# Job Hazard Analysis: Lead-safe paint removal URL: https://hardhatbinder.com/en/jha/painting/lead-safe-work Last updated: 2026-10-23 Removing loose and peeling paint from walls, trim, doors, and windows on a pre-1978 building where lead-based paint is present or assumed. Work is done by wet scraping, HEPA-shrouded sanding, and non-methylene-chloride chemical stripper, from the floor, 6-ft fiberglass stepladders, or a baker scaffold. No open-flame burning, dry sanding, or abrasive blasting. > A general example for this task. Your JHA should reflect your crew, equipment and site — review it with a competent person before work starts. ## Steps, hazards and controls ### 1. Set up the regulated work area and containment. - **Lead dust spreading to occupants, other trades, and outside areas.** (High): Move furniture out or cover it with 6-mil plastic taped tight.; Cover floors with 6-mil plastic, seal doors and vents, and shut off the HVAC to the room.; Post lead warning signs at every entrance and keep out anyone not in PPE.; Outside, lay plastic 10 ft out from the wall and stop work if wind blows dust off the plastic. - **Slipping or tripping on plastic sheeting and tape.** (Medium): Tape all plastic edges and seams flat to the floor.; Keep cords and hoses along the walls, not across walkways.; Wear shoe covers with grip soles. ### 2. Set up ladders, scaffold, and tools. - **Falls from a stepladder or baker scaffold.** (High): Use a baker scaffold with guardrails for long runs of high trim instead of moving a ladder over and over.; Inspect ladders before use; tag out any with cracked rails or loose steps.; Lock the stepladder spreaders open and never stand on the top cap or top step.; Lock the scaffold casters and install guardrails before climbing on. - **Electric shock from damaged cords or tools.** (Medium): Plug all tools into a GFCI.; Check cords for cuts and missing ground pins; remove damaged cords from service.; Keep cords out of water used for wet scraping. ### 3. Mist and wet-scrape loose paint. - **Breathing or swallowing lead dust and chips.** (High): Mist the surface with a spray bottle before and during scraping; never dry-scrape.; Scrape small sections and let chips fall onto the plastic.; No eating, drinking, smoking, or gum inside the work area.; Wear a fit-tested half-mask respirator with P100 filters until air monitoring shows a different level is acceptable. - **Paint chips or debris in the eyes.** (Medium): Scrape with downward strokes, away from your face.; Wear safety glasses with side shields or goggles. - **Cuts from scraper blades and putty knives.** (Low): Replace dull blades and pull the scraper away from your body.; Wear cut-resistant work gloves over nitrile gloves. ### 4. Remove remaining paint with HEPA-shrouded sander or chemical stripper. - **High lead dust levels from power sanding.** (High): Use only sanders with a shroud connected to a HEPA vacuum; no open power sanding, grinding, or heat guns over 1100°F.; Keep the shroud flat on the surface and stop if dust escapes.; Rotate workers to limit time spent sanding.; Wear a fit-tested P100 respirator and disposable coveralls with hood. - **Skin burns and vapors from chemical stripper.** (Medium): Use a stripper that does not contain methylene chloride.; Read the SDS before opening and follow its ventilation and glove instructions.; Keep an eyewash bottle and water within reach.; Wear chemical-resistant gloves and splash goggles while applying and scraping stripper. - **Heat stress while working in coveralls and respirator.** (Medium): Schedule hot-side or attic work for early morning.; Take water and shade breaks outside the work area after removing coveralls and washing up.; Watch each other for dizziness, cramps, or confusion. ### 5. Clean up the work area. - **Stirring up settled lead dust during cleanup.** (High): Never dry-sweep or use compressed air; use only a HEPA vacuum and wet wipes.; Mist the plastic, then fold it in on itself, dirty side in.; HEPA-vacuum all surfaces top to bottom, then wet-wipe with clean rags.; Keep respirators on until cleanup is finished. - **Back strain lifting bagged debris.** (Low): Keep bags under 40 lb and carry with a straight back. ### 6. Bag waste, decontaminate, and change clothes. - **Carrying lead home on skin, clothes, shoes, or tools.** (High): Seal waste in heavy-duty bags, gooseneck-tie them, and store them in a closed container.; HEPA-vacuum coveralls before removing them, then roll them inside out into a bag.; Wash hands and face with soap and water before eating, drinking, or leaving.; Change into clean clothes and shoes; do not take work clothes home.; Wipe down tools and keep the respirator in a clean sealed bag. ## Required PPE - Half-mask air-purifying respirator with P100 filters — Fit-tested and worn during all scraping, sanding, and cleanup until air monitoring results say otherwise. - Disposable coveralls with hood and shoe covers — Put on before entering the work area; remove and bag before leaving. - Safety glasses or goggles — ANSI Z87.1 safety glasses at all times; splash goggles when using chemical stripper. - Gloves — Nitrile gloves for dust work; chemical-resistant gloves matched to the stripper SDS; cut-resistant gloves for scraping. - Hearing protection — Foam earplugs when running sanders and HEPA vacuums for long periods. - Hard hat — When working below others on scaffold or where overhead hazards exist. ## Training - Lead hazard training before starting work, including health effects, respirator use, and hygiene practices. - Respirator medical evaluation, annual fit test, and training on use and care. - Lead blood testing as required by the employer's lead program based on exposure. - Hazard communication training on the SDS for chemical strippers and cleaning products. - Ladder and scaffold safety training from a competent person. - EPA RRP Certified Renovator on site for pre-1978 housing or child-occupied facilities. ## Emergency For a fall or serious injury: stop work, call 911, and give the site address. Do not move the injured worker unless they are in danger; give first aid until help arrives. For stripper in the eyes, flush with water for 15 minutes. Report any lead symptoms like headaches, stomach pain, or fatigue to your supervisor right away. ## Official sources - [29 CFR 1926.62](https://www.ecfr.gov/current/title-29/section-1926.62) — Lead - [29 CFR 1926.103](https://www.ecfr.gov/current/title-29/section-1926.103) — Respiratory protection - [29 CFR 1910.134](https://www.ecfr.gov/current/title-29/section-1910.134) — Respiratory protection program - [29 CFR 1926.59](https://www.ecfr.gov/current/title-29/section-1926.59) — Hazard communication - [29 CFR 1926.1053](https://www.ecfr.gov/current/title-29/section-1926.1053) — Ladders - [29 CFR 1926.451](https://www.ecfr.gov/current/title-29/section-1926.451) — Scaffolds — general requirements - [29 CFR 1926.25](https://www.ecfr.gov/current/title-29/section-1926.25) — Housekeeping - [OSHA](https://www.osha.gov/heat-exposure) — Heat — hazard recognition and prevention --- Source: HardHat Binder, operated by Leadspire LLC. Templates to be reviewed by a competent person before use; not legal advice; not affiliated with OSHA.