Icon has formally responded to the Health and Safety Executive (HSE) consultation on proposed changes to the Control of Lead at Work Regulations 2002 (CLAW), following widespread concern across the conservation and heritage sector.
Concerns Around Proposed Changes
Drawing on evidence gathered from across the stained glass conservation sector, Icon’s response emphasises that many professionals already operate under robust health and safety procedures, including ventilation systems, PPE, hygiene controls, regular monitoring, and occupational health oversight.
Despite these measures, the proposed thresholds would still place a significant proportion of the workforce above the proposed action and suspension levels. Icon argues that this reflects the unavoidable nature of lead use within heritage conservation rather than poor safety practice.
Implications for the Sector
Icon also raised concerns about the disproportionate impact the proposals may have on women of reproductive capacity, warning that the proposed limits could effectively prevent many professionals from continuing hands-on conservation work.
The response highlights the wider implications for equality, workforce sustainability, specialist skills retention, and training across the sector, particularly within specialist disciplines such as stained glass conservation where the workforce is already small and highly specialised.
Risks to Cultural Heritage
The response further outlines the potential risks posed to the UK’s cultural heritage if experienced practitioners are unable to continue carrying out essential conservation work on nationally important collections and historic buildings.
Icon notes that reducing the number of qualified professionals able to undertake lead-related conservation work could significantly impact the sector’s long-term ability to preserve and care for heritage assets.
Sector Engagement and Next Steps
Throughout the consultation period, Icon worked closely with members of the Icon Stained Glass Group and conservation professionals to gather evidence, facilitate discussions, and support engagement with the consultation process.
Icon continues to support proportionate, evidence-based approaches to improving worker protection and has called for greater flexibility within the regulations to recognise the unique realities of heritage conservation practice.
Read Icon's Response to the Consultation
You can read Icon's full response below.
