OSHAcademy Online Occupational Health and Safety Training Course 706.4 - Listing Preventive Measures in a Job Hazard Analysis (JHA)

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This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirements and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency.

MODULE 4: DEVELOP PREVENTIVE MEASURES

Introduction

After reviewing your list of hazards with the employee, next consider using hazard control methods that will eliminate or reduce them. There are two primary strategies to permanently or temporarily reduce the risk of injury. Each of these strategies employs a number of methods.

Hazard Control Strategies

Information obtained from a job hazard analysis are most useful when hazard control measures are developed and incorporated into the job. Everyone needs to recognize that not all hazard control strategies are equal. Some are more effective than others at reducing the risk in the job.

Remember, a very basic hazard control principle is that we must either (1) eliminate the hazard or (2) the exposure to the hazard. The second principle is that it's more effective to eliminate the hazard, if you can, than to control exposure to the hazard. After all, if you can get rid of the hazard, you don't have to manage the exposure. These two important principles guide safety and health professionals in constructing a "hierarchy" of hazard control strategies. Let's take a look at two important hazard control strategies and how they are prioritized:

Traditionally, a hierarchy of controls has been used as a means of determining how to implement feasible and effective controls. ANSI Z10-2005, Occupational Health and Safety Management Systems, encourages employer employ the following hierarchy of hazard control strategies:

Elimination
Substitution
Engineering controls
Administrative controls
Personal protective equipment

The idea behind this hierarchy is that the control methods at the top of the list are potentially more effective and protective than those at the bottom. Following the hierarchy normally leads to the implementation of inherently safer systems, ones where the risk of illness or injury has been substantially reduced. Let's take a closer look at the hierarchy of control strategies.

Elimination and Substitution

Elimination and substitution, while most effective at reducing hazards, also tend to be the most difficult to implement in an existing process. If the process is still at the design or development stage, elimination and substitution of hazards may be inexpensive and simple to implement. For an existing process, major changes in equipment and procedures may be required to eliminate or substitute for a hazard.

These strategies are considered first because they have the potential of completely eliminate the hazard, thus greatly reducing the probability of an accident. Redesigning or replacing equipment or machinery may be expensive, but remember the average direct and indirect cost of a lost-work injury can be over $50,000 and easily over $1 million to close a fatality claim.

Some examples of these two strategies include:

Removing the source of excessive temperatures, noise, or pressure
Substituting a toxic chemical with a less toxic or non-toxic chemical

Engineering Controls

The most effective strategy is to "engineer the hazard out" by using control methods that physically change a machine or work environment. If, during the JHA, you discover a hazard that can be engineered out, do it. Turn the dangerous step into a safe step that doesn't require safety precautions. Methods to eliminate or reduce hazards may include:

Eliminating/reducing the hazard -- Designing the facility, equipment, or process to remove the hazard, or substituting processes, equipment, materials, or other factors to lessen the hazard;
Enclosing the hazard using enclosed cabs, enclosures for noisy equipment, or other means;
Isolating the hazard with interlocks, machine guards, blast shields, welding curtains, or other means; and
Removing or redirecting the hazard such as with local and exhaust ventilation.

Administrative Controls

This is the "next best" strategy, if engineering control methods are insufficient. Since we can't get rid of the hazard in a JHA step, we'll need to manage exposure to it with safety precautions. Why are administrative controls lower on the hierarchy of controls? To work, administrative controls must rely on appropriate human behavior. According to Arthur Bloch's Murphy's Law - Book Two, "any system relying on human behavior is inherently unreliable." That's the problem. Human's can be rather unpredictable. Methods to eliminate or reduce employee exposure to hazards include:

Developing new policies, procedures, and practices to reduce frequency/duration and of exposure
Using personal protective equipment (PPE) as a safe work practice
Revising work schedules to reduce the frequency/duration of exposure
Monitoring the use of highly hazardous materials
Alarms, signs, and warnings
Buddy system
Training

Note: Administrative controls may also be referred to as "work practice" controls in other safety-related literature.

In a best case scenario, you might be able to eliminate the need for administrative controls if hazards can be eliminated through the use of engineering controls. The more reliable or less likely a hazard control method can be circumvented, the better. Bottom line: If you can get rid of the hazard, you don't have to manage exposure!

Personal Protective Equipment

Many procedures developed with a JHA will include the need to use PPE. Examples of PPE include respirators, hearing protection, protective clothing, safety glasses, and hardhats. PPE, as an administrative control strategy, is acceptable as a control method in the following circumstances:

When engineering controls are not feasible or do not totally eliminate the hazard
While engineering controls are being developed
When safe work practices do not provide sufficient additional protection
During emergencies when engineering controls may not be feasible.

Use of one hazard control method over another higher in the control precedence may be appropriate for providing interim (temporary) protection until the hazard is abated permanently. In reality, if the hazard cannot be eliminated entirely, the adopted control measures will likely be a combination of control methods used together.

Involve employees

However you decide to correct the hazards you've identified during the JHA, be sure to discuss your ideas with all employees who perform the job and consider their responses carefully. If you plan to introduce new or modified job procedures, be sure they understand what they are required to do and the reasons for the changes. The number one reason employees do not follow procedures is because they just don't know why the procedures are important.

Now let's take a look at what our sample JHA looks like now that we've identified some hazards and their related preventive measures in each step.

Sample JHA Worksheet

Job Description: Loading an empty trailer with pallets of product

Basic Job Step	Hazards - Possible Injuries	Preventive Measures
1. Ensure that trailer is correctly spotted.	Worker could be caught between backing trailer and dock Worker could fall from the dock.	Stay clear of the doorway while the trailer is being backed onto the dock. Keep others away from the area. Remove awareness chain or bar from the front of the dock door once the trailer is properly spotted.
2. Chock wheels; place jacks under trailer nose.	Worker could fall on stairs going to dock well. Head could be struck against trailer. Worker could slip on ice or snow.	If the truck driver has not chocked the wheels, go down tile ramp/stairs to the dock well and chock the wheels. Use caution when walking on snow or ice. Hold onto hand rails; use ice-melt chemical if needed. When placing the chock, avoid bumping the head on the underside of the trailer. Place jacks under the nose of the trailer. If the dock is equipped with an automatic trailer restraint, push the button to activate the device.
Safe Job Procedure

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