Painting SWMS: hazards, controls and what to include

A painting SWMS, or method statement for painting works, is required when the painting is high-risk construction work. Painting itself isn't on the list of 18 kinds, but painting often involves work at height, work near energised electrical lines, or work that disturbs asbestos or lead. Your SWMS should name each hazard, set out the controls for it, and say who checks those controls.

This guide covers when a painting SWMS is needed, the hazards that most often go unmanaged, the controls that work for each one, and what the document must include.

When painting needs a SWMS

A SWMS is required before high-risk construction work starts (regulation 299). The 18 kinds of high-risk construction work are listed in regulation 291 and include work where someone could fall more than 2 metres, work adjacent to a road, work near energised electrical installations, and disturbing asbestos.

A painter working on a two-storey exterior from a scaffold, for example, is doing high-risk construction work. A painter working on a single interior wall from a step ladder may not be, but the risks still need managing. Use the Do I need a SWMS? checker to work out which applies to your job, and check the Safe Work Australia construction guidance for more.

Painting hazards and controls

Painting hazards run from the preparation stage to clean-up. The table below sets out the main ones and the controls that work for each.

A common mistake is writing "PPE as required" against all of these. A respirator does nothing for a fall, and a harness does nothing for fumes. Each hazard needs a control that matches it, and the controls should go in the order of the hierarchy of controls: change the product or method first, then use engineering controls such as extraction and edge protection, and rely on PPE last.

Chemicals and lead

Read the safety data sheet (SDS) for every paint, primer, thinner and cleaner on site, and keep them where the painters can reach them. Some coatings carry risks that aren't obvious from the label, so the SDS should set the PPE and ventilation for each product. Lead-based paint is a particular concern in older homes and commercial buildings. Check the rules that apply in your state before you start stripping or sanding it, and see the lead paint removal SWMS for the controls.

Volatile organic compounds (VOCs) come off paint as gases. Short-term effects include headaches, eye irritation and dizziness, and some VOCs carry longer-term risks. Open products in ventilated areas and close them when not in use. The US EPA guidance on VOCs and indoor air explains the health effects in more detail.

What a painting SWMS must cover

Under regulation 299, a SWMS must identify the high-risk work, specify the hazards and risks, describe the controls, and explain how they'll be implemented, monitored and reviewed. It must take account of the site and be written so the painters can understand it. Our guide on what a SWMS must include has the full checklist. For a painting job that means:

1. The work. The areas, surfaces, heights and the method, such as roller and brush from a scaffold, or airless spray on a commercial shopfront.
2. The hazards. Each one from the table above that applies to this job, including the products and the surfaces.
3. The controls. Specific ones: "a second person holds the ladder and checks the feet", not "use a ladder safely".
4. Who does what. Who sets up the scaffold, who checks the respirators, who signs off the lead test, and who clears the area at the end of the day.
5. Review. When the SWMS is reviewed: after an incident, when the product changes, or when the site changes.
6. Emergency steps. What to do if a painter falls, is overcome by fumes or is hit by a spray leak.

A useful test is whether a new painter could read the SWMS and know what to do on the first morning. If the answer is no, rewrite the vague lines.

Painting templates

Start from a template that matches the work, then add the site details:

• Painting and decorating SWMS for general painting jobs.
• Abrasive blasting and coating SWMS for blasting and protective coatings.
• Hazardous chemicals SWMS for the products on site.
• Air compressor SWMS if you run a compressor for spray work.
• Lead paint removal SWMS for older coatings.

If the job is in a building that might contain asbestos, you'll need the asbestos removal value pack or a SWMS written for that work before anyone starts.

Common questions

Do interior painting jobs need a SWMS? Not always. Interior painting is only high-risk construction work if it involves something on the list, such as work at height over 2 metres, or disturbing asbestos. Other painting still needs its risks managed, usually with a JSA or safe work procedure.

Who prepares the painting SWMS? The business doing the high-risk work must make sure one is prepared before it starts. It's usually written with the supervisor and the painters, and the principal contractor must get a copy on a construction project. Who prepares, signs and keeps a SWMS covers the detail.

Does a painting SWMS need PPE listed? Yes, but PPE should be one control among several. List the specific PPE for each product and task, and make sure the crew knows how to fit and check it.

How often is a painting SWMS reviewed? Review it when the controls change, after an incident, when a new product or method is used, and when a health and safety representative asks for a review (regulation 38).

This is general information, not legal advice. Check the current law with your WHS regulator.