Lead Paint and Asbestos in London Victorian and Edwardian Homes: A Complete Guide

LEAD-BASED PAINT WAS THE DOMINANT INTERIOR AND EXTERIOR PAINT UNTIL THE LATE 1970S IN THE UK. THE UK DID NOT BAN LEAD PAINT FROM GENERAL SALE UNTIL 1992, THOUGH USE DECLINED SIGNIFICANTLY FROM THE 1960S ONWARDS. IN PRACTICE, ANY LONDON PROPERTY BUILT BEFORE 1970 SHOULD BE ASSUMED TO HAVE LEAD-BASED PAINT ON WOODWORK, WALLS, CEILINGS, AND EXTERNAL SURFACES UNLESS TESTED.

LEAD PAINT WAS USED MOST HEAVILY ON: WINDOW FRAMES AND SILLS (EXTERIOR AND INTERIOR); DOOR FRAMES AND ARCHITRAVES; SKIRTING BOARDS; EXTERNAL RENDER AND MASONRY; STAIR BALUSTRADES AND NEWELS; CEILING ROSES AND CORNICING (SOME PERIOD PAINTS USED LEAD-BASED COMPOUNDS); AND KITCHEN AND BATHROOM WOODWORK.

HEALTH RISKS: LEAD IS A CUMULATIVE NEUROTOXIN WITH NO SAFE BLOOD LEVEL. CHILDREN UNDER 6 ARE MOST VULNERABLE — LEAD INGESTION (FROM DUST, PAINT CHIPS, OR CONTAMINATED SOIL FROM EXTERIOR PAINT RUNOFF) CAUSES PERMANENT COGNITIVE IMPAIRMENT, DEVELOPMENTAL DELAYS, AND NEUROLOGICAL DAMAGE. IN ADULTS, HIGH LEAD EXPOSURE CAUSES NEUROLOGICAL, CARDIOVASCULAR, AND KIDNEY DAMAGE. THE MAIN EXPOSURE ROUTES DURING RENOVATION ARE: SANDING, GRINDING, OR CUTTING LEAD-PAINTED SURFACES WITHOUT DUST CONTROL (GENERATES RESPIRABLE FINE DUST); HEAT STRIPPING WITH HOT AIR GUNS (ABOVE 375°C VOLATILISES LEAD — USE CHEMICAL STRIPPERS OR INFRARED BELOW 375°C); WATER JETTING WITHOUT CONTAINMENT (LEAD-CONTAMINATED WASH-DOWN WATER).

TESTING FOR LEAD PAINT: THE MOST RELIABLE METHOD IS X-RAY FLUORESCENCE (XRF) TESTING — A NON-DESTRUCTIVE HANDHELD DEVICE THAT READS LEAD CONTENT IN MG/CM². SWAB TEST KITS (3M LEADCHECK, PRIMERA TECHNOLOGY) ARE AVAILABLE FROM TOOLSTATION/SCREWFIX — THEY DETECT LEAD ABOVE ~0.5% CONTENT BUT HAVE A SIGNIFICANT FALSE-NEGATIVE RATE ON SEALED OR MULTI-LAYER PAINT. FOR RENOVATION PROJECTS, PROFESSIONAL XRF TESTING (£150-500 SURVEY BY A LEAD PAINT SPECIALIST) PROVIDES RELIABLE DATA FOR RISK ASSESSMENT.

LEGAL FRAMEWORK: THE CONTROL OF LEAD AT WORK REGULATIONS 2002 (COLAW) APPLY TO EMPLOYERS AND SELF-EMPLOYED PERSONS — CONTRACTORS WORKING ON LEAD PAINT MUST CONDUCT A RISK ASSESSMENT, PROVIDE APPROPRIATE RPE (FFP3 MASK OR POWERED AIR-PURIFYING RESPIRATOR PAPR), AND ARRANGE BIOLOGICAL MONITORING (BLOOD LEAD TESTING) FOR WORKERS WITH SIGNIFICANT EXPOSURE. FOR DOMESTIC HOMEOWNERS DOING THEIR OWN WORK, THE REGULATIONS DO NOT DIRECTLY APPLY — BUT THE HEALTH RISKS ARE IDENTICAL.

THE MOST IMPORTANT PRINCIPLE IN LEAD PAINT MANAGEMENT IS: LEAD PAINT THAT IS IN GOOD CONDITION, FIRMLY ADHERED, AND NOT SUBJECT TO ABRASION OR DISTURBANCE IS BEST LEFT IN PLACE AND ENCAPSULATED. REMOVAL GENERATES DUST AND EXPOSURE RISK — THE ACT OF REMOVAL IS OFTEN MORE HAZARDOUS THAN LEAVING STABLE PAINT IN PLACE.

ENCAPSULATION (PAINT OVER): WHERE EXISTING LEAD PAINT IS SOUND (NO FLAKING, PEELING, OR CHALKING), CLEAN THE SURFACE AND APPLY A SPECIALIST ENCAPSULANT PRIMER (ZINSSER BULLS EYE 1-2-3 SHELLAC-BASED PRIMER OR ZINSSER GARDZ PROBLEM SURFACE SEALER) FOLLOWED BY STANDARD TOP COATS. THIS SEALS THE LEAD PAINT UNDER A NEW COATING AND PREVENTS DUST GENERATION. SUITABLE FOR INTERNAL WOODWORK IN GOOD CONDITION. NOT SUITABLE WHERE THE SUBSTRATE IS BEING DISTURBED (STRIPPING, SANDING, CUTTING).

REMOVAL — CHEMICAL STRIPPING: SOLVENT-BASED OR CAUSTIC STRIPPERS (PEEL AWAY 1 BY DUMOND CHEMICALS — ALKALINE PASTE THAT LIFTS MULTIPLE LAYERS OF PAINT; NX 180 SOLVENT STRIPPER; NITROMORS CRAFT PAINT REMOVER) APPLIED, ALLOWED TO DWELL, THEN SCRAPED OFF. GENERATES WET SLUDGE RATHER THAN DRY DUST — MUCH LOWER INHALATION RISK THAN DRY SANDING. RESIDUE MUST BE DOUBLE-BAGGED IN SEALED PLASTIC BAGS AS HAZARDOUS WASTE.

REMOVAL — INFRARED HEAT STRIPPING: INFRARED PAINT REMOVERS (SPEEDHEATER STANDARD OR COBRA DUAL) OPERATE AT SURFACE TEMPERATURES OF 250-350°C — BELOW THE VOLATILISATION TEMPERATURE OF LEAD (375°C). SAFER THAN HOT AIR GUNS. GENERATE SOFT SCRAPABLE PAINT RATHER THAN DUST. RPE STILL REQUIRED.

NEVER USE: ANGLE GRINDERS OR ORBITAL SANDERS ON LEAD PAINT WITHOUT VACUUM EXTRACTION AND RPE (FFP3); DRY WIRE BRUSHING; HIGH-TEMPERATURE HOT AIR GUNS (ABOVE 375°C); OR NEEDLE SCALERS ON LARGE AREAS.

WASTE DISPOSAL: LEAD PAINT WASTE (SCRAPINGS, STRIPPED MATERIAL) IS CLASSIFIED AS HAZARDOUS WASTE UNDER THE HAZARDOUS WASTE REGULATIONS 2005. IT MUST BE DOUBLE-BAGGED, LABELLED AS HAZARDOUS, AND DISPOSED OF AT A LICENSED HAZARDOUS WASTE TRANSFER STATION — NOT IN STANDARD SKIP OR DOMESTIC WASTE. PROFESSIONAL CONTRACTORS INCLUDE DISPOSAL IN THEIR PRICE — VERIFY THIS WHEN OBTAINING QUOTES.

PROFESSIONAL LEAD PAINT REMOVAL CONTRACTORS: LOOK FOR MEMBERS OF THE TRUSTMARK LEAD PAINT REMOVAL SPECIALIST SCHEME OR CONTRACTORS WITH CITY AND GUILDS / RSPH AWARD IN SAFE HANDLING OF LEAD PAINT. COSTS: £15-35 PER M² FOR PROFESSIONAL LEAD PAINT REMOVAL FROM WOODWORK; £20-50 PER M² FROM LARGER AREAS REQUIRING FULL CONTAINMENT.

ASBESTOS-CONTAINING MATERIALS (ACMS) ARE PRESENT IN A LARGE PROPORTION OF LONDON PROPERTIES BUILT OR REFURBISHED BETWEEN APPROXIMATELY 1920 AND 1999. ASBESTOS WAS WIDELY USED IN THE UK FROM THE 1920S AND ITS USE IN CONSTRUCTION PEAKED IN THE 1950S-1970S. ASBESTOS WAS NOT BANNED FROM NEW USE IN BUILDING MATERIALS IN THE UK UNTIL 1999 (PROHIBITION OF THE USE OF ASBESTOS REGULATIONS 1999 FOR CHRYSOTILE, FOLLOWING EARLIER BANS ON AMPHIBOLE TYPES IN 1985).

WHILE VICTORIAN PROPERTIES (PRE-1919) ARE UNLIKELY TO CONTAIN ASBESTOS IN THEIR ORIGINAL FABRIC, MANY HAVE BEEN REFURBISHED OR EXTENDED IN THE 1950S-1980S WHEN ASBESTOS USE WAS WIDESPREAD. TYPICAL ACMS FOUND IN LONDON RESIDENTIAL PROPERTIES:

AMOSITE (BROWN ASBESTOS) — HIGH-RISK: - THERMAL INSULATION ON PIPES AND BOILERS (PIPE LAGGING) — BROWN/GREY CORRUGATED WRAP - SPRAYED INSULATION ON STRUCTURAL STEEL OR CEILINGS IN SOME COMMERCIAL CONVERSIONS

CHRYSOTILE (WHITE ASBESTOS) — MOST COMMON: - ASBESTOS CEMENT ROOF SHEETS AND TILES (GARAGE AND OUTBUILDING ROOFS — VERY COMMON IN LONDON) - ASBESTOS CEMENT FLUE PIPES AND WATER TANKS - ASBESTOS INSULATING BOARD (AIB) PANELS — USED IN FIRE-RESISTANT PARTITIONS, CEILING TILES, BOXING AROUND STRUCTURAL STEEL, AND SOME FLOOR TILES (THERMOPLASTIC FLOOR TILES PRE-1990) - ARTEX AND TEXTURED COATINGS (CONTAINING CHRYSOTILE FIBRES PRE-1985) — EXTREMELY COMMON ON CEILINGS IN 1970S-1980S ADDITIONS AND EXTENSIONS - BITUMEN-BACKED VINYL FLOOR TILES (1960S-1980S)

CROCIDOLITE (BLUE ASBESTOS) — HIGHEST RISK: - RARE IN RESIDENTIAL BUILDINGS BUT FOUND IN SOME PIPE LAGGING AND INDUSTRIAL CONVERSIONS

ARTEX AND TEXTURED COATINGS: THIS IS THE MOST FREQUENTLY OVERLOOKED ACM IN LONDON RESIDENTIAL RENOVATIONS. ARTEX TEXTURED CEILING COATING WAS WIDELY APPLIED IN THE 1970S AND 1980S AND CONTAINS CHRYSOTILE ASBESTOS FIBRES AT UP TO 6% BY WEIGHT. IT IS A MATERIAL THAT CAN ONLY BE CONFIRMED BY LABORATORY ANALYSIS OF A SAMPLE. THE GENERAL RULE: IF THE PROPERTY HAS ARTEX OR TEXTURED CEILING COATING APPLIED BEFORE APPROXIMATELY 1985 (THE YEAR CHRYSOTILE WAS BANNED FROM ARTEX SPECIFICALLY), ASSUME IT CONTAINS ASBESTOS UNTIL TESTED.

LEGAL FRAMEWORK FOR ASBESTOS IN DOMESTIC PROPERTIES:

THE CONTROL OF ASBESTOS REGULATIONS 2012 (CAR 2012) APPLY TO: ALL COMMERCIAL PREMISES (INCLUDING HMOs, COMMERCIAL UNITS, AND BLOCKS OF FLATS); AND NON-DOMESTIC PREMISES. FOR SINGLE-UNIT DOMESTIC PROPERTIES, HOMEOWNERS ARE NOT DIRECTLY SUBJECT TO THE DUTY TO MANAGE ASBESTOS. HOWEVER, CAR 2012 DOES APPLY TO ANY CONTRACTOR WORKING ON THE PROPERTY — CONTRACTORS MUST CARRY OUT A RISK ASSESSMENT BEFORE DISTURBING POTENTIAL ACMS.

FOR HMO LANDLORDS: THE HOUSING ACT 2004 AND THE MANAGEMENT OF HOUSES IN MULTIPLE OCCUPATION (ENGLAND) REGULATIONS 2006 IMPOSE A DUTY TO ENSURE THE PROPERTY IS FIT FOR HABITATION — THIS INCLUDES MANAGING ASBESTOS RISK. AN ASBESTOS MANAGEMENT SURVEY IS BEST PRACTICE FOR ALL HMOs AND IS REQUIRED BY MANY LOCAL COUNCIL HMO LICENSING SCHEMES.

ASBESTOS SURVEYS: - MANAGEMENT SURVEY (FORMERLY TYPE 2): IDENTIFIES ACMS LIKELY TO BE DISTURBED DURING NORMAL OCCUPANCY AND MAINTENANCE. SAMPLES TAKEN FROM ACCESSIBLE AREAS. SUITABLE FOR ONGOING MANAGEMENT. - REFURBISHMENT AND DEMOLITION SURVEY (FORMERLY TYPE 3): REQUIRED BEFORE ANY REFURBISHMENT OR DEMOLITION WORK. MORE INTRUSIVE — INSPECTS AREAS THAT WILL BE DISTURBED DURING WORKS. THIS IS THE SURVEY REQUIRED BEFORE A LOFT CONVERSION, EXTENSION, OR FULL REFURBISHMENT.

SURVEY COSTS (LONDON RESIDENTIAL): MANAGEMENT SURVEY — £150-400 FOR A 3-BEDROOM TERRACE; REFURBISHMENT/DEMOLITION SURVEY — £200-600.

LABORATORY ANALYSIS: BULK SAMPLES FROM SUSPECTED ACMS SENT TO UKAS-ACCREDITED LABORATORY (EXOVA, SOCOTEC, BUREAU VERITAS) — TYPICALLY £15-40 PER SAMPLE, RESULTS IN 3-5 WORKING DAYS (EXPRESS 24-HOUR AVAILABLE).

LICENSED ASBESTOS REMOVAL (LAR): REQUIRED FOR REMOVAL OF HIGH-RISK ACMs (AMOSITE INSULATION, CROCIDOLITE, SPRAYED ASBESTOS, AIB) — A HSE-LICENSED CONTRACTOR MUST CARRY OUT THE WORK. ENCLOSURE ERECTED, NEGATIVE PRESSURE UNIT, FULL PERSONAL PROTECTIVE EQUIPMENT (POWERED AIR PURIFYING RESPIRATOR / P3 FILTERS), AIR MONITORING DURING WORK AND FOUR-STAGE CLEARANCE PROCEDURE AFTER.

NON-LICENSED ASBESTOS WORK (NLAW): FOR LOWER-RISK ACMS (ASBESTOS CEMENT SHEETS AND TILES, CHRYSOTILE FLOOR TILES, SOME ARTEX), REMOVAL MAY BE CARRIED OUT BY NON-LICENSED CONTRACTORS — BUT THE WORK MUST BE NOTIFIED TO THE HSE (NOTIFICATION OF NON-LICENSED WORK — NNLW) AND CARRIED OUT UNDER A WRITTEN PLAN OF WORK. STANDARD CONTRACTORS WITHOUT ASBESTOS TRAINING MUST NOT DISTURB KNOWN ACMS.

ARTEX REMOVAL SPECIFICALLY: ARTEX CONTAINING ASBESTOS IS A NON-LICENSED WORK ACM. IT SHOULD BE WET-SCRAPED (WATER MISTING TO SUPPRESS DUST) OR OVERBOARDED (1 LAYER OF 12.5MM GYPROC PLASTERBOARD SCREWED OVER — MOST COST-EFFECTIVE OPTION THAT ENCAPSULATES THE ARTEX WITHOUT DISTURBANCE). OVERBOARDING COSTS £15-30/M² INCLUDING MATERIALS AND LABOUR VS £25-60/M² FOR WET REMOVAL AND DISPOSAL.

FOR ANY NOTIFIABLE REFURBISHMENT OR CONSTRUCTION PROJECT IN A PRE-2000 LONDON PROPERTY, THE FOLLOWING PRE-CONSTRUCTION HAZARDOUS MATERIAL SURVEYS ARE REQUIRED OR STRONGLY ADVISABLE:

CDM 2015 (CONSTRUCTION DESIGN AND MANAGEMENT REGULATIONS 2015): WHERE A PROJECT IS NOTIFIABLE (MORE THAN 30 DAYS OR 500 PERSON-DAYS OF CONSTRUCTION WORK), THE PRINCIPAL DESIGNER HAS A DUTY TO GATHER PRE-CONSTRUCTION INFORMATION — INCLUDING HAZARDOUS MATERIALS. THE PRINCIPAL CONTRACTOR MUST INCLUDE HAZARDOUS MATERIAL MANAGEMENT IN THE CONSTRUCTION PHASE PLAN.

PRE-CONSTRUCTION INFORMATION PACKAGE FOR A LONDON VICTORIAN TERRACE REFURBISHMENT SHOULD INCLUDE: - ASBESTOS REFURBISHMENT/DEMOLITION SURVEY (FROM UKAS-ACCREDITED SURVEYOR) - LEAD PAINT SURVEY (XRF TESTING OR RISK ASSESSMENT) - SOIL CONTAMINATION ASSESSMENT WHERE EXCAVATION IS PLANNED (PARTICULARLY IN INNER LONDON WHERE GAS WORKS, TANNERIES, AND OTHER INDUSTRIAL USES HISTORICALLY OCCURRED NEAR RESIDENTIAL AREAS) - JAPANESE KNOTWEED SURVEY WHERE GARDEN EXCAVATION IS PLANNED (JAPANESE KNOTWEED ROOT BALL SPREAD 7M HORIZONTALLY, 3M DEPTH — DISPOSAL AS CONTROLLED WASTE CATEGORY A)

PRACTICAL ADVICE FOR RCB CLIENTS: RCB DESIGN & BUILD REQUIRES ASBESTOS AND LEAD PAINT SURVEYS TO BE COMPLETED BEFORE DETAILED PRICING AND DEFINITELY BEFORE CONSTRUCTION COMMENCEMENT IN ANY PRE-2000 PROPERTY. THIS PROTECTS BOTH THE CLIENT (FROM UNEXPECTED REMEDIATION COSTS DURING BUILD) AND THE RCB TEAM (WHO CANNOT LAWFULLY DISTURB KNOWN ACMS WITHOUT A PLAN OF WORK). THE COST OF SURVEYS IS SMALL RELATIVE TO THE COST OF DISCOVERING ACMS AFTER DEMOLITION HAS STARTED — WHEN MATERIAL HAS ALREADY BEEN DISTURBED AND CONTAMINATION OF THE SITE IS A RISK.

FINDING COMPLIANT CONTRACTORS: - ASBESTOS REMOVAL: HSE LICENSED ASBESTOS CONTRACTOR — CHECK THE HSE LICENSED CONTRACTOR LIST AT HSE.GOV.UK/ASBESTOS/LICENSING - LEAD PAINT REMOVAL: TRUSTMARK LEAD PAINT SPECIALIST OR CONTRACTOR WITH RSPH AWARD IN SAFE HANDLING OF LEAD PAINT - ASBESTOS SURVEYING: UKAS-ACCREDITED SURVEYOR — CHECK UKAS.COM - LABORATORY ANALYSIS: UKAS-ACCREDITED LABORATORY