U.S. Department of Labor t www.osha.gov t (800) 321-OSHA (6742)

Hazards Associated with Spray 

Painting in Shipyard Employment

The construction and maintenance of vessels often involves spray painting, which can pose serious 

hazards to workers. The primary dangers include fires and explosions from flammable paints and coatings, 

as well as exposures to chemical hazards and toxic substances. The work is frequently conducted in 

confined spaces that, if not properly ventilated, can cause sickness or death for workers. Employers must 

take the necessary precautions to safeguard workers.

Exposure to Hazardous Substances 

During spray painting operations, workers are at a greater risk of 

exposure to hazardous substances than when they are painting 

with a brush or roller. Paint particles are released into the 

atmosphere through the spray nozzle, which increases the release 

of hazardous vapors. While safer methods have been developed, 

such as using less volatile and less toxic paints and coatings, and 

low-flow airless spray nozzles, shipyard employers still need to 

take precautions to avoid hazardous exposures to workers. This is 

especially true in confined spaces. 

Shipyard employers are responsible for identifying, evaluating, 

and protecting workers from exposure to respiratory and other 

hazards in the workplace. Where appropriate, employers must 

ensure chemical labels and safety data sheets are made available 

to exposed workers, and train them on the hazards and measures 

necessary to protect themselves. 

For more information on hazard communication requirements 

specific to work performed in the maritime industry, see OSHA 

Fact Sheet — Hazard Communication in the Maritime Industry.

OSHA’s maritime standards specify permissible exposure limits 

(PELs) and other controls to protect workers from chemical hazards 

(29 CFR Part 1915, Subpart Z). However, based on more recent 

science, lower and more protective exposure limits have been 

recommended by many technical, professional, industrial, and 

government organizations, both inside and outside the United States. 

Details can be found at www.osha.gov under Permissible Exposure 

Limits — Annotated Tables. OSHA’s mandatory PELs in the Z-Tables 

remain enforceable. However, the agency recommends that 

employers use the most protective occupational exposure limits to 

better protect their workers.

Fires or Explosions

Spray painting releases significant amounts of flammable and 

combustible vapors into the atmosphere, which increases the 

potential for fires or explosions. A spark from electrical equipment or 

static discharge can be enough to ignite volatile vapors. Employers 

must follow the safety precautions provided in 29 CFR 1915.36

and 1915.35(b) when spray 

painting activities are capable 

of producing a flammable or 

combustible atmosphere. 

Control Measures

Exposure to dangerous 

compounds can be prevented 

by using engineering controls 

and personal protective 

equipment (PPE). However, 

the use of engineering 

controls should be evaluated 

and implemented before 

relying exclusively on PPE for 

protection. Always review the 

manufacturer’s safety data sheet (SDS) for all paints and coatings 

to determine flash points and if other volatile, toxic, or flammable 

substances are in the mixtures.

Photo: OSHA

A worker involved in spray 

painting applications.

Shipyard

Employment Fact Sheet
U.S. Department of Labor t www.osha.gov t (800) 321-OSHA (6742)

Engineering Controls

Engineering controls, such as ventilation, are used to prevent 

worker exposure to hazardous atmospheric conditions and fires or 

explosions. During the spray application of paints or coatings where 

the potential for such hazards exists, a shipyard competent person 

must conduct frequent tests to verify that solvent vapors are at a 

concentration below 10% of the lower explosive limit (LEL). Additionally, 

when using paint mixtures containing highly toxic, flammable, and 

explosive solvents with flash points below 80°F, employers must: 

• Stop painting operations and immediately evacuate exposed 

workers when atmospheric testing indicates that the concentration 

of solvent vapors reaches or exceeds 10% of the LEL. 

• Use exhaust ventilation that is discharged away from working 

areas and potential ignition sources to keep concentrations of 

flammable vapors below 10% of the lower explosive limit and 

prevent fires or explosions. 

• Continue using ventilation after the completion of paint or 

coating applications to dissipate excess vapor concentrations, 

keeping the compartment or space gas free. 

• Retest the atmosphere 10 minutes after ventilation has been 

discontinued to confirm that atmospheric conditions remain at 

an acceptable level.

For additional information on the selection, installation and use of 

ventilation equipment, see OSHA guidance document 3639 — 

Ventilation in Shipyard Employment.

Tools and Equipment

Tools and equipment have the potential to be an ignition source 

in flammable and combustible atmospheres through an electrical 

spark or static discharge. Employers must:

• Confirm that, where paints or coatings in use have flash points 

below 80°F, all tools, equipment, and associated metallic parts 

(e.g., spray guns, paint pots, motors, fans, ventilators, and duct 

work) are electrically bonded and/or grounded to the vessel to 

prevent static discharge. Fan blades and portable air ducts must 

be made of nonferrous material, no ferrous materials may be 

taken into work areas, and all staging and scaffolds must be 

erected in a manner that ensures they are non-sparking.

• Make sure that where paints or coatings in use have flash points 

below 80°F, all motors and control equipment are classified as 

explosion-proof and are properly maintained and grounded.

• Ensure that the metallic parts of air moving devices, such as 

fans, blowers, and jet-type air movers, and all duct work are 

bonded to the vessel’s structure where paints or coatings in use 

are mixed with toxic vehicles or solvents.

• Only permit explosion-proof lighting in work areas, approved by a 

Nationally Recognized Testing Laboratory for use in Class I, Group 

D atmospheres, or approved as permissible by the Mine Safety 

and Health Administration or the U.S. Coast Guard.

• Check that all power and lighting cables are inspected regularly by 

a competent person to verify that the insulation is free of cracks and 

worn spots, lines are not overloaded, and that cables are suspended 

with sufficient slack to prevent undue stress or chafing.

• Prohibit the use of objects or equipment that produce open 

flames or sparks, such as matches, lit cigarettes, cigars or pipes, 

cartridge-type stud guns, and tools used for hot work. Use only 

non-sparking paint buckets, spray guns, and tools.

• Keep electrical connections at least 50 feet or more from paint 

and tank coating operations.1

Each connection within 50 feet of painting operations must be 

evaluated based on the class of the location in which they are 

intended to be used, in addition to the ignitable or combustible 

properties of the specific gas or vapor present (29 CFR 1910.307(c)

(2)). The National Electrical Code, NFPA 70, which defines hazardous 

gases, vapors, and dusts by their ignitable or combustible properties, 

also contains guidelines for determining the type and design of 

equipment and installations approved for a specific hazardous 

(classified) location. Examples of such design principles and 

equipment characteristics may include the use of positive pressure 

ventilation, as well as explosion-proof, non-incendiary, intrinsically 

safe, and purged and pressurized equipment.

Personal Protective Equipment

Employers must assess work activities at their facility to determine 

if hazards are present or likely to be present that require worker 

use of PPE. 29 CFR Part 1915, Subpart 

I, specifies employer responsibilities to 

provide workers with and ensure the use 

of PPE that will adequately protect them 

from the hazards identified. To protect 

workers from hazards associated with 

spray painting operations, employers 

must make sure workers use: 

• Airline respirators with auxiliary selfcontained air supply for emergency 

escape when paint mixed with toxic 

solvents is being applied through 

spray application in confined spaces. 

During exterior spray painting 

operations, use of filter cartridge 

type respirators is required.

• The appropriate PPE, such as 

protective clothing, gloves, goggles, 

and face shields, that prevent air sprayed coatings from 

contacting the worker’s face, eyes, head, hands, feet and other 

exposed skin.

1. On vessels, 29 CFR Part 1910, Subpart S is applied when shore-based electrical 

installations provide power for onboard use (e.g., the power from the electrical system 

comes from shore or from portable electrical generators), but does not apply to 

permanently installed electrical systems on vessels. 

Photo: OSHA

Airline respirator with 

personal protective 

equipment (PPE) to 

prevent skin contact.
U.S. Department of Labor t www.osha.gov t (800) 321-OSHA (6742)

This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards. It does not impose any 

new compliance requirements. For a comprehensive list of compliance requirements of OSHA standards or regulations, refer 

to Title 29 of the Code of Federal Regulations. This information will be made available to sensory-impaired individuals upon 

request. The voice phone is (202) 693-1999; teletypewriter (TTY) number: 1-877-889-5627.

DSG FS-3897 06/2017

• Non-sparking footwear and gloves to prevent static electricity,

as well as coveralls or outer clothing made of cotton, and rubber

gloves, rather than plastic, where paints or coatings in use have

flash points below 80°F.

For additional information on other hazards associated with 

surface preparation and preservation activities, including 

the application of paint and other protective coatings, see 

Safety and Health Injury Prevention Sheet (SHIPS) on Surface 

Preparation and Preservation.

Disposal

• Employers must provide covered metal containers at worksites

for the disposal of scrapings and rags soaked with flammable

compounds.

Emergency Response

In case of a fire, response time is crucial. Employers must: 

• Provide suitable fire extinguishing equipment for each work area

that is immediately available in a state of readiness for instant use.

• Train workers to recognize unsafe conditions, including

significant fire hazards, and procedures to follow in the event

a fire occurs as outlined in the facility’s fire safety plan.

• Ensure workers designated as fire watches are trained in

accordance with 29 CFR 1915.508(c).

State Plans

There are 28 OSHA-approved occupational safety and health state 

plans. State plans are required to have standards and enforcement 

programs that are at least as effective as Federal OSHA standards, 

which may be different or more stringent. More information is 

available at: www.osha.gov/dcsp/osp.

OSHA’s On-site Consultation Program

OSHA’s On-site Consultation Program offers free and confidential 

advice to small and medium-sized businesses in all states, with priority 

given to high-hazard worksites. On-site consultation services are 

separate from enforcement and do not result in penalties or citations. 

For more information or to find the local On-site Consultation office 

in your state, visit www.osha.gov/consultation, or call 1-800-321-

OSHA (6742).

Workers’ Rights

Under federal law, workers are entitled to working conditions that 

do not pose a risk of serious harm.

For more information on how to assure a safe and healthful 

workplace, see OSHA’s Workers page.

How to Contact OSHA

For questions or to get information or advice, to report an 

emergency, fatality, inpatient hospitalization, amputation, or loss 

of an eye, or to file a confidential complaint, contact your nearest 

OSHA office, visit www.osha.gov or call OSHA at 1-800-321-

OSHA (6742), TTY 1-877-889-5627.