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 a rule published November 12, 2024. The rule took effect January 13, 2025, and compliance with the revised standards was required beginning January 12, 2026 in EPA-administered jurisdictions. 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 - but the compliance date and the state-adoption timeline are two different things, and mixing them up is the most common mistake with this rule.
Two Changes, One Compliance Date
The dates are the part most people get wrong. The November 12, 2024 final rule (89 FR 89416) took effect on January 13, 2025, but compliance with the revised standards themselves was January 12, 2026. Both changes below share that single compliance date - they are not two separate obligations a year apart. That compliance date applies in EPA-administered jurisdictions; see the Ohio section below for what it means in a state that runs its own authorized program.
Dust-Lead Reportable Levels
For risk assessments and lead hazard screens, any detectable level of lead in dust reported by a laboratory recognized under EPA’s National Lead Laboratory Accreditation Program (NLLAP) is a dust-lead “reportable level.” This replaces the previous numeric thresholds of 10 ug/ft2 for floors and 100 ug/ft2 for window sills.
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
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 half the previous level for floors (10 to 5 ug/ft2), well under half for window sills (100 to 40 ug/ft2), and one-quarter for window troughs (400 to 100 ug/ft2). 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
Laboratories have to report at lower limits now, and that is a requirement rather than a practical side effect of analytical uncertainty. EPA’s Laboratory Quality System Requirements (LQSR) Rev. 4.0 require that a laboratory demonstrate a quantitation limit at or below 80% of the lowest action level for the surface area being sampled - floors, window sills, or window troughs - for dust wipe samples. Against the new action levels, that works out to 4 ug/ft2 for floors, 32 ug/ft2 for window sills, and 80 ug/ft2 for window troughs. Confirm your laboratory is NLLAP-recognized under the current LQSR and ask what quantitation limits it actually reports, because a lab that cannot meet them cannot support a defensible clearance decision.
Ohio Considerations
Ohio’s lead program is administered by the Ohio Department of Health (ODH) under OAC 3701-32. This matters for the compliance date: the January 12, 2026 date applies in EPA-administered jurisdictions, and Ohio is not one of them. Ohio runs its own EPA-authorized lead program, as does Indiana.
Authorized states are not automatically bound by the revised federal levels on the federal compliance date. They must adopt standards at least as protective as EPA’s revised standards no later than January 11, 2027 - two years after the rule’s effective date. Until Ohio completes that adoption, do not assume the federal action levels are already enforceable here. Confirm with ODH which standard governs your specific obligation, and check the status of Ohio’s adoption of the 2024 rule before you write a clearance decision against a level Ohio has not yet adopted.
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.
Source
- Federal Register: Dust-Lead Hazard Standards and Clearance Levels - Final rule, compliance date January 12, 2026