Most painting jobs involve high risk construction work, usually working at heights, and many involve hazards painters aren’t trained well on, like lead paint. Here’s what a painting SWMS (Safe Work Method Statement) must cover, where painters most often get caught out, and how to avoid the compliance headaches that can cost you far more than the job is worth.
When does painting work need a SWMS?
A SWMS is legally required when the job includes high risk construction work. Painting commonly includes:
- a risk of a person falling more than 2 metres: ladders, trestles, stairwells, scaffold, EWPs and roofs
- work likely to involve disturbing asbestos, like old fibro walls, eaves, textured ceilings and asbestos cement roofs
- working where powered mobile plant is moving, such as EWPs, and other trades’ plant on building sites
- work on or near energised electrical services, like overhead powerlines when painting or washing exteriors
- work in or near a confined space, such as tanks and pits for industrial coatings
- work on or next to a road in use, including line marking and shopfronts
Lead paint isn’t on the high risk construction work list by itself, but it has its own rules, and it belongs in your SWMS whenever you’re preparing old surfaces. A SWMS is also the first document a WHS inspector asks for on site.
Working on a site where someone else’s excavator, bobcat or other plant is operating? That’s still high risk construction work for your business, even though you’re not operating it. See working near someone else’s plant.
Lead paint: the hazard painters are least trained on
Most painters know about asbestos, even if some choose to ignore it. Lead isn’t taught nearly as widely, and it causes more compliance headaches than almost anything else in painting. Get it wrong and fixing the problem can be very costly.
Houses and buildings painted before the 1970s are likely to have lead paint, often under newer coats. Lead dust is a poison: it builds up in the body, harms the brain, kidneys and nervous system, and is especially dangerous for children and pregnant women. It also travels home on clothes, boots and in the ute.
Real example: a painter dry-sanded the exterior of a house with lead paint. The dust went over the yard, the garden and the neighbours’ properties, and the authorities caught up with them. The clean-up of contaminated soil and surfaces, plus the penalties, cost far more than the paint job.
What the rules say
- Removing paint with more than 1% lead by dry sanding, abrasive blasting, or heating (like heat guns and torches) is a lead process under WHS law.
- Where the work is lead risk work, workers must have health monitoring, meaning blood lead tests arranged through a doctor, and there are rules about removing workers whose levels get too high.
- Environmental and public health laws also apply when lead dust or paint chips leave the site. That’s where neighbours, councils and EPAs get involved.
- Victoria has its own lead rules in its OHS Regulations, but the same safe work methods apply.
Working safely with lead paint
- Test before you prep any surface likely to be painted before the 1970s.
- No dry sanding, power sanding, abrasive blasting or high-heat stripping of lead paint. Use wet scraping, wet sanding, chemical strippers or low-heat methods instead.
- Contain the work with plastic sheeting on the ground and over gardens, close windows, and keep people and pets away.
- Clean up with an H-class vacuum and wet wiping, never dry sweeping.
- Protect your crew with P2 or better respirators fit-tested to the wearer, disposable coveralls, washing before eating or smoking, and no work clothes going home.
- Bag and dispose of waste the way your council or EPA requires.
Asbestos: never water-blast an asbestos roof
We still hear of painters using high-pressure water blasters to clean asbestos cement roofs before painting. It’s illegal: the water blasts asbestos fibres and debris over the property, gutters, gardens and neighbouring homes. Painters have been fined for it, and the contamination has to be cleaned up by a licensed asbestos removalist, which is often a very expensive job.
- Check before you prep: fibro walls, eaves, textured ceilings, and roofs on homes built before 1990.
- Assume it’s asbestos if you’re unsure, and get it tested.
- No high-pressure water, power sanding or abrasive blasting on asbestos.
- Asbestos cement roofs are fragile too: never walk on them without safe access and fall protection (see our roofing SWMS guide).
- Asbestos awareness for every painter, especially apprentices.
Epoxy floors, respirators and silica dust
We have particular experience with epoxy and floor coating work, and it has its own set of hazards that a general painting SWMS often misses:
- Floor prep creates silica dust. Grinding, shot blasting and scarifying concrete is high-risk silica work. Since 1 September 2024, Queensland, NSW and most states require dust controls, silica training and the right respirators, and your SWMS can cover the silica controls. Use on-tool extraction with an H-class vacuum. See the silica section of our plumbing SWMS guide for more.
- Coatings that need a respirator. Many epoxy, polyurethane and two-pack products need a respirator with the right cartridges (check the SDS). Some products contain isocyanates, which can cause occupational asthma and may need health monitoring and supplied-air respirators when sprayed.
- Skin sensitisation. Epoxy resins and hardeners cause dermatitis that can become a lifelong allergy, so use nitrile gloves, coveralls and good hygiene.
- Fumes and fire. Ventilate, control ignition sources, and treat enclosed rooms, tanks and pits as possible confined spaces.
- Slips and manual handling: wet floors, mixing and moving heavy product.
What your painting SWMS needs to cover
| Hazard | Controls to include |
|---|---|
| Falls from ladders, trestles and stairwells | The right ladder for short-duration work, secured and on firm ground. Platform ladders or mobile scaffold for longer work. Guardrails on stairwell voids. |
| Scaffold and EWPs | Only use tagged scaffold, and don’t alter it. EWP pre-starts, trained operators and harnesses in boom lifts. |
| Lead paint | Test, use wet methods with no dry sanding or high heat, contain, clean up with an H-class vacuum, respirators and hygiene, and health monitoring where it’s lead risk work. |
| Asbestos | Identify before prep. No water blasting or sanding. Fragile roof precautions. |
| Silica dust from floor prep | On-tool extraction, H-class vacuum, fit-tested respirators and silica training. |
| Solvents, epoxies and two-pack coatings | SDS for every product, the right respirator cartridges, ventilation, gloves and skin protection, and no ignition sources. |
| Spray painting | Spray booth or containment, respirator (supplied air for isocyanates), overspray control, and fire precautions. |
| Overhead powerlines | Keep ladders, EWPs and spray wands clear of the exclusion zone. |
| Pressure washing | Never on asbestos. Slips, electrical safety, and eye protection. |
| Roof painting | Edge protection or harness, no access to wet roofs, and identifying fragile sheets and skylights. |
Make your SWMS work on site
- Read it and talk it through with the crew before work starts, then everyone signs. It isn’t a “tick, flick and sign here” exercise.
- Make it site-specific: this building’s age and paint, these heights, these products.
- Keep it on site with the SDS for your products, and review it when the job changes.
- Give a copy to the builder before work starts. If there’s a principal contractor, it’s your responsibility to provide your SWMS before the high risk work begins.
How we can help
SWMS Done For You: $240. Tell us about the job, whether it’s a residential repaint, new build, commercial, epoxy floor or roof, and we write a painting SWMS that fits your work, including lead, asbestos, silica and coating controls. It arrives as a Word document within about 2 business days, ready to review, talk through, sign and take to site.
Running a painting business? The Projects One app keeps your SWMS, SDS, toolbox talks and EWP pre-starts in one place, on your phone, ready for the builder or an inspector.
Not sure what you need? Talk to a real person
Hi, I’m Wendy. Projects One actually started because I was trying to get a painting company compliant, so painters are close to my heart. Call me about your jobs and I’ll tell you what you actually need, even if that’s not our app.
Painting SWMS questions
Do I need a SWMS for every painting job?
You need one for any job with high risk construction work, and most painting jobs involve working at heights over 2 metres. Asbestos, powerlines, EWPs and confined spaces are also common. You can reuse a SWMS, but review it for each site. More on reusing a SWMS.
How do I know if there’s lead paint?
Assume any building painted before the 1970s may have lead paint, even under newer coats. Test it with a lead test kit or get samples tested before you sand, scrape or strip.
Can I sand lead paint?
Not dry. Dry sanding, power sanding, abrasive blasting and high-heat stripping of lead paint create lead dust and can make it lead risk work. Use wet methods or chemical strippers, contain the area, and protect your crew and the neighbours.
Can I pressure clean an asbestos roof before painting it?
No. Using high-pressure water on asbestos is illegal. It spreads fibres over the property and neighbouring homes, and the clean-up must be done by a licensed asbestos removalist. Get advice on safe methods before you start.
What respirator do I need for epoxy floor coatings?
Check the safety data sheet for each product. Many epoxy and two-pack products need a respirator with organic vapour and particulate cartridges, fitted and maintained properly. Products with isocyanates may need supplied-air respirators when sprayed. Grinding the floor first needs silica controls too.
Does the builder’s SWMS cover my painting work?
No. The business doing the high risk work prepares the SWMS for that work. As the painting contractor, you’re responsible for your SWMS, and you must give a copy to the builder (principal contractor) before work starts.
Related guides
- SWMS by trade: Roofing · Electrical · Plumbing · Concreting · Excavation and earthmoving · Carpentry and building · Plastering and rendering · More trades
- Do I need a SWMS for every job?
- SWMS vs Risk Assessment (JSA) vs Take 5
- SWMS rules in each state: Queensland, NSW, Victoria, WA
General information based on the model Work Health and Safety Regulations used in Queensland, NSW, WA and most states. Victoria uses its own OHS laws, but SWMS rules there are very similar. This isn’t legal advice, so check the detail for your state or ask us.