Quick answer: Painters in Australia have WHS obligations as PCBUs and, on construction sites, as subcontractors or principal contractors. Key requirements include SWMS for work at height and other high risk activities, hazardous substances management for paints and solvents, lead paint controls on older buildings, and respiratory protection for spray painting and isocyanate work. This page pulls together the essential resources, guides, and SWMS templates that painters and painting businesses need.
Last reviewed: 12 June 2026
Running a painting business in Australia means managing a set of WHS obligations that go well beyond a hard hat and a pair of gloves. Painters work at height, handle hazardous chemicals daily, and are regularly exposed to lead paint in older buildings. Whether you are a sole trader painter working on residential repaint jobs or a painting contractor managing crews across multiple commercial projects, WHS compliance applies to every job.
This page is a practical resource hub for painters and painting contractors. It links to guides, checklists, SWMS templates, and WHS document resources relevant to residential and commercial painting in Australia. Use it as a starting point to understand your obligations and find the tools you need.
Note: WHS laws in Australia are based on the model Work Health and Safety Act 2011, but each state and territory has its own legislation and regulator. Always check the requirements that apply in your jurisdiction.
WHS obligations for painters
Painters carry WHS obligations in multiple capacities. Understanding which duties apply to you is the first step to compliance.
Duty as a PCBU
Any painter carrying on a business — sole trader, partnership, or company — is a person conducting a business or undertaking (PCBU) under Australian WHS legislation. As a PCBU, a painter must ensure the health and safety of:
- their own workers (employees and labour hire)
- subcontractors and their workers on site
- other people on or near the workplace, including residents, occupants, and the public
The PCBU duty is to eliminate risks so far as is reasonably practicable, or if that is not possible, to minimise them so far as is reasonably practicable.
Duty as a subcontractor on construction sites
Painters frequently work as subcontractors on new build and renovation construction sites. As a subcontractor, a painter must:
- Prepare a SWMS for all high risk construction work (HRCW) activities before commencing work
- Follow the WHS management plan and site rules set by the principal contractor
- Cooperate with other duty holders on site — including the principal contractor and other subcontractors
- Ensure their workers are properly inducted and follow the SWMS
Being a subcontractor does not reduce your PCBU obligations. You and the principal contractor share overlapping duties for the safety of your workers on that site.
Managing your own workers and subcontractors
If you employ painters, use labour hire workers, or engage subcontractors for specialist tasks such as blasting or scaffolding, you carry duties as both a PCBU and potentially as a principal contractor or principal contractor equivalent, depending on the nature of the work. You must:
- Ensure workers are trained, competent, and supervised
- Provide adequate PPE and ensure it is worn
- Keep a register of subcontractors and their WHS documents on file
- Review subcontractor SWMS before allowing them to commence work
Key hazards for painters
Painting involves several hazards that are commonly associated with serious illness and injury. Understanding these hazards is fundamental to managing them.
Working at height
Working at height is one of the most significant causes of serious injury and fatality in painting work. Painters regularly work from ladders, scaffolding, elevated work platforms (EWPs), and roof edges. Work at a height of more than 2 metres is high risk construction work (HRCW) under the WHS Regulations, triggering a SWMS requirement.
Key height controls for painters include:
- Selecting the correct access equipment for the task — scaffolding, EWP, or ladder — based on the height, duration, and nature of the work
- Using edge protection and fall arrest systems where working from a roof or elevated surface
- Inspecting ladders before each use and setting them at the correct angle and footing
- Never using a ladder as a working platform for extended tasks above the safe working zone
- Using harness and lanyard systems where other controls are not reasonably practicable
Isocyanates and solvent fumes
Two-pack paints, polyurethane coatings, and certain industrial coatings contain isocyanates — chemicals that can cause occupational asthma and sensitisation with repeated exposure. Solvent-based paints and thinners release volatile organic compounds (VOCs) that can cause headaches, dizziness, and long-term health effects at high concentrations.
Controls for isocyanate and solvent exposure include:
- Using water-based products in preference to solvent-based where practicable
- Ensuring adequate ventilation in all work areas
- Wearing respiratory protective equipment (RPE) rated for the specific chemical — for isocyanates, supplied-air or powered air-purifying respirators are typically required
- Reviewing the Safety Data Sheet (SDS) before using any new product
- Maintaining a hazardous chemicals register on site
Lead paint in older buildings
Buildings constructed before 1970 are very likely to contain lead-based paint. Buildings constructed between 1970 and 1997 may also contain lead paint at lower concentrations. Sanding, scraping, cutting, and heat-stripping paint on older buildings can release lead dust and fumes — both of which are hazardous even at low levels.
Painters working on older buildings must:
- Treat all existing paint as potentially containing lead until tested
- Test for lead paint before disturbing any existing paint coating on older buildings
- Prepare a lead-based paint SWMS if lead is identified or suspected
- Isolate the work area and restrict access during lead paint disturbance work
- Wear appropriate RPE (P2 or P3 respirator as a minimum) and disposable coveralls
- Dispose of lead paint waste in accordance with state and territory requirements
- Not eat, drink, or smoke in areas where lead paint work is being carried out
- Consider biological monitoring (blood lead testing) for workers with regular exposure
Dust
Sanding, rubbing back, and surface preparation generate fine dust that can cause respiratory irritation and, in older buildings, may carry lead or other hazardous materials. Controls include dust suppression, vacuum-assisted sanding tools, and appropriate RPE.
SWMS requirements for painters
When does a painter need a SWMS?
A SWMS is required before commencing any high risk construction work (HRCW). For painters, HRCW most commonly arises from:
- Work at a height of more than 2 metres — painting from scaffolding, elevated platforms, or roof areas
- Work in or near a confined space — painting internal spaces with restricted entry or ventilation
- Work involving disturbance of hazardous materials — including lead paint in some jurisdictions
A SWMS must:
- Identify the specific HRCW activity
- List the hazards associated with that activity
- Set out the risk controls that will be implemented
- Be reviewed and signed by workers before work commences
- Be kept on site and accessible to workers throughout the activity
For a plain-language introduction to SWMS requirements, see What Is a SWMS?.
For painting-specific SWMS guidance, see the Painting SWMS Guide.
Common SWMS for painters
The table below lists the SWMS most commonly needed by painting businesses, with the typical situations in which they apply.
| SWMS | When needed |
|---|---|
| Painting and Decorating SWMS | General residential and commercial painting and decorating work |
| Spray Painting SWMS | Airless spray, HVLP, and conventional spray painting of any surface |
| General Working at Heights SWMS | Any painting work performed at or above 2 metres |
| Ladders SWMS | Use of extension, step, or combination ladders for painting access |
| Scaffolding SWMS | Erection, alteration, and dismantling of scaffolding for painting access |
| Lead-Based Paint SWMS | Any work that involves disturbing, removing, or painting over lead-based paint |
| Abrasive Blasting SWMS | Abrasive blasting for surface preparation on industrial or commercial structures |
| Hazardous Substances SWMS | Use of hazardous paints, solvents, thinners, and chemical strippers |
WHS documents a painter needs
Beyond SWMS, a painting business needs a broader set of WHS documents to support a compliant operation. The table below outlines the core documents, their purpose, and when they are required.
| Document | Purpose | When required |
|---|---|---|
| WHS Policy | Demonstrates leadership commitment to health and safety; sets out responsibilities | Any business with workers; expected by clients and head contractors |
| SWMS | Identifies HRCW activities, hazards, and risk controls | Before commencing any HRCW activity; kept on site throughout |
| Hazardous Chemicals Register | Lists all hazardous chemicals in the workplace with SDS reference | Required wherever hazardous chemicals are used or stored; includes all paints, solvents, and thinners |
| Safety Data Sheets (SDS) | Technical information on hazardous chemicals: composition, handling, PPE, and emergency response | Must be current and accessible to workers for every hazardous product used |
| Site Induction Records | Evidence that workers have received site-specific safety information | Before any person accesses the site; on construction sites, per the principal contractor's requirements |
| Incident Register | Records incidents, near misses, dangerous occurrences, and work-related injuries | Ongoing; serious incidents must be reported to the WHS regulator |
| Training Register | Records qualifications, licences, tickets, and training for each worker | Ongoing; includes trade licences, height safety training, and RPE fit testing records |
| Plant and Equipment Register | Tracks equipment on site, inspection status, and operator competencies | Maintained while plant and equipment such as EWPs, compressors, and spray equipment are in use |
| Emergency Plan | Sets out emergency response procedures for the workplace | Required for all workplaces; should address chemical spill, fire, and fall response |
| PPE Register | Records PPE issued to workers, including inspection and replacement schedules | Best practice; particularly important for RPE used in isocyanate and lead paint work |
Hazardous chemicals checklist for painters
Managing hazardous chemicals is a core part of WHS compliance for any painting business. The following checklist covers the key actions required.
Setting up for a job:
- Identify all hazardous chemicals to be used on the job
- Obtain current Safety Data Sheets (SDS) for every product
- Add products to the hazardous chemicals register
- Assess ventilation requirements for the work area
- Select correct PPE — including RPE rated for the specific chemical hazard
- Check for lead paint if working on buildings constructed before 1997
- Prepare a lead-based paint SWMS if lead is identified or suspected
During the job:
- Ensure SDS are accessible to all workers on site
- Confirm workers have read and understood the relevant SDS
- Ensure PPE is worn correctly throughout chemical use
- Maintain adequate ventilation — open windows, use mechanical ventilation or forced-air supply if required
- Store chemicals correctly — away from heat sources and ignition points, in original containers with labels intact
- Never mix chemicals unless directed by the SDS or manufacturer
After the job:
- Dispose of chemical waste and empty containers in accordance with the SDS and local requirements
- Clean and inspect PPE; replace filters and consumables as required
- Record any incidents involving chemical exposure in the incident register
For a full guide to managing hazardous chemicals as a painter, see the Hazardous Chemicals Checklist.
Useful guides for painters
The following guides cover the WHS topics most relevant to painting businesses.
- What Is a SWMS? — Plain-language explanation of SWMS and when they are required
- Painting SWMS Guide — How SWMS apply to residential and commercial painting work
- Lead Paint SWMS Guide — SWMS requirements for working with lead-based paint in older buildings
- Working at Heights SWMS Guide — SWMS requirements for painting work at height
- Hazardous Chemicals Checklist — Practical checklist for managing paints, solvents, and hazardous chemicals on the job
SWMS templates for painters
Blue Safe Online provides SWMS templates for the painting activities most commonly needed on residential and commercial jobs. Templates are professionally prepared, editable, and ready to customise to your specific site and work methods.
Browse the full range of painting SWMS at Blue Safe Online.
Frequently asked questions
Do painters need a SWMS?
Yes — painters need a Safe Work Method Statement (SWMS) for any high risk construction work (HRCW) activity they perform. For painters, the most common HRCW triggers include work at a height of more than 2 metres, working near an excavation, and work involving hazardous substances such as lead-based paint. A SWMS must be prepared before the work commences, reviewed with workers, signed off, and kept accessible on site throughout the activity. If you are a subcontractor on a construction site, the principal contractor may also require you to provide your SWMS before you start work.
Is there a WHS requirement to test for lead paint before painting older buildings?
Painters working on buildings constructed before 1970 — and in some cases before 1997 — should treat all existing paint as potentially containing lead until proven otherwise. Testing before disturbing paint on older buildings is considered best practice and is consistent with the duty to manage risks so far as is reasonably practicable. Some state and territory regulations include specific obligations around lead paint identification and control. At a minimum, painters should use lead paint test kits or engage a qualified assessor before sanding, scraping, or heat-stripping paint on older buildings, and ensure a lead-based paint SWMS is in place if lead is identified or suspected.
What hazardous substances obligations apply to painters?
Painters regularly work with products that are classified as hazardous substances or dangerous goods under Australian WHS legislation and the Globally Harmonised System of Classification and Labelling of Chemicals (GHS). Obligations include: obtaining and reading the current Safety Data Sheet (SDS) for each hazardous product used; assessing the risk of exposure and implementing appropriate controls; providing workers with information, training, and instruction on the hazardous substances they use; ensuring appropriate personal protective equipment is provided and used; and maintaining a register of hazardous chemicals in the workplace. Isocyanates used in two-pack paints and polyurethane coatings require particular attention and may need health monitoring arrangements depending on exposure levels.
What licences or tickets do painters need in Australia?
Licensing requirements for painters vary by state and territory. In states such as Queensland, New South Wales, Victoria, and South Australia, painters typically need a contractor licence to carry out residential or commercial painting work above a prescribed value. Beyond trade licensing, painters who use spray equipment with isocyanate-based paints may need specific training in respiratory protective equipment (RPE). Workers performing work at height on scaffolding will need a scaffolding licence if they erect, alter, or dismantle scaffolding (as distinct from simply working from it). If abrasive blasting is performed, specific licences apply in most states. Always check the requirements with the relevant licensing authority and WHS regulator in your state or territory.
Get your WHS documents sorted
Blue Safe Online provides SWMS templates and WHS management systems for Australian painters. Whether you are setting up your painting business for the first time, taking on a large commercial repaint project, or updating outdated documents, Blue Safe Online gives you access to professionally prepared, ready-to-customise WHS documents for the painting industry.
Browse SWMS and WHS documents for painters on Blue Safe Online
This page provides general information only and does not constitute legal advice. WHS requirements may vary by state or territory, project type, contract conditions, and your role on site. Consult the relevant WHS regulator or a qualified WHS professional for advice specific to your circumstances.