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Painting · Canada

FLHA for roof painting

Provincial OHS law requires hazards to be assessed and controlled before work starts. A field level hazard assessment (FLHA) for roof 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 falling from a roof edge, disturbing asbestos, falling through a fragile roof or skylight and falling from a ladder.

FLHA example: roof painting

This is a complete FLHA for roof 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)
Roof painting and restoration · Painting · Example
Document FLHA-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
  • Get an asbestos survey before work on buildings built before 1990. 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 your province's asbestos rules, including notification and trained or certified workers where required. Administrative
  • In BC, a qualified person must inspect and write a hazardous materials report before demolition or renovation, and asbestos abatement must be done by a WorkSafeBC licensed contractor (since 1 January 2024). Administrative
  • Stop work straight away if you find suspect asbestos. Do not touch it and tell your supervisor. Administrative
  • Wear a fit-tested respirator suited to the work, 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
  • Use one safe, controlled access point and keep others off the roof. Administrative
  • Use a platform ladder, mobile scaffold or aerial work platform for longer jobs instead of a straight ladder. Substitution
  • Use CSA Grade 1, 1A or 1AA ladders in good condition. Remove any damaged ladder from site. Engineering
  • Set extension ladders at a 4 to 1 angle on firm, level ground, tied or footed, and reaching 1 metre 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 side rails. Do not overreach. Administrative
  • Work from underneath or from an aerial work platform so nobody stands on the fragile roof. Elimination
  • Cover or guard every skylight and fragile sheet with a fixed, marked cover or mesh before work starts. Engineering (guarding)
  • Install safety mesh under new roof sheeting, and use crawl boards or staging to spread the load on fragile surfaces. 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 fibre 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 leads 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 equipment 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 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
  • 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 unauthorised entry". Administrative
  • Make the site safe at the end of each day: cover holes, lower buckets and booms, 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
  • 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 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
Medium

PPE

CSA green triangle safety boots (CSA Z195)Full body harness (fall arrest)Respirator fit tested to CSA Z94.4 (P100 for dust, or the type the air test calls for)Safety gogglesSun protection (sunscreen, hat, long sleeves)Chemical-resistant glovesCoverallsWork glovesHard hat (CSA Z94.1)Face shieldHearing protectionCut-resistant glovesSafety glasses (CSA Z94.3)High-visibility vest (CSA Z96)

Plant and equipment

Pressure washerAirless paint sprayerExtension ladderHand tools

Permits and plans

Roof access permitFall protection plan

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 roof 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 roof painting

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 painting

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 fibre 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 painting: Critical before controls (B), down to Medium after controls (A), on the Canada 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):

  • Could anyone fall 3 metres or more, or fall any distance into machinery, water, a hazardous substance or through an opening?
  • Will anyone work on a roof?
  • Will you use a scaffold or mobile tower?
  • Will you use an aerial work platform (scissor lift or boom lift)?
  • Was the building built before 1990, and will you sand, scrape, cut, heat or strip paint?

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 roof 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 roof painting?

Provincial OHS law requires hazards to be assessed and controlled before work starts. A field level hazard assessment (FLHA) for roof 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 roof painting?

Usually CSA green triangle safety boots (CSA Z195), Full body harness (fall arrest), Respirator fit tested to CSA Z94.4 (P100 for dust, or the type the air test calls for), Safety goggles, Sun protection (sunscreen, hat, long sleeves), Chemical-resistant gloves, Coveralls, Work gloves, Hard hat (CSA Z94.1), Face shield, Hearing protection, Cut-resistant gloves, Safety glasses (CSA Z94.3), High-visibility vest (CSA Z96). The site rules may add more, so check with the general contractor.

More painting FLHAs

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Toolbox talks for this job

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

Sources