The Health and Safety Executive (HSE) has published its policy position on Great Britain’s asbestos Control Limit (CL). The decision was telegraphed ahead of time, but after a full evidence review the limit will stay at 0.1 fibres per millilitre (f/ml), measured as a four-hour time-weighted average.

It’s always been tempting to look at the EU’s occupational exposure limit (OEL) – 10 times lower than our CL – and imagine the UK is falling behind. However, the OEL was always a permitted ceiling, the totem of a very different approach to our own. Set with reference to estimated cancer risks across a working lifetime of constant exposure, an OEL tells an employer that, provided they’re within it, the legal duty is broadly satisfied.

The Control Limit does no such thing. It is not a safe exposure level – in fact the UK does not have any safe limits. The CL is a trigger that defines licensable work under the Control of Asbestos Regulations 2012, bringing with it notification, the four-stage clearance procedure, personal exposure monitoring and medical surveillance. Beneath the CL, the duty to reduce exposure as low as reasonably practicable (ALARP) still applies in full. There is no permitted dose.

So it was that our CL and the EU’s OEL were always doing fundamentally different regulatory jobs, and as such they couldn’t be compared. But all that is changing fast, with the risk that the UK is being left behind.

From 21 December 2025 the EU OEL fell to 0.01 f/ml. By 2029 member states must reduce again to either 0.002 f/ml, counting wider fibres only, or 0.01 f/ml counting narrower fibres too. But there’s also been a change to the EU’s approach, and that’s what fundamentally changes the comparison.

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 – note that’s ‘technically possible’, not ‘reasonably practicable’.

This change 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 respiratory protective equipment (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. Now there is no permitted dose on either side of the Channel.

What this means for duty holders

The HSE’s review still has force. The principle of ALARP already drives exposures well below the 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. But now the EU has a similar requirement to drive exposure down to the minimum, reinforced by a lower permitted baseline than us.

The EU’s 0.01 f/ml figure is not a response to a step-change in the science. The toxicology of asbestos has been settled for years. What changed was that the bloc gained the political appetite to apply existing evidence at a tighter threshold. Now in the UK, “below the CL” is doing less reassuring work than it used to, especially given the EU benchmark is 10 times lower, and the duty above it is stricter. The UK’s four-stage clearance procedure remains more rigorous than the EU equivalent, but we’ve otherwise ceded our leading regulatory position.

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. But the benchmark for what ALARP looks like now sits in Brussels.