Painting · United States

JHA for lead paint removal (RRP)

By Safety PaperworkBuilt from OSHA standards and guidance · How we write and check theseUpdated November 9, 2026

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for lead paint removal (RRP) 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 fire from hot works, lead paint dust and fumes, public entering the work area and flammable liquids and gases.

Make this JHA now Word template PDF

JHA example: lead paint removal (RRP)

This is a complete JHA for lead paint removal (RRP), with 10 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)

Lead paint removal · Painting · Example

Document JHA-001 · Rev 1

Job steps, hazards and controls

#	Job step	Hazards	Risk before	Controls	Risk after
1	Test the paint (EPA-recognized test kit or certified inspector) or presume it has lead, and give the occupants the EPA Renovate Right pamphlet before work starts (40 CFR 745.84). Where the RRP rule applies, a Lead-Safe Certified firm with a certified renovator does the work. Keep children and pregnant people away	Lead paint dust and fumes Working in an occupied home or building	High	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 Plan noisy, dusty or risky work for when the building is empty. Elimination Close off the work area with barriers, plastic sheeting or locked doors, and put up signs. Engineering (guarding) Keep fire exits and paths clear at all times. Administrative Tell occupants before you turn off power, water or gas, and before noisy or dusty work. Administrative Lock away tools, chemicals and materials each day, out of reach of children. Administrative Clean up dust and debris at the end of each day. Administrative	Low
2	Turn off heating and cooling and close windows and vents in the work area	Lead paint dust and fumes General dust	High	Lead paint dust and fumes: see step 1 for the full controls Administrative Use low-dust products, such as dust-reduced or pre-mixed compounds. Substitution Seal off the work area with plastic sheeting in occupied buildings. Engineering (guarding) Use tools with dust extraction and a vacuum for clean up. Engineering Lightly mist the area with water to keep dust down, away from anything electrical. Engineering Never dry sweep or blow dust off with compressed air. Administrative Wear a dust mask and safety glasses. PPE	Low
3	Post warning signs and contain the area: indoors, close and cover ducts and cover the floor 6 feet past the work; outdoors, cover the ground 10 feet out and close doors and windows within 20 feet (40 CFR 745.85(a)(1), (2))	Lead paint dust and fumes Public entering the work area	High	Lead paint dust and fumes: see step 1 for the full controls 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 Use a spotter when moving plant or materials across public paths. Administrative	Low
4	Put on coveralls and a fitted respirator, and set up a wash point	Lead paint dust and fumes Hazardous chemicals	High	Lead paint dust and fumes: see step 1 for the full controls Administrative 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 Hazardous chemicals: see step 6 for the full controls Administrative	Medium
5	Mist and wet scrape the paint; no dry sanding or open flame	Lead paint dust and fumes Hazardous chemicals	High	Lead paint dust and fumes: see step 1 for the full controls Administrative 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 Hazardous chemicals: see step 6 for the full controls Administrative	Medium
6	Use chemical strippers with ventilation and chemical gloves	Hazardous chemicals Flammable liquids and gases	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 Have eye wash and a spill kit nearby, and wash hands before eating. Administrative Wear chemical-resistant gloves and safety glasses or goggles as listed on the SDS. PPE Use a respirator with the right cartridge if the SDS calls for one. PPE Use non-flammable or water-based products where you can. Substitution Keep ignition sources away: no smoking, no hot work and no running engines near flammables. Engineering (guarding) Store fuels and solvents in approved, closed containers in a ventilated area away from the work. Engineering Refuel equipment outdoors with the engine off and cool. Administrative Keep only what you need for the day on site. Administrative Store gas cylinders upright, secured and outdoors. Administrative Keep a suitable fire extinguisher where flammables are used or stored. Administrative Wear chemical gloves and safety glasses when pouring or mixing. PPE	Medium
7	Use a heat gun only below 1,100 degrees F, and never an open flame or torch (40 CFR 745.85(a)(3))	Burns from hot surfaces Fire from hot works Lead paint dust and fumes	Critical	Isolate heating systems and let parts cool before you touch them. Elimination Fit guards or insulation on hot pipes and equipment. Engineering Mark hot items with chalk or a "HOT" sign so others know. Administrative Keep a first aid kit and cool running water nearby for burns. Administrative Wear heat-resistant gloves and long sleeves. PPE Use cold work methods where you can, such as bolting, press fittings or cutting with a saw instead of a torch. Elimination Move anything that can burn at least 35 feet away, or cover it with fire blankets. Engineering (guarding) Use fire-resistant screens to stop sparks reaching people or gaps in walls and floors. Engineering Get a hot work permit before starting. Administrative Keep a charged fire extinguisher and fire blanket at the work spot. Administrative Lead paint dust and fumes: see step 1 for the full controls Administrative	Medium
8	Clean with a HEPA vacuum and wet wipes, never dry sweep	Lead paint dust and fumes Poor housekeeping and waste	High	Lead paint dust and fumes: see step 1 for the full controls Administrative 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
9	Bag waste, remove coveralls in the work area and wash before eating	Lead paint dust and fumes	High	Lead paint dust and fumes: see step 1 for the full controls Administrative	Low
10	Do the RRP cleaning verification before removing plastic and letting occupants back in	Lead paint dust and fumes Working in an occupied home or building	High	Lead paint dust and fumes: see step 1 for the full controls Administrative Working in an occupied home or building: see step 1 for the full controls Administrative	Low

PPE

Safety glasses (ANSI Z87.1)Half-face respirator (P100 cartridges)CoverallsChemical-resistant glovesSafety-toe boots (ASTM F2413)Work glovesN95 respiratorHigh-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways)Safety goggles (ANSI Z87.1)Welding glovesFace shield (ANSI Z87.1)

Plant and equipment

Heat gunHEPA vacuumPower sanderHand tools

Permits and plans

Hot work permit (fire watch at least 60 minutes after, NFPA 51B)

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.

Page 1 of the free lead paint removal (RRP) JHA template: business details, job steps with hazards, risk ratings and controls

Free JHA template for lead paint removal (RRP)

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 lead paint removal (RRP)

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

JHA read, explained and signed by everyone on the job
Hot work permit issued, extinguisher at hand, fire watch arranged
Exclusion zone below the work and public kept out
First aid / CPR person, first aid kit and emergency number (911) confirmed
PPE checked and worn: safety glasses (ANSI Z87.1), half-face respirator (P100 cartridges), coveralls, chemical-resistant gloves

The safe sequence of work

Test the paint (EPA-recognized test kit or certified inspector) or presume it has lead, and give the occupants the EPA Renovate Right pamphlet before work starts (40 CFR 745.84). Where the RRP rule applies, a Lead-Safe Certified firm with a certified renovator does the work. Keep children and pregnant people away
Turn off heating and cooling and close windows and vents in the work area
Post warning signs and contain the area: indoors, close and cover ducts and cover the floor 6 feet past the work; outdoors, cover the ground 10 feet out and close doors and windows within 20 feet (40 CFR 745.85(a)(1), (2))
Put on coveralls and a fitted respirator, and set up a wash point
Mist and wet scrape the paint; no dry sanding or open flame
Use chemical strippers with ventilation and chemical gloves
Use a heat gun only below 1,100 degrees F, and never an open flame or torch (40 CFR 745.85(a)(3))
Clean with a HEPA vacuum and wet wipes, never dry sweep
Bag waste, remove coveralls in the work area and wash before eating
Do the RRP cleaning verification before removing plastic and letting occupants back in

Hazards to watch on lead paint removal (RRP)

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

Step 1, 2, 3, 4, 5, 7, 8, 9, 10Lead 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 7Burns from hot surfacesTouching hot pipes, tools, asphalt, solder or freshly welded metal burns the skin.

Step 6Flammable liquids and gasesGasoline, solvents, thinners and propane catch fire or explode when vapor reaches a spark, flame or hot surface.

Step 7Fire from hot worksSparks and heat from welding, grinding or flame torches set fire to timber, insulation, rubbish or fuel nearby.

Step 1, 10Working in an occupied home or buildingResidents, staff or children wander into the work area and get hurt, or the work blocks exits or cuts off power or water while people are inside.

Step 2General dustDust from drywall, joint compound, cement and clean up irritates eyes and lungs and makes it hard to see.

Highest risk on lead paint removal (RRP): Critical before controls (B), down to Medium after controls (A), on the United States 5 by 5 risk matrix (possible and fatality becomes unlikely and recordable / lost time).

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 use a ladder or stepladder?
Will anyone work on a roof?
Is there a skylight, fiberglass panel or other fragile roofing?
Will you use a scaffold or rolling tower?

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 lead paint removal (RRP)?

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for lead paint removal (RRP) 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 lead paint removal (RRP)?

Usually Safety glasses (ANSI Z87.1), Half-face respirator (P100 cartridges), Coveralls, Chemical-resistant gloves, Safety-toe boots (ASTM F2413), Work gloves, N95 respirator, High-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways), Safety goggles (ANSI Z87.1), Welding gloves, Face shield (ANSI Z87.1). The site rules may add more, so check with the general contractor.

More painting JHAs

JHAInterior Painting6 steps JHAExterior House Painting6 steps JHASpray Painting6 steps JHARoof Coating6 steps JHAPressure Washing6 steps JHAEpoxy Floor Coating5 steps

Related jobs in other trades

Welding and fabricationSteel ErectionAlso involves public entering the work area ElectricalElectrical Panel UpgradeAlso involves working in an occupied home or building DrywallDrywall InstallationAlso involves general dust RoofingRoof ReplacementAlso involves public entering the work area Excavation and earthworksTrenching and ExcavationAlso involves public entering the work area ScaffoldingScaffold ErectionAlso involves public entering the work area

Toolbox talks for this job

Toolbox talkWorking at Heights Toolbox talkLead Paint Safety Toolbox talkWorking in Cold Weather Toolbox talkHot Works Safety

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