U.S. EPA’s Updated Soil Lead Guidance for CERCLA Sites and RCRA Hazardous Waste Cleanup Program Facilities

On October 16, 2025, the Office of Land and Emergency Management (“OLEM”) issued a Residential Lead Directive for CERCLA Sites and RCRA Hazardous Waste Cleanup Program Facilities (“Directive”) in order to provide guidance in addressing lead contaminated soil on residential properties at Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”) sites and Resource Conservation and Recovery Act (“RCRA”) hazardous waste cleanup program facilities. The Directive is intended to streamline response actions and update the Biden Administration’s January 2024 Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities (“2024 Guidance”).

In comparison to the 2024 Guidance, the Directive increases the removal management level (“RML”) for lead in soil to 600 parts per million (“ppm”) (from 200 ppm in 2024). The RML is used to prioritize and define areas that may pose the greatest threat to human health. The Directive maintains the regional screening level (“RSL”), used to help identify and define areas that may need further evaluation, at 200 milligrams per kilogram (“mg/kg” or “ppm”) for residential settings; and maintains the target children’s blood lead level (“BLL”), used to develop Preliminary Remediation Goals (“PRGs”), at 5 micrograms per deciliter (“ug/dL”). The Directive, however, eliminates the 2024 Guidance recommended lower level RSL of 100 mg/kg and BLL of 3.5 ug/dL for areas where additional sources of lead exposure are present (e.g., lead in drinking water, lead paint, etc.).

The RML increase to 600 ppm is established in order to “provide clear direction for prioritizing properties for cleanup based on lead concentrations, particularly with respect to when to pursue a CERCLA removal action” and is “consistent with the standard approach for other contaminants.” The Directive provides, however, that the RSLs and RMLs “are not default PRGs or cleanup levels.” EPA regions may further adjust RSLs, PRGs and cleanup levels “to ensure compliance with statutory and regulatory requirements and to account for relevant site-specific considerations such as technical limitations, bioavailability, and soil lead background levels.” The Directive also includes several “process improvements” that claim to reduce the time to respond to lead issues, create more nationally consistent cleanup decisions, and encourage early action with state and local entities.

We will continue to work with our clients to apply this Directive for all sites with residential lead contamination subject to CERCLA and RCRA. It may help to move decision-making forward at sites that have stalled.