Lead flashing RAMS UK 2026: a roofer's guide to risk assessment, method statement and CLAW 2002

Lead flashing is one of the most rewarding parts of roofing — visually distinctive, well-paid, and a genuine craft skill. It is also one of the most heavily regulated, because lead is a cumulative toxin and most lead work involves either hot works (oxy/acetylene welding) or substantial cutting and dressing that releases lead-bearing material. This guide covers what a lead flashing RAMS must contain in the UK in 2026, the regulations that apply, and the specific controls every Principal Contractor will look for before letting you on site.

Why lead flashing needs its own RAMS, not just a generic roofing one

Most general roofing RAMS treat lead works as an afterthought — a paragraph at the end about wearing a mask. That approach fails in two directions: it does not satisfy the legal requirements under the Control of Lead at Work Regulations 2002 (CLAW), and it does not protect the workers carrying out the actual operation.

The Health and Safety Executive treats lead exposure as a separate regulatory regime from general construction COSHH. CLAW 2002 sits alongside the Control of Substances Hazardous to Health Regulations 2002 (COSHH) but layers on additional requirements specifically because lead is cumulative and biologically persistent. A lead flashing RAMS must reference CLAW explicitly, must apply the CLAW-specific controls, and must demonstrate that the contractor understands lead is not "just another COSHH substance".

The second reason for a dedicated lead flashing RAMS is that the work involves hot works in almost all cases. Lead-burning, oxy/acetylene welding of joints, and torch-applied bossing all introduce fire risk into the roof structure, which means hot works permits, fire-watch arrangements, and additional equipment requirements that go far beyond standard roofing.

The legal framework: CLAW 2002 and L132

The Control of Lead at Work Regulations 2002 (CLAW) is the primary legislation for any work that exposes operatives to lead. It applies to lead in any form — sheet, sheet offcuts, pellet stock for burning, oxide and carbonate dusts, and fume from cutting and welding.

The supporting Approved Code of Practice (ACOP) is L132, "Control of lead at work". An ACOP has special legal status under the Health and Safety at Work etc. Act 1974: following the ACOP is treated by the courts as evidence that you have complied with the underlying regulations. Departing from the ACOP requires you to demonstrate that your alternative is at least as effective.

The key duties under CLAW for a lead-working roofer are:

Risk assessment. Specific assessment of lead exposure, not just a generic COSHH form. Must identify the operations, the duration, the level of expected exposure, and the controls.
Control measures. The hierarchy is the same as COSHH — eliminate, substitute, engineering controls (extraction, ventilation), administrative controls (work patterns, rotation), then PPE — but applied with knowledge of how lead behaves in practice.
Air monitoring. Where exposure is significant or regular, the employer must monitor airborne lead levels.
Medical surveillance. Workers regularly exposed to lead must be enrolled in a medical surveillance programme including blood lead monitoring at intervals defined by the action level.
Information, instruction and training. Operatives must be told how lead exposure occurs, what the symptoms are, how the controls protect them, and what to do if they suspect exposure.
Welfare facilities. Hand washing, separate eating areas, work clothing kept on site.

The CLAW action level (the level above which additional controls and surveillance are triggered) is currently 30 µg/dL of blood lead for adult male workers. The threshold is lower for women of reproductive age (typically 20 µg/dL) and lower again for young persons (15 µg/dL). The HSE expects your lead flashing RAMS to acknowledge these levels and the medical surveillance programme that monitors them.

What a credible lead flashing risk assessment includes

The risk assessment portion of a lead flashing RAMS should identify the specific lead-related hazards for the work, who is affected, the controls in place, and the residual risk after controls. The controls will not eliminate severity (lead toxicity is permanent if it occurs), but they should reduce the likelihood of significant exposure to a low level.

The hazards a lead flashing RAMS must identify are:

Inhalation of lead fume during burning. The dominant exposure route during oxy/acetylene welding of lead. Severity is high, controls are RPE plus working position upwind plus minimised duration.
Inhalation of lead dust during cutting and dressing. Lead is soft, so dressing operations release particles. Cutting with abrasive tools releases more.
Hand-to-mouth ingestion. Lead transfers from contaminated hands to food, cigarettes, vapes, and the general environment. This is why the welfare controls are heavily prescriptive.
Take-home contamination. Work clothing carrying lead particles into homes and exposing family members. The control is dedicated work clothing kept on site, ideally laundered by the employer.
Hot works fire risk. Lead-burning and oxy/acetylene work near combustible roofing materials.
Cylinder rupture and flashback. Specific risks of oxy/acetylene equipment.
Manual handling of lead sheet. Lead is dense — Code 4 sheet weighs about 20 kg/m², Code 8 is around 40 kg/m². Handling whole sheets unaided is a back injury waiting to happen.
Working at height. Lead flashing work is by definition at height. The standard roofing work-at-height controls apply.

Each hazard should be rated for likelihood and severity before and after controls, with the residual rating clearly justified.

The standard lead-work controls in detail

The controls below are the ones every reputable UK lead-working roofer applies. A RAMS that includes them in this level of detail will pass scrutiny by Principal Contractors and the HSE.

Eliminate hot works at height where possible. Joins in lead sheet are made at ground level wherever practicable, with the pre-formed assemblies lifted to the roof for installation. This single decision eliminates the majority of the hot-works-at-height risk on most lead jobs.

Hot works permit. Where lead-burning or oxy/acetylene work on the roof is unavoidable, a hot works permit-to-work is issued by the Principal Contractor before the torch is lit. The permit specifies the location, duration, equipment, fire-watch, and hand-over inspection time.

Combustible material clearance. A 3-metre clearance of combustibles around the work, or fire blankets covering anything that cannot be moved. Particular attention to roofing felt, timber battens, insulation, breather membranes, dust accumulations in voids and bird nests in eaves.

Acetylene cylinder management. Cylinders stored upright, oxygen and acetylene separated by at least 3 metres and at least 6 metres from any structure. Removed from the roof at the end of every shift. Photographed at end of shift to confirm removal to the permit issuer. Returned to a locked ground-level cage in open air.

Equipment per HSE INDG327. Regulators, flashback arrestors, hoses and blowpipes designed and marked for the gas in use, manufactured to BS EN ISO standards. Acetylene pressure not exceeding 0.62 bar (9 psi) for most welding and cutting. Pre-use inspection: cylinder identification correct, no obvious damage, flashback arrestors present and within service date, hoses free from cuts and abrasions.

Fire-watch. A competent person remains at the work location during the work and for at least 60 minutes after the last flame is extinguished. CO2 extinguisher and water extinguisher minimum, plus a fire blanket, positioned at the work location before the torch is lit.

RPE selection and face-fit. FFP3 disposable masks (EN 149) for short-duration low-exposure tasks. Powered air-purifying respirator (EN 12942) with P3 filter for sustained burning. Face-fit testing for each user, qualitative or quantitative, on each model of mask issued. No facial hair where the seal contacts the face. RPE stored in clean sealed bag between uses.

Welfare and hygiene. Hand-washing facilities with hot water, soap, and nail brushes positioned near the work. No eating, drinking, smoking or vaping in the work area or in contaminated work clothing. Designated welfare area away from the work. Workers wash hands, arms and face before any breaks and at end of shift.

Work clothing. Dedicated lead-work clothing kept on site and not taken home. Where exposure is regular and significant, the employer launders the clothing. Disposable Type 5/6 coveralls for high-exposure tasks (sustained burning, cutting old lead).

Lead waste handling. Offcuts collected into labelled, lidded containers at the work position. Transferred to a secure ground-level store. Disposed of as hazardous waste through a licensed carrier with the appropriate transfer documentation. Lead is not placed in general construction skips.

Blood lead monitoring. Workers regularly engaged in lead work are enrolled in occupational health surveillance. Baseline blood lead measurement before starting lead work, repeated at intervals defined by the action level. The action level (30 µg/dL for adult males) triggers a review of controls and may require removal from lead work until levels reduce. Records kept for 40 years per Regulation 22 of CLAW 2002.

Manual handling. Lead sheet is broken down to safe lifting weights. Code 4 lead in 600 mm widths is the practical maximum for one-person handling at most weights. Heavier codes are dual-lifted or lifted to the roof using telehandler, hoist, or gin wheel. SG6:15-equivalent manual handling techniques apply.

Method statement: how the lead work is actually carried out

The method statement section sets out the sequence of work. A practical lead flashing method statement might read like this — adapt the wording for your specific job and site.

Pre-start. Site induction and sign-in. Review the asbestos register and Refurbishment and Demolition Survey for the building. Confirm Principal Contractor permits and Listed Building Consent if applicable. Pre-start photographic survey of the work area and the immediate surroundings. Check wind speed (handheld anemometer), forecast for the shift, and tide times if work is harbour-side. Toolbox talk covering the day's specific risks: fragility, hot works, lead exposure, rescue plan.

Material preparation at ground level. Set out the lead at a designated cutting station at ground level. Cut to size with lead knife. Form bays, drips, and turn-in details using bossing tools. Pre-form joins where possible to minimise burning at height. RPE worn during cutting (FFP3 minimum). Hands washed before any break.

Material lift to roof. Lead lifted to the roof by telehandler, hoist, or gin wheel. Manual carrying of lead sheet up scaffold ladders is avoided where possible due to manual handling risk. Where manual handling is unavoidable, sheets are broken down to safe lifting weights.

Installation. Lead positioned and secured using copper or stainless copper nails to BS 5534 detailing. Clip and lap dimensions appropriate to the lead code. Sheet sizing within thermal-movement limits to prevent buckling. Welts and rolls formed using bossing tools.

Hot works on the roof. Where joins or repairs require lead-burning on the roof, the hot works permit is in force. Combustibles cleared or covered. Cylinders positioned per INDG327 separation distances. Torch lit using spark igniter after hose purge. Fire-watch in attendance throughout. Operative wearing PAPR with P3 filter for sustained burning.

Post-burn cool-down. Lead allowed to cool naturally; never quenched. Fire-watch maintained for 60 minutes minimum after the last flame. Hand-over inspection by permit issuer at the end of fire-watch.

End of shift. Cylinders removed from the roof and returned to ground-level secure storage. Photographs sent to permit issuer. Lead offcuts collected and lidded. Tools cleaned and lowered to ground. Operative changes from work clothing into clean clothing before leaving site. Hands, arms and face washed.

Competence requirements for lead work

The RAMS must specify the competence required for lead works. The standard requirements are:

CSCS Skilled Worker (Blue) card minimum. Held by every operative on site under the Construction Skills Certification Scheme.
NVQ Level 2 or 3 in a roofing discipline. Underlying competence for the trade.
Recognised lead-work training certificate. The Lead Sheet Training Academy (LSTA, formerly Lead Sheet Association) runs the recognised UK courses; alternative manufacturer-recognised training also exists. The certificate covers traditional lead-working techniques, the relevant British Standards, and the CLAW 2002 controls.
Oxy/acetylene safe-use training. Specific training before being permitted to operate the equipment, per HSE INDG327 and PUWER 1998. Training record held on site.
UKATA or IATP asbestos awareness. Annual refresh.
Working at Height training. One-day Awareness course minimum, with task-specific training for any access methods used (IPAF for MEWP, PASMA for tower scaffolds).
Face-fit testing for RPE. Repeated every 2 years or when the wearer's face changes.

Specific scenarios and how the RAMS adapts

A single template lead flashing RAMS rarely fits every job. The most common scenarios that need additional controls are:

Listed buildings and conservation areas. Listed Building Consent must be in place before work commences (held by the client, not the roofer). Tie strategy and any fixings into the historic fabric must be agreed with the local authority conservation officer. Foam or hessian padding at all contact points with stone reveals. Made-good drilled holes with conservation-officer-approved matching mortar at completion.

Occupied buildings. Hot works carry significantly higher consequences in occupied buildings because fire spread can endanger occupants. Increased fire-watch, occupant notification, alternative methods (cold-applied lead alternatives where the design permits) considered. Some major insurers will not cover hot works on occupied buildings without specific endorsement.

Heritage roofs above 30 metres. Many heritage buildings have steeple, spire, or tower lead work. The standard scaffold-and-eaves approach is replaced by abseil access (IRATA-trained operatives) or specialist scaffolding. The RAMS adapts accordingly with rope access controls and rescue plans appropriate to the access method.

Marine and tidal environments. Lead flashing on harbour-side and coastal buildings carries additional water-rescue requirements. Lifejackets, throw-lines, reach-poles, water rescue plan, and tide table monitoring add to the RAMS. The Merchant Shipping Act 1995 may apply.

Unplanned discovery of asbestos. Where asbestos is suspected to have been disturbed during the work, the RAMS triggers a stop-work, area evacuation, contaminated PPE bagging, and Principal Contractor notification under the Control of Asbestos Regulations 2012.

Where most lead flashing RAMS fall short

The most common failings in lead flashing RAMS submitted to Principal Contractors are:

Generic RPE specification ("dust mask") without referencing FFP3 (EN 149), face-fit testing, or PAPR for sustained work.
No reference to CLAW 2002 or L132. Just "COSHH" for everything.
No blood lead monitoring or surveillance programme, even where lead work is regular.
No hot works permit reference or fire-watch duration.
Acetylene cylinder separation distances either missing or wrong (the correct figures are 3 m apart and 6 m from any structure).
No INDG327 reference for oxy/acetylene safe use.
No work-clothing-stays-on-site rule, exposing workers' families.
Manual handling assessment that does not acknowledge lead's density.
No lead waste consignment route, with lead going into general skips.

A RAMS that addresses each of these explicitly is significantly more likely to pass the gate check than one that mentions lead in passing. Principal Contractors who deal with lead work regularly know what good looks like.

Producing the RAMS in practice

Writing a credible lead flashing RAMS by hand takes a competent roofer two to four hours. Most working roofers do not have that time on the night before a job. The realistic options are: a base template that you adapt for each job (still 30 to 60 minutes per RAMS, prone to forgotten details), or a tool that generates a job-specific RAMS from your brief in under 5 minutes with all the controls correctly populated.

Complys is built for the second option. Pick the roofing trade, fill in the activity (e.g. "lead flashing replacement around two chimneys, two storeys, occupied building"), and the document includes HSG33, CLAW 2002, INDG327, the right Beaufort thresholds, the right competence requirements, the right RPE, and the right fire-watch duration. The output is in the format Principal Contractors expect, branded with your company details, and ready to share via a public link or PDF.

Lead flashing is one of the few areas of roofing where the RAMS quality genuinely matters in protecting workers, not just in passing paperwork checks. The cumulative nature of lead toxicity means that controls applied poorly today produce harm decades later. The roofers who treat lead RAMS seriously are the ones whose workers retire healthy, and whose businesses do not face occupational health claims fifteen years later.