Painting and Decorating COSHH Assessment: A Practical Guide for UK Decorators
If you're a decorator working with paints, solvents, strippers or fillers, you're handling substances that can cause real harm — occupational asthma, dermatitis, solvent-induced neurological damage, and lung disease are all well-documented risks in the trade. A painting and decorating COSHH assessment isn't a box-ticking exercise; it's the legal mechanism under the Control of Substances Hazardous to Health Regulations 2002 (COSHH) that requires you to identify those risks and put meaningful controls in place before work starts.
What COSHH Requires of You
Under COSHH Regulation 6, you must not carry out work that could expose employees (or yourself, if self-employed with employees) to hazardous substances without first making a suitable and sufficient assessment. That assessment must:
- Identify the hazardous substances present or likely to be generated
- Evaluate the likelihood and degree of exposure
- Decide what control measures are needed
- Record the findings where you employ five or more people (though good practice means recording them regardless)
The underlying duty to assess all workplace risks sits in Management of Health and Safety at Work Regulations 1999, Regulation 3 — COSHH is the specific regime that applies to substances.
Substances Decorators Need to Assess
Many painting and decorating products are hazardous within the meaning of COSHH. Common ones include:
| Substance | Primary Hazard |
|---|---|
| Solvent-based paints and varnishes | Volatile organic compounds (VOCs); flammable |
| Paint strippers (especially dichloromethane-based) | Severe health risk; DCM is now heavily restricted under REACH |
| Isocyanate-containing coatings (2K systems) | Leading cause of occupational asthma in the UK |
| White spirit and thinners | Skin absorption, vapour inhalation |
| Filler dusts and sanding residues | Respiratory sensitiser; may contain silica |
| Mould-treatment biocides | Skin/eye irritant; possible respiratory irritant |
| Lead paint (in older properties) | Toxic by inhalation and ingestion when disturbed |
Always obtain the Safety Data Sheet (SDS) for every product. The SDS — provided by the manufacturer or supplier — is the primary source for your hazard information. Section 8 of the SDS will tell you the occupational exposure limits (OELs) to check against EH40 (the HSE's Workplace Exposure Limits document).
The Correct Control Hierarchy
COSHH Regulation 7 requires you to prevent exposure — or, where that is not reasonably practicable, adequately control it. Work down the hierarchy; do not jump straight to PPE.
1. Eliminate — Can you remove the substance entirely? Could the client accept a surface that doesn't need a chemical stripper?
2. Substitute — Use a less hazardous product. Water-based acrylic paints instead of solvent-based alkyd systems where performance allows. A paste stripper in place of a DCM product.
3. Engineering controls — Local exhaust ventilation (LEV) when sanding; forced dilution ventilation in confined rooms; enclosure of spray operations. These controls must be examined and tested at least every 14 months under COSHH Regulation 9.
4. Administrative controls — Reduce the number of people in the area, rotate tasks to limit individual exposure time, schedule solvent-heavy work when the space is unoccupied.
5. PPE — last resort — Respiratory protective equipment (RPE) appropriate to the substance: an FFP3 disposable or a half-mask with the correct filter for organic vapours. Nitrile gloves for solvent resistance. Eye protection where splash risk exists. PPE must be suitable, maintained, and — critically — fit-tested where a face-seal matters.
Isocyanates: A Special Note
Two-pack (2K) paints and lacquers that cure via isocyanate chemistry are one of the highest-risk substances in the decorating trade. The HSE is clear: anyone spraying isocyanate coatings must use supplied-air breathing apparatus (SABA) or powered air-purifying respirators (PAPR); an air-purifying half-mask alone is not adequate for spraying. Health surveillance (lung function testing and symptom questionnaires) is required under COSHH Regulation 11 for workers regularly exposed.
What a Completed COSHH Assessment Should Cover
A practical assessment document for a decorating task should state:
- The specific product(s) and task (e.g. "applying solvent-based gloss paint by brush in a kitchen")
- Who could be exposed and how (inhalation, skin contact, ingestion)
- Existing and additional controls identified through the hierarchy
- Any applicable WEL and how compliance will be achieved
- RPE/PPE type and standard required
- Emergency arrangements (spillage, first aid)
- Review trigger (change of product, change of task, or at least annually)
Generic COSHH assessments copied from a product website are rarely sufficient on their own. They must reflect your actual working conditions and controls.
Sanding and Dust: Don't Overlook It
Sanding old paintwork — particularly in properties built before 1978 — can generate dust containing lead. This triggers additional duties under COSHH and, on construction projects, under CDM 2015. Even without lead, fine paint dust is a respiratory hazard. Use a vacuum sander with an H-class filtered vacuum rather than open sanding wherever practicable.
Keeping Your Assessment Current
A COSHH assessment is not a one-off document. Review it when products change, when working conditions change significantly, or if a worker reports symptoms. Health surveillance records, where required, must be kept for 40 years under COSHH Regulation 11.
Getting the assessment right — specific, evidenced, and acted upon — protects your workers, demonstrates compliance, and keeps your RAMS documentation credible when clients or principal contractors ask to see it.