Painting and coatings JHA: job hazard analysis example and generator

A painting JHA starts with the products, their hazards, and their safety data sheets (SDS). It then covers surface prep (including lead), pressure washing, spraying and rolling, and work from ladders, scaffolds, and lifts. It ends with cleaning up solvents and rags. References include 1926.59 (hazard communication), 1926.62 (lead), 1926.152 (flammable liquids), and Subpart L (scaffolds).

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Draft only. Every JHA is a draft and must be reviewed by a competent person for the specific site before work begins. JHABox is not affiliated with OSHA or the US Department of Labor.

General contractors (GCs) list painting and epoxy work among the tasks that need a written JSA (job safety analysis). Painting firms tend to be small. The 2022 Census counts 37,963 employer establishments.

Common painting hazards

Lead dust when sanding or scraping pre-1978 paint
Solvent vapors and overspray
Fire from flammable liquids and oily rags
Falls from ladders, scaffolds and lifts
Injection injuries from pressure washers

Sample painting hazard table

Sample from the JHABox painting library. Example task: “Exterior repaint, two-story house built 1972, pressure wash and spray” at a Florida address. Showing 5 of 9 steps.

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Swipe sideways to see the full table.

#	Job step	Potential hazards	Risk before controls	Controls	Risk after controls	29 CFR reference
1	Review products, SDS and labels	Unknown chemical hazards in coatings and solvents Mixing incompatible products	MMedium	Keep SDS on site; brief crew on each product's hazards and PPE Keep containers labeled; never decant into unlabeled containers	LLow	1926.59
2	Surface prep: scraping, sanding and lead	Lead dust from pre-1978 paint Eye injury from chips and dust	HHigh	Determine lead exposure before disturbing old paint; use wet methods and HEPA vacuums Safety glasses; respirator where assessment requires No eating or smoking in the work area; wash before breaks	MMedium	1926.62(d)(1)(i) 1926.102(a)(1)
3	Pressure washing	Injection injuries from high-pressure spray Slips on wet surfaces Water near outlets and fixtures	MMedium	Never point the wand at people; trigger lock on when not spraying Face shield and safety glasses GFCI on electric washers; cover outlets	LLow	1926.102(a)(1) 1926.404(b)(1)(i)
4	Spraying and rolling coatings	Inhaling solvent vapors and overspray Fire from flammable vapors Skin contact with coatings	HHigh	Ventilate enclosed areas; respirator per SDS Flammables in approved containers; no ignition sources; no-smoking signs Chemical gloves and coveralls	MMedium	1926.152(a)(1) 1926.152(g)(9) 1926.95(a)
5	Ladder access and use	Fall from ladder Ladder slides out or tips Electrical contact (metal ladder near energized parts) Losing balance while carrying materials	HHigh	Competent person inspects ladders; tag and remove defective ladders Extend side rails 3 ft above landing; secure top; set at 4:1 angle Set on stable, level base Use non-conductive (fiberglass) ladders near electrical work Face the ladder, keep one hand on it; hoist materials instead of carrying	MMedium	1926.1053(b)(1) 1926.1053(b)(5)(i) 1926.1053(b)(6) 1926.1053(b)(12) 1926.1053(b)(15) 1926.1053(b)(20)-(22) 1926.1060(a)

Risk = Severity × Likelihood on a 3×3 matrix (1–2 Low, 3–4 Medium, 6–9 High). Citations link to the Electronic Code of Federal Regulations (eCFR).

Relevant 29 CFR 1926 subparts

DSubpart D: Occupational Health and Environmental Controls1926.50–1926.66 FSubpart F: Fire Protection and Prevention1926.150–1926.155 LSubpart L: Scaffolds (including aerial lifts)1926.450–1926.454 XSubpart X: Stairways and Ladders1926.1050–1926.1060 ESubpart E: Personal Protective and Life Saving Equipment1926.95–1926.107

Key paragraphs we cite

1926.59Hazard communication (identical to 1910.1200): SDS and labels
1926.62(d)(1)(i)Determine whether employees may be exposed to lead at or above the action level
1926.152(a)(1)Approved containers for flammable liquids
1926.451(g)(1)Fall protection on scaffolds more than 10 ft up

Checked against the eCFR (Title 29, as amended through October 14, 2026). Confirm the current text, and any state plan rules that apply to your site.

Florida job sites

Florida: exterior heat and pressure washing

Exterior repaints in Florida mean long days in direct sun and a lot of pressure washing for mildew. JHABox painting drafts add the heat step for Florida addresses and treat a ground-fault circuit interrupter (GFCI) on electric washers as a standard control.

Painting JHA FAQ

Does OSHA require a written painting JHA?

Federal OSHA has no construction standard that requires a document called a “JHA” (job hazard analysis). You still have to meet the specific 29 CFR 1926 standards for the work and run the accident-prevention program in 1926.20(b). General contractors (GCs), owners, and the US Army Corps of Engineers (USACE) often require one. USACE calls it an Activity Hazard Analysis.

Do I need to test for lead before sanding?

Under 1926.62(d)(1)(i), an employer covered by the lead standard must initially determine whether any employee may be exposed at or above the action level. For older buildings, plan the assessment before anyone disturbs the paint.

Can I hand this straight to my general contractor?

Not without review. Every JHABox document is a draft. A competent person (someone who can identify the hazards and is authorized to correct them) has to check it for that site, adjust it to real conditions, and sign it before work starts. JHABox is not affiliated with OSHA.

Is the Spanish version included?

Yes. Pick Spanish on the build form and the whole document comes out in Spanish, including the hazard table, personal protective equipment (PPE) list, and crew sign-off sheet. A paid document includes both languages.

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