New EPA Dust-Lead Action Levels Now in Effect - What Changed in January 2026
EPA finalized stronger requirements for identifying and cleaning up lead-based paint hazards in October 2024, with key provisions taking effect in January 2025 and January 2026. The changes affect how lead dust hazards are identified during risk assessments and how clearance testing is conducted after abatement. If you perform lead inspections, risk assessments, or abatement clearance in pre-1978 housing, these changes are directly relevant to your work.
Two Changes, Two Effective Dates
Dust-Lead Reportable Levels (Effective January 13, 2025)
For risk assessments and lead hazard screens, any detectable level of lead in dust reported by an accredited laboratory is now a dust-lead “reportable level.” This replaces the previous numeric thresholds of 10 ug/ft2 for floors and 100 ug/ft2 for window sills that had been in effect since 2020.
What this means in practice: if the lab reports any lead in a dust wipe sample, it is a reportable level for risk assessment purposes. The risk assessor must disclose and address it. The previous approach of comparing results to a numeric threshold and calling anything below it “not a hazard” no longer applies for risk assessment reporting.
Dust-Lead Action Levels (Effective January 12, 2026)
For abatement clearance, EPA established new “action levels” replacing the previous “clearance levels”:
| Surface | New Action Level | Previous Clearance Level |
|---|---|---|
| Floors | 5 ug/ft2 | 10 ug/ft2 |
| Interior window sills | 40 ug/ft2 | 100 ug/ft2 |
| Window troughs | 100 ug/ft2 | 400 ug/ft2 |
After an abatement, every individual dust wipe sample must be below the action level for the work to pass clearance. These are the levels that determine when an abatement can be considered complete.
The Terminology Change Matters
EPA replaced “clearance levels” with “action levels” and “dust-lead hazard standards” with “dust-lead reportable levels.” This is not just a relabeling. The action levels now serve as EPA’s recommended threshold for when abatement should occur and when it can be considered complete. The reportable levels set the bar for what must be disclosed and considered during risk assessments.
For abatement purposes, “abatement” now means measures designed to permanently eliminate dust-lead levels to below the action levels. This tightens the definition of what constitutes a complete abatement.
Practical Impact
For Risk Assessors
Your risk assessment reports must address any lab-detectable dust-lead results, not just results above a numeric threshold. If the lab reports lead in a dust wipe, you need to include it in your findings. This will increase the number of surfaces identified as having reportable lead levels and may increase the number of recommended response actions in your reports.
For Abatement Contractors and Clearance Technicians
Clearance standards are approximately half the previous levels for floors and window sills, and one-quarter for window troughs. Projects that would have passed clearance under the old standards may fail under the new ones. This means more thorough cleaning, potentially more clearance attempts, and tighter quality control during abatement.
For HUD-Funded Projects
HUD’s Lead Safe Housing Rule (24 CFR 35) requires compliance with EPA standards. HUD has indicated it will update its guidance to align with the new EPA requirements. Properties covered by HUD rules must meet the new action levels for clearance after abatement, interim controls, and certain renovation activities.
Laboratory Reporting
Accredited laboratories will need to report results at or near their detection limits. For most labs, the practical reporting threshold will be approximately 80% of the action level due to analytical uncertainty. Risk assessors and clearance professionals should understand their lab’s reporting limits and how they relate to the new thresholds.
Ohio Considerations
Ohio’s lead program is administered by the Ohio Department of Health (ODH) under OAC 3701-32. Ohio’s rules reference federal standards and will need to be updated to reflect the new EPA levels. Ohio has historically adopted federal lead standards, but there may be a lag between federal effective dates and state rule updates. Check with ODH for the current status of Ohio’s adoption of the 2024 EPA rule changes.
Under OAC 3701-32-03(B), when Ohio and federal standards conflict, the more stringent standard applies. Since the new federal levels are more stringent than the previous levels, they effectively apply even before Ohio formally updates its rules.
What to Do Now
If you perform lead work:
- Update your risk assessment and clearance report templates to reference the new action levels and reportable level framework
- Confirm your laboratory can report at the detection limits needed to assess compliance with the new thresholds
- Review your abatement cleaning procedures to ensure they can consistently achieve the lower action levels
- Communicate the changes to your clients, especially those with ongoing HUD-funded projects
For the complete set of current lead regulatory thresholds, see our Lead Standards Quick Reference. For Ohio-specific licensing requirements, see our Ohio Lead Licensing and Certification Guide.