The Health and Safety Executive (HSE) has launched a crucial consultation on updating the Control of Lead at Work Regulations 2002 (CLAW), marking the first major review of blood lead exposure levels in over two decades.
For organisations managing buildings constructed before 1992, when lead paint was finally banned in the UK, or those involved in refurbishment, development and demolition projects, these proposed changes could have significant implications for how lead hazards are identified, assessed and managed.
The Hidden Danger of Lead
Lead remains one of the most significant occupational health hazards. Whilst lead paint may not cause immediate obvious health effects, exposure to even low levels can accumulate in the body over time, with high levels causing headaches, poor attention span, and in severe cases, damage to the brain and kidneys.
Lead was extensively added to paints throughout the 20th century for its durability, corrosion resistance and accelerated drying properties. It was commonly used on both interior and exterior surfaces, particularly on metals and woodwork, with heaviest use up until the 1960s. Although its use was phased out and finally banned in 1992, the legacy of lead paint remains in countless buildings across the UK. The danger arises when lead paint becomes degraded, chipped, or is disturbed during maintenance or renovation work without proper precautionary measures, allowing lead dust to be inhaled or ingested.
Those most at risk include children under six, who absorb more ingested lead than adults and may suffer developmental delay and learning difficulties, pregnant women, as lead can affect the unborn baby potentially causing premature birth or brain damage, and workers involved in paint removal, stripping with blow lamps, or dry sanding old paint.
What Does The Control of Lead at Work Regulation Consultation Propose?
The HSE consultation seeks stakeholder views on updating blood lead exposure levels in CLAW 2002 to reflect current scientific understanding, revising the Approved Code of Practice and associated guidance, and gathering evidence on ‘lead in air’ monitoring practices.
Whilst the consultation is particularly relevant to employers in lead manufacturing and lead-use sectors, its implications extend to construction and facilities management organisations, Principal Designers and Principal Contractors under CDM 2015, building owners and duty holders responsible for pre-1992 buildings, and anyone involved in refurbishment and demolition work.
Anyone responsible for buildings where paintwork pre-dating 1992 is likely to be damaged or disturbed during work has a legal requirement to conduct lead paint sampling and risk assessments.
Industry Perspective
Adam Norgrove, Account Manager at our specialist hazardous materials testing and inspection company, Lucion Services Ltd, commented:
“The HSE’s consultation on updating CLAW regulations represents an important step forward in protecting workers and building occupants from lead exposure.
At Lucion, we’ve seen a significant increase in clients taking a proactive approach to lead hazards. Many now request lead-in-paint sampling alongside their asbestos surveys as part of a comprehensive hazardous materials management strategy.
What’s particularly encouraging is that our clients recognise the value of identifying lead hazards early in the project lifecycle. This not only ensures regulatory compliance but also prevents costly delays and protects workers from exposure. With our XRF technology, we can provide immediate on-site results, allowing clients to make informed decisions quickly.
These proposed regulatory updates will likely raise awareness further, and we’d encourage all companies with pre-1992 buildings to review their current approach to lead management. The consultation period is an excellent opportunity for businesses to understand what’s coming and prepare accordingly.”
Many of our clients are now adopting this proactive, integrated approach to hazardous materials management. By instructing lead in paint sampling during asbestos surveying works, our clients can reduce survey costs through combined site visits, minimise disruption to operations, and gain a complete picture of hazardous materials risks.
How Can You Get Involved?
With the consultation open until 24th May 2026, this is an ideal time to review your current approach to lead management. If your estate includes buildings constructed before 1992, or if you’re planning refurbishment, development or demolition projects, consider whether your current procedures are robust enough to meet both existing requirements and likely future standards.
At Lucion, we provide XRF testing and laboratory analysis for project management and lead in air monitoring, alongside our suite of asbestos management inspection and testing services, delivering end-to-end support for organisations navigating regulatory compliance.
The consultation on CLAW regulations represents an opportunity for the industry to strengthen protections for workers and building occupants whilst ensuring that businesses have clear, practical guidance for managing lead hazards effectively. By engaging with the consultation and reviewing your current practices now, you can ensure you are well-prepared for whatever changes lie ahead.
To discuss your lead in paint requirements or to learn more about how the proposed CLAW updates might affect your organisation, drop us an email at [email protected]
