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Changes Coming to U.S. Hazard Communications, California Lead Rules

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Significant changes are expected for U.S. federal hazard communications and for lead standards in California, and industrial painters should be especially vigilant because the impacts could be dramatic, a regulatory expert said during the 2024 AMPP Annual Conference + Expo.

Organized by the Association for Materials Protection and Performance (AMPP), the show was held from March 3-7 in New Orleans, La., at the Ernest N. Morial Convention Center.

This article features analysis from industry consultant Alison B. Kaelin of ABKaelin, LLC, as delivered at AMPP’s “Regulatory Update” session on March 6. In that forum, Kaelin explored a variety of updates from the U.S. Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA), and select state-level rules.

Beyond the proposed regulatory changes spotlighted here, information and insight regarding other proposals is available by contacting Kaelin.

Changes to HazCom Standard

OSHA’s Hazard Communication Standard (HCS) final rule is expected imminently, Kaelin said. Also known as HazCom, that rule is expected to include changes to definitions, health classifications, and concentrations that could impact coatings, thinners, and abrasives.

She expects the rule to become final in late 2024 or early 2025.

One of the most impactful provisions would be Section 2, where the standard would change to discuss health hazards of chemicals under normal conditions of use — and not while in the container. Other changes include Section 3, which covers trade secrets information; Section 8, which clarifies exposure limits for individual ingredients or constituents in mixtures; and Section 9, which includes particle size.

“The most significant part of the [new] HazCom standard, in my opinion, is going to be the impact on combustible dust,” she said.

According to Kaelin, the ordinary use of some products will generate combustible dust. The new definition means “finely divided solid particles of a substance or mixture that are liable to catch fire or explode on ignition when dispersed in air or other oxidizing media.”

“This could have an impact on abrasive blast cleaning, thermal spray, and other operations where small or finely divided dusts are generated or accumulate,” Kaelin said.

OSHA’s definitions of skin corrosion, skin irritation, serious eye damage, eye irritation, dermal corrosion, dermal irritation, respiratory sensitizer, specific target organ toxicity, reproductive toxicity, and carcinogenicity are also being slightly updated for additional clarity.

Cal/OSHA Lead Rules

In California, the pending lead rules of the Division of Occupational Safety and Health (Cal/OSHA) have Kaelin’s attention. She expects them to become effective in January 2025, with extra time for compliance allowed with some provisions — including abrasive blast cleaning.

As Kaelin sees it, the most concerning aspects involve low blood lead levels for employee removal, as well as reduced action level and permissible exposure limits (PELs).

Under new administrative controls, the amount of time an employee could conduct dry abrasive blasting would be limited to five hours per day until an exposure assessment has been completed. This would then decrease to just two hours per day after five years. “Forewarning is the best thing I can give you,” Kaelin said.

Under Cal/OSHA, the PEL for airborne lead will be at 10 μg/m3 as an eight-hour time-weighted average, while the action level is at 2 μg/m3. Today, those figures are at 50 μg/m3 and 30 μg/m3, respectively, so the proposal represents a very significant reduction.

Other aspects of California’s updated rules, according to Kaelin, include new washing requirements for exposed arms and utilizing special cleansing compounds, such as de-leading soaps; updated training requirements; and a burden of proof that will be placed on employers for the evaluation of worker exposures, engineering controls, respiratory protection, and cleaning. Specific information and data points from the proposed lead regulations are available via California’s Department of Industrial Relations.

Editor’s note: For more information on technical sessions and activities from the 2024 AMPP Annual Conference + Expo, check out AMPP’s 2024 Show Daily news coverage.

About Alison B. Kaelin

Alison B. Kaelin, Certified Quality Auditor (CQA), is the principal of ABKaelin, LLC, a women-owned business enterprise providing coatings inspection, environmental health and safety, and quality services to the coatings industry. She is a former SSPC and AMPP board member and currently sits on the SC 24 and SC 25 committees.

Kaelin is an environmental engineer, an industrial hygienist, a former regulator, an AMPP Senior Certified Coatings Inspector, and an American Society for Quality (ASQ) CQA. In all, Kaelin has over 35 years of experience. During that time, she has won numerous industry awards while also contributing as an author and technical editor for many industry publication articles and book chapters, as well as for standards and education courses.

Her areas of expertise include coatings quality; environmental, health, and safety issues; and lead training and consulting in the industrial coatings, steel fabrication, transportation, nuclear, locks/dams, and oil and gas markets. For more information, contact: Alison Kaelin, (412) 841-7260,

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