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This material is for training purposes only. Its purpose is to inform employers and employees of best practices in occupational safety and health and general OSHA compliance requirements. This material is not a substitute for any provision of the Occupational Safety and Health Act or any standards issued by OSHA.
MODULE FOUR: ANALYZING THE WORKPLACE
Introduction
In the identification phase of the hazard identification and control process we conduct surveys, interview workers, conduct inspections, and review records to determine the presence of hazardous conditions or program weaknesses. Analysis goes a step beyond mere identification. We not only want to determine if hazards exist, we want to know the negative impact that program weaknesses and hazards have on the workplace and what must be accomplished to eliminate or reduce that impact. We can do that if we closely examine each part of a component of a program, each procedure/phase in a process, or each step in a procedure to learn more about how they impact the whole.
 | There are various forms of hazard analysis. In this module we'll review:
- Job Hazard Analysis
- Change Analysis
- Process Hazard Analysis
- Phase Hazard Analysis
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Job Hazard Analysis
This is the most basic and widely used tool for routine hazard analysis. It is sometimes called job safety analysis. The supervisor conducting the analysis (usually the supervisor) can follow these basic steps:
- Meet with the employee before the JHA begins. Ask the employee to help you conduct the JHA by performing the job in the usual manner. It's important that the employee feel comfortable doing work while being monitored.
- Begin by asking the employee to join you in breaking down a job into a series of unique steps in column one of the JHA form. This is best done by describing each step in order of occurrence as you watch an employee performing the job. Make sure you watch at least five to six cycles of the procedure to get an accurate list of steps. It's a good idea to use a videotape recorder so that you and the employee can review the procedure while conducting the rest of the JHA.
- Next, examine each step to determine the hazardous conditions or unsafe work practices that exist or that might occur. Reviewing the job steps and hazards with the employee performing the job will help insure an accurate and complete list. Manufacturer's equipment operating instructions or Material Safety Data Sheets (MSDSs) should also be considered. Remember to think about root causes for each hazard identified so that permanent corrective actions can be made. Make sure you list hazards for all steps in column two of the form before moving on to the next phase of the JHA.
- Now determine whether the hazardous conditions can be eliminated or the job could be performed differently to reduce exposure to the hazards. Would it help to combine steps or change the sequence? Are safety equipment and other precautions needed? If a safer way of performing the job is possible, list each new step, being as specific as possible about the new procedure. If no safer way to perform the job is feasible, determine whether any physical changes will eliminate or reduce the danger. These might include redesigning equipment, changing tools, adding machine guards, using personal protective equipment, or improving ventilation. Establishing a personal hygiene routine may be appropriate where toxic dust is a hazard. Write a brief safe procedure in column three of the JHA form for each step in the job.
- Finally, at the bottom of the form write a new draft standard job procedure that includes each of the safe practices listed in column three. Write the procedure in a step-by-step format in easy-to-read language (preferably about 8th grade level). Assume you are actually demonstrating the procedure to one person. Write the procedure in present tense, first person, active verbs.
For instance, instead of writing, "Ensure leather gloves are worn as the frammel is slowly turned 90 degrees in a counter-clockwise direction using a 3/8" crescent wrench." write, "Use a 3/8" crescent wrench to slowly turn the frammel counter-clockwise 90 degrees. Wear leather gloves to protect your hands as you perform this step."
- After completing the draft standard job procedure, review them with all employees performing the job. Obtaining their ideas about the hazards and proposed changes is an important part of this process. It will help ensure that your proposed changes are sensible and are accepted by the workers you are trying to protect.
Here's a sample form:
XYZ, Inc.
Job Hazard Analysis
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| Date: ____________ |
JHA Number: _________ |
Steps: 1 through 5 |
| Location of Task: |
_______________________________________ |
| Task Description: |
_______________________________________ |
Step 1 Description |
Hazards |
Preventive Measure(s) |
| ____________________ |
____________________ |
____________________ |
Step 2 Description |
Hazards |
Preventive Measure(s) |
| ____________________ |
____________________ |
____________________ |
Step 3 Description |
Hazards |
Preventive Measure(s) |
| ____________________ |
____________________ |
____________________ |
Step 4 Description |
Hazards |
Preventive Measure(s) |
| ____________________ |
____________________ |
____________________ |
Step 5 Description |
Hazards |
Preventive Measure(s) |
| ____________________ |
____________________ |
____________________ |
Safe Job Procedures |
| __________________________________________________________________ |
| __________________________________________________________________ |
| __________________________________________________________________ |
| __________________________________________________________________ |
| __________________________________________________________________ |
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Which is more effective: The inspection or JHA?
The Job Hazard Analysis is more effective in eliminating and reducing injuries and illnesses in the workplace because it not only uncovers hazardous conditions, it also identifies unsafe work practices and procedures. The walk-around inspection, just by the nature of the process, limits the time an inspector can give to analyzing work practices. Consequently, the inspection emphasizes assessing for conditions. Unfortunately, most accidents are the result of unsafe practices and procedures.
The JHA, on the other hand, does take the time necessary to critically analyze each step of a job for both hazardous conditions and unsafe practices. The result is that most of the causes for accidents are discovered and changes made to prevent their occurrence. An effective JHA has the potential of significantly reducing injury and illness rates in the workplace.
The JHA may also be used by the employer as a training tool. In fact, the JHA can become a very useful lesson plan for conducting on-the-job training on hazardous tasks for new employees.
Change Analysis
Anytime you bring something new into your worksite, whether it be a piece of equipment, different materials, a new process, or an entirely new building, you unintentionally may introduce new hazards. If you are considering a change for your worksite, you should analyze it thoroughly beforehand.
Change analysis is cost-effective in terms of the human suffering and financial loss it prevents. Moreover, heading off a problem before it develops usually is less expensive than attempting to fix it after the fact.
An important step in preparing for a worksite change is considering the potential effect on your employees. Individuals respond differently to change, and even a clearly beneficial change can throw a worker temporarily off-balance -- literally as well as figuratively -- and increase the risk of accidents. You will want to inform all affected employees of the change, provide training as needed, and pay attention to worker response until everyone has adapted.
Building or Leasing a New Facility
Even something as basic as a new facility needs to be reviewed carefully to identify hazards it might pose. A design that seems to enhance production of your product and appears delightful to the architect may be a harmful or even fatal management decision. Have safety and health experts take a careful look beforehand at all the design/building plans.
When leasing a facility that was built for a different purpose at an earlier time, the risk of acquiring health and safety problems is even greater. You should make a thorough review of the actual facility, plus the blueprints or plans for any renovations. One of the most obvious concerns in acquiring an existing facility is whether asbestos insulation is present and whether it is friable (flaking off in tiny particles). But you also may discover that something as easy to fix as a loose stair railing has gone unnoticed in the rush to renovate production areas. Save frustration, money, and lives: Have expert safety and health professionals involved in the planning of any facility construction, purchase, or lease.
Installing New Equipment
An equipment manufacturer does not know how its product will be used at your worksite. Therefore, you cannot rely totally on the manufacturer to have completely analyzed and prepared controls or safe procedures for the product. Moreover, if the equipment is produced in a foreign country, it may not meet clear requirements of U.S. standards and laws. Therefore, involve health and safety professionals in the purchase decision and in the installation plans.
Many companies also provide a period to test newly installed equipment. The company assigns its most experienced operators to watch for hidden hazards in the operations before full production begins. As with new facilities, the sooner flaws are detected, the easier and cheaper the corrections are likely to be.
Using New Materials
Before introducing new materials to your production processes, research the hazards that the materials themselves present. Also try to determine any hazards that may appear due to the processes you plan to use with the materials.
In many instances, the place to start will be the manufacturer's Material Safety Data Sheet. An MSDS is required for all materials containing hazardous chemicals. It should arrive with each shipment. The MSDS should provide the information an industrial hygienist needs to analyze the hazard a chemical presents and to prevent or control it.
Some traditional materials, such as lead in paint, are dangerous to use but are replaceable with less hazardous mixtures. For other materials, you may not be able to find adequate substitutes. You may need to establish controls for the hazards these materials present.
Starting Up New Processes
New processes require workers to perform differently. Consequently, new hazards may develop even when your employees are using familiar materials, equipment, and facilities. Carefully develop safe work procedures for new processes. After the operators have become familiar with these procedures, perform routine hazard analysis (discussed below) to discover any hidden hazards.
Analyzing Multiple Changes
Often a big change is composed of several smaller changes. When you begin producing a new product, chances are you will have new equipment, materials, and processes to monitor. Make sure each new addition is analyzed not only individually, but also in relation to the other changes.
Once you have analyzed the changes at your worksite, add this information to your basic inventory of hazards. This inventory is the foundation from which you design your hazard prevention and control program.
Process Hazard Analysis
What Is a "Process" for the purpose of this analysis? A process can be defined as any series of actions or operations that convert raw material into a product. The process can terminate in a finished product ready for consumption or in a product that is the raw material for subsequent processes.
A process hazard analysis is a detailed study of a process to identify every possible hazard to employees. Every element of the process must be studied. Each action of every piece of equipment, each substance present, and every move made by an employee must be assumed initially to pose a hazard to employees. Process hazard analysis then is applied to show that the element either:
- Poses no hazard,
- Poses a hazard that is controlled in every foreseeable circumstance, or
- Poses an uncontrolled hazard.
Often the process hazard analysis will concentrate on the specialized equipment used in the process. The equipment may be used to:
- Move materials;
- Apply mechanical forces to change materials;
- Apply special forms or concentrations of energy to materials (e.g., ionizing radiation, magnetic or electric fields, and lasers);
- Mix materials; or
- Bring and hold materials together and contain them, under either ambient or special conditions, for chemical or biological reactions, etc.
The best time for an employer to conduct a process hazard analysis is when the process is first being designed, before equipment is selected. This review, in turn, will assist you in choosing process equipment for its effective, efficient, and safe operation. Be sure to consider the equipment's capacity for confining the process within predetermined safe limits. The type, number, and location of detectors you select for monitoring the process should ensure not only productive operation, but also safe operation. Remember to take into account any substance or mixture of substances that could present fire or explosion hazards.
When you have selected your equipment, the information from the process hazard analysis will help you to develop an appropriate inspection and maintenance schedule.
Who Should Do the Process Hazard Analysis?
OSHA believes that a team approach is the best approach for performing a process hazard analysis, because no one person will possess all of the necessary knowledge and experience. Additionally, when more than one person is performing the analysis, different disciplines, opinions, and perspectives will be represented, and additional knowledge and expertise will be contributed to the analysis. At least one member of the team should be an employee who has experience with and knowledge of the process being evaluated. (The Process Safety Management of Highly Hazardous Chemicals standard deals with the makeup of the process hazard analysis team at 29 CFR 1910.119(e).)
Remember, even when a process initially appears to be so simple that hazard analysis during the design phase seems unnecessary, it needs to be done anyway. If the process is simple, and there are no known potential hazards, then the process hazard analysis likewise will be simple and will require very little time and expense. On the other hand, if things are not as simple as they seem, the analysis may reveal potential problems that might have been overlooked otherwise. Correction at this early stage will save time, money, and possible injuries and grief.
Process hazard analysis will include hazards associated with:
- Mechanical and chemical operations,
- Low and high temperature and pressure operations,
- Possible high levels of radiant energy,
- Direct contamination of employees, and
- Contamination of the air with toxic substances.
Preparing for the Unplanned Event
Especially when dealing with high hazard chemicals or volatile explosives, it is not enough to analyze only those hazards associated with normal operations, those times when the process works as expected. Using analytical tools such as "what if," "checklist," hazard and operability study (HAZOP), failure mode and effect analysis (FMEA), or "fault-tree" analysis, you can determine most of the possible process breakdowns. You then can design prevention/controls for the likely causes of these unwanted events.
For additional information on Process Hazard Analysis, see OSHA's Process Safety Management of Highly Hazardous Chemicals standard, 1910.119 and OSHA Publication 3133 (Revised 1994), "Process Safety Management - Guidelines for Compliance."
Phase Hazard Analysis
Phase hazard analysis is a helpful tool in construction and other industries that involve a rapidly changing work environment, different contractors, and widely different operations. A phase is defined as an operation involving a type of work that presents hazards not experienced in previous operations, or an operation where a new subcontractor or work crew is to perform work. In this type of hazard analysis, before beginning each major phase of work, the contractor or site manager should assess the hazards in the new phase. He/she should not only coordinate appropriate supplies and support, but also prepare for hazards that can be expected and establish a plan to eliminate or control them.
To find these hazards and to eliminate or control them, you will use many of the same techniques that you use in routine hazard analysis, change analysis, process analysis, and job analysis. One major additional task will be to find those hazards that develop when combinations of activities occur in close proximity. Workers for several contractors with differing expertise may be intermingled. They will need to learn how to protect themselves from the hazards associated with the work of nearby colleagues as well as the hazards connected to their own work and the hazards presented by combinations of the two kinds of work.
When should the project phase analysis occur?
Well, you may have your own ideas about this, but when considering the entire project, it's best to conduct a thorough pre-planning phase analysis that involves all contractors (if possible) in the process. The sooner you can anticipate and respond to potential hazards, the better. At the beginning of each phase, an additional phase analysis would also be appropriate to make sure all contingencies have been addressed.
Putting it all together
Job hazard analysis, process hazard analysis, and phase analysis are all important tools you can use to make the workplace safe and healthful for workers. Remember, the analysis process begins with having industrial hygiene, safety, and occupational health experts conduct comprehensive assessments of your worksite to help you initially determine the existing and potential hazards.
Well, that's a lot of information to absorb. But there's light at the end of the tunnel...it's time to take the module quiz.
Take the Quiz
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