Is Lead Dangerous at Work? CLAW Regulations Explained

Is Lead Dangerous at Work? The Control of Lead at Work Regulations Explained

Yes. Lead is a toxic metal that builds up in the body, and at work it is controlled by its own law, the Control of Lead at Work Regulations 2002 (CLAW). Most people picture old water pipes, but the bigger workplace risks today come from disturbing old lead paint by dry sanding, burning off or blasting, hot cutting of lead-painted metal, lead roofing and flashing, demolition, scrap recycling, battery work and some soldering. You cannot see or smell the fine dust or fume, and it can be breathed in, swallowed from unwashed hands, or carried home on clothes.

At a glance: Nexis CPD offers a £9 CPD-accredited online Lead Awareness course — 100% online, with an instantly emailed, employer-verifiable certificate. Any three courses cost £18.

This guide covers who is at risk, what CLAW requires, the legal limits for lead in air and blood as they stand on 10 October 2026, the changes HSE has consulted on, and the controls that keep lead out of workers’ bodies and homes.

Why is lead dangerous to workers?

Lead has no useful role in the human body. Once absorbed, it travels in the blood and is stored in tissues and bone, so repeated small exposures add up. The Health and Safety Executive (HSE) explains that the body absorbs lead at work in two main ways: by breathing in lead dust, fume or vapour, and by swallowing it, for example when someone eats, drinks, smokes or bites their nails without washing their hands and face first. Lead alkyls, the organic lead compounds once used in petrol, can also pass through the skin.

The danger is easy to underestimate because it is invisible. HSE also warns, on its lead health effects page, that harm has been observed below the levels written into CLAW: blood changes that might lead to anaemia, effects on the nervous system and kidneys, and altered testicular function above 40 µg/dl, and raised blood pressure in middle-aged men at around 30 µg/dl. Lead exposure in pregnancy is a particular concern, which is why the law sets lower blood-lead levels for women of reproductive capacity.

Which jobs are most at risk from lead exposure?

HSE’s list of when workers are most at risk is dominated by processes that create lead dust, fume or vapour, not by touching solid lead. It includes:

  • blast removal and burning of old lead paint, and stripping old lead paint from doors and windows;
  • hot cutting in demolition and dismantling work;
  • recovering lead from scrap and waste, and smelting, refining, alloying and casting;
  • lead-acid battery manufacture, breaking and recycling;
  • manufacturing lead compounds, leaded glass, pigments and ceramic glazes;
  • working with metallic lead and its alloys, for example soldering;
  • some painting of buildings and some spraying of vehicles; and
  • recycling televisions and monitors that contain cathode ray tubes.

Construction and maintenance workers deserve special mention because their exposure is intermittent and often unexpected. HSE’s Approved Code of Practice, L132 Control of lead at work, points out that brief work in the open air can still produce very high concentrations close to a worker’s breathing zone, for example when welding or cutting lead-painted steel, burning lead during demolition, or removing old lead paint by chipping or shot-blasting. Where those activities involve lead-painted or lead-containing materials, the ACOP says exposure should be assessed as significant.

Roofers and leadworkers handle sheet lead for flashings and roof coverings. Handling cold sheet lead mainly creates an ingestion risk from contaminated hands and gloves, while heating, cutting or welding it creates fume. Decorators and restoration specialists are another key group: HSE says you are most at risk if you regularly remove paint in properties built before the 1980s, strip old paint with blow lamps or gas torches, or dry sand old paint.

A roofer wearing work gloves shaping a strip of grey sheet lead flashing with a wooden mallet at a workbench in a roofing workshop
Handling cold sheet lead is mainly an ingestion risk: gloves, separate work clothing and washing before breaks stop lead reaching the mouth.

What are the Control of Lead at Work Regulations 2002?

The Control of Lead at Work Regulations 2002 (SI 2002/2676) apply in England, Wales and Scotland and came into force on 21 November 2002. Northern Ireland has its own Control of Lead at Work Regulations (Northern Ireland) 2003. CLAW covers metallic lead, lead alloys, lead compounds and lead as part of another material, such as paint, wherever it is liable to be inhaled, swallowed or otherwise absorbed. Employers must:

  • assess the risk before work liable to expose employees to lead, including whether exposure is liable to be significant, and record the significant findings if they employ five or more people (regulation 5);
  • prevent exposure, by substitution where reasonably practicable, or otherwise adequately control it, with PPE only in addition to other measures (regulation 6);
  • stop eating, drinking and smoking in places liable to be contaminated by lead (regulation 7);
  • maintain, examine and test control measures such as extraction and respirators (regulation 8);
  • monitor lead in air and provide medical surveillance where required (regulations 9 and 10); and
  • give information, instruction and training and plan for emergencies (regulations 11 and 12).

CLAW also bans employing young persons and women of reproductive capacity in specified activities in lead smelting and refining and lead-acid battery manufacture (regulation 4 and Schedule 1). Employees must make full and proper use of the controls provided, report defects and attend medical surveillance. HSE adds that self-employed people need to take the same action to protect themselves as an employer would.

Why isn’t lead covered by COSHH?

Lead is clearly hazardous to health, so why is it not simply handled under the Control of Substances Hazardous to Health Regulations 2002? The answer is in COSHH itself. Regulation 5 of COSHH disapplies its main duties “where and to the extent that” CLAW applies, and does the same for asbestos.

Lead has its own regime because it needs things the general COSHH duties do not spell out: a legal air limit, a defined trigger for “significant” exposure, compulsory blood-lead testing with legal action and suspension levels, a doctor’s decision on whether a worker should come off lead work, lower levels for women of reproductive capacity and young persons, and health records kept for at least 40 years. The thinking behind a lead risk assessment is the same as for COSHH, and many workplaces handle both. For the general principles, see our guide to what COSHH is.

What counts as significant exposure to lead?

“Significant” is a defined legal term in CLAW, and it triggers the stronger duties, including air monitoring, protective clothing and medical surveillance. Under regulation 2, exposure is significant where:

  • an employee is, or is liable to be, exposed to lead in air at more than half the occupational exposure limit;
  • there is a substantial risk of an employee swallowing lead; or
  • there is a risk of skin contact with lead alkyls or other lead substances that can be absorbed through the skin.

The second limb is the one people miss. A task can produce very little airborne lead and still be significant if hands, gloves, tools and clothing become contaminated and lead is likely to reach workers’ mouths. HSE says you do not need a formal “lead survey”, but your risk assessment must decide whether the work will expose people to lead. Where it is unclear whether old paint contains lead, L132 says a sample should be analysed if necessary.

What is the workplace exposure limit for lead in air?

Lead does not appear in the general table of workplace exposure limits used for COSHH. Instead, CLAW sets its own occupational exposure limit (OEL), averaged over an 8-hour working day:

  • 0.15 mg/m³ for lead other than lead alkyls; and
  • 0.10 mg/m³ for lead alkyls, measured as lead.

These figures are in force on 10 October 2026, and HSE’s 2026 consultation did not propose changing them. Exposure is significant above half the OEL, so 0.075 mg/m³ for most forms of lead. If the OEL is exceeded, control only counts as adequate if the employer identifies why and takes immediate steps to put it right.

Where exposure is liable to be significant, regulation 9 requires lead in air to be measured at least every three months. The interval can stretch to 12 months, except for lead alkyls, if nothing material has changed and results have not exceeded 0.10 mg/m³ on the two previous occasions. Records must be kept for at least five years. For how exposure limits work more generally, see our explainer on workplace exposure limits and EH40.

What are the blood-lead action and suspension levels?

Because lead is swallowed as well as breathed in, air monitoring cannot show how much a worker has absorbed. CLAW therefore relies on biological monitoring, usually a blood test. These are the levels in force on 10 October 2026, from regulation 2 of CLAW and HSE’s significant exposure page:

  • Action level (blood-lead): 50 µg/dl for most employees; 25 µg/dl for women of reproductive capacity; 40 µg/dl for young persons under 18.
  • Suspension level (blood-lead): 60 µg/dl for most employees; 30 µg/dl for women of reproductive capacity; 50 µg/dl for young persons under 18.
  • Suspension level (urinary lead): 110 µg Pb/g creatinine for most employees; 25 µg Pb/g creatinine for women of reproductive capacity.

At the action level, the employer must find out why the worker’s blood-lead is high, take reasonably practicable steps to bring it down, and review the risk assessment. At the suspension level, a relevant doctor (an HSE-appointed doctor or employment medical adviser) must record whether the worker should be suspended from lead work, and the employer must review its controls and the health of others exposed in the same way.

Medical surveillance is required where exposure is, or is liable to be, significant, where blood-lead reaches 35 µg/dl (20 µg/dl for women of reproductive capacity), or where a relevant doctor says it is needed. It should start before lead work begins where reasonably practicable, and within 14 working days at the latest, with a medical assessment at least every 12 months. Blood tests are required at least every six months for most employees and at least every three months for women of reproductive capacity and young persons; the ACOP advises three-monthly tests at first for significantly exposed workers. Whether a woman is “of reproductive capacity” is a decision a relevant doctor records in her health record, and it can be reviewed by HSE on request.

Is HSE lowering the lead limits?

Not yet, but it has proposed to. HSE consulted on the CLAW exposure values and associated guidance from 30 March to 7 June 2026. Its consultation document proposed:

  • for most employees, cutting the action level from 50 to 20 µg/dl and the suspension level from 60 to 30 µg/dl from 1 October 2027, then to 10 and 15 µg/dl from 1 October 2029;
  • for women of reproductive capacity, an action level of 5 µg/dl and a suspension level of 7.5 µg/dl from 1 October 2027;
  • bringing young persons into line with the general levels; and
  • no change to the lead-in-air limit.

The same document reports that GB workers’ blood-lead levels fell by an average of 3.9% a year between 2013 and 2024. At the time of writing, 10 October 2026, HSE had not published its response on the consultation page and we found no amending regulations on legislation.gov.uk, so the current levels above still apply. HSE has said it will communicate any changes before they come into force. Employers with lead-exposed workers should watch for the outcome and talk to their appointed doctor about how close their workforce is to the proposed figures.

What are the symptoms of lead poisoning?

Early symptoms are vague and easy to put down to something else. HSE’s lead FAQs list headaches, tiredness, irritability, constipation, nausea and stomach pains. Continued uncontrolled exposure could cause anaemia, weight loss, kidney damage, nerve and brain damage, and infertility.

Because early signs are so non-specific, CLAW relies on blood testing rather than waiting for people to feel ill. In one of HSE’s case studies, restoration workers sanding old paint they had not been told contained lead inhaled and swallowed dust for months; two were treated in hospital and dust was carried home on overalls. If you work with lead and feel unwell, tell your employer and the doctor carrying out your surveillance, and speak to your GP or NHS 111, mentioning your work with lead.

How do you safely remove old lead paint?

Old paint is one of the most common ways lead reaches workers today. It may be hidden under later coats on doors, windows and other woodwork or metalwork, so on older properties assume it may be present until a test shows otherwise. HSE’s advice is to plan first and only strip paint back if it is flaking, chipping or a risk to children. Safe ways to remove old lead paint:

  1. Find out what you are dealing with. Include lead in the risk assessment and have a paint sample analysed if you are unsure.
  2. Leave sound paint in place. If it is in good condition, HSE recommends wet abrasive paper to key the surface rather than stripping.
  3. Use chemical strippers and wet methods for paint in poor condition. HSE recommends chemical paint stripper, wet abrasive paper and on-tool extraction. L132 says wet methods should be used for rubbing or scraping down lead-painted surfaces, and wetted material must not be allowed to dry out.
  4. Avoid dry sanding, blowlamps, gas torches and dry blasting. HSE singles these out because they create fine dust or fume.
  5. Use extraction and suitable RPE. Where the risk assessment calls for RPE, tight-fitting masks need face-fit testing.
  6. Contain the area. Lay plastic sheeting and keep other people out.
  7. Clean up damp, never dry. Remove debris with a damp cloth, not by dry sweeping or blowing.
  8. Bag the waste. Put debris, cloths and used abrasive paper in a plastic bag for disposal.
  9. Wash before breaks and before going home. Wash hands and face and scrub nails before eating, drinking or smoking.

Shot-blasting, burning off and hot cutting of lead-painted structures such as steelwork are specialist jobs needing full CLAW controls, including air monitoring and medical surveillance, not a quick fix with a dust mask.

A decorator in a white disposable coverall, half-mask respirator and nitrile gloves misting an old painted panelled door with water and scraping off loose paint onto plastic sheeting
Wet scraping onto plastic sheeting keeps old lead paint as damp flakes instead of fine dust, which is why HSE favours wet and chemical methods over dry sanding.

How should employers control lead exposure at work?

CLAW follows a clear order of priority. Prevention comes first: avoid using lead or creating lead dust or fume where reasonably practicable. Where exposure cannot be prevented, regulation 6 requires, in order:

  • work methods and engineering controls, such as wet methods, chemical stripping, and keeping molten lead below 500°C, the point at which L132 says fume emission becomes significant;
  • control at source, such as local exhaust ventilation (LEV) and on-tool extraction, with good general ventilation; and
  • personal protective equipment, including RPE, only in addition to the above where adequate control cannot otherwise be achieved.

RPE must suit the job and the wearer, which in practice means the right protection factor and filter and a successful face-fit test for tight-fitting masks. Our guide to whether face-fit testing is a legal requirement explains how that works.

Personal hygiene is a control measure in its own right, because so much lead is swallowed rather than breathed in. HSE’s guidance and L132 point to:

  • no eating, drinking or smoking in any place liable to be contaminated by lead, with clean areas for breaks;
  • washing facilities with warm water, mild skin cleanser and towels, including showers where the work requires them;
  • separate storage for clean clothes and contaminated work clothing, ideally with “dirty” and “clean” changing areas;
  • protective clothing for significantly exposed workers, which should not leave the premises except to go to a specialist laundry; and
  • housekeeping using vacuums with high-efficiency filters or wet cleaning, not dry sweeping.

Taking lead home is a real risk. HSE explains that if lead is carried into cars and homes on contaminated clothing, family and friends can be exposed too, which is why work clothing and PPE should never be taken home to wash. HSE also says handing out a leaflet is not enough training: workers need to understand the hazards, how to use and check controls and what to do if something goes wrong, with supervisors checking that they do.

A construction worker in a navy polo shirt washing his hands and forearms with soap at a stainless steel basin in a clean site welfare cabin
Much of the lead workers absorb is swallowed, so washing hands and face before every break is a control measure, not a courtesy.

Is lead poisoning reportable under RIDDOR?

Not as an occupational disease under the current rules, which surprises many people. Under the old RIDDOR 1995, poisoning by lead or its compounds was a reportable disease. The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013, in force from 1 October 2013, have a much shorter list: regulation 8 covers six conditions (carpal tunnel syndrome, hand or forearm cramp, occupational dermatitis, hand-arm vibration syndrome, occupational asthma and tendonitis or tenosynovitis), and regulation 9 covers occupational cancers and diseases caused by biological agents. Lead poisoning is not among them.

That does not reduce the employer’s duties. A high blood-lead result triggers the CLAW action and suspension steps, the risk assessment must be reviewed, and records must be kept and made available to HSE. Employers should still check RIDDOR for any separately reportable injury or dangerous occurrence.

What lead awareness training is available online?

Regulation 11 of CLAW requires employers to give employees liable to be exposed to lead suitable information, instruction and training. An online course can support that duty alongside the site-specific instruction, supervision and fit testing only the employer can provide.

Nexis CPD’s Lead Awareness course covers why lead is dangerous, assessing and controlling exposure, air monitoring, blood-lead medical surveillance and hygiene, and safe working and responsibilities. It pairs naturally with COSHH Awareness, for the other hazardous substances found on the same jobs, and Respiratory Protective Equipment (RPE), for selecting, wearing and looking after the masks lead work often needs.

£9 per course. CPD accredited, 100% online, verifiable e-certificate. Pay for 2, get 3 — any 3 courses for £18. These are CPD-accredited awareness courses, not Ofqual-regulated qualifications. They do not qualify anyone as an HSE-appointed doctor, an occupational hygienist or a face-fit tester, and they do not replace the employer’s risk assessment, air monitoring, medical surveillance or site-specific training required by CLAW.

Frequently asked questions

Is lead dangerous to work with?

Yes. Lead dust, fume and vapour can be breathed in, and lead on hands, food or cigarettes can be swallowed. It builds up in the body and can cause anaemia, damage to the kidneys, nerves and brain, and infertility. The Control of Lead at Work Regulations 2002 require employers to prevent or adequately control exposure.

What is the blood-lead suspension level in the UK?

Under the Control of Lead at Work Regulations 2002, as in force on 10 October 2026, the blood-lead suspension level is 60 µg/dl for most employees, 30 µg/dl for women of reproductive capacity and 50 µg/dl for young persons under 18. HSE consulted in 2026 on lowering these levels, but no change had been made at that date.

What is the workplace exposure limit for lead?

The occupational exposure limit set by the Control of Lead at Work Regulations 2002 is 0.15 mg/m³ for lead other than lead alkyls and 0.10 mg/m³ for lead alkyls, both as 8-hour time-weighted averages. Exposure above half the limit counts as significant.

Is lead covered by COSHH?

No. Regulation 5 of COSHH disapplies its main duties where the Control of Lead at Work Regulations 2002 apply. Lead has its own regulations because it needs specific air limits, blood-lead testing and medical surveillance by an HSE-appointed doctor.

Is lead poisoning reportable under RIDDOR?

Not as an occupational disease. Lead poisoning was reportable under RIDDOR 1995, but it is not on the list of reportable diseases in RIDDOR 2013. The CLAW duties on blood-lead action and suspension levels, risk assessment review and health records still apply.

Can I take my work clothes home if I work with lead?

No. HSE guidance says protective clothing contaminated with lead should not be taken home for washing. It should be cleaned at the workplace or by a specialist laundry, and clean and contaminated clothing should be stored separately so that lead is not carried into cars and homes.

This article is general information, not medical or legal advice. It summarises the Control of Lead at Work Regulations 2002 and HSE guidance in Great Britain as at 10 October 2026. Always follow your employer’s risk assessment, your appointed doctor’s advice and current HSE guidance, and check HSE’s consultation page for any changes to the blood-lead levels. If you are worried about your health, speak to your GP or NHS 111. Nexis CPD courses are CPD-accredited awareness training, not regulated qualifications.

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