Safety Statement for a Painting and Decorating Contractor: Key Hazards and Controls
Painting and decorating involves real hazards including working at height, isocyanate-based coatings, lead paint in older buildings, and confined spaces.
# Safety Statement for a Painting and Decorating Contractor: Key Hazards and Controls Painting and decorating may appear to be one of the lower-risk trades in construction, but the reality is more complex. Painters and decorators work at height, handle hazardous substances, work in confined spaces, and are exposed to a range of health hazards that can cause serious long-term illness. A Safety Statement that does not address these specific hazards is not suitable and sufficient under Irish law. This guide explains what a Safety Statement for a painting and decorating contractor must include, the key hazards that must be addressed, and the controls that should be in place. ## The Legal Requirement The Safety, Health and Welfare at Work Act 2005 requires every employer with three or more employees to prepare a written Safety Statement based on a risk assessment of the hazards in the workplace. Sole traders and self-employed persons also have duties under the Act, and while they are not required to have a written Safety Statement, they are required to carry out risk assessments and implement appropriate controls. For a painting and decorating contractor, the Safety Statement must address the specific hazards of the trade. A document that simply lists generic construction hazards without addressing the specific risks of painting and decorating work is unlikely to meet the legal standard. ## Key Hazards for Painting and Decorating Contractors ### Working at Height Working at height is the most significant safety hazard for painters and decorators. The trade involves extensive work on ladders, stepladders, mobile scaffold towers, and mobile elevated work platforms (MEWPs). Falls from height are a leading cause of fatalities and serious injuries among painters and decorators. The Safety Statement must address the risk of falls from height and the controls in place. The hierarchy of controls required by the Work at Height Regulations must be followed: collective fall prevention measures (guardrails, working platforms) are preferred over personal fall arrest equipment (harnesses). Ladders should only be used for work of short duration (no more than 30 minutes) or where the nature of the work makes other access equipment impracticable. The Safety Statement should set out the circumstances in which ladders may be used and the requirements for their safe use (three points of contact, correct angle, secured at the top). ### Hazardous Substances Painters and decorators work with a wide range of hazardous substances, including: **Solvent-based paints and coatings.** Many solvent-based products contain volatile organic compounds (VOCs) that can cause headaches, dizziness, and nausea at high concentrations, and long-term neurological damage with repeated exposure. They are also flammable. **Isocyanate-based coatings.** Two-pack polyurethane coatings and some specialist coatings contain isocyanates, which are a leading cause of occupational asthma. Once sensitised, a worker can suffer severe asthmatic reactions to even very low concentrations of isocyanates. The Safety Statement must address the risk from isocyanate-based products and specify the controls, including respiratory protective equipment and health surveillance. **Lead paint.** In older buildings, existing paint may contain lead. Sanding or burning off lead paint generates lead dust and fumes, which are highly toxic. Before working on older buildings, the contractor must assess whether lead paint is present and implement appropriate controls if it is. **Biocidal products.** Some paints and coatings contain biocides to prevent mould growth. These products may be hazardous to health and must be assessed under the Chemical Agents Regulations 2001. The Safety Statement must include assessments of all hazardous substances used by the contractor, specifying the hazards, the exposure limits, and the controls in place. ### Confined Spaces Painters and decorators sometimes work in confined spaces, including roof voids, crawl spaces, and enclosed tanks or vessels. Solvent vapours can accumulate in confined spaces to dangerous concentrations, creating both a health hazard and a fire and explosion risk. The Safety Statement must address the risk of working in confined spaces and specify the controls, including atmospheric testing, ventilation, permit to work systems, and rescue arrangements. ### Manual Handling Painters and decorators handle heavy and awkward items, including paint tins, scaffolding components, and access equipment. The Safety Statement must address the risk of manual handling injuries and the controls in place. ### Skin and Eye Contact Many painting products can cause skin sensitisation and dermatitis with repeated contact. The Safety Statement must address the risk of skin and eye contact with hazardous substances and specify the controls, including the provision and use of appropriate gloves and eye protection. ### Noise Some surface preparation activities, including needle gunning and angle grinding, generate significant noise levels. The Safety Statement must address the risk of noise-induced hearing loss for workers carrying out these activities. ## What the Safety Statement Must Include A Safety Statement for a painting and decorating contractor should include: **Company details and scope.** The name of the company, the types of work carried out, and the geographic area of operation. **Management structure and responsibilities.** Who is responsible for health and safety at each level of the organisation. **Risk assessments.** Written risk assessments for each significant hazard, including working at height, hazardous substances, confined spaces, manual handling, and skin and eye contact. **Safe systems of work.** Written safe systems of work for high-risk activities, including work with isocyanate-based products, work in confined spaces, and work on surfaces that may contain lead paint. **Training and competency.** The training required for different roles, including working at height training, COSHH awareness, and confined space entry training. **Health surveillance.** The health surveillance arrangements for workers exposed to isocyanates or other substances that require surveillance. **Emergency procedures.** What to do in the event of a spill, a fire, or a worker becoming unwell due to solvent exposure. **Review arrangements.** When and how the Safety Statement will be reviewed and updated. ## Conclusion A Safety Statement for a painting and decorating contractor must be specific to the hazards of the trade. Working at height, hazardous substances, and confined spaces are the key risk areas, and the Safety Statement must address each of them in a way that reflects the actual work carried out by the company. ## References [1] Safety, Health and Welfare at Work Act 2005, Section 20. Available at: https://www.irishstatutebook.ie/eli/2005/act/10/enacted/en/html [2] Safety, Health and Welfare at Work (General Application) Regulations 2007, Part 4. Available at: https://www.irishstatutebook.ie/eli/2007/si/299/made/en/print [3] Health and Safety Authority - Chemical Agents. Available at: https://www.hsa.ie/eng/your_industry/chemicals/chemical_agents/ [4] Health and Safety Authority - Working at Height. Available at: https://www.hsa.ie/eng/your_industry/construction/safety_topics/falls_from_height/