Work Health and Safety (Spray Painting and Powder Coating) Code of Practice 2015

The Work Health and Safety (Spray Painting and Powder Coating) Code of Practice 2015 is an approved code of practice under section 274 of the Work Health and Safety Act 2011. The foreword describes an approved code as a practical guide to achieving the standards of health, safety and welfare required under the WHS Act and the Work Health and Safety Regulations.

That matters because this is not just background guidance. The foreword says that, in most cases, following an approved code of practice would achieve compliance with the health and safety duties in the WHS Act for the subject matter of the code. It also says codes of practice are admissible in court proceedings, courts may regard a code as evidence of what is known about a hazard, risk or control, and inspectors may refer to a code when issuing improvement or prohibition notices.

The same foreword also sets out the limits. Codes deal with particular issues and do not cover all hazards or risks that may arise. Duty holders still need to consider all risks associated with work, not only those specifically covered by regulations and codes. The foreword also says compliance may be achieved by another method, such as a technical or industry standard, if it provides an equivalent or higher standard of work health and safety than the code.

The scope and application section says the Code provides practical guidance for persons conducting a business or undertaking on how to manage health and safety risks associated with spray painting or powder coating processes. It applies to all workplaces covered by the WHS Act where spray painting or powder coating activities are carried out and to all persons involved in those activities.

A PCBU is a person conducting a business or undertaking. In practical terms, that usually means the business operator responsible for the work. The Code also identifies other duty holders, including designers, manufacturers, importers and suppliers of plant or substances used in these activities, officers such as company directors, and workers.

The introduction explains that spray painting includes conventional air compressor spraying, airless spray painting and electrostatic spray painting. Powder coating is described as a process by which electrostatically charged powder is applied onto an earthed object. The examples given in the Code show how broad the coverage is. Commonly spray painted items include motor vehicles, buildings, furniture, white goods, boats, ships, aircraft and machinery.

The practical trigger is the activity itself. If your business carries out spray painting or powder coating, or has those activities carried out at your workplace, this Code is relevant. The official text makes clear that the risk is not limited to the moment paint leaves the spray gun or powder is applied. Exposure to hazardous chemicals is described as a significant risk in spray painting and powder coating activities including during preparation, storage, clean-up and disposal.

The Code becomes especially important where work creates airborne mists, vapours, dusts or fumes, where flammable liquids or combustible dusts are present, where electrostatic equipment is used, where work is done in enclosed or confined areas, or where workers are sanding old coatings or polyurethane paints that are not fully cured.

The table of contents also shows the Code deals with spray booths, ventilation systems, spray painting outside a spray booth, maintenance, information and training, PPE, powder coating controls, electrical safety, fire and explosion, manual tasks, confined spaces, heat, noise and injection injury. Businesses should read it as a whole-of-process document, not just a chemical handling note.

The Code says a PCBU has the primary duty to ensure, so far as is reasonably practicable, that workers and other persons are not exposed to health and safety risks arising from the business or undertaking. It specifically states that a PCBU involved in spray painting or powder coating must eliminate risks associated with this work, or if that is not reasonably practicable, minimise the risks so far as is reasonably practicable.

The Code also says the WHS Regulations include more specific requirements to manage the risks of hazardous chemicals, airborne contaminants and plant, as well as other hazards associated with spray painting or powder coating activities such as noise and manual handling.

Designers, manufacturers, importers and suppliers of plant or substances used in these activities must ensure, so far as is reasonably practicable, that the plant or substance is without risks to health and safety. The Code says this duty includes carrying out testing and analysis and providing specific information about the plant or substance.

Officers, such as company directors, have a due diligence duty to ensure the business or undertaking complies with the WHS Act and Regulations. The Code says this includes taking reasonable steps to ensure the business has and uses appropriate resources and processes to eliminate or minimise risks that arise from spray painting or powder coating. Workers must take reasonable care for their own health and safety, must not adversely affect others, must comply with reasonable instructions and must cooperate with reasonable workplace health and safety policies and procedures. If PPE is provided, workers must use it in accordance with the information, instruction and training provided.

The Code sets out the standard WHS risk management process. To manage risk, a duty holder must identify reasonably foreseeable hazards that could give rise to the risk, eliminate the risk so far as is reasonably practicable, and if elimination is not reasonably practicable, minimise the risk so far as is reasonably practicable by implementing control measures in accordance with the hierarchy of risk control. The Code also says control measures must be maintained so they remain effective, and reviewed and revised if necessary.

The Code explains that this should be done through a systematic process involving identifying hazards, assessing risks if necessary, implementing control measures, and reviewing control measures. It also points readers to the general Code of Practice on how to manage work health and safety risks.

For a business owner, this means you should not treat spray painting or powder coating as a single task. Map the whole job from delivery and storage of chemicals through to preparation, mixing, spraying, curing, sanding, cleaning equipment and waste disposal. Then identify where workers may inhale contaminants, have skin or eye contact, be exposed to ignition sources, interact with plant, work at height, or perform repetitive or awkward manual tasks.

The Code says consultation involves sharing information, giving workers a reasonable opportunity to express views and taking those views into account before making decisions on health and safety matters. A PCBU must consult, so far as is reasonably practicable, with workers who carry out work for them who are or are likely to be directly affected by a work health and safety matter. If workers are represented by a health and safety representative, the consultation must involve that representative.

The Code is clear that consultation with workers and their health and safety representatives is required at each step of the risk management process. That is especially important in spray painting and powder coating because workers often know where overspray drifts, where odours build up, when ventilation is not working properly, or when PPE is impractical for the task.

The Code also says a PCBU must consult, co-operate and co-ordinate activities with all other persons who have a work health or safety duty in relation to the same matter, so far as is reasonably practicable. The example given is where a contractor is engaged to carry out spray painting at your workplace. In that situation, the parties should work together to plan the work, discuss safety issues and decide how the risks will be controlled.

The Code says the first step is to identify all hazards that have the potential to cause harm. It gives practical ways to do that, including conducting a walk-through assessment, observing the work and talking to workers, inspecting materials and equipment, reading product labels, safety data sheets and manufacturer instruction manuals, talking to manufacturers, suppliers, industry associations and health and safety specialists, and reviewing incident reports.

The Code lists common hazards associated with spray painting and powder coating. These include hazardous chemicals, fire and explosion, confined spaces, machinery and equipment, working at height, manual tasks, electricity or static electricity, heat or high humidity, and noise. The potential harm ranges from dermatitis, respiratory illness and cancers through to burns, electric shock, hearing damage, fractures, permanent injury and death.

These examples show why a workshop should not focus only on chemical toxicity. A spray painting or powder coating job can involve overlapping hazards at the same time, such as flammable vapours, static electricity, awkward postures, compressed air equipment and loud plant operating in a poorly ventilated area.

The Code explains that hazards can cause different types and severities of harm, from minor discomfort to serious injury or death. It gives the example that exposure to spray painting or powder coating chemicals can range from headaches to major illness such as asthma. It also notes that spray painting vapours and mists, and powder paints used in powder coating, can spread rapidly, particularly in an enclosed space, and create a potentially explosive atmosphere.

If aerosol mist, vapour or powder paint is ignited, for example by static electricity, a lit cigarette or a spark, the Code says it could result in an explosion that could destroy the building and kill or injure anyone nearby. That is why the assessment is not just about whether a product is toxic. It is also about how likely ignition is, how quickly contaminants can spread, and what other people or processes are nearby.

The Code says a risk assessment is not mandatory for spray painting or powder coating in every case, but it is required for some specific situations, for example when working with asbestos. It also says that in many circumstances a risk assessment will help determine what control measures should be implemented, identify which workers are at risk, determine what sources and processes are causing the risk, and check the effectiveness of existing controls.

The questions suggested by the Code are practical ones. How often and for how long will exposure occur? If exposure happens, how severe could the outcome be? How do workers interact with the hazard, such as by inhalation or skin contact? Is there evidence of contamination, such as visible dust or fumes, chemical odours, spills or splashes? What are the conditions under which spray painting is carried out, such as a confined space? What are the skills, competence and experience of the operator?

The Code says exposure to hazardous chemicals is a significant risk in spray painting and powder coating activities, including during preparation, storage, clean-up and disposal. It lists paints, solvents, powders, lacquers, paint strippers, adhesives, surface preparation products, rust converters and rust removers as examples of chemicals workers may be exposed to.

In most cases, the product label and SDS will identify hazardous chemicals. The Code also says you should identify any dusts or fumes generated by sanding and surface preparation. One example given is sanding polyurethane paints that are not fully cured, which can generate dust containing unreacted isocyanates and lead to long term respiratory problems.

The Code explains that labels help ensure the contents of a container can be readily identified and communicate hazards and precautions through signal words, hazard pictograms and precautionary statements. It says you should always read the label and the SDS before using a hazardous chemical. An SDS includes information on health effects, physicochemical properties, safe handling and storage, emergency procedures, disposal considerations, and how hazardous chemicals can enter the body.

If you do not have an SDS for a hazardous chemical supplied to your workplace, the Code says you must obtain one from the manufacturer, importer or supplier. It also recommends obtaining a current SDS before deciding to purchase a new chemical so hazards can be identified before the chemical is introduced into the workplace.

The Code says a PCBU must ensure that no person at the workplace is exposed to a substance or mixture in an airborne concentration that exceeds the exposure standard for that substance or mixture. It explains that exposure standards represent airborne concentrations that must not be exceeded and refers readers to the Workplace Exposure Standards for Airborne Contaminants and the Hazardous Substances Information System on the Safe Work Australia website. It also notes that although exposure standards may be listed in section 8 of an SDS, you should check the official exposure standards source to be certain.

The Code states that monitoring of workplace contaminant levels for chemicals with exposure standards may need to be carried out to comply with the WHS Regulations. That is a practical warning for businesses using products that create mists, vapours or dusts in enclosed or poorly ventilated areas.

The Code treats isocyanates as a major issue. It says isocyanates are commonly found in 2-pack liquid spray paints, varnishes, adhesives and polyurethane plastics, and may also be present in certain paint polymers. Exposure can occur when aerosols, mists or powder paints containing isocyanates are released during spraying or powder coating, during sanding of polyurethane paint that is not fully cured, and when isocyanate-containing materials are heated. The Code says exposure to isocyanates should be considered high risk and that SDS and labels should be checked to determine whether products contain isocyanates.

The Code also discusses lead. Workers carrying out surface preparation, such as preparing old vehicles for spray painting, could be exposed to lead when removing and sanding lead-based paints. It notes that lead-containing paint can no longer be purchased in Australia, but older painted surfaces may still present a risk. The Code says the WHS Regulations contain specific requirements for working with lead, including identifying lead risk work and removing a worker from lead risk work in certain circumstances.

The Code says the WHS Regulations prohibit and restrict the use of some hazardous chemicals. It specifically states that the following chemicals must not be used, handled or stored for spray painting: arsenic, arsenic compounds, benzene if the substance contains more than 1 per cent by volume, carbon disulphide, lead carbonate, methanol if the substance contains more than 1 per cent by volume, tetrachloroethane, tetrachloromethane, and tributyl tin.

For businesses, this means chemical purchasing and stock control are part of WHS compliance. It is not enough to focus only on how products are used. You should also know what products are being bought, what old stock remains on site, and whether any inherited or decanted containers are properly identified.

The Code says that where hazardous chemicals are decanted into another container and the chemical will not be used immediately, or it is supplied to someone else for later use, the container should be labelled in accordance with the workplace hazardous chemicals labelling code. If the decanted hazardous chemical will be used immediately, labelling of its container is not required.

The Code also says you must maintain a register of the hazardous chemicals used, handled or stored at the workplace. The register must list all hazardous chemicals at the workplace and their current SDS, and it must be readily accessible to anyone likely to be affected by a chemical and to workers involved in using, handling or storing a chemical in the register.

The table of contents shows the Code gives detailed guidance on controlling the risks of spray painting and powder coating. For spray painting, it covers spray painting in spray booths, ventilation systems, spray painting outside a spray booth, maintenance, information, training, instruction and supervision, and personal protective equipment. For powder coating, it covers hazardous chemicals, controlling exposure and electrical safety. It also includes a separate chapter on other hazards and control measures, including fire and explosion, electrical risks, manual tasks, confined spaces, heat, noise and injection injury.

Even without reproducing every technical detail here, the structure of the Code makes the practical expectation clear. Businesses should not rely on PPE alone. They should consider the work area, the equipment used, the ventilation arrangements, ignition sources, maintenance, worker capability and supervision, and the specific hazards created by the chemicals and processes involved.

The Code also includes a sample risk assessment sheet and an appendix on spray painting exclusion zones and ventilation conditions. Those appendices are useful prompts for businesses reviewing their own procedures, especially where work is done outside a fixed spray booth or in areas where other workers may be present.

A practical way to use this Code is to test your current system against the main trigger points it identifies. Start with the chemicals. Do you know exactly what products are used, whether any are high risk, whether any contain isocyanates, and whether current SDS are available? Then look at the process. Where are chemicals mixed, sprayed, cured, sanded, cleaned up and disposed of? Where could airborne contaminants build up? Where are ignition sources, electrical risks or static electricity present?

Next, look at people and coordination. Have workers been consulted at each step of the risk management process? If contractors are involved, have the parties planned the work together and agreed how risks will be controlled? Are workers given the information, training, instruction and supervision needed for the actual tasks they perform?

Finally, check your records and review points. Is the hazardous chemical register current and accessible? Are labels in place on decanted containers where required? Are controls maintained and reviewed when chemicals, equipment, work areas or methods change? The Code is designed to be used in this practical way, as a benchmark for what reasonably practicable control of spray painting and powder coating risks should look like.