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Painting · Canada

FLHA for spray painting

Provincial OHS law requires hazards to be assessed and controlled before work starts. A field level hazard assessment (FLHA) for spray painting is done on site at the start of the shift and again whenever conditions change.

It lists the tasks, hazards and controls, and every worker signs on before starting and signs off at the end of the shift. The main hazards are flammable liquids and gases, fire and emergencies, hazardous chemicals and eye injuries.

FLHA example: spray painting

This is a complete FLHA for spray painting, with 6 job steps. Open it in the builder to add your site, crew and signatures, change anything, and download a PDF. Or download the free Word template below and fill it in by hand.

Field Level Hazard Assessment (FLHA)
Airless spray painting · Painting · Example
Document FLHA-001 · Rev 1

Job steps, hazards and controls

#Job stepHazardsRisk beforeControlsRisk after
1Mask off and ventilate the area, and remove ignition sources
  • Flammable liquids and gases
  • Fire and emergencies
High
  • Use non-flammable or water-based products where you can. Substitution
  • Keep ignition sources away: no smoking, no hot work and no running engines near flammables. Engineering (guarding)
  • Store fuels and solvents in approved, closed containers in a ventilated area away from the work. Engineering
  • Refuel equipment outdoors with the engine off and cool. Administrative
  • Keep only what you need for the day on site. Administrative
  • Store gas cylinders upright, secured and outdoors. Administrative
  • Keep a suitable fire extinguisher where flammables are used or stored. Administrative
  • Wear chemical gloves and safety glasses when pouring or mixing. PPE
  • Provide fire extinguishers suited to the site, checked and easy to reach. Engineering
  • Keep exits and escape routes clear and signed. Engineering
  • Have a site emergency plan: alarm, exits, assembly point and emergency contacts. Administrative
  • Keep a stocked first aid kit and at least one trained first aider on site. Administrative
  • Know the site address and how emergency services get in. Call 911. Administrative
  • Go through the emergency plan with every worker and visitor at induction. Administrative
  • Keep flammable materials and rubbish away from exits and escape routes. Administrative
Medium
2Check hoses and tip guard, and lock the trigger when not spraying
  • Stored energy
  • Hazardous chemicals
Medium
  • Release or block all stored energy before work: release the pressure in pipes, tanks and hoses, bleed hydraulics, release springs, lower loads. Elimination
  • Lock out and tag all energy sources with personal locks. Engineering (guarding)
  • Stored energy: see step 5 for the full controls Administrative
  • Choose the least harmful product that does the job, for example water-based instead of solvent-based. Substitution
  • Use chemicals in well-ventilated areas, or use fans and extraction in closed rooms. Engineering
  • Hazardous chemicals: see step 4 for the full controls Administrative
Medium
3Never point the gun at anyone or put a hand near the tip
  • Stored energy
  • Cuts from sharp edges
Medium
  • Put mechanical blocks or props under raised parts like buckets, tipper bodies and doors. Engineering
  • Test that the system is dead and nothing can move before you start. Administrative
  • Stored energy: see step 5 for the full controls Administrative
  • Deburr or cover sharp edges, and fit edge protectors on exposed sheet metal. Engineering
  • Use knives with retractable or self-retracting blades. Engineering
  • Cut away from your body and keep your other hand clear. Administrative
  • Put used blades in a blade bin or sharps container. Administrative
  • Use two people to handle large sheets of metal or glass. Administrative
  • Wear cut-resistant gloves and long sleeves. PPE
Low
4Spray with a respirator and goggles, keeping others out
  • Hazardous chemicals
  • Eye injuries
Medium
  • Choose the least harmful product that does the job, for example water-based instead of solvent-based. Substitution
  • Use chemicals in well-ventilated areas, or use fans and extraction in closed rooms. Engineering
  • Read the Safety Data Sheet (SDS) and WHMIS labels before use. Workers have WHMIS training. Administrative
  • Keep chemicals in labelled containers. Never decant into drink bottles. Administrative
  • Store chemicals away from heat, food and drink, and keep products that react with each other apart. Administrative
  • Have eye wash and a spill kit nearby, and wash hands before eating. Administrative
  • Wear chemical-resistant gloves and safety glasses or goggles as listed on the SDS. PPE
  • Use a respirator with the right cartridge if the SDS calls for one. PPE
  • Use tool guards and screens to stop flying particles. Engineering
  • Use dust extraction and water to keep dust out of the air. Engineering
  • Keep others out of the area when cutting, grinding or chipping. Administrative
  • Keep an eye wash station or eye wash bottles on site. Administrative
  • Wear safety glasses at all times, goggles for dust and chemicals, and a face shield for grinding. PPE
Medium
5Release pressure before cleaning or changing tips
  • Stored energy
Medium
  • Release or block all stored energy before work: release the pressure in pipes, tanks and hoses, bleed hydraulics, release springs, lower loads. Elimination
  • Lock out and tag all energy sources with personal locks. Engineering (guarding)
  • Put mechanical blocks or props under raised parts like buckets, tipper bodies and doors. Engineering
  • Test that the system is dead and nothing can move before you start. Administrative
  • Follow the maker's procedure, for example for garage door and roller door springs. Administrative
  • Wear safety glasses and gloves. PPE
Low
6Clean the pump and dispose of solvent waste properly
  • Flammable liquids and gases
  • Poor housekeeping and waste
High
  • Flammable liquids and gases: see step 1 for the full controls Administrative
  • Order materials to size and send packaging back where you can. Elimination
  • Put waste bins and chutes close to the work. Engineering
  • Clean as you go, and do a full clean up at the end of each day. Administrative
  • Keep exits, stairs and walkways clear at all times. Administrative
  • Stack materials neatly on level ground, away from edges. Administrative
  • Wear gloves when handling waste. PPE
Medium

PPE

Respirator fit tested to CSA Z94.4 (P100 for dust, or the type the air test calls for)Safety gogglesCoverallsChemical-resistant glovesCSA green triangle safety boots (CSA Z195)Safety glasses (CSA Z94.3)Work glovesCut-resistant glovesFace shield

Plant and equipment

Airless paint sprayerAir compressorRolling scaffold: Provincial scaffold trainingScissor lift: Provincial aerial work platform operator training (CSA B354.8)

Permits and plans

Lockout permit

Emergency

Call 911. Add the nearest hospital, the muster point and the first aid attendant for your site.

Sign-off

Supervisor and every worker sign to confirm they have read and understood this FLHA, then sign off at the end of the shift.

Free FLHA template for spray painting

Word (.docx) and PDF, Letter landscape, no email needed. Fill in your site details, then print or send it.

Make yours in 2 minutes

Same document, filled in for your job. Answer a few yes or no questions, the crew signs on the phone, and you send the PDF.

Start this FLHA

Pre-start checklist for spray painting

Tick these off before work starts. They come from the hazards, permits and equipment in this job.

The safe sequence of work

  1. Mask off and ventilate the area, and remove ignition sources
  2. Check hoses and tip guard, and lock the trigger when not spraying
  3. Never point the gun at anyone or put a hand near the tip
  4. Spray with a respirator and goggles, keeping others out
  5. Release pressure before cleaning or changing tips
  6. Clean the pump and dispose of solvent waste properly

Hazards to watch on spray painting

The hazards most specific to this job, and the step where each one comes up.

Step 1, 6Flammable liquids and gasesGasoline, solvents, thinners and propane catch fire or explode when vapour reaches a spark, flame or hot surface.
Step 1Fire and emergenciesA fire, injury or other emergency happens and workers cannot get out, raise the alarm or get first aid in time.
Step 2, 3, 5Stored energyEnergy left in springs, hydraulics, compressed gas, raised loads or capacitors releases suddenly and crushes or injures workers.
Step 4Eye injuriesFlying chips, dust, chemicals or sparks get into the eye and cause damage or blindness.
Step 2, 4Hazardous chemicalsGlues, sealants, solvents, acids, cleaners and cement burn skin and eyes or cause breathing problems and poisoning.
Step 3Cuts from sharp edgesSheet metal, glass, blades, cable tray and offcuts cut hands and arms.
Almost certainLikelyPossibleUnlikelyRareHow bad it could be: First aid only to FatalityBA
Highest risk on spray painting: High before controls (B), down to Medium after controls (A), on the Canada 5 by 5 risk matrix (unlikely and fatality becomes unlikely and lost time injury).

What changes on your site

This example covers the job itself. Your site may add more. Add controls for any of these that apply (the builder asks you these as yes or no questions):

  • Could anyone fall 3 metres or more, or fall any distance into machinery, water, a hazardous substance or through an opening?
  • Will anyone use a ladder or stepladder?
  • Will anyone work on a roof?
  • Is there a fragile roof, skylight or clear roof sheet?
  • Will you use a scaffold or mobile tower?

Licences and legal requirements in Canada

Equipment on this job that needs a licence, ticket or training:

  • Rolling scaffold: Provincial scaffold training
  • Scissor lift: Provincial aerial work platform operator training (CSA B354.8)

Employers must identify hazards before work starts and control them, and workers must be told about them. A field level hazard assessment is done on site, at the start of each shift or task, and reviewed again when conditions change.

Rules that apply: WHMIS 2015 and provincial OHS regulation.

Why FLHAs get rejected

Prime contractors and COR auditors send documents back for these reasons. This example avoids them, but check yours too.

  • End of shift boxes already say "None" when the form was signed at the start of the shift.
  • One FLHA reused for days or weeks, or a "review by" date a month away, when the work and conditions change daily.
  • No time of assessment and no record of any revision, which Alberta s.7(3) requires.
  • Workers signed that they "read" it, but nothing shows they took part, which Alberta s.8(1) requires.
  • Work at height with no fall protection plan where the province requires one, or no written rescue procedure for workers using fall arrest.
  • Permits or locates required on site but no permit or ticket numbers recorded.
  • No re-assessment entry after an obvious change such as weather, a new task or a new crew member.

Rules by province for spray painting

Province or territoryKey local ruleRegulator
OntarioFall protection (O. Reg. 213/91 s.26) applies at a fall of more than 3 m, more than 1.2 m where the work area is used as a path for a wheelbarrow or similar equipment, and at any height into operating machinery, water or other liquid, a hazardous substance, or through an opening.Ontario Ministry of Labour, Immigration, Training and Skills Development
British ColumbiaFall protection is required where a fall of 3 m or more may occur (s.11.2). A written fall protection plan is required at 7.5 m or more where there are no permanent guardrails (s.11.3).WorkSafeBC
AlbertaA hazard assessment must be done before work begins, and before a new work site is built (OHS Code s.7(1)). The results must be written down with the controls (s.7(2)).Alberta Occupational Health and Safety
QuebecGuardrails (Safety Code s.2.9.1, as amended by Decret 63-2025) are needed where a worker could fall into liquid or a hazardous substance, onto moving parts or dangerous equipment, 1.2 m or more when using a vehicle, 1.5 m or more when handling a load, and more than 3 m in all other cases.CNESST (Commission des normes, de l'equite, de la sante et de la securite du travail)
ManitobaA prime contractor is required whenever more than one employer or self employed person works on the site at the same time (Act s.7).Manitoba Workplace Safety and Health Branch
SaskatchewanAn occupational health committee is required at 10 or more workers of one employer (Act s.3-22).Saskatchewan Ministry of Labour Relations and Workplace Safety, OHS Division
Nova ScotiaWorkers must be trained in fall protection before using it or working in, supervising or planning work in a fall protection area, with a refresher at least every 3 years (WHSR s.21.19).Nova Scotia Department of Labour, Skills and Immigration, Safety Branch (OHS)
New BrunswickFall protection is needed from 3 m above water or the nearest permanent safe level (Reg 91-191 s.49(1)(a)(i)).WorkSafeNB
Newfoundland and LabradorGive written notice to the minister before starting a construction project that will last 30 days or more, with the site, location, type of work and number of workers (Regs s.8).Government Services, Occupational Health and Safety Division
Prince Edward IslandFall protection is needed from 3 m above the nearest safe surface or water (Fall Protection Regulations s.2(1)(a)).Workers Compensation Board of PEI, OHS Division
YukonEvery employer must do hazard assessments with the committee, representative or workers, and redo them after significant changes or incidents (Regs s.1.03.01).Yukon Workers' Safety and Compensation Board
Northwest TerritoriesFall protection is needed from 3 m, or lower if there is a risk of injury (s.119(1)). Guardrails are needed for falls of 1.2 m to 3 m at permanent work sites (s.119(2)).Workers' Safety and Compensation Commission (WSCC)
NunavutNo 911. To reach the RCMP in an emergency, dial your community's first three digits then 1111 (Iqaluit: 979-1111). Put the local fire, ambulance and RCMP numbers on every FLHA.Workers' Safety and Compensation Commission (WSCC)

Questions

Do I need an FLHA for spray painting?

Provincial OHS law requires hazards to be assessed and controlled before work starts. A field level hazard assessment (FLHA) for spray painting is done on site at the start of the shift and again whenever conditions change.

Who signs the FLHA?

The supervisor and every worker take part in the assessment and sign on before work starts, then sign off at the end of the shift. Review it and re-sign whenever the task or conditions change.

How long do I keep it?

Keep completed hazard assessments for at least 3 years (COR auditors sample the last 12 months). Review this FLHA and re-sign whenever the task, crew or conditions change.

What PPE is needed for spray painting?

Usually Respirator fit tested to CSA Z94.4 (P100 for dust, or the type the air test calls for), Safety goggles, Coveralls, Chemical-resistant gloves, CSA green triangle safety boots (CSA Z195), Safety glasses (CSA Z94.3), Work gloves, Cut-resistant gloves, Face shield. The site rules may add more, so check with the general contractor.

More painting FLHAs

Toolbox talks for this job

Blank FLHA template: free FLHA templates. Also for other countries: Australia (SWMS) · United Kingdom (RAMS) · United States (JHA)

Sources