Using Job Hazard Analysis (JHA) to Meet OSHA Regulatory Requirements

Editor’s note: This article summarizes a recent Risk Strategies webinar based on OSHA content. For additional details, please refer to OSHA's Job Hazard Analysis documentation, OSHA 3071.

Navigating OSHA regulations to maintain a safe work environment can seem daunting. However, a Job Hazard Analysis (JHA) offers a practical framework to safeguard your construction or manufacturing workforce. A JHA systematically identifies and addresses potential risks, so your team can perform their tasks confidently, without exposure to unnecessary dangers.

What is a Job Hazard Analysis?

JHA is an occupational safety tool applicable across industries and work environments. It pinpoints potential hazards before they result in accidents by examining the relationship between workers, tasks, tools, and the environment. A JHA enables you to take proactive steps to eliminate or mitigate risks.

A well-executed JHA goes beyond meeting regulatory requirements by driving behavioral change at every organizational level to foster a safety culture.

Jobs that require a JHA

Not all jobs present the same level of risk. While everyone can benefit from a JHA, focus first on jobs that:

• Have high injury or illness rates.
• Result in severe or disabling injuries from human error.
• Involve new processes or significant changes.
• Require detailed written instructions.

By conducting a JHA, you help ensure your working environment is safe for all employees.

Examining hazard sources, uncovering hidden dangers

You might think a JHA is unnecessary if your worksite appears to have minimal or no hazards. But a closer examination of your employees' daily tasks might reveal hidden risks often overlooked. What may seem like routine or harmless aspects of the job could unexpectedly lead to a severe accident. Conducting a JHA helps uncover these potential dangers, ensuring proactive measures are in place to prevent incidents.

Hazards can arise from numerous sources:

• Physical risks: Falls, confined spaces, moving equipment, pinch points, crushing hazards, or damage from repetitive motions.
• Chemical exposures: Solvents, acids, pesticides, or airborne particulates.
• Environmental factors: Weather, fire/explosion risks, or poor mobility access.
• Human factors: Inadequate training, fatigue, or physical limitations.

By categorizing potential hazards, you can systematically evaluate your workplace and identify areas for improvement.

Conducting a JHA: a step-by-step guide

The first step in the JHA process is to recognize and accept that your workspace may contain hazards. From there, the process unfolds, with each step playing a vital role in identifying, mitigating, and ultimately controlling potential risks:

1. Identify hazardous conditions: Evaluate work processes comprehensively. Even if past practices have seemed safe, set aside your assumptions and look at your worksite with fresh eyes.
2. Determine root causes: Pay attention to how long workers are exposed to a particular risk.
   • Talk with them to find out what they think is the most hazardous part of their job, and ask if what you observed them doing is typical.
   • List all potential hazards as a part of your evaluation (high risk and low risk).
   • Determine underlying factors causing the hazards, such as inadequate supervision, poor training, or unsafe equipment.
3. Eliminate hazards and implement control measures: Develop strategies to eliminate or manage hazards using the hierarchy of controls.
4. Evaluate effectiveness: Periodically assess how well the newly implemented controls are working. Incorporate employee feedback.

Other elements of a successful JHA program

• Management support: Have leadership endorse and participate in the JHA process.
• Documentation and monitoring: Maintain detailed records of JHA processes and track results.
• Proactive communication: Initiate daily briefings for all staff to share their experience running the JHA and to reinforce safety awareness.

Hierarchy of controls

The hierarchy of controls phase comes during the eliminate hazards and implement control measures segment of the JHA. This framework from the National Institute for Occupational Safety and Health (NIOSH) helps you decide hazard mitigation strategies. You want to adopt the lowest number solution that’s feasible (1 is ideal):

1. Elimination: Remove the hazard completely.
2. Substitution: Replace hazardous elements with safer alternatives.
3. Engineering controls: Reduce or prevent hazards from coming into contact with workers. This can involve modifying equipment or the workspace.
4. Administrative controls: Establish work practices that reduce the duration, frequency, or intensity of exposure to hazards, including:
   • Work process training
   • Job rotation
   • Adequate rest breaks
   • Limiting access to hazardous areas or machinery
   • Adjusting line speeds
5. Personal protective equipment (PPE): Provide gear to minimize exposure to hazards, such as gloves, hard hats, and other wearable protective items. This is a last resort if no other controls are available or possible, as it doesn’t provide a permanent solution to the hazard.

While elimination and substitution are the most effective controls, they can be challenging to implement in existing operations due to the need for substantial process changes. As you design new processes, incorporating the right controls from the outset can prevent illness, injuries, and business interruption.

Prioritize safety for all

JHA is a transformative process that reduces operational risks. By systematically identifying hazards and implementing controls, you can protect your workers, improve efficiency, and maintain compliance with regulatory standards.

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Connect with the Risk Strategies Risk Management Services team at safety@risk‐strategies.com.