HSE Holds the Line. The EU Has Pulled Ahead.
The Health and Safety Executive(opens in new tab) recently published its policy position on the asbestos Control Limit. The decision was telegraphed, but after a full evidence review, the limit will stay at 0.1 fibres per millilitre, measured as a four-hour time-weighted average. With the EU now operating a limit ten times tighter, and a stricter enforcement duty above it, the decision raises questions.
Next to the EU, the position is harder to defend than it once was. For years, industry shorthand drew a clean philosophical line between the EU’s Occupational Exposure Limit and the GB Control Limit. The OEL was a permitted ceiling. The CL was a trigger. Two regulators, two instruments, two ideas. That line is no longer there.
The amended Asbestos at Work Directive, consolidated on 20 December 2023, has reshaped the EU position. Three articles do the work. Article 6 requires employers to reduce asbestos exposure to as low as is technically possible. That is ALAP, not ALARP. It strips out the financial element of the cost-benefit analysis and sets a stricter enforcement bar than ours. Article 8 fixes the interim limit value at 0.01 f/ml, with further reductions scheduled for 2029 depending on the testing methodology Member States adopt. Article 10 makes the limit value operate as the trigger for a hierarchy of precautions, with RPE as the last line of defence.
In other words, the EU limit now functions in much the same way as the GB Control Limit. Same architecture. Tighter number. Stricter duty. There is no permitted dose on either side of the Channel anymore.
HSE’s review still has force. ALARP already drives exposures well below the GB CL on most jobs, and lowering the figure in isolation would sweep lower-risk work, such as cement or floor tile removal, into the licensed regime at significant cost. The EU’s 0.01 figure is not a response to a step-change in the science either. The toxicology of asbestos has been settled for years. What changed in 2023 was the political appetite, to apply existing evidence at a tighter threshold.
The Chief Scientific Adviser, the Workplace Health Expert Committee and a May 2025 industry workshop all signed off on the conclusion. But “below the CL” is doing less reassuring work than it used to when the EU benchmark is ten times lower and the duty above it is stricter. The one area where the UK still leads is the four-stage clearance procedure, which remains more rigorous than the EU equivalent.
The message for dutyholders is unchanged. The Control Limit is not a target. Air monitoring strategies, RPE selection and method statements should be built around ALARP, not the figure on the certificate. The benchmark for what ALARP looks like, however, now sits in Brussels.