09/05/2026
Appeal for help from the Stained Glass Museum
HSE Consultation on Lead:
Your Help is Needed
Concerns over HSE’s proposed changes to Control of Lead at Work Regulations 2002 (CLAW)
Dear Friends and supporters,
Along with other organisations and individuals who work with stained glass or are custodians of heritage buildings, we are writing to share our concerns over proposed changes to Control of Lead at Work Regulations 2002 (CLAW) by the Health and Safety Executive (HSE), which aim to significantly reduce the permitted levels of lead (Pb) in workers’ blood.
We are concerned about the impact these proposed changes might have on the practice of stained glass by artists and conservators, as well as to the wider heritage sector – as lead is a material used extensively in historic buildings, e.g. the roof of Ely Cathedral, as well as in stained glass windows, organs, and other objects in heritage collections across the country.
We need to respond to these proposals to ensure that proposed measures have considered the implications for the stained glass industry and for the preservation of our heritage at large.
The deadline for responses to the consultation is 24th May so there is not long to act. https://consultations.hse.gov.uk/hse/control-lead-at-work-regs-2002-exposure-guidance/
Please send any responses by
24 May 2026
About the Proposals
Health and Safety regulations aim to ensure that everyone working with lead does so in a safe controlled manner through an approved code of practice.
As part of this, those working with lead undergo regular biological monitoring with defined ‘action’ and ‘suspension’ blood-lead levels that employers and employees both have a responsibility to adhere to.
If an employee is at or above the ‘action’ level, the employer must take steps to reduce it. If an employee is at or above the ‘suspension’ level, an employer must suspend them from working with lead until the level is reduced. The HSE has recently undergone a long overdue review of these levels and made the following proposed changes to the levels, due to come into force in 2027.
Whilst a review of these levels is welcomed, the current proposals reduce permitted blood lead levels by up to 80% within less than four years. We believe that in many cases this will be unachievable, even with best-practice health and safety measures in place.
It can take years to reduce the detectable lead levels in blood and so these levels may be unattainable for many. Various industries have challenged this review and in response HSE have opened consultation for stakeholders to make comment on at: https://consultations.hse.gov.uk/hse/control-lead-at-work-regs-2002-exposure-guidance/
For women of reproductive capacity (i.e. under 49, regardless of whether they plan to or can have children), the proposed limits are lower than some background levels we believe are found in the general population, although there is precious little data on background levels. This proposal would disproportionately impact women working in the sector, and so we propose that HSE’s proposed 2027 lower action/suspension levels are only applied to ‘pregnant women’ and otherwise the general employees’ level should apply.
This is one of many perhaps unintended consequences of these proposals which ought to be considered, including unemployment levels, the mental health of employees forced from a career they love, and the health benefits of stained glass for recreation and wellbeing, to name just a few.
What can you do?
Write to your MP – help us raise awareness of these proposals and their potential impact by writing to your MP. Find your MP - MPs and Lords - UK Parliament
Respond to the Consultation – if you feel able to, please respond to the HSE consultation questionnaire. We have been advised that having a large number of responses to the HSE consultation questionnaire from a wide range of people will help our case. https://consultations.hse.gov.uk/hse/control-lead-at-work-regs-2002-exposure-guidance/
Please encourage others who care about stained glass to respond.
Historic stained glass window making is already classed as 'endangered' by the Heritage Crafts Association and included in its annual Red List of Endangered Crafts.
These proposals present an additional threat to the art of making and conserving stained glass – an industry which relies on the use of lead, as well as increasingly rare, specialist skills.
Find and participate in consultations run by the Health and Safety Executive
