RAMS for Painting & Decorating

Painting and decorating appears low-risk on the surface, but the combination of solvents, work at height, dust generation, and confined spaces creates a hazard profile that demands careful documentation. A well-written RAMS demonstrates that you have thought through each activity, applied controls in the right order, and briefed your operatives — not simply ticked a procurement box.

Legal Basis

The duty to assess and control risks sits in the Management of Health and Safety at Work Regulations 1999 (MHSWR), regulation 3. This applies to every employer and self-employed person, regardless of whether the project is notifiable under CDM 2015. Additional obligations arise under the Control of Substances Hazardous to Health Regulations 2002 (COSHH), the Work at Height Regulations 2005, the Control of Asbestos Regulations 2012 (CAR 2012), and the Regulatory Reform (Fire Safety) Order 2005 for fire risk on premises. DSEAR applies where flammable vapours may accumulate.

Key Hazards and Controls

**Chemical hazards — solvents and isocyanates**

Apply the hierarchy: eliminate first by specifying water-based coatings wherever the specification permits. Where solvent-borne products are required, substitute for the lowest-hazard formulation. Engineer the exposure down through forced local exhaust ventilation (LEV) or general dilution ventilation before relying on respiratory protective equipment. For isocyanate-containing products — two-pack polyurethanes and many industrial coatings — spraying must only be carried out with air-fed respiratory protective equipment; a filtering facepiece does not provide adequate protection against isocyanates. Confirm workplace exposure limits against EH40 (HSE's publication of WELs) before completing the COSHH assessment, as limits are periodically revised. Skin sensitisation is also a significant route of harm; nitrile gloves and barrier cream are PPE and therefore last in the hierarchy, not substitutes for ventilation. Ensure Safety Data Sheets are on site and operatives have been briefed on the specific products in use.

**Work at height**

Under the Work at Height Regulations 2005, collective protection takes precedence over personal protection. This means scaffolding, tower scaffolds, or mobile elevated work platforms (MEWPs) must be considered before harnesses and lanyards. Ladders are only appropriate for short-duration, low-risk work where a more stable platform is not reasonably practicable. Inspect access equipment before each use, ensure tower scaffold is erected by a competent person following PASMA guidance, and confirm ground conditions are suitable for MEWPs. Never use makeshift platforms — chairs, paint tins, or unsecured planks — these appear in a disproportionate number of fatal falls.

**Dust from sanding and preparation**

Surface preparation generates fine particulate. In any building constructed before 2000, stop and consider two separate hazards before work begins. First, lead paint was commonly used prior to the 1960s and can still be present in older stock; assess exposure and control accordingly. Second, and critically, any disturbance of suspect materials in a pre-2000 building requires a CAR 2012 asbestos survey to be in place — artexed ceilings, textured coatings, and wall boards can all contain asbestos. Work must not proceed until the survey confirms the area is clear or the material has been removed by a licensed contractor. Where dust is unavoidable, use vacuum sanding equipment with H-class filtration as an engineering control before specifying a dust mask as PPE.

**Slips, trips, and housekeeping**

Wet paint, dust sheets, and extension cables on stairs are a persistent cause of injury on decorating sites. Control through good housekeeping, cable management, and ensuring access routes are kept clear.

Common Failings That Get a RAMS Rejected

The most frequent reasons a painting RAMS is returned are: generic text that does not name the specific products, surfaces, or locations on the contract; PPE listed as the first or only control rather than last; no reference to isocyanate controls where two-pack coatings are specified; missing asbestos survey confirmation for older buildings; and work at height addressed only with "operative to wear harness" without any consideration of collective protection.

What the Document Must Include

A painting and decorating RAMS should cover: the scope of work and location; the specific substances in use with COSHH assessments referencing current EH40 WELs; the access equipment selected and the inspection regime; confirmation of an asbestos survey for pre-2000 buildings; emergency procedures including first aid arrangements and, where confined spaces are involved, a rescue plan prepared before entry (regulation 5 of the Confined Spaces Regulations 1997 requires a safe system including rescue as a precondition of entry); fire precautions under the RRO 2005 and DSEAR where flammable vapours may be present; operative briefing records and signatures; and the name of the competent person who prepared and reviewed the assessment.