Code of Practice — Spray Painting and Powder Coating

The full title is the Code of Practice: Spray Painting and Powder Coating, published by Safe Work Australia. The code becomes legally binding from 1 July 2026 under Section 26A of the WHS Act. The code applies to all spray painting, powder coating, and related surface coating operations performed in any industry. It covers spray booth design and construction including airflow requirements, filter specifications, and explosion protection, ventilation system performance standards, respiratory protective equipment selection and management, health surveillance requirements for workers exposed to isocyanates and other sensitising agents, storage and handling of paints, solvents, and coating materials, waste management for paint waste and contaminated materials, and training requirements for spray painters.

The code applies to every PCBU who performs or manages spray painting and powder coating operations. Automotive spray painting businesses are the primary audience, including panel and paint shops, fleet maintenance workshops, and custom coating operations. Industrial spray painting operations in manufacturing, construction, and infrastructure maintenance are covered. Powder coating operations using thermoset and thermoplastic powders must comply. Marine coating businesses applying antifouling and protective coatings are captured. Furniture and joinery finishing operations using lacquers, stains, and clear coats must follow the code. The code also applies to mobile spray painting operations performed on construction sites and at client premises, where temporary enclosures and portable ventilation may be required. PCBUs who engage spray painting contractors retain upstream duties to ensure the contractor's operations comply with the code.

The code requires spray painting to be performed in a purpose-designed spray booth that provides adequate airflow to capture overspray and vapour before it reaches the worker's breathing zone. Downdraft booths are preferred for vehicle painting because airflow moves paint overspray away from the painter's face and body. The minimum face velocity for spray booths is specified in the code and must be verified through regular airflow testing. Intake and exhaust filters must be maintained and replaced at frequencies that ensure consistent airflow performance. Personal respiratory protection must be selected based on the coating system — supplied-air respiratory protection is required for all isocyanate-containing two-pack coatings, while air-purifying respirators with combination cartridges may be suitable for single-pack coatings. Health surveillance must be provided for all workers exposed to isocyanates and other respiratory sensitisers, including baseline and periodic lung function testing, respiratory symptom questionnaires, and serial peak flow monitoring. Paint and solvent storage must comply with the Australian Dangerous Goods Code requirements for flammable liquids.

First, commission an airflow survey of all spray booths by a competent ventilation engineer, verifying that face velocities meet the code's requirements and that airflow patterns effectively capture overspray and vapour away from the painter's breathing zone. Second, conduct isocyanate-specific air monitoring during spray painting operations using reagent-coated sampling media to establish current exposure levels against the incoming 0.005 mg/m³ WEL. Third, review respiratory protection for all spray painters, ensuring that supplied-air systems are used for all isocyanate-containing coatings, that equipment is maintained and serviced at manufacturer-specified intervals, and that all users have received fit-testing and training. Fourth, verify that the health surveillance program covers all spray painters with baseline and periodic lung function testing, and that workers who develop any respiratory symptoms are assessed promptly and removed from exposure pending medical evaluation. Fifth, audit paint and solvent storage against the Dangerous Goods Code requirements for segregation, ventilation, bunding, and fire protection, and rectify any non-conformances.

Isocyanate sensitisation from spray painting is irreversible and typically career-ending for the affected worker. After 1 July 2026, failure to follow the code constitutes a standalone offence. Category 2 penalties of up to $1,731,500 for a body corporate apply where workers are exposed to isocyanate or solvent vapours through inadequate booth design or ventilation failure. The incoming isocyanate WEL reduction to 0.005 mg/m³ creates additional enforcement exposure for spray painting businesses operating at the margins of compliance. Prohibition notices may be issued for spray painting operations performed outside approved spray booths or without adequate respiratory protection. Fire and explosion incidents in spray painting operations attract environmental and building code enforcement in addition to WHS penalties. Workers' compensation claims for occupational asthma from spray painting exposure are among the most costly in the workers' compensation system. All WHS penalties are uninsurable in NSW since 10 June 2020.