Regardless of industry, all employers must provide employees with a safe and healthy working environment, free from recognized hazards. While some perils are obvious, like toxic chemicals and dangerous machinery, other threats, such as heavy office files or poor lighting, can be covert. In these instances, dangers are often only recognized once it's too late and someone is hurt.
Among the many strategies used to mitigate dangerous workplace conditions, Job Hazard Analyses (JHA) stand out as a successful tool for identifying and addressing potential hazards before they escalate into accidents or injuries. This article will explore the JHA model, its significance, and how organizations can effectively implement JHAs to promote a safe and healthy work culture.
What is a Hazard?
Defining a hazard is essential to understanding how JHAs can improve workplace safety. According to the Occupational Safety and Health Administration (OSHA), a hazard is the potential for harm. In practical terms, a hazard is often associated with a condition or activity that, if left uncontrolled, can result in an injury or illness. Workplace hazards include things like chemicals, energized equipment, ergonomics, working from heights, moving objects, and environmental threats like noise, heat, and lighting.
What is Job Hazard Analysis (JHA)?
A Job Hazard Assessment (JHA), sometimes called a Job Hazard Analysis or Job Safety Analysis (JSA), is a technique that focuses on job tasks, activities, and the work environment to identify hazards before they occur. There are several different methods for conducting a JHA. One of the most common methods is a simple form that identifies the individual tasks of the job alongside the uncontrolled hazards of each task.
Once hazards are identified, the hierarchy of controls should be followed to eliminate or reduce the hazard to an acceptable risk level.
The hierarchy of controls, from most effective in hazard reduction to least, includes:
Elimination: The best way to control a hazard is to eliminate it altogether. Evaluate each hazard and determine if employees can complete their work without it. For example, does the job task need a toxic chemical for a desired outcome? If the answer is no, remove the dangerous product.
Substitution: If the hazard cannot be eliminated, determine if there is a safer alternative. Using the toxic chemical scenario, is there an alternative, non-toxic solution that can be swapped for the toxic one?
Engineering Controls: When hazards cannot be removed, engineering controls should be used to isolate workers from danger, such as increasing ventilation in areas where the toxic chemical is used.
Administrative Controls: These controls are often used with other risk-reduction techniques and include strategies to educate workers. These controls involve implementing safe work policies, employee training, and warning signs of potential dangers.
Personal Protective Equipment (PPE): PPE should be used only after all the previous controls have been attempted to eliminate or reduce hazards. For example, employers should only provide respirators to protect workers from toxic chemicals after the previous controls have been exhausted.
When is a JHA Required?
Many employers ask whether a JHA is a compliance requirement or a safety best practice. The answer is a bit complicated. While no blanket rule applies to all employers, OSHA states that JHAs are "one component of the larger commitment of a safety and health management system." In other words, completing JHAs can signify an employer's commitment to workplace safety. Furthermore, OSHA has two broad requirements related to JHAs.
First, the General Duty Clause in the OSHA Act of 1970 states that employers must provide a safe work environment free from recognized hazards that are causing or likely to cause death or serious physical harm to employees. This clause doesn't specify the need for JHAs, but using them is a successful way to document efforts to identify and mitigate workplace hazards to ensure compliance with the rule.
Second, OSHA has a Personal Protective Equipment (PPE) standard 1910.132 that requires employers to conduct a workplace hazard assessment to identify the dangers present or that are likely to be present, which would necessitate the need for PPE. While a PPE Assessment is similar to a JHA in that employers must identify workplace hazards, this standard only looks at PPE as a means to control hazards and does not consider the more effective mitigation methods outlined in the Hierarchy of Controls. Employers that utilize JHAs will find that their use will comply with both OSHA General Duty Clause and PPE requirements.
Depending on industry, work activities, or state laws, some employers may find that some rules specify that JHAs are required. For example, employers with jobs involving bloodborne pathogen exposure, such as healthcare workers, will find that JHAs are part of their exposure control plans. Some state safety agencies, like those in Washington and California, also require using JHAs to help build mandatory safety and health programs.
Using JHAs to Identify Safety-Sensitive Positions
Recently, Washington passed a new law, RCW 49.44.240, that prohibits employers from basing hiring decisions on drug test results showing non-psychoactive cannabis metabolites. There are exemptions to this rule, including occupations requiring federal background checks or security clearance, positions within law enforcement, fire services, first responders, aerospace industries, correctional facilities, and safety-sensitive positions.
While the rule clarifies that safety-sensitive positions are jobs where working while impaired "presents a substantial risk of death" and that employers must identify these positions before an applicant applies, the rule does not provide a detailed list of affected job titles. Instead, it is up to the employer to identify the positions within its organization that meet this level of risk criteria and update the job descriptions with the safety-sensitive designation. Using JHAs for this purpose is a fantastic way to document the reasoning behind the classification decision, as they will show the hazards associated with each job.
Additional Benefits of JHAs
Some additional benefits of using JHAs include:
Incident Prevention: JHAs enable organizations to identify potential hazards before accidents or injuries occur. Employers can anticipate risks and take preventive measures by systematically analyzing tasks and processes before people get hurt.
Enhanced Safety Culture: This tool demonstrates the organization's commitment to employee safety. Furthermore, involving employees in identifying and addressing hazards also helps them become more aware of potential risks and take proactive measures to maintain a safe workplace.
Financial Advantages: By identifying and mitigating hazards proactively, organizations can significantly reduce the frequency and severity of workplace incidents. This, in turn, leads to lower injury rates, decreased workers' compensation costs, and improved productivity. Lower incident rates can also help secure more contracts for employers who use rates when submitting project bids, such as contractors. If this wasn't enough, employers with low frequency and severity rates can also take advantage of state safety incentive programs, often resulting in rebates on insurance costs or waivers on scheduled compliance inspections.
Achieving Success
Employers usually have good intentions when it comes to workplace safety. However, the road to failed safety practices is often paved with good intentions. For JHAs to effectively reduce workplace hazards, organizations should consider the following strategies:
Involve Employees: The JHA process should tap into the workplace's talent. This means involving employees at all levels in the JHA process. Employees have valuable insight into job hazards and can provide helpful input on effective control measures. Additionally, involving employees can create a sense of ownership in the safety culture.
Review and Update Regularly: Work hazards can change due to new equipment, processes, environmental conditions, and even new employees. It's essential to review and update JHAs regularly to account for changes.
Use with Safety Programs: Combining JHAs with existing safety programs helps ensure programs account for all potential risk scenarios and that mitigation efforts are part of daily work practices. Additionally, they are a fantastic tool for new hire orientations to help employees learn job activities, potential dangers, and how to protect themselves and others.
Seek Improvement: Employers should treat JHAs as a dynamic process that evolves with changing workplace conditions and employee feedback. Employers can encourage continuous process and safety improvement by soliciting input, reviewing incident trends and inspection reports, and revising JHAs accordingly.
Want More? Archbright Can Help!
Organizations can create a safer work environment by systematically identifying, assessing, and mitigating hazards. This can help keep employers' safety programs compliant and prevent workplace incidents and injuries.
Eligible Archbright members have access to several JHA templates in the mozzo Resource Library. Members are encouraged to contact the Safety Hotline or mozzo Chat to speak with an available Safety Consultant for additional support. For more information on membership, contact info@Archbright.com.