COSHH guide · Lead

Lead at work: lead paint, leadwork and the lead regulations

Lead has its own regulations, so most of COSHH does not apply to it. This page sets out what the Control of Lead at Work Regulations 2002 require of trades working with old paint, roofing lead and painted steel.

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Published 5 October 2026 · Checked against legislation.gov.uk and HSE on 5 October 2026

Does COSHH apply to lead at work?

Lead at work is controlled by the Control of Lead at Work Regulations 2002, not COSHH. COSHH’s main duties do not apply where, and to the extent that, those regulations apply. COSHH still covers the other substances on the same job, such as the paint stripper or the dust.

Trades meet lead in old paint on joinery and steelwork, in sheet lead on roofs, in old pipework and solder, and when hot cutting painted steel. Lead enters the body as dust or fume breathed in, or as dust swallowed from unwashed hands. Some stays in the bones for years.

Before the work starts, the employer must assess the risk and decide whether exposure is “significant”. Exposure must be prevented or adequately controlled, and nobody eats, drinks or smokes where lead may be. Significant exposure also brings protective clothing, air monitoring and medical surveillance with blood tests.

For old paint, HSE’s advice is to leave sound paint in place and key it with wet abrasive paper. Where paint must come off, use methods that keep dust and fume down, never blowlamps or gas torches.

Where trades meet lead

From L132 and HSE

L132 lists work liable to give significant exposure in its Table 1, and work not liable to in its Table 2. Scale, duration and controls still decide the answer for each job.

Trade tasks that involve lead, how it gets into the body, and what HSE’s L132 guidance says about significant exposure
Task	Where trades meet it	How lead gets in	Liable to be significant?
Dry sanding or scraping old paint	Doors, windows, skirtings and joinery in buildings painted before the 1980s	Fine dust breathed in, and dust on hands swallowed	HSE’s CIS79 lists dry sanding old paint among the jobs of most risk. L132 Table 1 lists dry abrasion with power tools
Burning off old paint	Blowlamps or gas torches on old paintwork	Lead fume breathed in	Yes for burning old lead paint (L132 Table 1). HSE says do not use blowlamps or gas torches
Blast cleaning old paint	Steelwork, railings, bridges and ironwork	Dust in the air, often in large amounts	Yes (L132 Table 1)
Hot cutting painted steel	Demolition, dismantling and alterations to old steelwork	Fume released close to the breathing zone	Yes. L132 says to assess it as significant where the coating contains lead
Lead burning (lead welding)	Joints and details in roofing leadwork	Fume from lead heated above 500°C	Yes (L132 Table 1, high-temperature lead work)
Cutting, dressing and fixing sheet lead	Flashings, soakers and gutters on roofs	Dust and oxide on hands, then swallowed	Not liable to be for handling clean sheet lead (L132 Table 2), though poor hygiene can still make it significant
Old lead pipework and soldering	Plumbing alterations in older buildings	Dust from dross, and lead on hands	Not normally below 500°C (L132 Table 2), though dust from dross still needs care

L132 says its tables are not exhaustive, and intensive or poorly controlled work in Table 2 can still give significant exposure. Looking for a lead safety data sheet? Data sheets for lead products, such as solder, come from the supplier: see reading a safety data sheet.

What lead does to health

HSE’s leaflet Lead and you lists what too much lead in the body can cause: headaches, tiredness, irritability, constipation, nausea, stomach pains, anaemia and weight loss. Continued uncontrolled exposure could cause kidney damage, nerve and brain damage and infertility. HSE’s construction guidance adds that published research has linked lead exposure to a small number of occupational cancers.

The same symptoms can have other causes, so they do not on their own mean lead poisoning. The body gets rid of a little lead, but some is stored in the bones and can stay there for many years. HSE says there is growing scientific evidence that health is at risk even below the levels set in the lead regulations.

An unborn child is at particular risk, especially in the early weeks before a pregnancy is known. Lead on overalls, boots and in the van can also reach a worker’s home and family. In one HSE case, two restoration workers sanding old lead paint were hospitalised, and the dust reached workers’ homes on their overalls.

Sources: HSE INDG305 Lead and you; HSE construction hazardous substances: lead; HSE lead case studies.

What the Control of Lead at Work Regulations require

The duties below are the law, from the regulations on legislation.gov.uk. Where a row cites L132, that is HSE’s Approved Code of Practice (ACOP) or its guidance, labelled which. The ACOP has special legal status: depart from it and you must show you complied another way.

Where COSHH stops

COSHH regulations 6 to 13 do not apply where, and to the extent that, the lead regulations apply. EH40 has no lead entry and says lead is regulated separately. The lead risk assessment must still consider combined exposure where the work also involves another substance hazardous to health.

COSHH regulation 5; EH40 paragraph 52; CLAW regulation 5(2)(j)

What counts as lead

Lead includes its alloys, its compounds and lead as part of any material, such as paint, where it can be breathed in, swallowed or absorbed. L132 guidance says the regulations do not apply where the nature of the work means lead cannot get into the body that way.

CLAW regulation 2; L132 guidance, paragraphs 4 to 6

Assess before the work starts

An employer must not carry out work liable to expose employees to lead without a suitable and sufficient risk assessment, and the steps it identifies in place. It must consider whether exposure is liable to be significant. With five or more employees, the significant findings are recorded. The L132 ACOP strongly advises smaller firms to record them too.

CLAW regulation 5; L132 ACOP paragraph 81

Prevent, then control

Exposure must be prevented or, where that is not reasonably practicable, adequately controlled. Substitution comes first. Then, in order: work processes and engineering controls, control at source including ventilation, and suitable PPE only where other means cannot achieve adequate control. Adequate washing facilities are among the required measures.

CLAW regulation 6(1) to (4)

The air limit

The occupational exposure limit for lead is 0.15 mg/m³, as an 8-hour time-weighted average (0.10 mg/m³ for lead alkyls). If it is exceeded, the employer must identify why and take immediate steps to remedy the situation.

CLAW regulations 2 and 6(6)

No eating, drinking or smoking

Employers must ensure, so far as is reasonably practicable, that employees do not eat, drink or smoke where lead is, or is liable to be. Employees must not eat, drink or smoke anywhere they have reason to believe is contaminated.

CLAW regulation 7

Clothing and contaminated PPE

Where exposure is, or is liable to be, significant, the employee gets suitable protective clothing. PPE that may be contaminated is removed on leaving the work area, kept apart from clean clothing, then decontaminated or destroyed. The L132 ACOP says it should not be taken home to wash.

CLAW regulations 6(5), 8(6) and 8(7); L132 ACOP paragraph 207

Maintain and test the controls

Controls are kept in efficient working order. Local exhaust ventilation is thoroughly examined and tested at least once every 14 months, and reusable RPE at suitable intervals. Records are kept for at least 5 years.

CLAW regulation 8(1) to (4)

Air monitoring

Where exposure is liable to be significant, lead in air is measured at least every 3 months. The interval may stretch to 12 months if nothing material has changed and the two previous results were no more than 0.10 mg/m³. Records are kept for at least 5 years.

CLAW regulation 9

Information and training

Everyone liable to be exposed gets suitable and sufficient information, instruction and training. It covers the risks, the limits and levels, the assessment findings, the precautions, and the monitoring and collective surveillance results.

CLAW regulation 11

Other people and the self-employed

Employers owe the same duties, so far as is reasonably practicable, to others affected by the work, such as other trades and occupants. Medical surveillance, monitoring and training duties are narrower for non-employees. A self-employed person has the duties of both employer and employee, except air monitoring.

CLAW regulation 3(1) and (2)

Under-18s and women of reproductive capacity are barred only from lead smelting and refining and lead-acid battery manufacture. They are not barred from trade work with lead, but lower blood-lead levels apply to them. See the next section.

Blood-lead levels in the regulations

CLAW regulations 2 and 10(2)

Copied from the regulations on legislation.gov.uk on 5 October 2026. Figures are micrograms of lead per decilitre of blood (µg/dl). At the action level the employer must find out why and act. At the suspension level a doctor decides whether the worker comes off lead work.

Blood-lead levels set by the Control of Lead at Work Regulations 2002, by group of employee
Group	Level that requires medical surveillance	Action level	Suspension level
Women of reproductive capacity	20 µg/dl	25 µg/dl	30 µg/dl
Young persons (under 18)	35 µg/dl	40 µg/dl	50 µg/dl
Any other employee	35 µg/dl	50 µg/dl	60 µg/dl

A woman of reproductive capacity is an employee a relevant doctor has recorded as such in her health record. The regulations also set urinary lead levels, used for lead alkyls, the old leaded petrol additives. HSE consulted from 30 March to 7 June 2026 on updating the blood-lead levels. On 5 October 2026 its consultation page showed no published response, and the levels above remained the law.

Controlling lead on site

Find the lead first, then follow the order regulation 6 sets: prevent, control at source, then PPE. The practical detail is from HSE’s construction guidance and CIS79 unless a note says otherwise.

Find the lead

Before work on older buildings, find out whether lead paint or other lead material is present, and have a sample analysed if necessary. HSE says lead pigments were widely used in paint until the 1960s, and were not removed from all commonly used paint until the early 1980s.

NoteL132 guidance, paragraph 76; dates from HSE’s construction guidance. HSE’s CIS79 links the risk to properties built before the 1980s. Our practical advice: treat old paint in those buildings as lead until a test shows otherwise.

Prevent the exposure

Leave paint that is in good condition in place and key it with wet abrasive paper. Strip only paint that is flaking, chipping, giving off dust or a risk to children. Use cold or mechanical cutting instead of hot cutting, or different materials.

NoteCLAW regulation 6(2) puts substitution first. The L132 ACOP, paragraph 94, calls prevention the employer’s first priority.

Keep dust and fume down

Use chemical paint stripper, wet abrasive paper and a scraper, or on-tool extraction with an H or M class unit. Infrared or a hot air gun with a scraper also works. Keep hot air guns and infrared below 500°C. Do not use blowlamps or gas torches.

NoteThe stripper is itself a hazardous substance, so COSHH applies to it. See solvents. L132 guidance, paragraph 106, says wet methods should be used for rubbing or scraping down lead-painted surfaces.

Stop it spreading

Separate the work with plastic sheeting and cover surfaces. Remove or protect soft furnishings. Keep children and pregnant women away. Clean up with a damp cloth and bag debris, cloths and abrasive paper for disposal.

NoteThe L132 ACOP, paragraph 202, says lead dust should not be swept up. It should be removed with a HEPA-filtered vacuum or by wet cleaning.

Protect the worker

Wear RPE with an assigned protection factor of 20, such as an FFP3 disposable mask or a half mask with a P3 filter. For longer work, consider powered RPE with the same protection. Wear disposable coveralls, and washable or disposable gloves where lead dust is likely.

NoteTight-fitting masks need a face fit test and a clean-shaven wearer. Under regulation 6(3)(c), PPE comes after other controls, not instead of them.

Wash before every break

Wash hands and forearms before eating, drinking, smoking, using a phone or taking medication. Take breaks away from the work area. CIS79 says a small sink is not suitable: provide a large sink, hot or warm running water, soap and towels.

NoteCLAW regulations 6(4)(e) and 7. The L132 ACOP, paragraph 146, asks for basins large enough to immerse the arms to the elbow, with nail brushes.

Keep lead out of the van and the home

Take coveralls and gloves off when leaving the work area, and keep them away from clothes worn home. Do not wash contaminated work clothing at home.

NoteThe L132 ACOP, paragraphs 207 to 209, says contaminated clothing leaves site only for a specialist laundry, bagged and labelled “lead-contaminated clothing”.

Supervise and review

Check that methods, PPE and washing are used, and that water, sheeting and clothing do not run out. Review the assessment if anything changes, or if monitoring or blood results call for it.

NoteReview triggers are in CLAW regulation 5(3). Where exposure is significant, medical surveillance follows.

Most site extraction for paint removal is on-tool. Fixed extraction in a workshop is covered in local exhaust ventilation.

Medical surveillance for lead workers

Lead has its own medical surveillance, separate from health surveillance under COSHH. It is carried out by a relevant doctor and includes blood tests.

Who must be under surveillance

Every employee whose exposure is, or is liable to be, significant. Also anyone whose measured blood-lead reaches the level in the table above, or whom a relevant doctor certifies should be.

CLAW regulation 10(1) and (2)

Who carries it out

A relevant doctor: an appointed doctor, appointed in writing by HSE, or an HSE employment medical adviser. HSE advises employers to consult an appointed doctor about the surveillance their work needs.

CLAW regulation 2; L132 ACOP paragraph 262; HSE, action required by employers

When it starts and how often

Before first exposure where reasonably practicable, and within 14 working days at the latest. Then at intervals of no more than 12 months. Blood tests are at least every 6 months for most employees (yearly in limited cases), and for under-18s and women of reproductive capacity at intervals the doctor sets, no longer than 3 months.

CLAW regulation 10(3) and (4)

Variable site work

The L132 ACOP says blood-lead is measured every three months at first. For burning lead paint in demolition or blast removal of old paint, three-monthly tests may continue throughout.

L132 ACOP paragraphs 276 and 277

At the action level

The employer must find the reasons for the high blood-lead and, so far as is reasonably practicable, bring it back below the action level. The risk assessment is reviewed.

CLAW regulations 10(7) and 5(3)(d)

At the suspension level

A relevant doctor records whether the worker should be suspended from lead work, and the employer must follow that. The assessment and controls are reviewed, and others similarly exposed are checked. The L132 ACOP asks employers to make every effort to get a repeat test result within ten working days.

CLAW regulation 10(8) to (10); L132 ACOP paragraph 285

Pregnancy

The L132 ACOP says a woman of reproductive capacity who becomes pregnant should tell her employer as soon as possible. The employer tells the doctor and, on the doctor’s advice, removes her from work with significant exposure.

L132 ACOP paragraph 291

Records and the worker’s part

The health record is kept for at least 40 years from the last entry, and the worker may see it. Workers must attend surveillance in working hours, at the employer’s cost.

CLAW regulation 10(5), (6) and (12)

HSE’s statistics count 4,712 lead workers under medical surveillance in Great Britain in 2024/25, and 2 suspended for excess blood-lead. HSE’s leaflet Lead and you says a suspended worker with no suitable alternative work has the right to be paid for up to 26 weeks. That right is medical suspension pay under section 64 of the Employment Rights Act 1996, and needs at least one month’s continuous employment (section 65).

The COSHH register in Unibuild

Every data sheet to hand,
tied to the job that uses it.

In Unibuild, each hazardous substance holds its safety data sheet and its supplier, linked to the jobs, materials and purchase orders that use it. Review dates are tracked, every version is kept, and the current one is the one out on site.

When an auditor or a principal contractor asks for the COSHH register, it is a search by name or supplier, not a spreadsheet somebody else kept.

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A data sheet for every substance held with its supplier
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Review dates tracked and every version kept
Searched by product name or supplier

Free COSHH templates

Free to use and reuse, no sign-up

Free downloadCOSHH assessment templateOne substance per assessment: the hazards from the safety data sheet, who is exposed and how, the controls, PPE, storage, spills and first aid. Free downloadCOSHH register templateEvery hazardous substance on site or in the van, with its data sheet date, assessment reference, location and review date. Free downloadCOSHH risk assessment, pre-filledA risk assessment and method statement for work with cement, solvents, resins, dusts and fume on site, filled in and editable. Free downloadCOSHH symbols posterThe nine hazard pictograms and what each one means, for the store, the van or the welfare cabin. A4 or A3.

Asked most often

Lead at work: common questions

Does COSHH apply to lead?

Not where the Control of Lead at Work Regulations 2002 apply. COSHH regulation 5 switches off its main duties, regulations 6 to 13, to that extent. Lead has its own assessment, air limit and medical surveillance. COSHH still applies to other substances on the job, such as paint stripper, solvents and dust, and the lead assessment must consider combined exposure.

What are the symptoms of lead poisoning from work?

HSE lists headaches, tiredness, irritability, constipation, nausea, stomach pains, anaemia and weight loss. Continued uncontrolled exposure could cause kidney, nerve and brain damage and infertility. These symptoms have other causes too. A worker who is worried should tell a doctor about the lead work. Blood tests under medical surveillance are meant to catch rising lead before symptoms appear.

How do I know if old paint contains lead?

HSE says lead pigments were widely used in paint until the 1960s and not removed from all commonly used paint until the early 1980s. Lead paint can sit under newer coats. L132 says to identify whether lead paint is present before the work, and to have a sample analysed if necessary. Our advice: until then, treat old paint in buildings from before the 1980s as containing lead.

How do you remove lead paint safely?

Strip it only if it is flaking, chipping or a risk to children; otherwise key sound paint with wet abrasive paper. Where it must come off, use chemical stripper, wet abrasive paper or on-tool extraction. Keep hot air guns below 500°C and never use blowlamps or gas torches. Sheet off the area, wear FFP3 or equivalent RPE, clean with a damp cloth and bag the waste.

Can I use a heat gun on lead paint?

HSE says hot air guns and infrared equipment can be used with a scraper if kept below 500°C. L132 treats lead work above 500°C as high-temperature work, and says lower temperatures control the fume. Blowlamps and gas torches should not be used on old paint at all. The fume from burning old lead paint is work L132 lists as liable to give significant exposure.

What is significant exposure to lead?

The regulations define it as exposure above half the air limit, so above 0.075 mg/m³ as an 8-hour average. It also covers a substantial risk of swallowing lead, or skin contact with lead alkyls. Significant exposure brings protective clothing, air monitoring and medical surveillance by a relevant doctor.

Do roofers working with lead need blood tests?

It depends on the assessment. L132 lists lead burning above 500°C as work liable to give significant exposure, which needs medical surveillance with blood tests. Handling clean sheet lead is listed as work not liable to give significant exposure. Occasional or small-scale work may not be significant either, so the scale, duration and controls decide.

What are the blood-lead action and suspension levels?

For most employees, the action level is 50 µg/dl and the suspension level 60 µg/dl. For women of reproductive capacity they are 25 and 30, and for under-18s 40 and 50. At the action level the employer investigates and acts; at the suspension level a doctor decides whether the worker comes off lead work.

Can pregnant women or under-18s work with lead?

The law bars under-18s and women of reproductive capacity only from lead smelting, refining and battery manufacture. Otherwise lower blood-lead levels and more frequent tests apply. The L132 ACOP says a pregnant worker is removed from significantly exposed work on the doctor’s advice. L132 guidance strongly advises against school work experience students doing significant lead work.

Are the lead limits changing?

HSE consulted from 30 March to 7 June 2026 on updating the blood-lead action and suspension levels for all three groups. It said no change was proposed to the air limit. On 5 October 2026 HSE had not published its response, and the levels on this page remained the law.

Substances and diseases

Read in any order

GuideSilica dustWhere respirable crystalline silica comes from on site, what it does to the lungs, the exposure limit and the controls. GuideIsocyanatesIsocyanates in 2K paints, foams, coatings and adhesives: asthma risk, controls, RPE and health surveillance. GuideWood dustHardwood, softwood and MDF dust: the exposure limits, why hardwood dust is a carcinogen, and how to control it. GuideCement burns and dermatitisWhy wet cement burns and causes dermatitis, how to prevent it, and what to do when it gets on skin. GuideSolventsSolvents in paints, thinners, adhesives, strippers and cleaners: the health effects, enclosed spaces and controls. GuideDiesel, petrol and exhaustDiesel and petrol as hazardous substances, diesel engine exhaust on site and in workshops, and the controls. You are hereLead at workLead paint, roofing and pipework: why the lead regulations apply instead of COSHH, and what they require. GuideOccupational asthmaThe substances that cause asthma at work, how it develops, the legal duties and health surveillance. GuideOccupational dermatitisContact dermatitis at work: wet work, cement, resins and cleaning products, prevention, skin checks and reporting.

Sources

Great Britain law and HSE guidance, read on the dates above. Northern Ireland has its own COSHH Regulations.

Next step

The COSHH register,
tied to the job.

Unibuild keeps each substance’s data sheet and supplier against the jobs, materials and purchase orders that use it, with review dates tracked and every version kept.

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