Proposed Ban on the Use of Lead

Twelfth-century window leads in a window from the transept clerestory of Kloster Eberbach, Hesse, Germany © Sarah Brown

A threat to the manufacture, use, handling, storage and display of lead is posed by the European Chemicals Agency (ECHA). It is driven by the Agency’s statutory remit to remove from the public realm all chemicals and materials injurious to public health. An online consultation on this matter opened in February 2022 and closed on 2 May.

While not imminent (there will be several stages in a consultative process involving the ECHA, the European Commission and European Parliament), the addition of lead to Appendix IV (Authorisation List) of the REACH regulation would pose an existential threat to the fabrication, conservation, handling storage and display of stained glass, as well as to the making, conservation and display of many craft and heritage assets, including organs, the roofing and fixing of historic masonry in heritage buildings and the display, preservation and conservation of all lead-related artefacts held in museums and galleries. If implemented, these restrictions would have a crippling impact on all businesses, craftspeople, conservators and heritage institutions involved in the manufacture and use of lead, and not only in EU member countries. Stained glass makers and conservators in the UK and North America would inevitably suffer as members of a community in which international exchange and collaboration is inherent, and a decline in the international pool of expertise in design, scholarship, research and technical know-how in stained glass creation, history, fabrication and conservation might also be anticipated.

The ICOMOS/Corpus Vitrearum Scientific Committee for the Conservation of Stained Glass has submitted a joint statement on behalf of the stained glass and heritage communities, in partnership with ICOM, ICOM-Glass and ECCO. ICOMOS has also communicated with the relevant departments of the European Commission and the European Parliament. Similar statements have been submitted by the international secretariat of the Corpus Vitrearum and its sponsor, the Union Académique Internationale. Other institutions, including the Chambre Syndicale Nationale du Vitrail, ICON and the Deutschen Nationalkomitees für Denkmalschutz bei der Beauftragten der Bundesregierung für Kultur und Medien have also expressed their concern and have mobilised their own contacts.

We are also aware of interventions made by the European Council’s working group on culture and have been asked to supply information to the office of one of the Vice-Presidents of the European Parliament and to the All-Party Parliamentary Group on Craft in the UK. On the grounds that in the heritage context lead is an integral, irreplaceable and indispensable historic material, used in quantities that have negligible impact on the environment and with risks to health that are well understood and are well managed and mitigated through well-regulated safety practices and the use of appropriate PPE by practitioners and professionals in the field, we hope to secure an exemption from any regulation.

Vidimus readers are encouraged to disseminate information and encourage the engagement of their own network of contacts in order to ensure that the concerns of the heritage sector in general and the stained-glass community in particular are strongly represented.