COSHH · Mandatory · Pre-Construction
COSHH Assessment — Lead Paint
This COSHH assessment covers the risks of disturbing lead-based paint during refurbishment, strip-out, or maintenance of pre-1970s buildings. Lead exposure causes neurological damage, kidney disease, and reproductive harm. Controls include wet removal methods, HEPA-filtered extraction, blood lead monitoring, and specialist waste disposal as hazardous waste.
Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. COSHH Regs / Control of Lead Regs remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.
| Primary legislation | Control of Lead at Work Regulations 2002 (CLAW) supported by COSHH 2002 and MHSWR 1999 |
| Where found | Pre-1960 buildings: presume lead paint present. Pre-1980 buildings: lead paint likely. Post-1992: lead paint banned for consumer sale under CHIP Regulations. |
| High-risk activities | Dry sanding, hot work (burning off with blowtorch), power grinding, needle-gun descaling, blasting — any process that generates lead dust or fume |
| Biological monitoring | Blood lead level testing required. Action level: 50 ug/dL. Suspension level: 60 ug/dL (males), 25 ug/dL (women of reproductive capacity) |
| Waste classification | Lead paint waste is hazardous waste under the Hazardous Waste Regulations 2005 — must be disposed of via licensed hazardous waste carrier |
1. Lead Paint in UK Buildings
Lead-based paints were used extensively in the UK construction industry until the late twentieth century. White lead (lead carbonate) was the standard pigment in primers and undercoats for both interior and exterior surfaces, prized for its durability and adhesion. Red lead was the conventional primer for structural steelwork. As a result, any building constructed or decorated before 1980 may contain lead paint, and any building constructed before 1960 should be presumed to contain it unless testing proves otherwise.
Lead paint in good condition and left undisturbed presents a low risk. The hazard arises when the paint is disturbed — by sanding, scraping, cutting, grinding, burning off, or demolition. These activities generate lead-containing dust and fume that is readily inhaled or ingested. Lead is a cumulative poison: it builds up in the body over time, causing damage to the nervous system, kidneys, and reproductive system. There is no safe threshold for chronic exposure, which is why the Control of Lead at Work Regulations 2002 (CLAW) impose strict duties on employers whose workers may be exposed.
CLAW is the primary regulatory framework for lead exposure at work. It sits alongside the COSHH Regulations 2002 and requires employers to assess the risk, prevent or adequately control exposure, provide health surveillance including biological monitoring, and maintain records. CLAW applies to all work that is liable to expose employees to lead, including maintenance, refurbishment, decoration, and demolition of buildings containing lead paint.
Women of reproductive capacity: lower suspension level applies
Under CLAW, the blood lead suspension level for women of reproductive capacity is 25 ug/dL — significantly lower than the 60 ug/dL threshold for males. This reflects the severe risk that lead exposure poses to fetal development. Employers must identify whether any workers fall within this category and ensure that exposure is controlled to a level that protects against this lower threshold. This is not optional guidance — it is a specific legal requirement under CLAW Regulation 10.
2. Key Controls for Lead Paint Work
Before any work begins on surfaces that may contain lead paint, a lead paint survey must be carried out to confirm whether lead is present and at what concentration. The survey results determine the level of controls required. The hierarchy of control applies: eliminate the hazard where possible (for example, by encapsulating rather than removing), substitute with a less hazardous method, and apply engineering controls before relying on personal protective equipment. The following table sets out the key controls for lead paint work.
| Control measure | Detail |
|---|---|
| Survey first | Commission a lead paint survey before any disturbance work begins. XRF (X-ray fluorescence) testing provides rapid, non-destructive results. Laboratory analysis of paint chip samples provides definitive confirmation. Do not assume the absence of lead paint without testing. |
| Wet methods | Use wet sanding, wet scraping, and misting to suppress dust generation. Never dry sand, dry scrape, or dry abrade surfaces containing lead paint. Wet methods reduce airborne lead dust by up to 90 percent compared with dry methods. |
| HEPA extraction | Where power tools are used, they must be fitted with HEPA-filtered local exhaust ventilation (LEV) at the point of dust generation. Standard workshop vacuum extractors are not adequate — only H-class (HEPA) extraction meets the required filtration standard for lead dust. |
| Avoid hot work | Never use a blowtorch, heat gun above 450 degrees Celsius, or any open flame to remove lead paint. Burning off generates lead fume, which is far more hazardous than lead dust because the particles are smaller and penetrate deeper into the lungs. Chemical paint strippers or infrared paint removers operating below 450 degrees Celsius are the accepted alternatives. |
| RPE | Respiratory protective equipment must be appropriate to the task. Minimum FFP3 disposable mask for low-dust tasks. Half-mask with P3 filters for sustained sanding or scraping. Full-face powered air purifying respirator (PAPR) with P3 filters for high-dust activities or prolonged exposure. RPE must be face-fit tested to the individual wearer. |
| Hygiene facilities | Dedicated washing facilities must be provided at the work area. Workers must wash hands and face before eating, drinking, or smoking. Work clothing must not be taken home — it must be laundered separately or disposed of as contaminated waste. No eating, drinking, or smoking in the work area. |
Biological monitoring is not optional under CLAW
Where exposure to lead is significant, CLAW Regulation 10 requires the employer to place employees under medical surveillance, including regular blood lead level testing. The action level is 50 ug/dL, at which point the employer must investigate why controls are not preventing significant absorption and take corrective action. The suspension levels — 60 ug/dL for males and 25 ug/dL for women of reproductive capacity — require the employee to be removed from lead work until their blood lead level falls below the relevant threshold. Records of biological monitoring must be kept for 40 years.
3. Common Mistakes
Dry sanding or blasting surfaces without lead paint controls
Dry sanding, dry scraping, or abrasive blasting of lead-painted surfaces without dust suppression, HEPA extraction, and appropriate RPE generates extremely high concentrations of airborne lead dust. This is the most common cause of occupational lead poisoning in the construction industry. Workers may exceed the suspension blood lead level after just a few hours of uncontrolled dry sanding on lead-painted surfaces.
Using a blowtorch or high-temperature heat gun to remove paint
Burning off lead paint with a blowtorch or heat gun above 450 degrees Celsius generates lead fume — ultra-fine particles that penetrate deep into the lungs and are absorbed into the bloodstream far more readily than lead dust. This method has been prohibited by industry guidance for decades, yet it continues to be used on refurbishment projects. Chemical strippers or infrared removers below 450 degrees Celsius must be used instead.
Not conducting blood lead monitoring for workers exposed to lead paint
CLAW requires biological monitoring (blood lead level testing) for all employees whose exposure to lead is significant. Failing to arrange blood lead testing means the employer has no way of knowing whether controls are effective and no early warning of excessive absorption. The 40-year record-keeping requirement reflects the long latency of lead-related disease.
Disposing of lead paint waste in general skips
Lead paint waste — including paint scrapings, contaminated dust, used abrasives, disposable overalls, and RPE filters — is classified as hazardous waste under the Hazardous Waste Regulations 2005. It must be segregated on site, stored in sealed containers marked as hazardous waste, and collected by a licensed hazardous waste carrier for disposal at a licensed facility. Mixing it with general construction waste is an offence that can result in prosecution and an unlimited fine.
Not informing workers of survey results and risks
Workers have a legal right to be informed of the findings of the lead paint survey and the results of the risk assessment. This includes the location and extent of lead paint, the control measures required, the health surveillance arrangements, and the results of any air monitoring. Keeping this information from the workforce is a breach of CLAW and prevents workers from taking the precautions necessary to protect their own health.
5. Frequently Asked Questions
How do you identify whether paint contains lead?▾
The only reliable way to confirm the presence of lead paint is testing. XRF (X-ray fluorescence) analysis provides rapid, non-destructive results on site and is the preferred screening method. Laboratory analysis of paint chip samples provides definitive confirmation of lead content and concentration. Visual inspection alone cannot determine whether paint contains lead. As a rule of thumb, presume lead paint is present in any building constructed before 1960 and consider it likely in any building constructed before 1980. Paint applied after 1992 should not contain lead, as consumer sale was banned under CHIP Regulations, but industrial and marine paints containing lead remained available after this date.
Does CLAW apply to domestic painting and decorating?▾
Yes. The Control of Lead at Work Regulations 2002 apply to all work that is liable to expose any employee to lead. This includes domestic painting and decorating work where the preparation involves disturbing lead paint — for example, sanding, scraping, or stripping painted surfaces in pre-1980 properties. Domestic decorators working on older properties must carry out a lead risk assessment and apply the same controls as commercial contractors. Self-employed workers have equivalent duties under the Health and Safety at Work Act 1974.
What RPE is required for lead paint removal?▾
The type of RPE depends on the task and the level of dust or fume generated. For low-dust tasks such as careful wet scraping, a minimum of an FFP3 disposable mask is required. For sustained sanding or scraping, a half-mask respirator with P3 particulate filters is the minimum standard. For high-dust activities such as mechanical removal, power tool use, or work in enclosed spaces, a full-face powered air-purifying respirator (PAPR) with P3 filters is required. All RPE must be face-fit tested to the individual wearer in accordance with HSE guidance INDG479. Disposable masks must not be reused between shifts.
Which takes priority — CLAW or COSHH?▾
CLAW is the specific regulation for lead exposure and takes priority where its requirements are more stringent than the general COSHH Regulations. In practice, CLAW sets out additional duties that go beyond COSHH — particularly the requirements for biological monitoring, specific suspension levels, and the 40-year record-keeping period. However, COSHH still applies to the general framework of assessment, prevention, and control. The two regulations operate together: CLAW provides the lead-specific standards, and COSHH provides the general framework within which they sit.
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