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California Code of Regulations, Title 8 (T8 CCR), section 1532.1 (“Lead”) applies to all construction work where an employee may be occupationally exposed to lead. All construction work excluded from coverage by section 5198 (Lead standard for general industry) is covered by section 1532.1.

Cal/OSHA developed this model program to assist employers engaged in construction activities, as defined by section 1502(a), with creating their written lead compliance program. This includes activities where lead-containing materials are altered or disturbed, such as the following:

  • Demolition or salvage of structures
  • Removal or encapsulation of materials
  • New construction, alteration, repair, or renovation of structures, substrates, or portions thereof.
  • Installation of products
  • Contamination/emergency cleanup
  • Transportation, disposal, storage, or containment of materials on the site at which construction activities are performed
  • Maintenance operations associated with the construction activities described in section 1532.1.

Employers are not required to use this model program, but if they do, the person with authority and responsibility for implementing the worksite written lead compliance program must do the following:

  • Carefully review all the elements of section 1532.1.
  • Ensure that this compliance program addresses the specific type of jobsite, and the lead hazards encountered. Depending on the circumstances, this may require separate compliance programs for each jobsite. Using it will not guarantee that it will meet regulatory requirements. However, it should save some development time.

Construction employers have the option of using this template or modifying it so that it effectively addresses the required elements, as outlined in this model and section 1532.1. Using this template is not required and employers may alternatively use a different lead compliance program template or develop their program from scratch.

For more information, review through the informational flyer from Cal/OSHA. We've also prepared a Compliance Program Template to assist in implementing the new regulations. Download this template (word doc) using the button below, remember to check your download folder after clicking on the document link.