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 6: IMPROVING THE JHA PROCESS
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Introduction
Periodically reviewing your job hazard analysis ensures that it remains current and continues to help reduce workplace accidents and injuries. Even if the job has not changed, it is possible that during the review process you will identify hazards that were not identified in the initial analysis.
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It is particularly important to review your job hazard analysis if an illness or injury occurs on a specific job. Based on the circumstances, you may determine that you need to change the job procedure to prevent similar incidents in the future. If an employee's failure to follow proper job procedures results in a "close call," discuss the situation with all employees who perform the job and remind them of proper procedures. It may also be possible that the problem is with the procedure. Maybe it needs to be changed. Talk with employees about their reasons for the apparent unsafe behavior. You might be surprised to learn they have been "trapped" into doing the task that way. On the other hand, discipline may be appropriate if the safety management system has not failed the employee (the employer is meeting all safety obligations). Any time you revise a job hazard analysis, it is important to train all employees affected by the changes in the new job methods, procedures, or protective measures adopted.
When is it appropriate to hire a professional to conduct a job hazard analysis?
If your employees are involved in many different or complex processes, you may need professional help conducting your job hazard analyses. Sources of help include your insurance company, the local fire department, and private consultants with safety and health expertise. Some state OSHA agencies may offer assistance through consultation services.
Even when you receive outside help, it is important that you and your employees remain involved in the process of identifying and correcting hazards because you are on the worksite every day and most likely to encounter these hazards. New circumstances and a recombination of existing circumstances may cause old hazards to reappear and new hazards to appear. In addition, you and your employees must be ready and able to implement whatever hazard elimination or control measures a professional consultant recommends.
What does an improved JHA look like?
To improve the JHAs and its related SJP, think about the "ergonomics" of the job. Find ways to further reduce lifting, lowering, pushing, pulling, carrying, throwing, holding, twisting, or tasks using force. A SJP should remove any unnecessary actions and prevent the need to do things more than once if possible. There should be a little heavy carrying as possible and also include rest breaks if needed. If feasible, provide mechanical aids such as hoists, adjustable workbenches, and hooks. Make sure tools and equipment are position so that they are in easy reach.
What are some tips to improving the JHA?
A solid JHA improvement process will make good use the experience and knowledge of workers and subject matter experts (SMEs) various safety and health specialties to review the tasks and identify new hazards.
SMEs provide a level of involvement as experts in their field to review the tasks and the hazards identified to determine the proper set of controls required. Workers and SMEs can also help improve the methods to communicate instructions or procedures. Any time you revise a job hazard analysis, it is important to train all employees affected by the changes in the new job methods, procedures, or protective measures adopted.
Improve the JHA Process by Taking a Team Approach
To further improve the quality of your JHA program, you may want to establish a formal JHA Team. The JHA Team membership might consist of:
- the first line supervisor, or designee, of the affected area as Team Leader
- non-exempt employees experienced in the job that the JHA will be conducted on. If this is a new type of task experienced employees will probably not be available.
- additional subject matter expert resources as needed to evaluate the task, including, but not limited to the area safety engineer, industrial hygienist, safety manager, fire protection, emergency preparedness coordinator, or safety observer, etc.
- developing a JHA by defining the key steps of each job, identifying the potential hazards of each key step and recommending safe practices (e.g., engineering controls, administrative controls, etc.) to eliminate or reduce each hazard/exposure
- conducting the JHA for the selected process or activity by discussing and completing each of the sections on the JHA form
- recommending any changes required to facilitate personnel safety; including, but not limited to, specific procedures, policies, equipment, training, etc., that may be involved
- providing the appropriate manager with a completed copy of the JHA
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