Painting Work Above 2m (WAH) SWMS

Painting work performed above 2 metres combines two of the highest-risk activities in Australian construction: working at height and the application of hazardous chemicals. Whether crews are cutting in eaves from an extension ladder, rolling render coats from a mobile scaffold, or spraying facades from a boom-type EWP, the work exposes painters to fall hazards, solvent inhalation, dermal absorption, and overspray drift onto adjacent trades and the public. Under WHS Regulation 2025, painting above 2 metres is classified as High Risk Construction Work (HRCW) under section 291, triggering the mandatory requirement for a Safe Work Method Statement prepared in consultation with workers before work commences. The SWMS must be kept available for inspection, reviewed when conditions change, and retained for at least two years (or for the duration of any notifiable incident investigation). This document provides the controls, hazard register, and consultation framework PCBUs and principal contractors need to lawfully discharge their primary duty of care under section 19 of the WHS Act.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.

1. 1Elimination — Specify pre-finished cladding, factory-coated panels or ground-level spray booth application during design review to remove the at-height painting task entirely.
2. 2Elimination — Schedule painting before edge protection, perimeter scaffold or roof safety mesh is removed so fall hazards are eliminated by existing engineered systems.
3. 3Substitution — Replace solvent-based enamels and two-pack epoxies with low-VOC water-based equivalents wherever specification allows, reducing inhalation and flammability risk.
4. 4Substitution — Use long-handled rollers and extension poles to bring high work down to platform level, substituting reach for climbing additional ladder rungs.
5. 5Engineering — Erect compliant mobile or modular scaffold to AS/NZS 1576 with mid-rails, toe boards and locked castors; prohibit ladder use above 2m where scaffold is reasonably practicable.
6. 6Engineering — Provide local exhaust ventilation or forced-air extraction in enclosed stairwells, plant rooms and lift shafts to keep solvent vapours below the workplace exposure standard.
7. 7Administrative — Conduct daily pre-start SWMS sign-on, wind-speed check (cease spray above 32 km/h), EWP and scaffold pre-use inspection, and SDS review for each coating in use.
8. 8Administrative — Implement exclusion zones, public signage and spotters below all EWP and scaffold work; rotate painters off two-pack tasks to limit cumulative exposure.
9. 9PPE — Supply A2P2 (organic vapour) half-face respirators for water-based, and supplied-air or full-face A2P3 for isocyanate spraying, fit-tested annually to AS/NZS 1715.
10. 10PPE — Issue full body harness with twin lanyard and shock absorber to AS/NZS 1891 for EWP and unprotected edges, plus nitrile gloves, coveralls and safety eyewear for every applicator.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

On a four-storey townhouse refurbishment, the painting leading hand is preparing his three-person crew to apply two-pack polyurethane to balustrades and weatherboard fascias accessed from a scissor-lift EWP. At the 6:45am pre-start brief, he opens the Painting Work Above 2m SWMS on a tablet and walks the crew through the hazard register, pausing on isocyanate inhalation and EWP entrapment because today's facade has projecting eaves that force the basket close to the structure. He nominates a ground-level spotter, confirms wind speed is 18 km/h (within the 32 km/h spray limit), checks SDS for the hardener, and verifies each painter has a fit-tested A2P3 supplied-air respirator rather than the half-face used yesterday for water-based undercoat. All three painters sign on, including a new second-year apprentice whose induction is noted on the SWMS register. Mid-morning, wind gusts climb to 35 km/h; the leading hand stops work, returns to the SWMS, documents the trigger event under the review section, switches the crew to brush cutting-in on the sheltered eastern elevation, and re-briefs the change. The signed SWMS, the EWP logbook entry and the atmospheric monitoring record are filed with the principal contractor that afternoon, satisfying the consultation, review and record-keeping duties under WHS Regulation 2025.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• Hazardous Manual Tasks CoP; Managing Risks of Hazardous Chemicals CoP

Frequently asked questions