The Health and Safety Executive (HSE) has recently launched an informal consultation regarding proposals to lower the action and suspension blood lead levels as laid out in the Control of Lead at Work (2002) regulations (CLAW 2002). While still under consultation, these proposals could mark a significant change in the way lead exposure is managed and monitored in the workplace.
What Is Being Proposed?
Since the introduction of CLAW in 2002 the blood suspension level has been set at 60 µg/dl. HSE is now reviewing CLAW 2002 with a view to amending this blood lead suspension level. The proposal is as follows:
• All employees (including young workers 16 – 18) - reduce the current suspension level of 60µg/dl to 30µg/dl in October 2026, then reduce further to 15µg/dl in October 2028. (There would be a similar reduction in the action levels - from 50µg/dl to 20µg/dl, then
10µg/dl).
• Women of childbearing capacity - reduce the current suspension level of 30µg/dl to 10µg/dl in October 2026, then reduce further to 5µg/dl in October 2028. (There would be a similar reduction in the action levels - from 25µg/dl to 5µg/dl, then 2µg/dl).
As the trade association representing lead roofing specialists, the Lead Contractors Association’s role is twofold: to ensure that members are fully aware of regulatory developments, and to represent the practical realities of specialist lead roofing work in discussions with policymakers. Should these proposals be formalised in the future, there would be a significant impact on anyone working in leadwork of any form, including conservation and
heritage roofing.
Why Context Matters: The Realities of Leadwork
Lead is not a generic material, and leadwork is not a uniform industry. The environment in which lead is used makes a huge difference.
In industrial, enclosed settings, exposures can be more concentrated and standardised controls may be easier to apply. In other areas such as roofing and conservation, however, the work is typically outdoors, on unique structures, under conditions that can never be entirely standardised.
Lead has been used for centuries in roofing and remains highly valued today not only for its durability and workability but also for its authenticity. It continues to be the material of choice not only in conservation work, where historical accuracy is essential, but also in many modern and residential settings where performance and sustainability are priorities. Its proven track record makes it a critical material across both heritage and contemporary construction. Our members work daily on some of the nation’s most treasured landmarks, balancing safety with precision craftsmanship.
Working Towards Balanced Regulation
There is need for an approach that both safeguards worker health and recognises the specialist nature of leadwork in heritage and construction. If workable solutions are not found, projects could face rising costs, delays, or even difficulty sourcing skilled leadworkers — challenges that directly impact the protection of historic buildings. Achieving a balance is essential to ensure improvements are made while supporting the continued delivery of skilled trades that rely on lead as a proven material.
While these discussions are ongoing, it is clear that tighter requirements are likely to emerge in the near future. The Lead Contractors Association aims to ensure that any new measures are workable, evidence-led, and aligned with the realities of our specialist trade. We stand ready to work with regulators and industry partners to develop a framework that achieves these shared
objectives.