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Painting & Decorating JSA (NZ)

Surface preparation is where the exposure happens — not the painting. Lead on pre-1980 substrates, solvent vapour in unventilated interiors, and the access method that puts most painters at height for the whole job.

⚖️HSWA + HS Regs 2017
👷Reviewed by OH Professionals
✏️Editable .docx
NZD 99
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Painting reads as a low-risk trade and is not one. The health exposures are chronic rather than acute, which is exactly why they are under-controlled: lead from preparing old substrates, isocyanates and solvents from two-pack and spray systems, and organic vapour accumulating in interiors with the windows shut because the client wants the doors closed. Layered on top is that most painting is done at height for most of the day. This JSA treats preparation as the hazardous phase, because it is.

Heat guns and sanders on pre-1980 paint

Lead-based paint was in common New Zealand use for decades. Heating and abrasive removal are the methods that turn a stable coating into an inhalable and ingestible exposure.

Interior solvent work without ventilation

Vapour accumulates in a closed room and does not announce itself. The template requires ventilation to be planned rather than improvised.

Ladders as the default access method

Painting from a ladder for an entire exterior is normal and it is also why painters fall. The access decision belongs at the top of the analysis, not as an afterthought.

Who this is for

Painting and decorating contractors
Residential and commercial interior and exterior work.
Painters subcontracting to main contractors
Submit alongside your SSSP where a task analysis is required per activity.
Property maintenance teams
Repaint cycles on older housing stock and council property.
Spray applicators
Two-pack, industrial and roof coating work with respiratory and overspray control.

If your painting SSSP is what a main contractor has asked for, that is the project-level document — this sits underneath it.

What's inside the template

Word — 15 pages (pre-populated JSA + substrate check + forms) · Formats: DOCX

  • Section 1 — Task and scopeInterior or exterior, substrate, building age, coating system, occupancy and duration.
  • Section 2 — Substrate and coating history checkBuilding age, likelihood of lead-based coatings, and testing or assumption before any preparation begins.
  • Section 3 — Access method decisionScaffold, EWP, mobile tower or ladder — decided against the hierarchy with the reason recorded.grwm 6
  • Section 4 — Pre-populated step analysisSet up, protect, prepare, prime, coat, clean and pack down — each with hazards and controls drafted.grwm 5
  • Section 5 — Lead paint controlsProhibited methods, wet methods, on-tool extraction, containment, hygiene and waste. Written for the case where lead is present or assumed.
  • Section 6 — Solvent and vapour exposureProduct selection, ventilation planning for interiors, and the difference between water-based and solvent systems for exposure.hs 3 1
  • Section 7 — Spray applicationOverspray control, exclusion, airless injection injury, and respiratory protection selection for isocyanate-containing systems.as 1715
  • Section 8 — Dust from sandingOn-tool extraction and wet sanding before RPE, including silica where filler and plaster are involved.
  • Section 9 — Health monitoring triggersWhere blood lead or other monitoring applies, and who arranges it.grwm 9
  • Section 10 — Hygiene and take-home exposureWashing, eating separately, and not carrying lead dust home on clothing — the exposure route that reaches families.
  • Section 11 — Occupants and publicWorking in occupied houses, schools and workplaces, and protecting people who are not your workers.hswa 34
  • Section 12 — Pre-start and crew sign-onWeather for exterior work, substrate surprises, and crew changes.
  • Appendix A — Substrate assessment recordArea, age, coating, tested or assumed, method permitted.
  • Appendix B — Product and SDS scheduleCoatings and solvents in use, with SDS reference and hazard classification.
Compliance checklist

HSWA 2015 ss.30, 34, 36 · GRWM Regulations 2016 regs 5–7

A Job Safety Analysis is not a named statutory document in New Zealand — unlike an Australian SWMS, no regulation requires one by that name. Its weight comes from the duties it discharges, and from the fact that main contractors and prequalification schemes treat it as the expected evidence that a high-risk task was thought through before it started.

  1. GRWM reg 5Identify hazards that could give rise to reasonably foreseeable risks to health and safety→ Step-by-step breakdown — hazards identified against each step rather than for the task as a whole
  2. GRWM reg 6Eliminate risks so far as is reasonably practicable; otherwise minimise by substitution, isolation, engineering, then administrative controls, then PPE→ Control column — every control declares its hierarchy level
  3. GRWM reg 7Ensure control measures are effective and maintained so they remain effective→ Verification and pre-start review sections
  4. HSWA s36Primary duty of care — ensure health and safety so far as is reasonably practicable→ Residual risk assessment and the sign-on record
  5. HSWA s34Consult, cooperate and coordinate with other PCBUs where duties overlap→ Interfacing trades section — who else is affected by this task and how it is coordinated

How this template compares

The most common alternative in New Zealand is an Australian SWMS with the branding changed. It is worth being precise about why that is a problem.

FeatureBlank JSA formAU SWMS relabelledOH Consultant JSA (NZ)
Cost$0NZD 25–60NZD 99
Legislative anchorNone statedAU WHS Regulation — no NZ equivalentHSWA 2015 + GRWM Regs 2016
Task steps pre-draftedNo — you write themAustralian work sequencesNZ work sequence, editable
Hazards pre-populatedNoSometimesYes — per step
Hierarchy of control level per controlNoRarelyRequired field
Interfacing trades / overlapping dutiesNoNo — different provisionSection on s34 coordination
Pre-start and sign-on recordSignature lineSignature lineSign-on plus pre-start change check
Correct document name for NZYesNo — SWMS is not an NZ instrumentYes — JSA / Task Analysis

Reviewed by OH Professionals

Written and reviewed by the occupational health and safety team at OH Consultant. These are drafted as New Zealand Job Safety Analyses, not as Australian SWMS with the terminology swapped. That distinction is substantive: a SWMS is an instrument created by Australian WHS regulation for high-risk construction work, with prescribed content and a statutory trigger. New Zealand has no equivalent provision, so a document presented as a "NZ SWMS" is citing a requirement that does not exist here.

Legislation referenced

Frequently asked

How do I know if the paint contains lead?+
Building age is the first indicator — lead-based paints were in common New Zealand use for decades and their presence should be expected in older stock. From there you either test, or you assume lead is present and work to the controls in Section 5. Assumption is a legitimate and often cheaper route than testing for a small job; proceeding on neither is not.
Which preparation methods are the problem?+
Heat and abrasion. Heating lead-based paint volatilises lead; dry sanding, grinding and abrasive blasting make it respirable. Wet methods, chemical stripping and on-tool extraction substantially reduce exposure, which is why Section 5 puts them ahead of respiratory protection.
Do I need health monitoring for my painters?+
Where workers are exposed to lead in a way that requires it, health monitoring obligations arise under the general risk regulations. Section 9 flags the trigger and records who arranges it. Whether monitoring is required in your case depends on the work and the exposure, and should be confirmed against current WorkSafe guidance rather than assumed either way.
Is this different from my painting SSSP?+
Yes. The SSSP is the project-level plan covering how health and safety is managed across the job — it is what the main contractor accepts before you start. This JSA is the task-level analysis that sits underneath it, and the SSSP indexes it.
Is a JSA the same as a SWMS?+
In substance they do the same job — break a task into steps and assign hazards and controls to each. In law they are not the same. A SWMS is an Australian instrument required by Australian WHS regulation for high-risk construction work, with prescribed content. New Zealand has no equivalent provision, which is why the NZ convention is Job Safety Analysis or Task Analysis. If a supplier is selling you a "New Zealand SWMS", they are selling you an Australian document.
Is a JSA legally required in New Zealand?+
Not by name. What is required is that you identify hazards under GRWM Regulation 5, apply controls in the hierarchy order under Regulation 6, and keep them effective under Regulation 7. A JSA is how those duties are discharged at task level, and main contractors and prequalification schemes ask for it as a matter of course.
How does this relate to my SSSP?+
The SSSP is the project-level plan covering how health and safety is managed across the whole site. Job Safety Analyses sit underneath it — one per higher-risk task. On a typical job you have one SSSP and several JSAs, and the SSSP indexes them.
Who should complete and sign it?+
Someone competent in the work, with the crew who will actually do the task involved in developing it rather than handed a finished document. The sign-on section records that involvement, which is the part that distinguishes a JSA that was used from one that was filed.
How often does it need reviewing?+
Before each use, at minimum as a pre-start check for anything that has changed — different site conditions, different plant, different crew, weather. The pre-start section exists for that. A full review is warranted after any incident involving the task, or when the method or equipment changes.
Can I edit it for my business?+
Yes — it ships as an editable .docx with a single-buyer licence covering use across your own business and its projects. It is a starting point that reflects standard practice for the task, not a substitute for assessing the specific job in front of you. It is not licensed for resale or redistribution as your own template product.