CLAW 2002: HSE Control of Lead at Work Rules

Regulatory citation: Control of Lead at Work Regulations 2002 (SI 2002/2676)

What Are the Control of Lead at Work Regulations?

The Control of Lead at Work Regulations 2002 (CLAW) protect workers in Great Britain from lead that can be inhaled, ingested or absorbed. They cover metallic lead, lead alloys, lead compounds and lead alkyls. Common sources include lead smelting, battery manufacture, hot work on lead-painted steel, removing old lead paint and lead roofing work.

Why Lead Control Matters

Lead builds up in the body and can damage the blood, nervous system, kidneys and fertility. It can also harm an unborn child. Lead dust on skin and clothing is easily swallowed, so hygiene matters as much as air controls.

Core Requirements

1. Assess the Risk Before Work (reg 5)

Employers must not start work that could expose employees to lead until they have assessed the risk and put the necessary steps in place. The assessment must decide whether exposure is likely to be significant. Exposure is significant if airborne lead exceeds half the occupational exposure limit, if there is a substantial risk of ingesting lead, or if there is a risk of skin contact with lead alkyls or other absorbable lead compounds. Employers with five or more employees must record the significant findings, and the assessment must be reviewed if a monitored employee's blood-lead reaches the action level.

2. Prevent or Adequately Control Exposure (reg 6)

Exposure must be prevented, or if that is not reasonably practicable, adequately controlled. Substitution comes first, then engineering controls, ventilation and organisational measures, with PPE in addition where those are not enough. The occupational exposure limit 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. If the limit is exceeded, the employer must find out why and take immediate steps to fix it.

3. Stop Eating, Drinking and Smoking in Contaminated Areas (reg 7)

Employers must take reasonable steps to stop employees eating, drinking or smoking in places that are or may be contaminated by lead. Drinking facilities may be provided in such areas only where they stay free of contamination and are needed for welfare.

4. Maintain and Test Controls (reg 8)

Control measures must be kept in efficient working order. Local exhaust ventilation must be thoroughly examined and tested at least once every 14 months. Reusable respirators must be examined at suitable intervals. Records must be kept for at least 5 years.

5. Monitor Lead in Air (reg 9)

Where exposure is significant, air monitoring must be carried out at least every 3 months. The interval can be extended to up to 12 months if conditions have not changed, results for each group or area were at or below 0.10 mg/m³ on the previous two occasions, and lead alkyls are not involved. Records must be kept for at least 5 years.

6. Provide Medical Surveillance (reg 10)

Employees with significant exposure must be under medical surveillance by a relevant doctor, starting within 14 working days of first exposure and repeated at least every 12 months. Biological monitoring is required at least every 6 months for most employees, and at intervals of no more than 3 months for young persons and women of reproductive capacity. Health records must be kept for at least 40 years.

7. Act on Blood-Lead Levels (regs 2 and 10)

The blood-lead action levels are 25 µg/dl for women of reproductive capacity, 40 µg/dl for young persons and 50 µg/dl for other employees. The suspension levels are 30, 50 and 60 µg/dl respectively. At the action level the employer must investigate and reduce exposure. At the suspension level the doctor decides whether the employee should be suspended from lead work, and the employer must review its assessment and controls.

8. Protect Young Persons and Women of Reproductive Capacity (reg 4 and Sch 1)

They must not be employed in lead smelting and refining processes involving material containing 5 per cent or more lead, or in specified lead-acid battery manufacturing processes, including cleaning where those processes are carried out.

Common Compliance Approaches

Control Dust at Source

Use wet methods, on-tool extraction and HEPA vacuums instead of dry sweeping or compressed air.

Separate Clean and Dirty Areas

Provide washing facilities and store contaminated PPE apart from personal clothing so lead does not leave the site.

Example: Lead Control in Practice

A steel fabrication contractor is asked to cut up an old lead-painted bridge section with hot cutting gear. Its risk assessment treats exposure as significant. It fits local exhaust ventilation, issues powered respirators, sets up a clean welfare unit and bans food on the work area. Air monitoring is arranged each quarter, and the cutters are placed under medical surveillance with regular blood-lead tests. One worker's result rises close to the action level, so the contractor reviews his work practices and the extraction position.

Related regulations: COSHH hazardous substances, OSHA lead in construction, WHS lead regulations.

Note: HSE consulted from 30 March to 7 June 2026 on updating the blood-lead levels in CLAW and its Approved Code of Practice. No changes had been made to the regulations when this guide was written, so check for updates. This summary reflects the law in Great Britain, and Northern Ireland has equivalent but separate legislation.

Frequently Asked Questions

What is the workplace exposure limit for lead?

The occupational exposure limit is 0.15 mg/m³ for lead other than lead alkyls and 0.10 mg/m³ for lead alkyls, as 8-hour time-weighted averages.

How often is lead air monitoring required?

At least every 3 months where exposure is significant, extendable to 12 months only when conditions are unchanged, results are at or below 0.10 mg/m³ on the previous two occasions, and lead alkyls are not involved.

How long must lead health records be kept?

Health records must be kept for at least 40 years from the date of the last entry.