Risk Assessments · Mandatory · Pre-Construction

RAMS — Painting and Decorating

This RAMS covers painting, staining, varnishing, and wallpapering operations on construction sites. It addresses COSHH risks from paints, solvents, and dust from surface preparation, along with working at height from ladders, steps, and mobile towers. Adequate ventilation must be provided when using solvent-based products in enclosed areas.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. MHSWR 1999 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.

Legal basis	MHSWR 1999 Regulation 3 + COSHH 2002 (solvents / isocyanates / epoxy / lead) + CLAW 2002 (Control of Lead at Work) + WAH Regulations 2005 + DSEAR 2002 (flammable vapours)
Key guidance	COSHH Essentials for painting and decorating; EH40 WELs for solvents, isocyanates, lead; HSE INDG411 (lead paint); PASMA guidance for towers; IPAF guidance for MEWPs
Who	Painting and decorating contractor, specialist coatings applicator, spray operative
COSHH substances	Solvents (white spirit, xylene, toluene); isocyanates (2-pack polyurethanes); epoxy resins (2-pack floor/structural coatings); lead paint (pre-1992 surfaces); surface dust; chemical strippers
Lead paint	CLAW 2002 applies to any disturbance of lead paint on pre-1992 surfaces — blood lead monitoring required above action level
Enforcing authority	Health and Safety Executive (HSE)

1. What It Covers

Painting and decorating presents a wider range of chemical health hazards than most trades on a construction site. A RAMS for this work scope must address every coating type and application method to be used — from standard emulsion applied by brush and roller through to isocyanate-based polyurethanes and epoxy floor coatings applied by spray.

The legal framework is dominated by COSHH 2002, which applies to every substance handled in the painting and decorating process — solvents, isocyanates, epoxy resins, lead paint, surface dust, and chemical strippers. The Control of Lead at Work Regulations 2002 (CLAW) apply specifically where lead paint is disturbed on surfaces dating from before 1992. The Work at Height Regulations 2005 apply to all access arrangements for painting at height, including stepladders, towers, scaffolds, and MEWPs. The Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) apply where flammable solvent vapours create an explosive atmosphere risk, particularly in confined or poorly ventilated spaces.

Isocyanate sensitisation is irreversible and career-ending

Isocyanates are present in two-pack polyurethane coatings, some spray paints, and expanding foam products. Once an operative becomes sensitised to isocyanates, they will react to any subsequent exposure at any concentration — even below the workplace exposure limit. Sensitisation is permanent and irreversible. An operative who becomes sensitised to isocyanates cannot work with any isocyanate-containing product again. The RAMS must treat isocyanate exposure as a high-severity, irreversible health hazard requiring specific controls, health surveillance, and competent application.

2. COSHH Substances

The following table sets out the six principal categories of hazardous substances encountered in painting and decorating work, their health effects, the exposure routes, and the control measures that must be specified in the COSHH assessment and referenced in the RAMS.

Substance type	Common examples	Health effects	Exposure route	Controls
Solvents	White spirit, xylene, toluene, acetone, MEK (methyl ethyl ketone)	CNS depression (dizziness, drowsiness, headache); dermatitis; liver and kidney damage with chronic exposure; narcotic effects at high concentrations	Inhalation of vapour; skin absorption; ingestion	Ventilation (natural or mechanical); water-based coatings in preference to solvent-based where specification permits; RPE where ventilation insufficient; skin protection (barrier cream, gloves); exposure monitoring where indicated
Isocyanates	HDI (hexamethylene diisocyanate), MDI (methylene diphenyl diisocyanate) in 2-pack polyurethane coatings and spray foams	Respiratory sensitisation (occupational asthma) which is irreversible; skin sensitisation; acute irritation of eyes and respiratory tract	Inhalation of vapour/aerosol (primary route during spraying); skin contact	Elimination where possible (specify non-isocyanate alternative); LEV or forced ventilation; air-fed RPE for spray application (minimum APF 20); full face shield and chemical-resistant gloves; health surveillance (lung function + symptom questionnaire); trained operative only
Epoxy resins	Two-pack epoxy floor coatings, structural adhesives, primer systems	Skin sensitisation (allergic contact dermatitis) which is irreversible once sensitised; respiratory sensitisation from vapour/aerosol; eye irritation	Skin contact (primary route); inhalation of vapour during mixing and application	Chemical-resistant gloves (nitrile, not latex); barrier cream; long sleeves; eye protection; ventilation; COSHH assessment specific to the product; health surveillance for dermatitis; skin checks
Lead paint	Lead-based paint on pre-1992 surfaces (common in heritage buildings, steelwork, and window frames)	Lead poisoning (abdominal pain, neurological damage, kidney damage, reproductive harm); chronic low-level exposure causes cumulative harm	Inhalation of dust/fume during sanding, scraping, burning off, or blasting; ingestion from hand-to-mouth transfer	CLAW 2002 assessment before any disturbance; wet methods to suppress dust; no dry sanding or burning off; RPE (minimum FFP3, air-fed for blasting); decontamination facilities; blood lead monitoring above action level; disposal as hazardous waste
Surface dust	Plaster dust, sanding dust from fillers and coatings, wood dust from preparation	Respiratory irritation; silica exposure from plaster/render dust; wood dust is a nasal carcinogen (hardwood); general nuisance dust	Inhalation	Dust extraction on power sanders; wet sanding where practicable; RPE (FFP2 minimum, FFP3 for silica or hardwood dust); COSHH assessment; housekeeping to prevent dust accumulation
Chemical strippers	Dichloromethane (DCM) strippers (restricted), NMP-based strippers, caustic strippers	DCM: CNS depression, cardiac sensitisation, liver damage; NMP: reproductive toxicity (Repr. 1B); caustic: chemical burns	Inhalation of vapour; skin absorption (NMP penetrates most glove materials); skin contact (caustic)	Substitute less hazardous product where effective; DCM strippers restricted to professional use only (EU regulation); chemical-resistant gloves matched to the product (check SDS for glove type); ventilation; RPE where vapour exposure; COSHH assessment for the specific product used

“Where there is exposure to lead...the employer shall ensure that the exposure of his employees to lead is either prevented or, where this is not reasonably practicable, adequately controlled.”— Control of Lead at Work Regulations 2002, Regulation 6

3. Key Hazards

The following table sets out the principal hazards associated with painting and decorating, who is at risk, the key risk factors, and the control measures that should be addressed in the RAMS.

Hazard	Who at risk	Risk factors	Control measures
Isocyanate sensitisation (occupational asthma)	Spray operative, mixer, adjacent operatives in unventilated areas	Spraying 2-pack polyurethane coatings generates isocyanate aerosol; even brush/roller application of 2-pack PU can generate vapour in confined spaces; once sensitised, any exposure triggers asthma	Air-fed RPE (minimum APF 20) for all spray application; forced ventilation; exclusion zone during spraying; health surveillance (lung function baseline, then 6-weekly for first year, then annually); trained operatives only; product substitution where possible
Lead paint disturbance (CLAW 2002)	Operative preparing or removing lead paint; occupants of adjacent areas	Sanding, scraping, or burning off lead paint on pre-1992 surfaces generates lead dust and fume; lead is a cumulative poison with no safe threshold for chronic exposure	CLAW 2002 assessment before any disturbance; wet methods only (no dry sanding, no burning off); RPE (FFP3 minimum, air-fed for blasting); containment to prevent spread; decontamination; blood lead monitoring; disposal as hazardous waste; young persons and women of child-bearing age excluded from significant lead work
Solvent vapour inhalation	Painter, decorator, adjacent trades	Solvent-based paints, varnishes, and stains release organic vapour during application and drying; enclosed rooms concentrate vapour; multiple operatives painting in same space increases total vapour load	Natural ventilation (windows open, doors propped); mechanical ventilation where natural ventilation inadequate; water-based products in preference where specification permits; RPE with organic vapour filter (A2) where ventilation insufficient; vapour monitoring where indicated
Falls from height	Painters, decorators	Stepladders, podium steps, mobile towers, scaffolds, MEWPs used to access ceilings, high walls, stairwells, and external elevations; overreaching from ladders	Hierarchy: podium steps or mobile tower in preference to stepladders; PASMA-erected towers; MEWPs for external work; scaffold for large-area access; stepladders only for short-duration, low-risk tasks; 3-point contact; no overreaching; WAH risk assessment
Skin sensitisation from epoxy resins	Operative mixing and applying 2-pack epoxy coatings	Epoxy hardener is a strong skin sensitiser; skin contact during mixing or application causes allergic contact dermatitis which is irreversible once sensitised; sensitisation can occur after very few exposures	Chemical-resistant gloves (nitrile minimum 0.3mm thickness); barrier cream under gloves; long sleeves tucked into gloves; eye protection; immediate skin wash if contact occurs; COSHH assessment; health surveillance for dermatitis; skin checks
Fire and explosion from flammable vapours	All operatives in the work area	Solvent vapour from paints, thinners, and strippers can form explosive atmospheres in enclosed spaces; ignition from electrical equipment, hot work, or static discharge	DSEAR assessment where flammable vapours present; ventilation to maintain vapour below 10% of LEL; no ignition sources in work area; ATEX-rated equipment where required; fire extinguisher at point of work; solvent-soaked rags in metal lidded containers
Spray overspray and contamination	Adjacent trades, building occupants, public	Airless spray equipment produces fine aerosol that drifts beyond the immediate work area; overspray contaminates surfaces, vehicles, and can affect respiratory health of bystanders	Containment sheeting and masking; exclusion zone around spray area; forced extraction where enclosed; notification to adjacent trades; timing of spray work to minimise impact; environmental protection (drains, watercourses)
Manual handling	Painters, decorators, labourers	Paint tins (5-25 litres, up to 25 kg); scaffolding components; access equipment; repetitive overhead work causing shoulder and neck strain	Mechanical handling for bulk materials; roller extensions to reduce overhead work; task rotation for prolonged overhead painting; manual handling assessment; correct lifting technique training

4. Competence Requirements

Painting and decorating requires trade-specific qualifications and, for specialist coatings, additional product-specific training. The RAMS must confirm that all operatives hold the required competence and that evidence has been verified before work begins. Note that the CSCS Industry Accreditation (IA) card expired on 31 January 2025 and is no longer accepted on most major contractor sites.

Role	Required competence
Painter and decorator	NVQ Level 2 in Decorative Finishing and Industrial Painting (or Painting and Decorating pathway); CSCS Skilled Worker (blue) card with painting and decorating occupation listed; site-specific induction; COSHH awareness for coatings
Isocyanate spray operative	Manufacturer or industry-recognised isocyanate awareness training; competent in the use of air-fed RPE; trained in the specific spray equipment being used; health surveillance enrolled (lung function baseline before first exposure); named in the COSHH assessment
Spray operative (general)	Training in airless spray equipment operation, maintenance, and safety (including injection injury awareness); COSHH awareness for the specific products being sprayed; RPE face-fit tested; trained in containment and overspray control
PASMA tower user	PASMA Towers for Users certificate (valid for 5 years); trained in the specific tower system being used on site; competent to erect, inspect, and dismantle towers within the scope of their training
MEWP operator	IPAF Operator card for the relevant MEWP category (3a scissor, 3b boom, static, mobile as applicable); familiarisation on the specific machine; pre-use inspection trained
Supervisor	SSSTS as minimum; SMSTS preferred; direct trade experience in painting and decorating; competent to review COSHH assessments and verify that operatives are using the correct PPE for the products being applied

CSCS Industry Accreditation (IA) card expired 31 January 2025

The CSCS Industry Accreditation (IA) card expired on 31 January 2025 and is no longer valid. Operatives who previously held an IA card must now obtain the relevant NVQ (Level 2 in Decorative Finishing and Industrial Painting for painters and decorators) and apply for a CSCS Skilled Worker (blue) card. The RAMS should verify that all operatives hold current, valid CSCS cards and that no expired IA cards are being presented as proof of competence.

5. Common Mistakes

No COSHH assessment for each coating product

Every coating product used on site requires a product-specific COSHH assessment. A generic assessment that says "paint" is not sufficient. The COSHH assessment must identify the specific hazardous substances in each product (by reference to the Safety Data Sheet), the exposure route, the workplace exposure limit where applicable, the control measures, and the health surveillance requirements. A site using five different coating products needs five COSHH assessments.

Spraying isocyanate coatings without air-fed RPE

Spraying two-pack polyurethane coatings generates isocyanate aerosol at concentrations that can cause respiratory sensitisation within a single exposure event. A disposable FFP3 mask does not provide adequate protection for isocyanate spray application. Air-fed respiratory protective equipment with a minimum assigned protection factor of 20 is required. The operative must be trained in the use and maintenance of air-fed RPE, and the equipment must be maintained and tested in accordance with the manufacturer instructions.

Lead paint disturbed without a CLAW 2002 assessment

Any surface dating from before 1992 may contain lead paint. Before any preparation work (sanding, scraping, stripping) is carried out on a pre-1992 surface, a CLAW 2002 assessment must be completed. This includes testing the surface for lead content and, where lead is confirmed, implementing the specific controls required by CLAW 2002: wet methods only, no dry sanding or burning off, RPE, containment, decontamination, blood lead monitoring where exposure is significant, and disposal as hazardous waste.

Stepladders used for prolonged painting at height instead of a proper platform

Stepladders are only appropriate for short-duration, low-risk work at height where the task can be completed without overreaching. Painting a full wall or ceiling from a stepladder is not short-duration work. The RAMS should specify podium steps, a mobile tower, or scaffold as the primary access for painting at height, with stepladders reserved only for brief touch-up tasks. Overreaching from a stepladder is one of the most common causes of falls from height in the painting and decorating trade.

No DSEAR assessment where flammable solvent vapours are present

Solvent-based paints, varnishes, thinners, and chemical strippers release flammable organic vapour during application and drying. In enclosed rooms or poorly ventilated spaces, this vapour can accumulate to form an explosive atmosphere. Where there is a foreseeable risk of explosive atmosphere, a DSEAR assessment is required under the Dangerous Substances and Explosive Atmospheres Regulations 2002. The assessment must identify the zones where explosive atmospheres may form, the ignition sources to be controlled, and the ventilation required to keep vapour concentrations below 10% of the lower explosive limit (LEL).

6. Frequently Asked Questions

Does CLAW 2002 apply to every pre-1992 surface being painted?▾

CLAW 2002 applies wherever there is a foreseeable risk of exposure to lead. If the painting work involves preparation of a pre-1992 surface (sanding, scraping, burning off, blasting, or any other method that disturbs the existing coating), the surface must be tested for lead content before work begins. If lead is confirmed above the threshold, the full CLAW 2002 controls apply. If the work is simply overcoating an existing surface in good condition without any disturbance, the risk of lead exposure is low and CLAW 2002 controls may not be required, but the assessment must still be documented.

What health surveillance is required for operatives spraying isocyanate coatings?▾

Operatives with any exposure to isocyanates require health surveillance consisting of a lung function test (spirometry) and a respiratory symptom questionnaire at baseline (before first exposure), then at 6-weekly intervals for the first year, then annually thereafter. If any operative develops symptoms (cough, wheeze, shortness of breath, chest tightness) they must be referred to an occupational health physician immediately. Isocyanate sensitisation is irreversible, so early detection is critical.

Can a disposable FFP3 mask be used for spraying solvent-based paints?▾

A disposable FFP3 mask is a particulate filter and does not protect against organic vapour. Spraying solvent-based paints generates both aerosol (particulate) and organic vapour. The correct RPE for spraying solvent-based paints is a half-face or full-face respirator fitted with a combination filter (A2P3) that provides both organic vapour and particulate protection. For isocyanate-containing products, air-fed RPE is required regardless of the application method.

Is a PASMA certificate required to use a mobile access tower on site?▾

PASMA (Prefabricated Access Suppliers and Manufacturers Association) provides the industry-standard training for the erection, inspection, and use of mobile access towers. While there is no specific legal requirement to hold a PASMA certificate, the Work at Height Regulations 2005 require that any person erecting or dismantling a tower is competent to do so. In practice, a current PASMA Towers for Users certificate is the accepted evidence of competence and is required by most principal contractors as a minimum standard for tower use on site.

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