Spray Painting (Manufacturing) SWMS

Spray painting in manufacturing applies primers, topcoats, lacquers, and specialty coatings to products ranging from furniture to automotive components. The incoming WEL for isocyanates drops from 0.02 to 0.005 mg/m³ — a 75 per cent reduction that will require most spray painting operations to upgrade ventilation and RPE programs. Two-pack polyurethane coatings containing isocyanates are widely used in manufacturing for their durability, but isocyanates are potent respiratory sensitisers that cause irreversible occupational asthma. This template maps controls to the binding Spray Painting and Powder Coating and Hazardous Chemicals Codes 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

Spray Painting and Powder Coating, Managing Risks of Hazardous Chemicals (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 coatings	Occupational asthma, permanent respiratory sensitisation	Likely
Solvent vapour inhalation from paints and thinners	CNS depression, liver damage, chronic disease	Likely
Fire or explosion from flammable overspray and vapour	Flash fire, explosion, severe burns	Possible
Skin sensitisation from isocyanate and epoxy contact	Occupational dermatitis, systemic sensitisation	Likely
Paint mist inhalation	Respiratory irritation, chronic lung disease	Likely
Static discharge in spray booth	Ignition of flammable atmosphere	Unlikely

Controls (Hierarchy of Controls)

Conduct all spray painting in a compliant spray booth with mechanical ventilation meeting AS/NZS 4114

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

Substitute water-based or low-isocyanate coatings where product performance permits

Implement health surveillance including spirometry for all workers exposed to isocyanates

Ground all spray equipment and workpieces to prevent static discharge

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

Provide chemical-resistant gloves and coveralls to prevent skin contact

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

Recent Prosecutions

Orica Australia Pty Ltd$1,200,000

Workers exposed to hazardous chemical fume without adequate ventilation or health monitoring.

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

SafeWork SA prosecution$840,000

Inadequate chemical exposure controls in manufacturing resulting in worker harm.

2024 — SafeWork SA Manufacturing Prosecution [2024]

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 the incoming isocyanate WEL and protect your workers from respiratory sensitisation.