Spray Painting (Metal) SWMS

Spray painting in metal fabrication applies protective coatings, primers, and finishes to fabricated steel, aluminium, and stainless steel components. The primary hazards are isocyanate exposure from two-pack polyurethane paints, solvent vapour inhalation, and fire or explosion risk from flammable overspray accumulation. Isocyanates are potent respiratory sensitisers — once a worker becomes sensitised, even trace exposure causes severe asthma attacks. The WHS Regulation 2025 requires spray painting to be conducted in compliant spray booths with mechanical ventilation, and health surveillance is mandatory for workers exposed to isocyanates. This template maps controls to the binding Hazardous Chemicals Code of Practice effective 1 July 2026.

Legal Requirements

regulation

WHS Regulation 2025 Part 7.1 — Hazardous Chemicals

hrcw category

Work in or near a flammable atmosphere

code of practice

Managing Risks of Hazardous Chemicals in the Workplace (binding 1 July 2026 under Section 26A)

section 26a binding

Yes — effective 1 July 2026. Non-compliance is admissible as evidence of breach.

Hazards

Hazard	Consequence	Likelihood
Isocyanate inhalation from two-pack polyurethane paints	Occupational asthma, permanent respiratory sensitisation	Likely
Solvent vapour inhalation from paint and thinners	Central nervous system depression, liver damage, cancer	Likely
Fire or explosion from flammable overspray accumulation	Flash fire, explosion, severe burns, death	Possible
Skin sensitisation from isocyanate and epoxy contact	Occupational dermatitis, systemic sensitisation	Likely
Paint mist inhalation without isocyanate content	Respiratory irritation, chronic lung disease	Likely
Static discharge igniting flammable atmosphere	Explosion, flash fire	Unlikely

Controls (Hierarchy of Controls)

Conduct all spray painting in a compliant spray booth with mechanical ventilation and filtration

Provide supplied-air respiratory protection for all isocyanate spray painting operations

Substitute water-based or low-isocyanate coatings where performance requirements permit

Implement a health surveillance program including spirometry for all workers exposed to isocyanates

Ground all spray equipment and workpieces to prevent static discharge in flammable atmospheres

Store paints, solvents, and thinners in compliant flammable liquids cabinets

Provide chemical-resistant gloves and coveralls to prevent skin contact with isocyanates and solvents

Maintain spray booth ventilation systems on a documented schedule with airflow verification testing

Recent Prosecutions

Orica Australia Pty Ltd$1,200,000

Workers exposed to hazardous chemicals without adequate ventilation or health monitoring, resulting in occupational disease.

2024 — SafeWork NSW v Orica Australia Pty Ltd [2024]

KML Auto Parts Pty Ltd$375,000

Inadequate safety controls and training during operations involving hazardous substances.

2022 — SafeWork NSW v KML Auto Parts Pty Ltd [2022]

What Your SWMS Must Include

✓Spray booth ventilation specifications and airflow verification schedule

✓Isocyanate identification in all paint products with SDS cross-reference

✓RPE selection and fit-testing schedule for spray painting personnel

✓Health surveillance program including spirometry baseline and annual testing

✓Flammable liquids storage and handling procedures

Need a compliant Spray Painting SWMS?

Our WHS consultants build booth-specific SWMS that address isocyanate exposure, ventilation compliance, and health surveillance for your painting operations.