MINNESOTA OSHA LEAD IN CONSTRUCTION STANDARD DRAFT REVISIONS
Date postedApril 15, 2026
In August 2025, MN OSHA released drafts of revised lead standards for the construction and general industries. These proposed revisions follow updated lead regulations in Michigan and California and proposed regulations in Washington. While similar, these reduce the Action Level rather than the Permissible Exposure Limit.
The draft regulations and 3 Appendices can be located at: MNOSHA lead rulemaking | Minnesota Department of Labor and Industry.
Some key changes include the following:
• Scope – clean-up, transportation and disposal and other tasks have been added.
• Definitions
o Action Level – reduced to 10 micrograms per cubic meter (µg/m3) as an eight-hour Time Weighted Average vs. 30 µg/m3 8-hour TWA.
o Altering and disturbing lead was added to definition
• Level 1, 2 and 3 trigger tasks and trigger levels revised lower
o Level 1 – 30 to 300 µg/m3 8-hour TWA vs. 50 to 500 µg/m3 8-hour TWA – Any presumed exposure to lead above Action Level of 10
o Level 2 – 300 to 500 µg/m3 8-hour TWA vs. 500-2,500 µg/m3 8-hour TWA – when lead paint is present, manual sanding and power tool cleaning, grinding or sanding without dust collection
o Level 3 – greater than 500 µg/m3 8-hour TWA vs. greater than 2,500 µg/m3 8-hour TWA – lead burning, when lead paints are present, rivet busting, power tool cleaning, grinding, or sanding without dust collection, clean up of dry abrasives, abrasive enclosure movement and removal, abrasive blasting, torch cuttiing and burning.
• Interim controls
o Shower facility for Level 3 tasks
o Regulated areas
o Limitations on duration of blasting (5 hours)
• Testing of surface coating and material (0.06% considered lead)
• Medical Surveillance – automatic, with exceptions for Level 1 tasks.
o Frequency of testing and threshold for medical testing and removal revised
▪ Monthly for exposures above 500 µg/m3 8-hour TWA
o Emergency plans for exposures over 10 µg/dL
• Medical Removal – at 30 µg/dL and 20 µg/dL dependent upon frequency of testing
o When voluntary removal is performed, employer must provide medical protection benefits
• Medical exam – required at BLL of 20 µg/dL
• Training to include recommendation to take a shower immediately upon return home
Appendix C provides summary tables of the medical surveillance and removal requirements.