SafetyPaperwork
Painting · United States

JHA for interior painting

By Safety PaperworkBuilt from OSHA standards and guidance · How we write and check theseUpdated

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for interior painting before you start.

A JHA breaks the job into steps, lists the hazards in each step and the controls that protect the crew, and the crew signs it. The main hazards are lead paint dust and fumes, falling from a ladder, flammable liquids and gases and working in an occupied home or building.

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JHA example: interior painting

This is a complete JHA for interior 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.

Job Hazard Analysis (JHA)
Interior painting · Painting · Example
Document JHA-001 · Rev 1

Job steps, hazards and controls

#Job stepHazardsRisk beforeControlsRisk after
1Agree work areas with occupants and protect floors and furniture
  • Working in an occupied home or building
  • Slips and trips
Medium
  • Plan noisy, dusty or risky work for when the building is empty. Elimination
  • Close off the work area with barriers, plastic sheeting or locked doors, and put up signs. Engineering (guarding)
  • Keep fire exits and paths clear at all times. Administrative
  • Tell occupants before you turn off power, water or gas, and before noisy or dusty work. Administrative
  • Lock away tools, chemicals and materials each day, out of reach of children. Administrative
  • Clean up dust and debris at the end of each day. Administrative
  • Plan walkways and keep them clear of materials, hoses and leads. Elimination
  • Run cords and hoses overhead on hooks or stands, or along walls, not across walkways. Engineering
  • Fill or cover holes, and lay boards or mats on muddy access paths. Engineering
  • Clean up offcuts, packaging and spills as you go, not at the end of the day. Administrative
  • Keep work areas, stairs and access paths well lit. Administrative
  • Wear safety boots with good grip, laced up. PPE
Low
2Test old paint for lead before sanding
  • Lead paint dust and fumes
High
  • Test old paint for lead before you sand, scrape, cut or heat it. Elimination
  • Use wet scraping, chemical strippers or shrouded tools with extraction instead of dry sanding. Never burn off lead paint with an open flame. Substitution
  • Seal off the work area with plastic sheeting and keep residents, children and pets out. Engineering (guarding)
  • Clean up with a HEPA vacuum and wet wipes. Never dry sweep. Engineering
  • In homes and child-occupied facilities built before 1978 (such as child care centers, preschools and kindergarten classrooms), work that disturbs more than 6 sq ft inside or 20 sq ft outside is done by an EPA Lead-Safe Certified firm with a certified renovator (RRP rule). Administrative
  • Do an initial lead exposure assessment and protect workers as if over the limit until results are in. Over 50 micrograms per cubic meter, follow a written lead compliance program (29 CFR 1926.62(d), (e)). Administrative
  • Never torch painted surfaces, keep heat guns below 1,100 degrees F, and use sanders, grinders or planers only with a shroud and HEPA vacuum attachment (40 CFR 745.85(a)(3)). Administrative
  • Provide a clean change area and handwashing, and keep food, drink and tobacco out of the work area (29 CFR 1926.62(i)). Administrative
  • Wash hands and face before eating, drinking or smoking. Change out of dusty clothes before going home. Administrative
  • Wear a NIOSH-approved respirator with N100 or P100 filters, disposable coveralls and gloves. PPE
Low
3Fill and sand walls with a dust mask and vacuum sander
  • General dust
  • Repetitive work and awkward postures
Medium
  • Use low-dust products, such as dust-reduced or pre-mixed compounds. Substitution
  • Seal off the work area with plastic sheeting in occupied buildings. Engineering (guarding)
  • Use tools with dust extraction and a vacuum for clean up. Engineering
  • Lightly mist the area with water to keep dust down, away from anything electrical. Engineering
  • Never dry sweep or blow dust off with compressed air. Administrative
  • Wear a dust mask and safety glasses. PPE
  • Use tools that cut the effort: powered screwdrivers, long-handled tools and extension poles for overhead work. Substitution
  • Set work up at waist height on benches or trestles where you can. Engineering
  • Use light tools with good grips, and keep blades and bits sharp. Engineering
  • Rotate tasks and take short breaks every hour on repetitive work. Administrative
  • Warm up before heavy physical work and report aches and pains early. Administrative
  • Wear knee pads for kneeling work and gloves for grip. PPE
Medium
4Paint from a platform ladder, not chairs or tins
  • Falling from a ladder
  • Repetitive work and awkward postures
High
  • Use a platform ladder, mobile scaffold or aerial lift for longer jobs instead of a straight ladder. Substitution
  • Use Type I, IA or IAA ladders in good condition. Tag and remove any damaged ladder. Engineering
  • Set extension ladders at a 4 to 1 angle on firm, level ground, secured, and reaching 3 feet above the landing. Engineering
  • Use ladders only for short, light work. Do not carry heavy or awkward loads up a ladder. Administrative
  • Keep three points of contact and your belt buckle between the stiles. Do not overreach. Administrative
  • Do not stand on the top three rungs of an extension ladder or the top step of a stepladder. Administrative
  • Check the ladder before each use: feet, rungs, side rails and locks. Administrative
  • Wear non-slip safety boots with clean soles. PPE
  • Repetitive work and awkward postures: see step 3 for the full controls Administrative
Medium
5Keep windows open and lids on tins
  • Hazardous chemicals
  • Flammable liquids and gases
High
  • 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 labels before use, following OSHA Hazard Communication. Administrative
  • Keep chemicals in labeled containers. Never pour them 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 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
Medium
6Clean brushes away from drains and clear drop sheets
  • Poor housekeeping and waste
  • Slips and trips
Medium
  • Order materials to size and send packaging back where you can. Elimination
  • Put dumpsters and waste 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
  • Slips and trips: see step 1 for the full controls Administrative
Low

PPE

Safety-toe boots (ASTM F2413)Safety glasses (ANSI Z87.1)N95 respiratorChemical-resistant glovesHalf-face respirator (P100 cartridges)CoverallsWork glovesKnee padsHard hat (ANSI Z89.1)Safety goggles (ANSI Z87.1)

Plant and equipment

Platform ladderStep ladderPower sanderHand tools

Emergency

Call 911. Add the nearest hospital, the assembly point and the first aid / cpr person for your site.

Sign-off

Supervisor and every worker sign to confirm they have read and understood this JHA.

Free JHA template for interior painting

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

Word template (.docx)PDF template

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 JHA

Pre-start checklist for interior painting

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

The safe sequence of work

  1. Agree work areas with occupants and protect floors and furniture
  2. Test old paint for lead before sanding
  3. Fill and sand walls with a dust mask and vacuum sander
  4. Paint from a platform ladder, not chairs or tins
  5. Keep windows open and lids on tins
  6. Clean brushes away from drains and clear drop sheets

Hazards to watch on interior painting

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

Step 2Lead paint dust and fumesHomes and child-occupied facilities built before 1978 may have lead paint. Sanding, scraping or heating it releases dust that poisons workers and children.
Step 5Flammable liquids and gasesGasoline, solvents, thinners and propane catch fire or explode when vapor reaches a spark, flame or hot surface.
Step 1Working in an occupied home or buildingResidents, staff or children wander into the work area and get hurt, or the work blocks exits or cuts off power or water while people are inside.
Step 3General dustDust from drywall, joint compound, cement and clean up irritates eyes and lungs and makes it hard to see.
Step 3, 4Repetitive work and awkward posturesDoing the same movement for hours, kneeling or working overhead causes long-term damage to joints, muscles and tendons.
Step 5Hazardous chemicalsGlues, sealants, solvents, acids, cleaners and cement burn skin and eyes or cause breathing problems and poisoning.
Almost certainLikelyPossibleUnlikelyRareHow bad it could be: First aid only to FatalityBA
Highest risk on interior painting: High before controls (B), down to Medium after controls (A), on the United States 5 by 5 risk matrix (possible and serious injury becomes unlikely and serious 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):

  • Will anyone work 6 feet or more above a lower level?
  • Will anyone work on a roof?
  • Is there a skylight, fiberglass panel or other fragile roofing?
  • Will you use a scaffold or rolling tower?
  • Will you use an aerial lift (scissor lift or boom lift)?

Why JHAs get rejected

General contractors send documents back for these reasons. This example avoids them, but check yours too.

  • Generic steps such as "work safely" or "use PPE" with no task-specific hazards or controls.
  • No OSHA standards referenced for the hazards that have them, such as fall protection, ladders, scaffolds or silica.
  • No competent person named for fall protection, excavation, scaffolds or silica where those hazards exist.
  • Equipment listed without inspection requirements, and no training listed for the people using it.
  • Respirators listed with no respiratory protection program, medical clearance or fit test.
  • Controls rely only on PPE when engineering controls such as guardrails, wet cutting or extraction are feasible.
  • No crew sign-off, or no date and revision when the job has changed.

Questions

Do I need a JHA for interior painting?

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for interior painting before you start.

Who signs the JHA?

The supervisor or competent person who prepared it signs, and every crew member signs to show they were trained on the hazards and controls before the job starts. Many general contractors also sign to accept it.

How long do I keep it?

Keep this JHA on site during the job, and keep it with the training and inspection records for at least 1 year after the job (longer if your state plan or general contractor requires it). OSHA does not set a retention period for JHAs themselves.

What PPE is needed for interior painting?

Usually Safety-toe boots (ASTM F2413), Safety glasses (ANSI Z87.1), N95 respirator, Chemical-resistant gloves, Half-face respirator (P100 cartridges), Coveralls, Work gloves, Knee pads, Hard hat (ANSI Z89.1), Safety goggles (ANSI Z87.1). The site rules may add more, so check with the general contractor.

More painting JHAs

JHALead Paint Removal (RRP)10 stepsJHAExterior House Painting6 stepsJHASpray Painting6 stepsJHARoof Coating6 stepsJHAPressure Washing6 stepsJHAEpoxy Floor Coating5 steps

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Toolbox talks for this job

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

Sources