Lead-Based Paint (pre-1992 painted surfaces)
COSHH assessment
A COSHH assessment for lead-based paint (pre-1992 painted surfaces) on a UK construction site: what it does to people, how it gets into them, the controls that stop it, the PPE for what is left, and what to do when it goes wrong. Copy it into your assessment and change what does not fit your job.
Hazards to health
Cumulative neurotoxin, IQ deficits, peripheral neuropathy, anaemia, kidney damage, reproductive toxicity (Cat 1A reprotoxin). Bioaccumulates. Children and pregnant women must be excluded from contaminated areas. Blood lead WEL: women of reproductive capacity 30 µg/100ml suspension, men 60 µg/100ml.
Routes of exposure
Inhalation (sanding/burning dust), Ingestion (hand-to-mouth), Skin absorption (organic lead)
Control measures
- Test paint first (XRF or chemical kit) before disturbance.
- Notifiable to HSE under CLAW 2002 if significant.
- No dry sanding, no sandblasting, no naked-flame burning, no high-temp heat guns >450°C.
- Chemical strippers or low-temp infrared preferred.
- Enclose work area with poly sheeting and negative-pressure HEPA extraction.
- H-class HEPA vacs only.
- Site cabin separate from clean areas, dirty boots and overalls left in airlock.
- Wash hands before eating, drinking or smoking, no eating in work area.
- Air and biological monitoring (blood lead).
- Hazardous waste disposal under EPR 2010.
PPE for what is left
- P3 half-mask or PAPR (TH2/TH3) for prolonged work, Disposable Type 5 coveralls (single-use), Nitrile gloves, Overshoes/boot covers, Eye protection
Emergency procedures
- Suspected exposure: HEPA-vac off PPE, shower and change before leaving site.
- Blood lead test within 1 week.
- Symptoms (abdominal pain, fatigue, paraesthesia) often delayed weeks/months, report any to occupational health.
- Pregnant workers: immediate removal from exposure pending review.
Questions people ask
Do I need a COSHH assessment for lead-based paint (pre-1992 painted surfaces)?
If the substance is hazardous to health and your work exposes people to it, yes. The Control of Substances Hazardous to Health Regulations 2002, regulation 6, require a suitable and sufficient assessment before the work starts, with the significant findings recorded if you employ five or more. The safety data sheet is an input to the assessment, not a substitute for it. Guidance, not legal advice.
What is the difference between a safety data sheet and a COSHH assessment?
The data sheet is the manufacturer describing the product in general. The assessment is you describing how your people use it on your job: how much, how often, for how long, in what ventilation, with what controls. Two firms using the same tin can have very different assessments.
What is a WEL?
A Workplace Exposure Limit, the maximum airborne concentration averaged over a reference period, set in HSE document EH40. For this substance: WEL: women of reproductive capacity 30 µg/100ml suspension, men 60 µg/100ml.
Is PPE enough?
No. COSHH puts PPE last: eliminate the substance, substitute for something less harmful, control at source with ventilation and enclosure, then organise the work to reduce exposure, and only then PPE for what is left. An assessment that jumps straight to gloves and a mask is the kind an inspector questions. Guidance, not legal advice.
How often should it be reviewed?
When the product, the method, the quantities or the people change, if there is any sign the controls are not working, and at least every year or so regardless. Health surveillance may be required where exposure could cause an identifiable disease, such as dermatitis or occupational asthma.
The COSHH assessment writes itself
Pick the substance in the SiteLynx RAMS editor and the COSHH assessment fills in with the hazards, controls and PPE, alongside the HAVS and noise assessments for the tools you chose. Signed on site on a phone. 14 days free.
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