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Vehicle Painting Process

  • Issued: October 5, 2016
  • Content last reviewed: October 2016

Disclaimer: This resource has been prepared to help the workplace parties understand some of their obligations under the Occupational Health and Safety Act (OHSA) and regulations. It is not legal advice. It is not intended to replace the OHSA or the regulations. For further information please see full disclaimer.

Hazard summary

The application of rubberized coatings to the painted surface of vehicles and/or vehicle components (rims, spoiler) is a relatively new and emerging trend in the vehicle customization field. This coating is available in numerous colours and finishes including clear. The coating is used to protect the painted surface or to change the appearance of the vehicle. The coating is applied using an air gun or an aerosol can.

The use of this product is increasing in the vehicle customization field as it is a cost-effective alternative to traditional painting (minimal surface preparation when compared to traditional vehicle painting process). Another reason for the gaining popularity is that the rubberized coating can be easily removed by peeling off in sheets, much like removing an adhesive sticker.

While increasingly popular, the process of applying this rubberized coating may pose a hazard to workers as the product is a flammable liquid that may be ignited by heat, sparks, flames or static electricity that could be found in the workplace.

Hazard location

This product may be found at any workplace where automotive finishes are applied including automotive detailing, body shops, and service garages.


An area of a workplace where flammable liquids are in use must be kept free of any source of ignition including heat, sparks, flame or static electricity.

In Regulation 851 (Industrial Establishments) under the Occupational Health and Safety Act (OHSA), “flammable liquid” is defined to mean a liquid having a flash point below 37.8° Celsius, and a vapour pressure below 275 kilopascals absolute at 37.8° Celsius [section 1]. The rubberized coating described above falls within the definition of flammable liquid.

Legal requirements

Regulation 851 (Industrial Establishments)

Under section 22 of Regulation 851:

  • (1) Subject to subsections (2), (3) and (4), where not required for immediate use, flammable liquids shall be,
  • (a) in sealed containers; and
  • (b) located,
    • (i) outdoors and remote from any means of egress,
    • (ii) in a building not used for any other purpose, or
    • (iii) in a room,
      • (A) separated from the rest of the building with partitions having,
        • 1. at least a one-hour fire-resistance rating, and
        • 2. self-closing doors, hinged to swing outwardly on their vertical axes,
      • (B) equipped with,
        • 1. a drain connected to a dry sump or holding tank, and
        • 2. liquid-tight seals between interior walls and floor and a liquid-tight ramped sill at any door opening, which is not in an exterior wall, and
      • (C) having natural ventilation to the outdoors by upper and lower exterior wall gravity louvres.
  • (2) Where not required for immediate use, flammable liquids,
    • (a) in opened containers; or
    • (b) having a flash point below 22.8° Celsius and a boiling point below 37.8° Celsius, shall,
    • (c) comply with the requirements of clause (1) (b);
    • (d) be stored in facilities having no potential source of ignition; and
    • (e) when located in a room, be located in a room equipped with,
      • (i) explosion venting to the outdoors, and
      • (ii) a spark resistant floor.
  • (3) A maximum of 235 litres of flammable liquids may be stored,
    • (a) in sealed containers of not more than twenty-three litre capacity each; or
    • (b) in a metal cabinet of double walled construction with a 3-point door latch and a liquid-tight door sill raised at least fifty millimetres above the floor.
  • (4) An area where flammable liquids are dispensed shall have,
    • (a) mechanical ventilation from floor level to the outdoors at the rate of eighteen cubic metres per hour per square metre of floor area; and
    • (b) containers and dispensing equipment bonded and grounded when flammable liquid is dispensed.

Under section 23 of Regulation 851:

  • A portable container used for dispensing flammable liquid in a work area shall be made of material suitable to provide for the safety of all workers and have,
    • (a) a spring-loaded cap; and
    • (b) a flame arrestor.

Under section 63 of Regulation 851:

  • A process that is likely to produce a gas, vapour, dust or fume, to such an extent as to be capable of forming an explosive mixture with air shall be carried out in an area which has provision for safe disposal by burning under controlled conditions or in an area which,
    • (a) is isolated from other operations;
    • (b) has a system of ventilation adequate to ensure that the gas, vapour, dust or fume does not reach a hazardous concentration;
    • (c) has no potential sources of ignition;
    • (d) has provision for explosion venting; and
    • (e) has, where applicable, baffles, chokes or dampers to reduce the effects of any explosion.

Under section 127 of Regulation 851:

  • An industrial establishment shall be adequately ventilated by either natural or mechanical means such that the atmosphere does not endanger the health and safety of workers [section 127].

Occupational Health and Safety Act

Relevant provisions under the OHSA include the following sections.

Under section 25 of the OHSA, the employer must:

  • take every precaution reasonable in the circumstances to protect workers [clause 25(2)(h)]
  • provide information, instruction and supervision to protect the health and safety of the worker [clause 25(2)(a)]
  • ensure the measures and procedures prescribed (i.e. required by the regulations) are carried out in the workplace [clause 25(1)(c)]
  • acquaint a worker or a person in authority over a worker with any hazard in the work and in the handling, storage, use, disposal and transport of any article, device, equipment or a biological, chemical or physical agent [clause 25 (2)(d)].

Under section 27 of the OHSA, the supervisor must:

  • ensure that a worker works in a manner and with the protective devices, measures and procedures required by the Act and its regulations [clause 27(1)(a)]
  • advise a worker of the existence of any potential or actual danger to the health or safety of the worker of which the supervisor is aware [clause 27(2)(a)]
  • take every precaution reasonable in the circumstances for the protection of a worker [clause 27(2)(c)].

Under section 28 of OHSA, a worker must:

  • work in compliance with the provisions of the Act and its regulations [clause 28(1)(a)].

Regulation 860 (Workplace Hazardous Materials Information System)

Under section 6 of Regulation 860 (Workplace Hazardous Materials Information System (WHMIS)):

  • (1) An employer shall ensure that a worker who works with or who may be exposed in the course of his or her work to a hazardous product received from a supplier is informed about all hazard information the employer receives from the supplier concerning the hazardous product and all further hazard information of which the employer is or ought to be aware concerning its use, storage and handling.

Under section 17 of Regulation 860:

  • (1) An employer who receives a hazardous product from a supplier for use, storage or handling at a workplace shall obtain a supplier safety data sheet for the hazardous product from the supplier unless the supplier is exempted under the Hazardous Products Regulations (Canada) from providing a safety data sheet for the hazardous product.

Note: Recent amendments to the OHSA and the WHMIS Regulation (Regulation 860) made under the OHSA adopt new, international standards that are part of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

The amendments to the OHSA and WHMIS Regulation affect various requirements governing labels and safety data sheets for hazardous workplace chemicals. Also affected are definitions, terminology and provisions that protect confidential business information related to hazardous workplace chemicals. The changes reflect amendments to the federal Hazardous Products Act and new Hazardous Products Regulations, which came into force February 11, 2015.

The new requirements in the OHSA and WHMIS Regulation came into effect July 1, 2016. To give workplace parties time to adjust to the new requirements, there will be a transition period to gradually phase out the old requirements.

  • Employers have until May 31, 2018 to continue to receive and use hazardous products with either the old WHMIS labels and safety data sheets or the new ones.
  • Employers have from June 1, 2018 to November 30, 2018 to bring any hazardous products still in the workplace with the old WHMIS labels and safety data sheets into compliance with the new requirements.
  • By December 1, 2018, the transition to the new WHMIS labels and safety data sheets must be complete. During the transition, employers must ensure workers are trained on both the old and new labels and safety data sheets for as long as both are present in the workplace.

For more information

Disclaimer: This web resource has been prepared to assist the workplace parties in understanding some of their obligations under the Occupational Health and Safety Act (OHSA) and the regulations. It is not intended to replace the OHSA or the regulations and reference should always be made to the official version of the legislation.

It is the responsibility of the workplace parties to ensure compliance with the legislation. This web resource does not constitute legal advice. If you require assistance with respect to the interpretation of the legislation and its potential application in specific circumstances, please contact your legal counsel.

While this web resource will also be available to Ministry of Labour inspectors, they will apply and enforce the OHSA and its regulations based on the facts as they may find them in the workplace. This web resource does not affect their enforcement discretion in any way.