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Painting · United States

JHA for exterior house 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 exterior house 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 falling from height, aerial lift tip-over or crush, scaffold collapse or fall from scaffold and disturbing asbestos.

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JHA example: exterior house painting

This is a complete JHA for exterior house 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)
Exterior house painting · Painting · Example
Document JHA-001 · Rev 1

Job steps, hazards and controls

#Job stepHazardsRisk beforeControlsRisk after
1Check for power lines and set up barricades under the work
  • Contact with overhead power lines
  • Public entering the work area
  • Falling tools and materials
High
  • Ask the utility to de-energize, move or insulate the lines before work starts. Elimination
  • Use non-conductive (fiberglass) ladders near any power lines. Substitution
  • Mark the safe distance with flags, tape or warning lines and keep all equipment and people outside it. Engineering (guarding)
  • Keep equipment at least 10 feet from lines up to 50 kV once the utility confirms the voltage, more for higher voltages, and 20 feet when the voltage is unknown (29 CFR 1926.1408). Administrative
  • Use a dedicated spotter whenever equipment moves or raises anything near lines. Administrative
  • Treat all lines as energized. If equipment touches a line, the operator stays in the cab and everyone else keeps well away. 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
  • Barricade and sign the drop zone under overhead work so nobody walks beneath. Engineering (guarding)
  • Fit toe boards, kick plates and mesh screens on scaffolds and edges. Engineering
  • Use catch fans, debris netting or covered walkways where people pass below. Engineering
  • Tether hand tools when working at height. Engineering
  • Keep platforms tidy. Do not stack materials near edges or above toe board height. Administrative
Medium
2Set up scaffold, aerial lift or secured ladders on firm ground
  • Falling from height
  • Falling from a ladder
  • Aerial lift tip-over or crush
  • Scaffold collapse or fall from scaffold
Critical
  • Do the work from the ground where you can, for example pre-assemble on the ground or use extension poles. Elimination
  • Install guardrails or edge protection on all open edges before work starts. Engineering (guarding)
  • Use a scaffold, mobile work platform or aerial lift instead of working off a ladder. Engineering
  • Where edge protection is not practical, use a fall restraint or fall arrest system on a rated anchor point. Engineering
  • Provide fall protection at 6 feet or more and train workers to recognize fall hazards (29 CFR 1926.503). 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
  • Check the ground before setting up. Use outriggers and spreader pads, and keep clear of trenches, pits and slopes. Engineering
  • Use a platform with tilt alarm and secondary guarding (anti-entrapment) where there is an overhead crush risk. Engineering
  • Only trained and authorized operators use aerial lifts and scissor lifts (29 CFR 1926.453 for boom lifts, 1926.452(w) and 1926.454 for scissor lifts). Administrative
  • Do a pre-start check each day. Keep a trained person on the ground who can lower the platform in an emergency. Administrative
  • Never exceed the safe working load, climb on the rails or use a ladder in the basket. Administrative
  • Scaffold is built, moved and taken down under the supervision of a competent person. Engineering
  • Fit guardrails, mid rails and toe boards on every platform more than 10 feet above a lower level, or use personal fall arrest (29 CFR 1926.451(g)(1)). Engineering
  • Use mobile scaffolds only on firm, level ground with casters locked, and guy, tie, brace or fit outriggers once the height is more than 4 times the base width (29 CFR 1926.451(c)(1)). Never move one with anyone on it. Engineering
  • Every worker on the scaffold is trained by a qualified person (29 CFR 1926.454). Administrative
  • A competent person inspects the scaffold before each shift and after anything that could affect it (29 CFR 1926.451(f)(3)). Administrative
Medium
3Test for lead paint and asbestos sheeting before any prep
  • Lead paint dust and fumes
  • Disturbing asbestos
Critical
  • 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
  • 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
4Wash down and scrape, keeping water away from power
  • High pressure water jetting
  • Electric shock from cords and power tools
  • Slips and trips
High
  • 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
  • Use battery-powered tools where you can. Substitution
  • Use GFCIs on all 120-volt, 15, 20 and 30 amp temporary receptacles, or a written assured equipment grounding conductor program run by a competent person with recorded tests (29 CFR 1926.404(b)(1)). Engineering
  • Keep cords off the ground and out of water, using stands or hooks. Engineering
  • Check cords, plugs and tools before every use. Tag out and remove anything damaged. Administrative
  • Do not use tools in rain or wet areas unless they are rated for it. 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
Low
5Paint or spray, watching wind drift
  • Hazardous chemicals
  • Strong wind and storms
  • Sun exposure (UV)
  • Heat stress
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
  • 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
  • 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
  • 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
  • In California, Washington, Oregon and Maryland, follow the state heat illness rule: written plan, shade, water, rest and high-heat procedures. Administrative
Medium
6Clean up, dispose of waste paint properly and remove access
  • Poor housekeeping and waste
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
Low

PPE

Safety-toe boots (ASTM F2413)Safety glasses (ANSI Z87.1)N95 respiratorChemical-resistant glovesSun protection (sunscreen, hat, long sleeves)Personal fall arrest system (harness)High-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways)Hard hat (ANSI Z89.1)Half-face respirator (P100 cartridges)CoverallsWork glovesFace shield (ANSI Z87.1)Hearing protection (earmuffs or plugs)Safety goggles (ANSI Z87.1)

Plant and equipment

Extension ladderMobile (rolling) scaffold: Erected under a competent person (29 CFR 1926.451)Boom lift (aerial lift): Trained and authorized operator (29 CFR 1926.453, ANSI A92.24 training and familiarization)Pressure washerAirless paint sprayer

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 exterior house 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 exterior house 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 power lines and set up barricades under the work
  2. Set up scaffold, aerial lift or secured ladders on firm ground
  3. Test for lead paint and asbestos sheeting before any prep
  4. Wash down and scrape, keeping water away from power
  5. Paint or spray, watching wind drift
  6. Clean up, dispose of waste paint properly and remove access

Hazards to watch on exterior house painting

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

Step 4High pressure water jettingHigh pressure water cuts through skin and injects water and dirt into the body, or the hose whips.
Step 2Aerial lift tip-over or crushThe platform tips on soft or sloping ground, the worker is crushed against a beam or ceiling, or is thrown out of the basket.
Step 3Lead 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 2Scaffold collapse or fall from scaffoldA scaffold that is badly built, overloaded or altered collapses or tips, or a worker falls from an unguarded platform.
Step 5Sun exposure (UV)Long hours in the sun cause sunburn, eye damage and skin cancer.
Step 1Contact with overhead power linesA ladder, aerial lift, crane, dump truck or long length of material touches or gets close to an overhead line and electrocutes people.
Almost certainLikelyPossibleUnlikelyRareHow bad it could be: First aid only to FatalityBA
Highest risk on exterior house painting: 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 on a roof?
  • Is there a skylight, fiberglass panel or other fragile roofing?
  • Will you cut, grind or drill concrete, brick, stone, tile or fiber cement?
  • Will you use chemicals, solvents, glues, paints or fuels?
  • Will people be living or working in the building while you work?

Licences and legal requirements in United States

Equipment on this job that needs a licence, ticket or training:

  • Mobile (rolling) scaffold: Erected under a competent person (29 CFR 1926.451)
  • Boom lift (aerial lift): Trained and authorized operator (29 CFR 1926.453, ANSI A92.24 training and familiarization)

OSHA requires employers to find and fix hazards and to train workers on them. A JHA breaks the job into steps, lists the hazards in each step and the controls that protect the crew. General contractors often require one before you start.

Rules that apply: 29 CFR 1926.1408 and 1926.416; 29 CFR 1926.501(c); 29 CFR 1926 Subpart M; 29 CFR 1926 Subpart X; 29 CFR 1926.453 (boom lifts); 1926.452(w) and 1926.454 (scissor lifts); 29 CFR 1926 Subpart L; 40 CFR Part 745 (RRP rule) and 29 CFR 1926.62; 29 CFR 1926.1101 and 40 CFR 61 Subpart M (NESHAP); 29 CFR 1926 Subpart K; 29 CFR 1926.59 Hazard Communication; OSH Act Section 5(a)(1) General Duty Clause; state heat rules where they apply (Cal/OSHA T8 3395, WA WAC 296-62-095, OR OAR 437-002-0156, MD COMAR 09.12.32).

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 exterior house painting?

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

Usually Safety-toe boots (ASTM F2413), Safety glasses (ANSI Z87.1), N95 respirator, Chemical-resistant gloves, Sun protection (sunscreen, hat, long sleeves), Personal fall arrest system (harness), High-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways), Hard hat (ANSI Z89.1), Half-face respirator (P100 cartridges), Coveralls, Work gloves, Face shield (ANSI Z87.1), Hearing protection (earmuffs or plugs), 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 stepsJHAInterior Painting6 stepsJHASpray Painting6 stepsJHARoof Coating6 stepsJHAPressure Washing6 stepsJHAEpoxy Floor Coating5 steps

Related jobs in other trades

RoofingRoof ReplacementAlso involves disturbing asbestosScaffoldingScaffold ErectionAlso involves contact with overhead power linesWelding and fabricationSteel ErectionAlso involves contact with overhead power linesConcretingConcrete Slab PourAlso involves contact with overhead power linesLandscapingTree RemovalAlso involves contact with overhead power linesDrywallDrywall InstallationAlso involves falling tools and materials

Toolbox talks for this job

Toolbox talkLadder SafetyToolbox talkScaffold SafetyToolbox talkOverhead Power LinesToolbox talkExtension Leads and Power Tools

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

Sources