Decorators
Lead paint: how to identify it, test it and work safely in 2026
Most of the time you do not strip it. A sound paint film is safer overcoated than taken off. If you do take it off, the Control of Lead at Work Regulations 2002 apply to you in full, sole trader with no employees or not. Age tells you to stop and think. Condition tells you what to do.
Adding the English Housing Survey’s four oldest published age bands gives about 18.2 million English dwellings, 71.1% of the stock, built before 1981. The Health and Safety Executive puts you most at risk if you regularly remove existing paint coatings in properties built before the 1980s. That is not a rare case. That is the ordinary staircase and the ordinary sash window.
What follows is the order the decisions come in on the job: which houses, what the 1992 restriction did and did not do, how you test, whether you strip at all, which methods are left, and what the Regulations put on you when you do.
Which houses have lead paint?
Anything built before the early 1980s, on age alone. That is as far as the published numbers go. No UK source publishes how many homes contain lead paint, and the English Housing Survey covers England only, so the age band tells you which houses are worth testing rather than which houses have it.
The British Coatings Federation guidance for professional decorators, published by the Painting and Decorating Association, puts it on surfaces rather than buildings: many wood or metal surfaces painted before the 1960s could contain significant levels of lead. The Institute of Occupational Medicine names where it sits: doors, architraves, downpipes, window frames and sills, stairs and railings.
| When it was built | English dwellings | Share of stock | What the paint is likely to be |
|---|---|---|---|
| pre-1919 | 5,154,000 | 20.1% | Lead pigments widely used. Wood or metal surfaces painted before the 1960s can contain significant levels of lead |
| 1919–44 | 3,683,000 | 14.4% | As pre-1919. Any original paintwork predates the 1960s withdrawal |
| 1945–64 | 4,482,000 | 17.5% | Lead pigments widely used in paints for homes, schools and offices until the 1960s |
| 1965–80 | 4,882,000 | 19.1% | Lead taken out of most paints in the 1960s, but not out of all commonly used paint until the early 1980s |
Sources: the English Housing Survey 2024-25, the British Coatings Federation guidance and the Health and Safety Executive, accessed August 2026. England only. These are dwelling-age figures, not lead figures.
Take the first three of those four oldest published age bands and 13,319,000 dwellings, 52.0%, were built before 1965. Total English stock in 2024 was 25.6 million, on fieldwork that ran March 2023 to March 2025 and was weighted to April 2024.
When was lead paint actually banned in the UK?
28 February 1992, and the word ban does more work than the law does. Three separate things get run together: an Act of 1926 that was not a ban, a withdrawal of lead pigments by the paint makers through the 1960s to the early 1980s, and the legal restriction on supply and use that took effect on that date and stands today. Here they are apart.
| Date | What changed | What it did not do |
|---|---|---|
| 1926 to 1927 | The Lead Paint (Protection against Poisoning) Act 1926 made better provision for the protection against lead poisoning of persons employed in painting buildings. From 19 November 1927 it was not lawful to employ any woman or young person in painting any part of a building with lead paint | It was not a ban on lead paint |
| The 1960s | Lead pigments were taken out of most paints. Until then they were widely used in paints for homes, schools and offices | Most is not all, and nothing in law changed on this date |
| The early 1980s | Lead pigments and driers were completely removed from decorative paints. HSE dates removal from all commonly used paint to the same point | A change in what was made, not in what was already on the wall |
| 28 February 1992 | The Environmental Protection (Controls on Injurious Substances) Regulations 1992 came into force: no person shall supply by way of sale for any purpose, or use in connection with any trade or business, lead carbonate or lead sulphate intended for use as paint | Specific to lead carbonate and lead sulphate rather than the full spectrum of lead pigments and driers, on The Building Conservation Directory's reading |
| Today | The same restriction stands under entries 16 and 17 of Annex XVII to REACH, as it applies in Great Britain: lead carbonates and lead sulphates shall not be placed on the market or used where intended for use as paint | It restricts supply and use. It says nothing about the paint already on your customer's staircase |
Sources: legislation.gov.uk for the 1926 Act, the 1992 Regulations and REACH Annex XVII; the British Coatings Federation guidance; the Health and Safety Executive; The Building Conservation Directory. Accessed August 2026.
The Building Conservation Directory records that the 1992 Regulations implemented Directive 89/677/EEC. A narrow permission for restoration work survives, and the mechanics of it are in the questions below.
What does lead paint look like, and can you tell by eye?
No, you cannot tell by eye. There are signs, and none of them clears a surface.
The Society for the Protection of Ancient Buildings gives three. Old lead paint frequently has a creamy or soft colour. It may develop a fine, oblong pattern of cracking. Detached samples feel heavier than with other paints. SPAB then routes the reader straight from those signs to a test kit or more sophisticated analysis, which tells you what it thinks looking is worth.
The pigments behind the signs are worth picturing. The British Coatings Federation guidance names white lead as lead carbonate or lead sulphate, and colouring pigments as yellow and red lead chromes. The materials testing laboratory Sandberg adds red lead, lead tetroxide, a bright red or orange pigment most often used as a pigment for undercoat paints for iron.
Then the limit on all of it. No UK source consulted claims visual identification is reliable, and every determination route the British Coatings Federation guidance sets out is a test rather than a look. The eye raises suspicion and sets the age band; it cannot clear a surface. HSE gives the reason it cannot: lead paint can be found underneath existing paintwork in older buildings, so a surface that has been overpainted twice looks like whatever went on last.
How do you test a surface for lead?
Four routes, and what separates them is what a negative result is worth. The British Coatings Federation guidance sets them out: an experienced professional decorator with lead expertise, a lead test kit, a specialist company and a specialist laboratory.
| Route | What it tells you | What it misses |
|---|---|---|
| An experienced professional decorator with lead expertise | Raises suspicion from the age of the building and the look of the film | Reliability. No UK source consulted treats a look as a determination, so a surface this route does not flag has not been cleared |
| A lead test kit | A simple indication of the presence of lead. Follow the instructions carefully, and a positive response on the test paper means lead is present | The test is not necessarily 100% accurate, so a negative reading should not be relied upon to show the absence of lead. Where lead could be present, a professional test should be carried out |
| A specialist company | Tests the surface on site | A surface test reads the top coat, not what is beneath it. The Building Conservation Directory puts laboratory testing above in-the-field portable XRF testing |
| A specialist laboratory | Analysis of a sample. Accredited laboratories are found through UKAS | Price. No UK source publishes one for laboratory paint-chip analysis or for an XRF survey; both quote on request |
Sources: the British Coatings Federation guidance, the Health and Safety Executive and The Building Conservation Directory, accessed August 2026.
The kit is the route you can act on today, so it is worth knowing where it was found. B&Q listed a lead paint test kit as at 31 August 2026. A retail check in August 2026 found no lead test kit listed at Brewers, Screwfix, Toolstation, Wickes or Rawlins Paints, so on that day the decorator centre was not where to start. Neither check says what is on the shelf this week, so ring before you drive.
Should you strip it at all?
Only if it is failing. HSE says to strip back old paint if it is flaking, chipping, giving off dust or particles, or is a risk to children. Everything else stays.
The British Coatings Federation guidance puts the reason the other way round, and this is the sentence that should change what you do on Monday: there is only a risk if the paint film is unsound or disturbed. Where the surface is in good condition or already overcoated with a non-lead paint and is maintained in good condition, removal could result in a greater exposure to lead dusts and particles than leaving the paint undisturbed. Do not remove paint if it is in a sound condition, especially where the lead paint is not the top layer. Overcoating is the safest option to prevent exposure.
So on a sound staircase the job is a key, not a strip. Sound surfaces should be rubbed down wet with waterproof abrasive paper to provide a key, and the debris should not be allowed to dry out and form dust. Walls and ceilings may be treated with wallcoverings or lining paper after wet keying. What goes on top is then the ordinary decision about which finish goes over it.
HSE’s instruction lands in the same place: leave in place paintwork that is in good condition or covered by non-leaded paint. Everything in the next section is for the surfaces where that is not an option and the film has to come off.
Which stripping methods are allowed, and which are not?
Nothing dry and nothing with a flame. HSE bars blow lamps and gas torches outright and caps hot air guns and infrared equipment below 500 degrees C.
In their place HSE gives four controls to consider: chemical paint stripper, wet abrasive paper and scraper, on-tool extraction with an H or M class extraction unit, and infrared equipment or a hot air gun and scraper.
| Method | Position | The reason |
|---|---|---|
| Dry sanding | Not to be used | Do not use dry abrasive paper or techniques to remove lead paint. HSE lists dry sanding old paint among the activities that put you most at risk |
| Blow lamps and gas torches | Not to be used | Do not over heat leaded paint by using blow lamps or gas torches. HSE's builder's sheet says it flat: do not use gas torches or blow lamps |
| Hot air gun or infrared | Allowed, with a limit | Keep the tool below 500 degrees C. Take care that the paint does not burn |
| Wet abrasive paper and scraper | Preferred | One of the controls HSE tells you to consider. Keep the surface wet throughout, and keep all debris wet |
| Chemical stripper | Preferred | One of the controls HSE tells you to consider, and the British Coatings Federation option for surfaces in poor condition |
| On-tool extraction | Preferred | HSE specifies an H or M class extraction unit. Passive capture bags on tools are less effective |
| Leaving it alone and overcoating | Preferred | Leave in place paintwork that is in good condition or covered by non-leaded paint. Make a key for a new paint layer by using wet abrasive paper |
Sources: the Health and Safety Executive and the British Coatings Federation guidance, accessed August 2026.
The temperature is a ceiling for the tool, not a threshold for the paint. HSE publishes no temperature at which lead paint starts to give off fume, so there is no onset figure to work back from. The control is the tool setting and the bar on open flame, and nothing else. The British Coatings Federation guidance states it as an outcome instead of a number: do not create lead fumes by over-heating lead-containing paints. Where a hot air gun is used, scrape the softened paint immediately into a suitable container before it re-hardens.
The Lead Paint (Protection against Poisoning) Act 1926 gave the Secretary of State power to make regulations prohibiting dry rubbing down and scraping, so dry sanding has been recognised as the wrong method for a century. HSE’s own risk list still names it, alongside blast removal and burning of old lead paint, and stripping of old lead paint from doors and windows. One line covers all of it: do not create any dry paint dust during the whole process.
Do the Control of Lead at Work Regulations apply if you work for yourself?
Yes, in full, with one exception. The Control of Lead at Work Regulations 2002 apply to a self-employed person as they apply to an employer and an employee, and as if that person were both, except that regulation 9, air monitoring, does not apply to a self-employed person. HSE puts the practical half of that in one line: take the same action to protect yourself as an employer takes to protect employees, and use protective equipment on the same basis as employees.
The duty that bites first is the assessment. An employer must not carry out work liable to expose employees to lead without first making a suitable and sufficient assessment of the risk and of the steps needed, and implementing those steps. The assessment must consider, among twelve listed matters, any relevant occupational exposure limit, action level and suspension level, and whether exposure is liable to be significant. Recording the significant findings is a duty on employers with five or more employees, so on your own the assessment is still required and the written record is not.
Significant has a definition. Exposure is liable to be significant where the person is exposed to lead in air above half the occupational exposure limit, or there is a substantial risk of ingesting lead, or there is a risk of skin contact with lead alkyls or other lead compounds for which skin absorption is a significant route. The occupational exposure limit is 0.15 mg/m³ for lead other than lead alkyls, as an 8-hour time-weighted average, and 0.10 mg/m³ for lead alkyls.
Whether the work in front of you reaches that threshold is also on paper. Paint stripping and blast removal or abrasion of lead painted surfaces are listed in the Approved Code of Practice L132 under activities that may result in significant exposure, on the British Coatings Federation guidance’s account.
What does lead do to you, and what stops it getting in?
It gets in through your lungs and your mouth. HSE is specific: lead is not absorbed through the skin, except in the form of lead alkyls and lead naphthenate. Absorption is by breathing dust, fume or vapour, or by swallowing, for example by eating, drinking, smoking or biting nails without washing hands and face. Every control below follows from that one sentence.
The mask is a specification, not a preference. HSE gives RPE with an assigned protection factor of 20, for example an FFP3 disposable mask or a half mask with a P3 filter, and for longer duration work powered RPE with the same protection, for example a TH2 powered hood or helmet. Anyone wearing tight fitting RPE needs to be clean shaven and face fit tested. That is one particulate specification for the whole job: HSE publishes no separate mask class for fume, because its position is that fume should not be generated at all.
Clothing and washing close the swallowing route. Wear disposable coveralls and washable or disposable gloves where lead dust contamination is likely. Remove them when leaving the work area, and do not wear them in rest areas. Wash hands and forearms before eating, drinking, smoking, using the telephone or taking medication, and avoid hand-mouth contact in contaminated areas. Take rest and meal breaks away from the work area, and do not smoke, eat or drink in it.
Welfare is a specification too. A small sink is not suitable. Provide a large sink, hot or warm running water, soap and towels. Agree that with the customer before the sheets go down. It is not kit you carry in the van, so the answer comes from whoever owns the building.
When does the law expect a blood test?
Wherever exposure is or is liable to be significant, and at the blood-lead concentrations below. Medical surveillance must commence before the person first does work giving rise to exposure and in any event within 14 working days, and health records are kept at least 40 years from the last entry.
| Who | Medical surveillance from | Action level | Suspension level |
|---|---|---|---|
| Any other employee | 35 micrograms per decilitre | 50 micrograms per decilitre | 60 micrograms per decilitre |
| Young person under 18 | Not stated as a blood-lead figure | 40 micrograms per decilitre | 50 micrograms per decilitre |
| Woman of reproductive capacity | 20 micrograms per decilitre | 25 micrograms per decilitre | 30 micrograms per decilitre |
Sources: the Control of Lead at Work Regulations 2002, with the Health and Safety Executive's INDG305 as the corroborating published table. Accessed August 2026.
Read yourself into the first row, unless you are under 18 or a woman of reproductive capacity, because regulation 3 makes you your own employee for this purpose.
The two levels do different jobs. At the action level the employer must investigate why this has happened and try to reduce it to below that level. At the suspension level the doctor repeats the test and will usually decide that the person should not carry on working with lead, and there is a right to suspension pay for up to 26 weeks.
How do you clean up, and what happens to the waste?
Wet, bagged, sealed and classified. Remove debris with a damp cloth, and place debris, cloths and abrasive paper in a plastic bag for disposal. Clean up all debris frequently, as well as at the end of each day. Thoroughly wash all surfaces from which lead-containing paints have been removed and others in the work area, and allow to dry before applying new paint. Never burn or incinerate lead-containing wastes. Use additional controls to prevent dust or fume spreading, such as plastic sheeting to separate the work and cover surfaces, and remove or protect soft furnishings.
Two vacuum standards run through this work and they are not the same standard. HSE’s H or M class is a specification for on-tool extraction. The British Coatings Federation guidance gives a separate instruction for general clean-up: vacuum all surfaces with a vacuum cleaner fitted with a high efficiency particle air (HEPA) filter. No UK source consulted sets a class for the clean-up vacuum beyond that filter specification, so work to the specification rather than to a brand.
Then the waste. A business must classify its waste before it is collected, disposed of or recovered, and describe it with the classification code and whether it is hazardous. An asterisk at the end of a waste code means the waste is hazardous. GOV.UK gives waste paint and varnish containing organic solvents or other dangerous substances as 08 01 11*, hazardous; without them it is 08 01 12, non-hazardous; and paint or varnish remover as 08 01 21*, hazardous. There is no published code specific to lead paint removal debris, so classify what you actually have and describe it.
What do you tell the customer?
Who is out of the house, when, and until when. HSE says to pay particular attention to keeping children and pregnant women away from the work area. The British Coatings Federation guidance goes further: prohibit anyone not involved in the work from the area, and preferably from the building until the area has been thoroughly and effectively cleaned.
Give them the reason. Children absorb lead mostly by eating it, or by touching contaminated dust or soil and then putting their fingers into their mouths. UK Health Security Agency guidance published on GOV.UK puts most cases of lead poisoning in children down to the consumption of paint containing lead. An unborn child is at particular risk from lead exposure, especially in the early weeks before a pregnancy becomes known, which is why this conversation happens before the work rather than during it.
The rest is what moves and what gets covered. Remove furniture, curtains and soft furnishings as far as possible. Where that cannot be done, cover these and other permanent items including flooring with plastic sheeting sealed with heavy duty tape, and beware of slipping on those surfaces. Agree all of it before the first day, because moving a sofa halfway through the job means moving it through the work area.
Common questions
Can you still buy lead paint in the UK?
Not for ordinary decorating. The Environmental Protection (Controls on Injurious Substances) Regulations 1992 exempt paint supplied for the restoration or maintenance of an historic building, or a fine or decorative work of art, where it is required to restore or maintain historic textures or finishes. Supply waits three weeks from a completed declaration to the competent authority. The Society for the Protection of Ancient Buildings limits that to listed buildings Grades I and II*, their Scottish equivalents, scheduled monuments and works of art.
What are the symptoms of lead poisoning?
HSE lists headaches, tiredness, irritability, constipation, nausea, stomach pains, anaemia and loss of weight, and says continued uncontrolled exposure can cause kidney damage, nerve and brain damage and infertility. These symptoms have causes other than lead, so they do not necessarily mean lead poisoning. Absorbed lead circulates in the blood; some stays, stored mainly in the bones, for years without making you ill. The British Coatings Federation guidance routes you to NHS 111 in England, or NHS 24 on 111 in Scotland.
How often would a blood test be repeated?
At least every 6 months under the Control of Lead at Work Regulations 2002, dropping to annually only where air exposure is above 0.075 mg/m³ but below 0.100 mg/m³ and the individual blood-lead is under 30 micrograms per decilitre. For young persons and women of reproductive capacity the interval is set by the relevant doctor and may not exceed 3 months. HSE puts usual practice at every 3 months for those groups. There is a legal obligation to provide the samples.
Does a chemical stripper need a different mask from sanding?
Yes, and the trap is that one will not do the other job. The British Coatings Federation guidance says a suitable face mask to protect against chemical-stripper fumes might be required, and that such masks will not protect against dusts and should not be used for that purpose. So a vapour mask worn for stripping is the wrong mask the moment you pick up abrasive paper. The dust specification is in the section on what stops lead getting in.
What changes when the work is outside?
The ground and the wind. The British Coatings Federation guidance says to avoid contaminating the soil when working outside, to cover all grass and garden beds in the near vicinity with plastic sheeting, and to avoid working in windy conditions. That last one decides your day: wind stops the work, so check the forecast before you load the van. Sheet the ground before the first scraper goes near the window.
How do you avoid taking lead dust home?
Split the site into a dirty area and a clean area. HSE puts PPE and RPE on and off in the dirty area, then a shower, then the clean area where the clothes you travel home in are kept. That split reduces secondary contamination of your car and home. Keep contaminated clothing away from the clothes you wear outside work, and do not wash contaminated clothing at home.
Sources
- The Environmental Protection (Controls on Injurious Substances) Regulations 1992, SI 1992/31, regulation 3. Accessed August 2026. https://www.legislation.gov.uk/uksi/1992/31/regulation/3/made
- Annex XVII to Regulation (EC) No 1907/2006 (REACH) as retained in Great Britain, entries 16 and 17. Accessed August 2026. https://www.legislation.gov.uk/eur/2006/1907/annex/XVII
- Lead Paint (Protection against Poisoning) Act 1926, as enacted. Accessed August 2026. https://www.legislation.gov.uk/ukpga/Geo5/16-17/37/pdfs/ukpga_19260037_en.pdf
- The Control of Lead at Work Regulations 2002, SI 2002/2676, regulations 2, 3, 5 and 10. Accessed August 2026. https://www.legislation.gov.uk/uksi/2002/2676/body
- Health and Safety Executive, Construction hazardous substances: Lead, last updated 12 November 2024. Accessed August 2026. https://www.hse.gov.uk/construction/healthrisks/hazardous-substances/lead.htm
- Health and Safety Executive, CIS79, Old lead paint: What you need to know as a busy builder, September 2014. Accessed August 2026. https://www.hse.gov.uk/pubns/cis79.pdf
- Health and Safety Executive, INDG305(rev2), Lead and you: Working safely with lead, August 2012. Accessed August 2026. https://www.hse.gov.uk/pubns/indg305.pdf
- Health and Safety Executive, Frequently asked questions on lead. Accessed August 2026. https://www.hse.gov.uk/lead/faqs.htm
- British Coatings Federation, HS034, Lead in painted surfaces: Repainting and removal, guide for professional decorators, April 2016, published by the Painting and Decorating Association. Accessed August 2026. https://paintingdecoratingassociation.co.uk/wp-content/uploads/2020/12/HS-034-Lead-in-Painted-Surfaces-guidance-for-Professional-Decorators-April-2016.pdf
- English Housing Survey 2024-25, Chapter 1 annex tables, Table 1.6, Stock profile of dwellings 2024, published 4 December 2025. Accessed August 2026. https://assets.publishing.service.gov.uk/media/6985b1dd6da2dee8230a9b0e/2024-25_EHS_Headline_Report_Chapter_1_Profile_of_households_and_dwellings_Annex_Tables.ods
- English Housing Survey 2024-25 headline report, Chapter 1, Profile of households and dwellings. Accessed August 2026. https://www.gov.uk/government/statistics/chapters-for-english-housing-survey-2024-to-2025-headline-findings-on-demographics-and-household-resilience/chapter-1-profile-of-households-and-dwellings
- Society for the Protection of Ancient Buildings, Lead paint. Accessed August 2026. https://www.spab.org.uk/advice/lead-paint
- Hesaan Sheridan, Lead paint, The Building Conservation Directory, 2018. Accessed August 2026. https://www.buildingconservation.com/articles/lead-paint/lead-paint.htm
- Sandberg, Lead in Paint. Accessed August 2026. https://www.sandberg.co.uk/laboratories/chemistry/lead-in-paint/
- Institute of Occupational Medicine, Lead in Paint. Accessed August 2026. https://www.iom-world.org/lab-services/lead-in-paint/
- UK Health Security Agency, Lead: information for the public, published on GOV.UK 8 October 2024. Accessed August 2026. https://www.gov.uk/government/publications/lead-poisoning-advice-for-the-public-and-healthcare-professionals/lead-information-for-the-public
- GOV.UK, Construction and demolition waste: how to classify, last updated 13 August 2025. Accessed August 2026. https://www.gov.uk/guidance/construction-and-demolition-waste-how-to-classify
- GOV.UK, Classify different types of waste: your legal responsibilities. Accessed August 2026. https://www.gov.uk/guidance/classify-different-types-of-waste-your-legal-responsibilities
- UKAS, the United Kingdom Accreditation Service, directory of accredited testing laboratories. Accessed August 2026. https://www.ukas.org
- B&Q, SenSafe Lead Paint Test, pack of 10, product listing observed 31 August 2026. Accessed August 2026. https://www.diy.com/departments/sensafe-lead-paint-test-pack-of-10/0809762803108_BQ.prd