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 prioritized methods within what's called the "Hierarchy of Controls". The rest of this module will discuss the various hazard control methods within the hierarchy.
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) control 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.
Traditionally, a hierarchy of controls has been used as a means of determining how to implement feasible and effective controls. ANSI Z10, Occupational Health and Safety Management Systems, encourages employer employ the following hierarchy of hazard control strategies:
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, 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 a hazard.
These strategies are considered first because they have the potential of completely eliminating 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 more than $50,000 and easily more than $1 million to close a fatality claim.
Some examples of these two strategies include:
If you cannot eliminate or substitute a hazard, the next best strategy is to "engineer the hazard out" by using control methods that physically change a machine or work environment. Engineering controls are built into the design of a facility, equipment or process to minimize the hazard. Engineering controls are a very reliable way to control worker exposures as long as the controls are properly designed, used and maintained.
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. Engineering controls may include:
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.
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. Humans can be rather unpredictable. Methods to eliminate or reduce employee exposure to hazards include:
Note: Administrative controls may also be referred to as "work practice" controls in 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!
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
Using a lower priority hazard control method over another higher priority control strategy may be appropriate for providing interim (temporary) protection until the hazard is abated permanently. If you can't eliminate the hazard entirely, the interim control measures will likely be a combination of control methods used together.
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.
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