EPA Lead Soil Screening Levels Cut in Half - What Ohio Consultants Need to Know
After 30 years at 400 parts per million (ppm), EPA lowered its recommended residential soil lead screening level to 200 ppm in January 2024. The January 2024 guidance set a lower 100 ppm screening level for properties with multiple sources of lead exposure (lead water service lines, lead-based paint, or areas exceeding National Ambient Air Quality Standards for lead), but the October 2025 OLEM directive eliminated that 100 ppm level and standardized the screening level at 200 ppm across all residential properties.
Then in October 2025, EPA issued a new directive that kept the 200 ppm screening level but revised the removal management level (RML) upward. Here is what the current framework looks like and what it means for site work in Ohio.
Current Lead Soil Framework (October 2025 Directive)
The October 2025 Residential Soil Lead Directive for CERCLA Sites and RCRA Hazardous Waste Cleanup Facilities established:
- Regional Screening Level (RSL): 200 ppm for residential soil, standardized across all residential properties (the January 2024 guidance’s lower 100 ppm multiple-source level was eliminated by this directive)
- Regional Removal Management Level (RML): 600 ppm (raised from the January 2024 level of 200 ppm, and set at three times the RSL, consistent with EPA’s standard approach for other contaminants)
- Target children’s blood lead level: 5 ug/dL for determining preliminary remediation goals
The RSL is the threshold for deciding whether further investigation is needed. The RML is the threshold for evaluating whether a removal action may be warranted. The directive applies to CERCLA (Superfund) sites and RCRA corrective action facilities.
These are not cleanup standards - they are screening values that trigger further evaluation. Final cleanup levels are still determined on a site-specific basis.
What Changed from the Previous Guidance
The January 2024 guidance was the first update to EPA’s residential soil lead screening levels since 1994. The key changes across the three frameworks:
| Value | 1994 Guidance | January 2024 | October 2025 |
|---|---|---|---|
| RSL (standard residential) | 400 ppm | 200 ppm | 200 ppm |
| RSL (multiple lead sources) | 400 ppm (no separate level) | 100 ppm | 200 ppm (standardized) |
| RML | Not established | 200 ppm | 600 ppm |
| Target blood lead level | 10 ug/dL | 5 ug/dL (3.5 ug/dL multiple sources) | 5 ug/dL (standardized) |
The 1994 guidance established a screening level only - it did not set a separate removal management level. The RML is a later screening tool.
The October 2025 directive raised the RML from 200 ppm to 600 ppm and standardized the RSL at 200 ppm across all residential properties regardless of other lead sources. On blood lead: the January 2024 guidance used a target of 5 ug/dL for developing preliminary remediation goals, dropping to 3.5 ug/dL where an additional source of lead was identified. The October 2025 directive kept the 5 ug/dL target and eliminated the lower 3.5 ug/dL multiple-source tier along with the 100 ppm RSL.
How This Affects Ohio Site Work
VAP Sites
Ohio’s Voluntary Action Program (VAP) uses its own standards from CIDARS for lead in soil and groundwater. The VAP derives its values through its own risk assessment methodology and does not automatically adopt EPA’s RSLs. Check the current CIDARS values for lead - they may differ from the federal screening levels.
CERCLA and RCRA Corrective Action Sites
For sites being addressed under CERCLA or RCRA, the new federal screening levels apply directly. The directive applies to all sites with residential lead contamination subject to CERCLA response and RCRA Hazardous Waste Cleanup Program authorities, including federal facility cleanup programs under CERCLA Section 120. (RCRA Corrective Action was rebranded as the Hazardous Waste Cleanup Program in October 2024, which is why the directive’s title differs from the 2024 guidance it supersedes.) For properties previously screened or cleaned up under the old 400 ppm level, the directive points to CERCLA five-year reviews as the mechanism for evaluating whether existing remedies remain protective - it does not itself direct re-evaluation of previously addressed sites.
Phase I and Phase II ESAs
While the screening levels are not directly applicable to Phase I or Phase II Environmental Site Assessments under ASTM standards, environmental professionals conducting due diligence should be aware that the lower screening levels may affect how lead-impacted properties are evaluated in real estate transactions. A site that was previously below the 400 ppm threshold may now exceed the 200 ppm screening level.
Brownfield Projects
The OLEM directive governs CERCLA and RCRA cleanup sites - it does not set screening levels for brownfield projects. Under EPA’s Brownfields Program, states and tribal nations oversee brownfield site assessment and cleanup and set the applicable soil screening and cleanup levels, with EPA deferring to state and tribal response programs. For Ohio brownfield work, that generally means the state program framework covered above rather than the federal directive numbers. See our Ohio Brownfield Programs Overview for funding and eligibility details.
Bottom Line
If you work on sites with lead-impacted soil in Ohio, the practical impact is straightforward: the threshold for flagging lead as a potential concern in residential soil dropped from 400 to 200 ppm. More sites will require further investigation. The October 2025 directive softened some of the January 2024 changes (particularly the RML increase to 600 ppm), but the screening level remains at half the previous standard.
For a complete table of all current lead regulatory thresholds across paint, dust, soil, air, and water, see our Lead Standards Quick Reference.