-regs/standardinterpretations/2003-01-13-1. This letter referenced an OSHA Instruction, CPL 02-02-058, 29 CFR 1926.62, Lead Exposure In Construction; Interim Final Rule-- Inspection and Compliance Procedures, December 13, 1993. That OSHA Instruction recommended employers use the U.S. Department of Housing and Urban Development's (HUD) recommended level for acceptable decontamination of 200 µg/ft2 for floors in evaluating cleanliness of change areas, storage facilities, and lunchrooms/eating areas

2 See the Lead standard's Appendix A, Substance Data Sheet for Occupational Exposure to Lead, https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.62AppA.

3 HUD's current acceptable level for lead decontamination can be found under 24 CFR 35.1320(b)(2)(i).

4 See Federal Register Vol. 58 No. 84, May 4, 1993, pages 26590-26591 and 26602-26603.