BACKGROUND: Current occupational rules for lead are outdated and not protective of worker health. In response to a petition, the Washington State Department of Labor and Industries initiated the rulemaking process to update the lead rules to reflect current knowledge of the health effects of lead and to be more protective of workers and their families.
METHODS: Rulemaking stakeholder meetings commenced in October 2015 and have included representatives from state and local government, academic institutions, business, and labor. A preproposal was filed in April 2016 to officially begin the rulemaking process. Stakeholder meetings have included presentations on up-to-date research on lead exposure and health effects, rulemaking efforts in other states, recommendations from local public health agencies, and updates from the Washington State industrial hygiene laboratory and ABLES program. RESULTS: As proposed, Washington State’s new rules for lead would be unified and apply to all industries instead of having separate rules for general industry and construction. This includes trigger tasks currently applicable only to construction industry activities. Rule changes recommended by public health under consideration are similar to those proposed by California. These include: Providing medical surveillance to all workers with potential for lead exposure; reducing the removal from exposure level to a single blood lead test result of 30µg/dl or two successive test results of greater than 20µg/dl; and reducing the maximum permissible exposure limit (PEL) to 10µg/m3 and the action level (AL) to 2µg/m3. Also under consideration is expanding the rules for PPE use and hygiene facilities and practices to cover all workers who may be exposed to lead and not just those exposed at the AL or PEL. According to the state industrial hygiene laboratory manager, exposure assessment quality objectives can be achieved by increasing the volume of air samples collected. The ABLES program reported that between 2002-2014, 74% of elevated (≥25µg/dl) blood lead reports were from workers in three industry sectors with an additional 14% of cases from indoor shooting range industries. CONCLUSIONS: Proposed lead rule changes under consideration in Washington State are focused on preventing lead exposure and maintaining low blood lead levels among all exposed workers. The change to a single unified rule including trigger tasks that apply to all industries will be easier to explain, understand, follow, and enforce.