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Painting · United States

JHA for roof coating

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for roof coating 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 falling from a roof edge, disturbing asbestos, falling through a fragile roof or skylight and falling from a ladder.

JHA example: roof coating

This is a complete JHA for roof coating, 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)
Roof painting and restoration · Painting · Example
Document JHA-001 · Rev 1

Job steps, hazards and controls

#Job stepHazardsRisk beforeControlsRisk after
1Check for asbestos roofing; asbestos roofs must not be pressure cleaned
  • Disturbing asbestos
Critical
  • Treat insulation, surfacing and resilient flooring in buildings built before 1981 as asbestos unless testing shows otherwise, and get the owner's asbestos survey before you start. Elimination
  • Seal off the work area and keep everyone else out. Engineering (guarding)
  • If asbestos must be disturbed, keep it wet, use hand tools not power tools, and clean up with a HEPA vacuum. Engineering
  • Follow 29 CFR 1926.1101: competent person, work class, regulated area and exposure monitoring. Administrative
  • Commercial renovation and any demolition need a NESHAP asbestos inspection first, and demolition needs written notice to the state or EPA 10 working days before work starts (40 CFR 61 Subpart M). Administrative
  • Roofing felts, cement shingles and siding, roof coatings and old panel backboards can also contain asbestos. Test them or treat them as asbestos; asbestos roofing is removed intact with hand tools by trained workers (29 CFR 1926.1101(g)(8)). Administrative
  • Stop work straight away if you find suspect asbestos. Do not touch it and tell your supervisor. Administrative
  • Wear a fit-tested NIOSH-approved respirator suited to the work class, and disposable coveralls. PPE
Medium
2Set up edge protection or harness anchors and a secured ladder
  • Falling from a roof edge
  • Falling from a ladder
  • Falling through a fragile roof or skylight
Critical
  • Do what you can from the ground or from a scaffold at the gutter line, for example pre-assemble parts on the ground. Elimination
  • Install edge protection or guardrails on all open roof edges before work starts. Engineering (guarding)
  • Use a perimeter scaffold with handrails and toe boards along the eaves where practical. Engineering
  • Where guardrails cannot be fitted, use fall restraint on certified roof anchors so workers cannot reach the edge. Engineering
  • Low-slope roofs: guardrails, safety nets, personal fall arrest, or a warning line combined with one of these or with a safety monitor (a safety monitor alone only on roofs 50 feet wide or less). Steep roofs: guardrails with toe boards, safety nets or personal fall arrest (29 CFR 1926.501(b)(10), (11)). Administrative
  • Use one safe, controlled access point and keep others off the roof. Administrative
  • 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
  • Work from underneath or from an aerial lift so nobody stands on the fragile roof. Elimination
  • Cover every skylight with a fixed, marked cover that can hold at least twice the weight it may carry, or guard it with a guardrail. Engineering (guarding)
  • Use crawl boards or staging to spread the load on fragile or rotten decking, and cover or guard any hole left where decking is removed (29 CFR 1926.501(b)(4)). Engineering
  • Use fall arrest on rated anchors when working near fragile areas. Engineering
  • Treat all roof sheets as fragile until a competent person confirms they are not. Old fiber cement and plastic sheets are fragile. Administrative
Medium
3Pressure clean, aware that wet roofs are very slippery
  • High pressure water jetting
  • Slips and trips
  • Falling from a roof edge
Critical
  • Set an exclusion zone around the jetting area. Engineering (guarding)
  • Use a dead man's trigger that stops the jet when released, and check hoses and fittings before use. Engineering
  • Only trained operators use high pressure jetting gear. Administrative
  • Never point the lance at anyone or put a hand in front of it. Administrative
  • Treat any jetting injury as serious and go to hospital, even if it looks small. 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
  • Stop roof work in strong wind or rain, and when the roof is wet, icy or covered in dust or frost. Administrative
  • Wear a harness clipped to a rated anchor when using restraint or fall arrest, and soft-soled non-slip boots. PPE
  • Falling from a roof edge: see step 2 for the full controls Administrative
Medium
4Repair and re-point ridges
  • Lifting and carrying heavy loads
  • Cuts from sharp edges
High
  • Plan to avoid carrying: have materials delivered, and old items picked up, as close as possible to where they are used. Elimination
  • Use lighter or smaller loads: order smaller bags and shorter lengths, and drain or break down old items before moving them. Substitution
  • Use trolleys, pallet jacks, hoists, vacuum lifters or plant instead of carrying by hand. Engineering
  • Use a two-person lift for anything heavy, long or awkward. Plan the route first and clear it. Administrative
  • Keep the load close, back straight and no twisting. Turn with your feet. Administrative
  • Rotate tasks and take breaks on long lifting jobs. Administrative
  • Wear gloves for grip and safety boots to protect your feet. PPE
  • 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
Medium
5Spray coatings in calm weather, protecting cars and neighbours
  • Hazardous chemicals
  • Strong wind and storms
  • Public entering the work area
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
  • Check the forecast each morning and plan work at height and lifting around the weather. Elimination
  • Tie down or weigh down loose sheets, panels, boards and rubbish at the end of each shift. Engineering
  • Set wind limits for roof work, platforms and cranes, using the manufacturer's limits, and stop when they are reached. Administrative
  • Stop work and get down in lightning. Wait 30 minutes after the last thunder before going back up. Administrative
  • Check scaffold, fencing and edge protection after strong wind before anyone uses them. Administrative
  • Fence off the site with secure temporary fencing and lock the gates when you leave. Engineering (guarding)
  • Give pedestrians a safe, marked path around the work, with ramps for strollers and wheelchairs. Engineering (guarding)
  • Use hoarding, covered walkways or catch fans where work is above public areas. Engineering
  • Put signs at each entry: site name, contact number and "No unauthorized entry". Administrative
  • Make the site safe at the end of each day: cover holes, lower plant, remove ladders and lock tools away. Administrative
Medium
6Clean up and remove access
  • Heat stress
  • Sun exposure (UV)
  • Poor housekeeping and waste
High
  • Schedule heavy work for the cooler part of the day. Elimination
  • Provide shade over work and rest areas, and fans or cooling in attics. Engineering
  • Supply cool drinking water close by and drink a cup every 15 to 20 minutes. Administrative
  • Take regular rest breaks in the shade, more often as it gets hotter. Administrative
  • Let new and returning workers build up to full work in the heat over about a week. Administrative
  • In California, Washington, Oregon and Maryland, follow the state heat illness rule: written plan, shade, water, rest and high-heat procedures. Administrative
  • Plan outdoor work for early morning or late afternoon when UV is lower. Elimination
  • Put shade covers over fixed work areas. Engineering
  • Check the UV index each day. Use sun protection when it is 3 or higher. Administrative
  • Check your skin regularly and see a doctor about any new or changing spots. Administrative
  • Wear a broad-brim hat or hard hat brim, long sleeves, sunglasses and SPF 30 or higher sunscreen, reapplied every 2 hours. PPE
  • 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
Medium

PPE

Safety-toe boots (ASTM F2413)Personal fall arrest system (harness)Half-face respirator (P100 cartridges)Safety goggles (ANSI Z87.1)Sun protection (sunscreen, hat, long sleeves)Chemical-resistant glovesCoverallsWork glovesHard hat (ANSI Z89.1)Face shield (ANSI Z87.1)Hearing protection (earmuffs or plugs)Cut-resistant glovesSafety glasses (ANSI Z87.1)High-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways)

Plant and equipment

Pressure washerAirless paint sprayerExtension ladderHand tools

Permits and plans

Written fall protection plan (only where guardrails, nets or personal fall arrest are not feasible, 1926.502(k))

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 roof coating

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 JHA

Pre-start checklist for roof coating

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

The safe sequence of work

  1. Check for asbestos roofing; asbestos roofs must not be pressure cleaned
  2. Set up edge protection or harness anchors and a secured ladder
  3. Pressure clean, aware that wet roofs are very slippery
  4. Repair and re-point ridges
  5. Spray coatings in calm weather, protecting cars and neighbours
  6. Clean up and remove access

Hazards to watch on roof coating

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

Step 3High pressure water jettingHigh pressure water cuts through skin and injects water and dirt into the body, or the hose whips.
Step 2Falling through a fragile roof or skylightA worker steps on a skylight, clear sheet or old fiber cement roof and falls through to the floor below.
Step 6Sun exposure (UV)Long hours in the sun cause sunburn, eye damage and skin cancer.
Step 5Strong wind and stormsWind blows sheets, panels and people off roofs and scaffolds, and storms and lightning make work at height and lifting unsafe.
Step 2, 3Falling from a roof edgeA worker slips or walks off the edge of a roof or gutter line and falls to the ground.
Step 6Heat stressHard work in hot weather or hot attics causes heat exhaustion or heat stroke, which can kill.
Almost certainLikelyPossibleUnlikelyRareHow bad it could be: First aid only to FatalityBA
Highest risk on roof coating: Critical before controls (B), down to Medium after controls (A), on the United States 5 by 5 risk matrix (likely and fatality 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?
  • Will you use a scaffold or rolling tower?
  • Will you use an aerial lift (scissor lift or boom lift)?
  • Is it a home or child-occupied facility (such as a child care center or preschool) built before 1978, and will you disturb paint?

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 roof coating?

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for roof coating 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 roof coating?

Usually Safety-toe boots (ASTM F2413), Personal fall arrest system (harness), Half-face respirator (P100 cartridges), Safety goggles (ANSI Z87.1), Sun protection (sunscreen, hat, long sleeves), Chemical-resistant gloves, Coveralls, Work gloves, Hard hat (ANSI Z89.1), Face shield (ANSI Z87.1), Hearing protection (earmuffs or plugs), Cut-resistant gloves, Safety glasses (ANSI Z87.1), High-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways). The site rules may add more, so check with the general contractor.

More painting JHAs

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

Sources