Painting Contractor Safety Manual

What Should a Painting Contractor Safety Manual Include?

The contents of a Painting Contractor Safety Manual should reflect the company’s actual operations.

A residential painting contractor primarily using brushes and rollers may have very different hazards than a commercial painter working from aerial lifts or an industrial painting contractor abrasive blasting and coating tanks, structural steel, bridges, or other large structures.

The manual should begin with the company’s Core Construction Safety Programs and then include additional programs applicable to the contractor’s painting and coating activities.

Core Safety Programs for Painting Contractors

A comprehensive Painting Contractor Safety Manual may include core programs addressing:

• Accident and Incident Investigation.
• Emergency Action Plan.
• Fire Prevention.
• First Aid.
• Hand and Power Tool Safety.
• Hazard Communication.
• Housekeeping.
• Job Safety Analysis (JSA/JHA).
• Manual Lifting and Material Handling.
• Personal Protective Equipment.
• Slips, Trips and Falls.
• Walking-Working Surfaces.
• Electrical Safety.
• Ladder and Stairway Safety.

The manual should also establish responsibilities for management, supervisors, employees, competent and qualified persons, hazard identification, inspections, safety training, hazard correction, incident reporting, recordkeeping, and periodic review of the company’s safety programs.

Painting Contractor Safety

Painting work can expose employees to chemical, respiratory, fire, fall, equipment, and material-handling hazards.

Before work begins, contractors should evaluate:

• Products and coatings being used.
• Existing coatings being disturbed.
• Application methods.
• Surface-preparation methods.
• Ventilation.
• Respiratory hazards.
• Ignition sources.
• Work at heights.
• Access equipment.
• Occupants and other workers.
• Weather and environmental conditions.
• Emergency procedures.

The hazards should be reassessed when products, work methods, equipment, or site conditions change.

Pre-Job Planning and JSA/JHA

A Job Safety Analysis or Job Hazard Analysis should address hazards associated with the specific painting operation.

A JSA may evaluate:

• Surface preparation.
• Brush and roller application.
• Spray painting.
• Sanding.
• Grinding.
• Pressure washing.
• Chemical stripping.
• Abrasive blasting.
• Ladder work.
• Scaffolding.
• Aerial lifts.
• Roof work.
• Confined spaces.
• Hazardous coatings.
• Public or occupant exposure.

Employees should review applicable hazards and controls before beginning the work.

Residential Painting Safety

Residential painting can involve interior and exterior work, ladders, roofs, occupied homes, solvents, coatings, power tools, and surface preparation.

Planning should consider:

• Occupants.
• Children and pets.
• Furniture and belongings.
• Ventilation.
• Ladder placement.
• Lead-containing coatings in older structures.
• Electrical hazards.
• Trip hazards.
• Chemical storage.
• Fire prevention.

Work areas should be controlled so employees and occupants are not unnecessarily exposed to painting hazards.

Commercial Painting Safety

Commercial painting may involve offices, retail facilities, warehouses, schools, hospitals, multi-story buildings, and other occupied or partially occupied locations.

Additional concerns may include:

• Building occupants.
• Other contractors.
• Aerial lifts.
• Scaffolds.
• Public access.
• Ventilation systems.
• Fire alarms.
• Emergency exits.
• Chemical odors.
• Off-hours work.
• Material storage.

Painting activities should be coordinated with the building owner, general contractor, or other controlling party where necessary.

Industrial Painting and Coating Safety

Industrial painting may involve tanks, structural steel, bridges, process equipment, towers, pipelines, manufacturing facilities, and other structures requiring specialized coatings or surface preparation.

Depending on the operation, hazards may include:

• Abrasive blasting.
• Lead-containing coatings.
• Confined spaces.
• Suspended scaffolds.
• Respiratory hazards.
• High-pressure equipment.
• Hazardous coatings.
• Fire and explosion.
• Fall hazards.
• Noise.

Industrial painting procedures should reflect the actual structures, products, processes, and exposures involved.

Paints, Coatings, Solvents and Thinners

Paints and coatings can contain solvents, pigments, resins, hardeners, catalysts, and other hazardous ingredients.

Before use, employees should understand:

• Product hazards.
• Required ventilation.
• PPE.
• Respiratory requirements.
• Flammability.
• Storage requirements.
• Spill procedures.
• First-aid information.

Products should be used according to applicable safety procedures and manufacturer instructions.

Hazard Communication and Safety Data Sheets

Painting contractors should maintain an effective Hazard Communication Program for hazardous chemicals employees may encounter.

Employees should have access to applicable Safety Data Sheets for paints, coatings, thinners, solvents, cleaners, hardeners, adhesives, and other hazardous products.

Containers should be appropriately labeled, and employees should receive information and training regarding chemical hazards and protective measures.

Respiratory Hazards

Painting employees may inhale:

• Paint mist.
• Solvent vapors.
• Coating vapors.
• Isocyanates.
• Dust.
• Lead.
• Silica.
• Abrasive-blasting contaminants.
• Chemical-stripping products.

The contractor should evaluate respiratory exposures and use engineering and work-practice controls where appropriate.

Respiratory Protection

Respirators should be used when required by the hazard, exposure, applicable OSHA requirements, or product information.

Where respirator use is required, the company’s Respiratory Protection Program should address applicable requirements for:

• Respirator selection.
• Medical evaluation.
• Fit testing.
• Employee training.
• Inspection.
• Cleaning.
• Storage.
• Cartridge or filter selection.
• Program evaluation.

Respirator selection should be based on the contaminants and exposure conditions involved.

Ventilation

Ventilation can be an important means of controlling paint mist, vapors, dust, and other airborne contaminants.

Depending on the work, ventilation may include:

• General ventilation.
• Local exhaust ventilation.
• Mechanical exhaust.
• Spray-booth ventilation.
• Confined-space ventilation.

Ventilation equipment should be suitable for the contaminants and potential fire or explosion hazards involved.

Spray Painting and Spray Finishing

Spray painting can generate airborne paint mist and hazardous vapors and may create fire or explosion hazards when flammable materials are used.

Procedures should address:

• Spray equipment.
• Hoses and connections.
• Ventilation.
• Ignition sources.
• Flammable vapors.
• Overspray.
• Respiratory protection.
• Eye and skin protection.
• Spray areas or booths where applicable.
• Housekeeping.
• Equipment cleaning.

Spraying should be performed only under conditions appropriate for the products and equipment being used.

Isocyanates and Hazardous Coatings

Certain polyurethane, two-component, and specialty coatings may contain isocyanates or other hazardous substances.

Where these products are used, the contractor should evaluate:

• Inhalation exposure.
• Skin exposure.
• Application method.
• Ventilation.
• Respiratory protection.
• Protective clothing.
• Product-specific precautions.

Hazardous coating procedures should be based on the actual products used rather than assumed to apply to every painting operation.

Flammable and Combustible Liquids

Paints, thinners, solvents, cleaners, and other painting products may be flammable or combustible.

Procedures should address:

• Approved containers.
• Storage.
• Quantity limitations where applicable.
• Ignition-source control.
• Transfer.
• Spill prevention.
• Waste materials.
• Fire extinguishers.

Flammable products should be kept away from open flames, sparks, hot work, and other potential ignition sources.

Fire and Explosion Prevention

Painting and spray-finishing operations may generate flammable vapors or combustible residues.

Fire-prevention procedures should address:

• Ignition sources.
• Smoking restrictions.
• Hot work.
• Electrical equipment.
• Static electricity where applicable.
• Ventilation.
• Product storage.
• Combustible waste.
• Fire extinguishers.
• Emergency procedures.

Spray areas should be kept as free as practical from accumulations of combustible residue.

Surface Preparation

Surface preparation can create some of the most significant exposures encountered by painting contractors.

Methods may include:

• Scraping.
• Sanding.
• Grinding.
• Power-tool cleaning.
• Pressure washing.
• Abrasive blasting.
• Chemical stripping.

Before beginning surface preparation, contractors should determine what materials and existing coatings may be disturbed and evaluate the potential for lead, silica, dust, chemical, noise, and other exposures.

Lead Exposure and Lead-Based Paint

Painting contractors may encounter lead when removing or disturbing older coatings or when working with certain lead-containing products.

Potential lead-generating activities include:

• Dry scraping.
• Sanding.
• Grinding.
• Power-tool cleaning.
• Abrasive blasting.
• Heat-gun removal.
• Spray application of lead-containing coatings.
• Welding, cutting, or burning painted metal.

Where employees may be occupationally exposed to lead during construction activities, applicable lead requirements should be followed.

Lead hazards should be evaluated before employees disturb suspect coatings.

Silica Exposure During Surface Preparation

Painting contractors may generate respirable crystalline silica while sanding, grinding, drilling, cutting, or otherwise disturbing concrete, masonry, stucco, and other silica-containing materials.

Where applicable, procedures should address:

• Exposure assessment.
• Engineering controls.
• Dust collection.
• Water-delivery systems.
• Respiratory protection.
• Housekeeping.
• Employee training.

A silica program should be included when the company’s operations create applicable exposure.

Abrasive Blasting and Coating Removal

Some painting contractors use abrasive blasting to remove coatings, corrosion, scale, or other material before applying new coatings.

Hazards may include:

• Airborne contaminants.
• Lead.
• Silica or other blasting media.
• High noise.
• Flying material.
• Blast pressure.
• Hose movement.
• Reduced visibility.
• Respiratory exposure.
• Containment hazards.

Where abrasive blasting is performed, specialized procedures and PPE should be established for the operation.

Sanding and Grinding

Sanding and grinding may expose employees to:

• Dust.
• Lead.
• Silica.
• Flying particles.
• Noise.
• Sparks.
• Tool hazards.

Employees should use appropriate dust-control methods, guarded equipment, and required PPE.

The material being disturbed should be evaluated before selecting controls.

Pressure Washing

Pressure washing may be used for cleaning and surface preparation.

Hazards can include:

• High-pressure injection injuries.
• Flying debris.
• Slippery surfaces.
• Electrical hazards.
• Hose movement.
• Chemicals.
• Falls.

Employees should not direct high-pressure water toward themselves or other persons and should use equipment according to manufacturer instructions.

Chemical Paint Stripping

Chemical stripping products can expose employees to corrosive, toxic, or otherwise hazardous chemicals.

Before using chemical strippers, employees should review applicable Safety Data Sheets and understand:

• Ventilation requirements.
• Required PPE.
• Skin and eye hazards.
• Respiratory hazards.
• Flammability.
• Spill procedures.
• Waste handling.

Chemical stripping products should not be substituted for mechanical methods without evaluating the hazards created by the chemical itself.

Fall Protection

Painting contractors frequently work at heights.

Potential exposures include:

• Roof edges.
• Scaffolds.
• Aerial lifts.
• Elevated platforms.
• Openings.
• Structural steel.
• Tanks.
• Other elevated surfaces.

Applicable fall-protection requirements should be identified during pre-job planning.

Employees should be trained in the fall-protection equipment and procedures they are required to use.

Scaffolding

Scaffolds are frequently used for exterior, commercial, and industrial painting.

Procedures should address:

• Proper erection.
• Competent-person requirements.
• Inspections.
• Platforms.
• Access.
• Guardrails.
• Fall protection.
• Load capacity.
• Foundations.
• Falling-object protection.

Employees should not use damaged, incomplete, or improperly erected scaffolds.

Suspended Scaffolds

Suspended scaffolds may be used for painting high-rise buildings, tanks, bridges, towers, and other structures.

Additional hazards may include:

• Suspension systems.
• Rigging.
• Counterweights.
• Anchorage.
• Hoists.
• Lifelines.
• Fall arrest.
• Electrical hazards.
• Wind.

Suspended-scaffold systems should be installed, inspected, and used according to applicable requirements and manufacturer instructions.

Ladder Safety

Painting contractors frequently use portable ladders.

Ladders should be:

• Appropriate for the task.
• Inspected before use as required.
• Positioned on stable surfaces.
• Protected from doors and traffic.
• Secured where necessary.
• Kept clear of electrical hazards.

Employees should maintain appropriate contact while climbing and should not overreach from ladders.

Aerial and Boom Lifts

Aerial and boom lifts may be used for exterior walls, ceilings, structural steel, industrial facilities, and other elevated painting work.

Procedures should address:

• Operator training.
• Pre-use inspections.
• Fall protection.
• Ground conditions.
• Equipment positioning.
• Overhead hazards.
• Electrical hazards.
• Load limits.
• Emergency lowering.

Scissor Lifts

Scissor lifts may be used for painting ceilings, walls, structural components, and other elevated surfaces.

Employees should:

• Inspect equipment.
• Use required platform protections.
• Remain within the platform.
• Avoid climbing on guardrails.
• Evaluate floor and ground conditions.
• Maintain clearance from overhead hazards.

Equipment should be operated according to manufacturer requirements.

Roof and Elevated Work

Exterior painting may require work from roofs and other elevated surfaces.

Planning should address:

• Roof edges.
• Skylights.
• Openings.
• Roof condition.
• Access.
• Weather.
• Material handling.
• Fall protection.
• Falling objects.

Paint containers, tools, hoses, and other materials should be controlled so they do not create fall or falling-object hazards.

Confined Spaces

Industrial painters may perform work inside tanks, vessels, pits, process equipment, and other spaces that meet the definition of a confined space.

Where applicable, procedures should address:

• Space evaluation.
• Atmospheric testing.
• Entry permits.
• Ventilation.
• Entrants.
• Attendants.
• Entry supervisors.
• Communication.
• Rescue.
• Flammable atmospheres.

Painting inside confined spaces can introduce additional contaminants and flammable vapors and should be carefully evaluated before entry.

Hand and Power Tools

Painting contractors may use:

• Sanders.
• Grinders.
• Drills.
• Scrapers.
• Mixers.
• Saws.
• Heat guns.
• Pressure washers.
• Other hand and power tools.

Tools should be inspected, properly guarded where required, maintained in safe condition, and used according to manufacturer instructions.

Compressed Air and Spray Equipment

Painting operations may involve compressors, spray guns, airless sprayers, pressure pots, hoses, and other pressurized equipment.

Procedures should address:

• Equipment ratings.
• Hose condition.
• Couplings.
• Pressure controls.
• Spray-gun safety.
• Unexpected pressure release.
• Equipment cleaning.
• Maintenance.

Pressure should be relieved before servicing or disconnecting equipment where necessary.

Compressed Gas Cylinders

Some painting and coating operations may use compressed gases.

Where applicable, procedures should address:

• Cylinder securing.
• Valve protection.
• Storage.
• Transportation.
• Regulators.
• Hose inspection.
• Separation from hazards.

Damaged cylinders or equipment should be removed from service.

Electrical Safety

Painting contractors may work near:

• Electrical panels.
• Receptacles.
• Lighting.
• Temporary power.
• Extension cords.
• Energized equipment.
• Overhead electrical lines.

Electrical hazards should be identified before work begins.

Employees should not allow conductive equipment, ladders, spray equipment, or other materials to create unnecessary exposure to energized electrical systems.

Personal Protective Equipment

PPE should be selected according to the painting task and chemical products involved.

Depending on the operation, PPE may include:

• Safety glasses.
• Goggles.
• Face shields.
• Chemical-resistant gloves.
• Work gloves.
• Protective clothing.
• Protective footwear.
• Hard hats.
• Hearing protection.
• Respiratory protection.
• Fall-protection equipment.

Chemical-resistant PPE should be compatible with the products being used.

Eye and Face Protection

Painting and surface-preparation work can expose employees to splashes, dust, flying particles, paint mist, chemicals, and pressurized materials.

Appropriate eye or face protection should be used for activities such as:

• Mixing coatings.
• Spray painting.
• Grinding.
• Sanding.
• Abrasive blasting.
• Chemical stripping.
• Pressure washing.

Hearing Conservation

Employees may be exposed to high noise from abrasive blasting, grinding, sanding, compressors, pressure washing, and other equipment.

Where employee exposures meet applicable criteria, required hearing-conservation measures should be implemented.

Manual Material Handling

Painting contractors frequently handle:

• Paint containers.
• Coating materials.
• Ladders.
• Scaffold components.
• Spray equipment.
• Hoses.
• Cable and extension cords.
• Tools.

Employees should use appropriate lifting techniques and mechanical assistance when loads are too heavy, bulky, or awkward to handle safely.

Heat Stress

Exterior and industrial painting may expose employees to heat, direct sun, protective clothing, and physically demanding work.

Heat-stress procedures should address:

• Drinking water.
• Rest.
• Shade or cooling.
• Acclimatization.
• Work scheduling.
• Recognition of heat illness.
• Emergency response.

Protective clothing and respirators can increase heat stress and should be considered during work planning.

Cold Stress and Severe Weather

Painting work may be affected by cold, rain, wind, lightning, and other weather.

Weather can affect:

• Ladders.
• Scaffolds.
• Aerial lifts.
• Roof work.
• Coating application.
• Employee footing.
• Equipment stability.

Work should be modified or suspended when conditions create unacceptable hazards.

Working Around the Public

Painting contractors may work around pedestrians, customers, building occupants, motorists, and other members of the public.

Controls may include:

• Barricades.
• Signs.
• Controlled access.
• Drop cloths.
• Equipment separation.
• Ventilation.
• Traffic control.
• Falling-object protection.

Painting materials and equipment should be stored so they do not create unnecessary public exposure.

Working in Occupied Buildings

Painting in occupied homes, offices, schools, healthcare facilities, retail locations, and other buildings requires additional planning.

Considerations may include:

• Occupant access.
• Ventilation.
• Odors.
• Chemical sensitivities.
• Emergency exits.
• Work scheduling.
• Noise.
• Dust.
• Trip hazards.
• Material storage.

The contractor should coordinate work with the owner or controlling party where necessary.

Housekeeping and Trip Hazards

Painting operations can create trip and slip hazards from:

• Drop cloths.
• Hoses.
• Extension cords.
• Tools.
• Paint containers.
• Overspray.
• Spills.
• Surface-preparation debris.

Work areas should be maintained in an orderly condition, and access routes and emergency exits should remain clear.

Driving and Fleet Safety

Painting contractors may operate vans, pickups, trailers, service vehicles, and other fleet equipment.

Procedures may address:

• Driver qualification.
• Seat-belt use.
• Distracted driving.
• Vehicle inspection.
• Trailer towing.
• Load securement.
• Backing.
• Accident reporting.

Ladders, paint containers, compressed gases, tools, and equipment should be appropriately secured during transportation.

Working Alone

Painters may work alone at residential properties, commercial facilities, remote locations, or during off-hours.

Where applicable, procedures should address:

• Communication.
• Check-in procedures.
• Emergency contacts.
• Location information.
• Restricted high-hazard activities.

Certain activities involving confined spaces, fall hazards, hazardous atmospheres, or other serious hazards should not be performed alone when immediate assistance may be necessary.

Emergency Response

Painting contractor emergency planning should consider:

• Falls.
• Chemical exposure.
• Eye exposure.
• Fire.
• Flammable-vapor emergencies.
• Respiratory exposure.
• Equipment incidents.
• Confined-space emergencies.
• Heat illness.
• Medical emergencies.

Employees should understand how to report emergencies, obtain first aid, use emergency equipment, and summon outside assistance.

Painting Contractor Training

Employees should receive training appropriate to their assigned work and hazards.

Training may include:

• Hazard Communication.
• PPE.
• Respiratory protection.
• Lead.
• Silica.
• Fall protection.
• Ladder safety.
• Scaffolding.
• Aerial lifts.
• Spray equipment.
• Flammable liquids.
• Hand and power tools.
• Confined spaces.
• Emergency procedures.

Competent-person, qualified-person, equipment-operator, or other specialized training should be provided where required by applicable standards or work activities.

Painting JSA/JHA

Painting-specific JSAs may address:

• Interior painting.
• Exterior painting.
• Spray painting.
• Surface preparation.
• Sanding.
• Grinding.
• Pressure washing.
• Chemical stripping.
• Abrasive blasting.
• Ladder work.
• Scaffold work.
• Aerial-lift painting.
• Roof painting.
• Tank or confined-space painting.

The JSA should reflect the actual products, equipment, access methods, work location, occupants, and environmental conditions involved.

Additional Safety Programs for Painting Contractors

Not every painting contractor requires every safety program.

Depending on the company’s operations, additional programs may include:

• Abrasive Blasting and Sandblasting.
• Aerial and Boom Lift Safety.
• Chemical Safety.
• Cold Stress.
• Compressed Air Safety.
• Compressed Gas Cylinders.
• Confined Space.
• Driving and Fleet Safety.
• Electrical Safety.
• Emergency Action Plan.
• Fall Protection.
• Fire Prevention.
• Flammable and Combustible Liquids.
• Hand and Power Tools.
• Hazard Communication.
• Hearing Conservation.
• Heat Stress Prevention.
• Isocyanate Safety.
• Ladder and Stairway Safety.
• Lead Awareness.
• Lead Exposure.
• Manual Lifting and Material Handling.
• Painting and Coating Safety.
• Personal Protective Equipment.
• Pressure Washing Safety.
• Respiratory Protection.
• Roof Safety.
• Scaffold Safety.
• Scissor Lift Safety.
• Severe Weather.
• Silica Exposure.
• Slips, Trips and Falls.
• Spray Painting and Spray Finishing.
• Surface Preparation Safety.
• Suspended Scaffold Safety.
• Working Alone.
• Working Around the Public.
• Working in Occupied Areas.

Programs should be selected according to the contractor’s actual operations, products, equipment, and employee exposures rather than simply because they may be associated with the painting industry.

Customer and General Contractor Requirements

Painting contractors may perform work for general contractors, property owners, industrial facilities, commercial businesses, municipalities, and other clients that maintain their own contractor safety requirements.

Customer requirements may address:

• Site orientation.
• Contractor qualification.
• JSA or pre-task planning.
• PPE.
• Respiratory protection.
• Fall protection.
• Hot-work or spray permits.
• Chemical approval.
• Work scheduling.
• Incident reporting.
• Emergency procedures.

Applicable customer or general-contractor requirements should be incorporated into project planning and followed in addition to the painting contractor’s own safety procedures.

Subcontractor Coordination

Painting projects may involve scaffold companies, abrasive-blasting contractors, traffic-control contractors, equipment-rental companies, other trades, and additional subcontractors.

Coordination should address:

• Scope of work.
• Chemical hazards.
• Simultaneous operations.
• Fall hazards.
• Scaffold access.
• Equipment movement.
• Surface preparation.
• Fire hazards.
• Public or occupant exposure.
• Emergency procedures.

Each employer remains responsible for protecting its employees while coordinating hazards that may affect other workers.

Painting Toolbox Talks

Painting toolbox talks can reinforce current field hazards and safe-work practices.

Useful topics may include:

• Ladder safety.
• Scaffold safety.
• Fall protection.
• Respirator use.
• Paint and solvent hazards.
• Lead exposure.
• Silica.
• Spray painting.
• Surface preparation.
• PPE.
• Housekeeping.
• Heat stress.
• Aerial lifts.
• Flammable liquids.

Toolbox talks supplement required safety training but do not replace training specifically required by applicable OSHA standards.

Painting Contractor Safety Manual vs. Site-Specific Safety Plan

A Painting Contractor Safety Manual establishes the company’s overall written safety policies, programs, and procedures.

A Site-Specific Safety Plan (SSSP) applies applicable requirements to a particular painting project or worksite.

For example, the company manual may contain Fall Protection, Respiratory Protection, Hazard Communication, Lead, Silica, Scaffold, Aerial Lift, Flammable Liquids, and other programs. Project-specific planning can then address the coatings, existing surfaces, access methods, building occupants, ventilation, equipment, customer requirements, and other hazards unique to that project.

The company safety manual therefore provides the foundation for project-specific painting safety planning.

Building a Painting Contractor Safety Manual

A practical Painting Contractor Safety Manual should reflect the operations the contractor actually performs.

When determining which programs to include, consider:

• Residential painting.
• Commercial painting.
• Industrial painting.
• Interior work.
• Exterior work.
• Spray painting.
• Surface preparation.
• Abrasive blasting.
• Lead-containing coatings.
• Silica-generating activities.
• Hazardous coatings.
• Ladders.
• Scaffolds.
• Aerial lifts.
• Roof work.
• Confined spaces.
• Occupied buildings.
• Customer requirements.
• Contractor-prequalification requirements.

Selecting programs according to actual operations produces a safety manual that addresses the contractor’s real hazards without filling the document with unrelated safety programs.

Customized Safety Manuals for Painting Contractors

Painting contractors can request a customized Construction Safety Manual containing the Core Safety Programs and additional programs applicable to their painting, coating, surface-preparation, access-equipment, chemical, respiratory, and other operations.

Programs can be selected according to the company’s actual work, products, equipment, and hazards so the manual addresses relevant painting operations without including large numbers of unrelated safety programs.

Individual safety programs can also be selected when a painting contractor needs to add or update a particular program within an existing manual.