Lead-Based Paint Definition

Measurement Method	Threshold	Regulation
XRF (in place)	1.0 mg/cm2	TSCA Section 401 / OAC 3701-32-19
Laboratory (weight)	0.5% (5,000 ppm)	TSCA Section 401 / OAC 3701-32-19

Any paint or surface coating meeting or exceeding either threshold is classified as lead-based paint.

Dust-Lead Standards

Dust-Lead Reportable Levels (for Risk Assessments)

As of January 13, 2025, any detectable level of lead in dust reported by an accredited laboratory is a dust-lead reportable level. This replaced the previous numeric thresholds of 10 ug/ft2 (floors) and 100 ug/ft2 (window sills).

Dust-Lead Action Levels (for Abatement Clearance)

Effective January 12, 2026:

Surface	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. These levels replaced the previous “clearance levels” terminology.

Note: HUD’s Lead Safe Housing Rule (24 CFR 35) may have different clearance levels that apply to federally assisted housing. When HUD and EPA standards conflict, the more stringent standard applies.

Soil-Lead Standards

EPA Residential Soil Screening Levels (CERCLA/RCRA Sites)

Condition	Screening Level	Effective Date
Residential (standard)	200 ppm	January 2024
Residential (multiple lead sources)	100 ppm	January 2024
Previous standard	400 ppm	1994-2024

These screening levels apply to CERCLA (Superfund) sites and RCRA corrective action facilities. They are not cleanup standards - they are thresholds for determining whether further investigation is needed.

EPA Removal Management Level (CERCLA/RCRA Sites)

Level	Effective Date
600 ppm	October 2025 directive
Previous RML	200 ppm (January 2024)
Original RML	400 ppm (1994)

The RML is the threshold for evaluating whether a removal action may be warranted.

EPA Soil-Lead Hazard Standard (TSCA - Residential)

Area	Hazard Standard
Play areas	400 ppm
Rest of yard	1,200 ppm

These are the TSCA Section 403 standards for identifying soil-lead hazards during risk assessments. Note that the CERCLA/RCRA screening levels (200/100 ppm) are more stringent.

Target Blood Lead Level

EPA uses a target children’s blood lead level of 5 ug/dL to determine preliminary remediation goals at CERCLA/RCRA sites (per the October 2025 directive). CDC’s blood lead reference value is 3.5 ug/dL.

Drinking Water

Standard	Level	Authority
Lead action level	10 ug/L	SDWA / Lead and Copper Rule Improvements
Previous action level	15 ug/L	Original Lead and Copper Rule
MCLG	0 ug/L	SDWA (non-enforceable health goal)

The action level is not an MCL. It is a trigger for water system-level actions (treatment optimization, public notification, lead service line replacement) when more than 10% of tap samples exceed the level.

OSHA Workplace Exposure Limits

Construction Standard (29 CFR 1926.62)

Limit	Concentration	Averaging Period
Permissible Exposure Limit (PEL)	50 ug/m3	8-hour TWA
Action Level	30 ug/m3	8-hour TWA

General Industry Standard (29 CFR 1910.1025)

Limit	Concentration	Averaging Period
Permissible Exposure Limit (PEL)	50 ug/m3	8-hour TWA
Action Level	30 ug/m3	8-hour TWA

Both standards use the same numeric limits. The construction standard has additional provisions specific to demolition, renovation, and abatement activities. See OSHA Lead in Construction for details.

RRP Rule Thresholds

Threshold	Limit
Pre-1978 trigger	Target housing built before January 1, 1978
Interior de minimis	6 SF per room
Exterior de minimis	20 SF
Window replacement	Never considered de minimis