Sir Michael Bichard, whose inquiry into the Soham murders resulted in new child protection procedures, said he has concerns over the Vetting and Barring Scheme, which will become compulsory from November 2010.
Speaking to The Independent, he said proposals that actors, authors or entertainers who only occasionally visit a school, should register with the scheme should be reconsidered.
"If you visit one school in January, and then don't visit that school again, but visit another school in February and another in March, is that frequent or intensive?
"I think that's something which might merit reconsideration," he said.
"Based on the discussions and conversations I've had, clearly there is an issue."
The issue was previously raised last month by a group of children's authors, including Philip Pullman, Michael Morpurgo and Anthony Horowitz, who claimed they will stop visiting schools from the start of the next academic year if they are made subject to checks.
The Home Office has said that the regulations had to be rigorous and the rules do not discriminate on the grounds of an individual's job.
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