Conducting a Worksite Analysis
To make sure the CSMS has been effectively deployed (it’s working), conduct regular worksite analyses to analyze and evaluate the performance (results). Conduct systematic actions that provide information as needed to recognize and understand the hazards and potential hazards of your worksite.
Listed below are types of worksite analysis actions that can assist you with making an inventory of potential and actual hazards in your worksite:
- Job safety analysis.
- Comprehensive hazard surveys (insurance inspections, OSHA consultation, etc.).
- Hazard analysis of changes in your worksite (new equipment, new processes
- Regular site Safety inspections (employee and management).
- Employee report of hazards or potential hazards.
- Injury and illness trend analysis.
- Personal protective equipment assessment.
- Ergonomic analysis.
- Specific identification of confined spaces.
- Identification of energy sources for specific machines.
- Copies of written inspections and surveys by: fire department, in-house as required by Safety standards (e.g., overhead crane inspections, powered industrial truck daily inspection, etc.).
OSHAcademy courses 702, 704, 706, 707, 709, 710, and 711 cover these topic areas.
OSHA Challenge: Baseline Safety and Health Hazard Analysis, including Industrial Hygiene (IH) Surveys
Stage 1: Conduct a S&H baseline analysis including a review of previous accidents, injuries, and illnesses; complaints; previous studies; etc.
Stage 2: Require subcontractors to perform baseline analysis as necessary in accordance with OSHA and company requirements and share pertinent information with the general contractor, or other subcontractors.
Stage 3: Repeat baseline surveys, if warranted, by significant changes in tasks, equipment, or processes.
Analyzing a Construction Worksite
Each of the following program components should be analyzed on the worksite. Use a checklist to make sure your analysis is most efficient and effective. Be sure to document what you find whether it is in conformance or not.
- Program Administration – OSHA postings, emergency numbers, HAZCOM labels, training and meeting documents, incident reports, medical kits, etc.
- Housekeeping/Sanitation – Work area orderliness, passageways/walkways clear, lighting, waste containers, sanitary facilities, eating/drinking area.
- Fire Prevention – Fueling/Welding areas, GFCI and overcurrent protection, breaker boxes, lockout/tagout procedures, drop cords, utility lines located and marked, overhead lines, high-voltage lines.
- Fall Protection – Hazards identified and controlled; such as guardrails, walking-working surfaces, skylights, floor holes, window openings, fall protection systems (arrest and restraint systems), equipment use/care, and inspections.
- Hand and Power Tools – Training documentation, defective or damaged tools, proper tools for the job being used, power tool grounding and insulation, condition of cords, mechanical safeguards, power-actuated tools.
Excavation and shoring should be analyzed on the worksite..
- Ladders/Stairs – Ladder inspections, training documentation, condition of ladders, job-made ladders in use, proper ladders for job, ladders secured, extend above landing, stepladders fully open, overhead electrical exposures, stair pans filled, stair railings.
- Scaffolds – Proper erection, supervision, inspection procedures, training documentation, competent person, connections, footing and mudsills, scaffold secured to building, protection from falling objects, scaffold access, planks properly placed and secured, debris, ice, snow, overhead electrical exposure.
- Excavation and Shoring – Competent person, soil analysis documentation, proper equipment (coffins, etc.), area supervision, adjacent structures shored, excavation barricaded, cave-in protection, spoils set back, ladders adequate and properly spaced, equipment away from edge, PPE use.
- Heavy Equipment/Motor Vehicles – Maintenance and inspection, operations manuals available, operator qualification, training documents, roads, speed limits, seat belts in use, vehicle inspections, wheels properly chocked, glass/windows, weight limits and load capacities, personnel properly riding vehicles.
- Welding and Cutting – Extinguishers available, firewatch posted, screens and shields adequate, cylinders secured and stored, proper PPE being used, training documentation, electrical grounding, cables.
- Materials Handling and Storage – Materials properly stored and stacked, dust protection, proper number of workers for job, proper ergonomics practices, training documentation.
- Barricades and Fencing – worksite properly fenced, condition of fencing, evidence of tampering, roadways and sidewalks protected, proper access, traffic control measures, training documentation.
- Cranes, Derricks and Hoists – Equipment maintenance and inspections, equipment support and proper outriggers, proper load capacities posted and observed, use of signalman as necessary, overhead electrical exposure, training documentation for operators and signalman.
- Roadway Construction – Local regulations, permits, ordinances observed, use of PPE, flagman use as necessary, postings and signage, warning markers, training documentation.
- Demolition – Preplanning and documentation, protection of public and property/structures, clear areas for chutes and trucks.
- Personal Protective Equipment – Training documentation, eye/face protection, hand protection, head protection mandatory, foot protection, fall protection, respiratory protection, proper ventilation, noise testing and protection, high visibility vests, outerwear.
Recognized and Foreseeable Hazards
In conducting the worksite analysis, it’s important to look for hazards that are generally recognized within the industry, and those hazards that should be foreseeable on the worksite.
As described in OSHA's Field Compliance Manual, recognition of a hazard is established on the basis of industry recognition, employer recognition, or "common sense" recognition criteria.
- Industry Recognition: A hazard is recognized if the employer's industry recognizes it. Recognition by an industry, other than the industry to which the employer belongs, is generally insufficient to prove industry recognition. Although evidence of recognition by the employer's specific branch within an industry is preferred, evidence that the employer's industry recognizes the hazard may be sufficient.
- Employer Recognition: A recognized hazard can be established by evidence of actual employer knowledge. Evidence of such recognition may consist of written or oral statements made by the employer or other management or supervisory personnel
- Common Sense Recognition: If industry or employer recognition of the hazard cannot be established, recognition can still be established if it is concluded that any reasonable person would have recognized the hazard. This argument is used by OSHA only in flagrant cases. Note: Throughout our courses we argue that "common sense" is a dangerous concept in safety. Employers should not assume that accidents in the worksite are the result of a lack of common sense.
OSHA Challenge: Certified Professional Resources
Stage 1: Ensure outside sources are available in needed to conduct baseline hazard analysis.
Stage 2: Ensure adequate resources (e.g., access to certified S&H professionals, licensed health care professionals). Subcontractors ensure adequate resources, as well.
Stage 3: Continue to provide necessary resources (e.g., Certified Safety Professionals, Certified Industrial Hygienists). *
*Note – There are other safety professionals that can provide suitable professional services as well. They need not be CSPs or CIHs.
An important, and potentially difficult, question to ask about the nature of worksite hazards relates to whether they are "foreseeable." The question of foreseeability should be addressed by safety managers during the
worksite analysis. A hazard for which OSHA issues a citation must be reasonably foreseeable. However, all the factors which could cause a hazard need not be present in the same place at the same time in order to
prove foreseeability of the hazard.
OSHA Challenge: Trend Analysis
Stage 4: Conduct initial trend analysis of 3 previous years’ injury & illness rates and begin developing a plan for conducting analysis of other S&H-related information.
Stage 5: Conduct trend analysis of other S&H information not yet studied; conduct one of injury & illness history if a year has gone by since initial analysis. Require subcontractors to develop and implement similar systems.
Stage 6: Conducts trend analysis regularly (at least annually) of company and subcontractor S&H information and use results in setting future goals to address trends.
New Equipment, Processes, and Worksite Hazard Analysis
Designate a competent person to analyze new equipment, processes, procedures and materials on the worksite for hazards and potential hazards at your companies work sites. Document the findings and develop plans to minimize
or design out the hazards using the “hierarchy of control” strategies. (See course 704 for more on this topic)
OSHA Challenge: Pre-Use Analysis
Stage 7: Establish and begin implementing a pre-use analysis of new equipment, chemicals, facilities/project sites, or significantly different operations or procedures and recommend
controls prior to the activity or use. Require subcontractors to develop and implement similar systems.
Stage 8: Continue conducting pre-use analysis of new equipment, chemicals, facilities/project sites, or significantly different operations or procedures and recommend controls prior
to the activity or use. Subcontractors begin performing pre-task analysis of work they are contracted to perform.
Stage 9: Continue pre-task hazard analysis of new equipment, chemicals, facilities/project sites, or significantly different operations or procedures and recommend controls prior to
the activity or use.
OSHA Challenge: Hazard Analysis of Significant Changes
Stage 1: Establish and begin implementing systems for identification and documentation of S&H hazards of significant changes, new processes, and changes in design/engineering plans. Require subcontractors, if applicable, to adopt and begin implement similar systems.
Stage 2: Continue conducting hazard analysis for significant changes (e.g., non-routine tasks or new processes, materials, equipment and facilities/project site) and recommend controls prior to the activity or use per company requirements and OSHA standards. Subcontractors implement a policy and begin identify and document hazards of significant changes.
Stage 3: Continue conducting and documenting hazard analysis for significant changes (e.g., non-routine tasks or new processes, materials, equipment and facilities/project sites) and recommend controls prior to the activity or use.
Job Hazard/Safety Analysis
A Job Hazard/Safety Analysis (JSA) should be used to determine potential hazards and identify methods to reduce exposure to the hazards at your work sites. (See course 706 for more on this topic).
Job Safety Analysis is a method of planning for Safety. There are three basic parts to a JSA.
Sample Job Hazard/Safety Analysis
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- The first component of a JSA is breaking down a job or task into the specific steps it takes to complete the job. Although this can be done in small detail, typically only the major steps are listed. This often results in five to ten steps. The steps are listed in chronological order, listing the first thing that should be done, then what comes next, and so on.
- The second component of a JSA is to list all the hazards that are involved in each step. There may be many hazards that get listed next to some steps and may not be any associated with some steps.
- The third step is to write down how each hazard will be eliminated or controlled. In other words, describe what needs to be done in order to perform that task safely.
Note: Job Hazard Analysis is often called different things. Other names for it include: job hazard analysis, job task analysis, task hazard analysis, safe work procedure, and
safety task analysis.
OSHA Challenge: Hazard Analysis of Routine Jobs, Tasks, and Processes
Stage 1: Review routine tasks to ensure compliance with local, state, and Federal safety and health regulations. Begin to formalize system to ensure employees are properly trained
on routine jobs, tasks, and processes.
Stage 2: Conduct hazard analysis for work and recommend controls for routine jobs, tasks, & processes that have potential to cause an injuries/illnesses or significant incidents;
are perceived as high-hazard; or are required by a regulation or standard. Update the company hazard analysis, as appropriate. Require subcontractors to adopt and implement hazard analysis of routine work
Stage 3: Conduct hazard analysis and recommend controls for routine jobs, tasks, and processes that have written procedures, have been recommended for more in-depth analysis, or
are determined by the Challenge participant to warrant hazard analysis. Ensure subcontractors continue implementing similar processes.
Employee Hazard Reports
Employees play a key role in identifying, controlling, and reporting hazards that may occur or already exist in your worksite. Employee reports of potential hazards can be an effective tool to trigger
a closer look at a piece of equipment, operation, or how work is being performed. Reports of potential hazards can also provide suggestions to eliminate a hazard. They can also help to determine if any
trends in hazardous conditions or unsafe behaviors exist.
OSHA Challenge: Hazard Reporting System for Employees
Stage 1: Use data collected from accident incident reports and other sources to determine areas to concentrate on. Obtain supervisor and employee input for suggested plan of action in developing a hazard reporting system.
Stage 2: Develop & begin implementing hazard-reporting system for employees (maybe anonymous), requiring timely responses back to employees. Require subcontractors to participate in the company process or establish equivalent processes.
Stage 3: Continue implementing hazard reporting systems and encouraging more active reporting by both company and subcontractor employees; ensure timely investigations of the hazard reported, ensure regular feedback, using different media, to all employees on status of hazards reported.
Informal and Formal Employee Observation Processes
An informal observation process is nothing more than being watchful for hazards and unsafe behaviors throughout the work shift. No special procedure is involved. All employees should be expected to look over their work areas once in a while.
One of the most effective proactive methods to collect useful data about the hazards and unsafe behaviors at the worksite is the formal observation program because it includes a written plan and procedures.
For example, safety committee members or other employees may be assigned to complete a minimum number of observations of safe/unsafe behaviors during a given period of time. This data is gathered and analyzed to produce graphs and charts reflecting the current status and trends in employee behaviors.
Posting the results of these observations tends to increase awareness and lower injury rates. But, more importantly, the data gives valuable clues about safety management system weaknesses.
Observation is important because it can be a great tool to effectively identify behaviors that account for fully 95 percent of all worksite injuries. The walk-around inspection, as a method for identifying hazards, may not be as effective as observation in identifying unsafe behaviors.
Worksite Safety Inspections
Inspections are the best understood and most frequently used tool to assess the worksite for hazards. Much has been written about them, and many inspection checklists are available in various OSHA publications. The term "inspection" means a general walk-around examination of every part of the worksite to locate conditions that do not comply with safety standards. This includes routine industrial hygiene monitoring and sampling.
The regular site inspection should be done at specified intervals. The employer should inspect as often as the type of operation or character of equipment requires.
The inspection team can document in writing the location and identity of the hazards and make recommendations to the employer regarding correction of the hazards. Regular inspections of satellite locations should be conducted by the committee team or by a person designated at the location.
The frequency of a safety inspection depends on the nature of the work being performed and the worksite. More frequent change and higher probability for serious injury or illness require more frequent inspections. For construction sites, daily inspections are a must because of the rapidly changing nature of the site and its hazards.
At small fixed worksites, the entire site should be inspected at one time. And even for the smallest worksite, inspections should be done at least quarterly. If the small worksite uses hazardous materials or involves hazardous procedures or conditions that change frequently, inspections should be done more often.
OSHA Challenge: Routine Self-Inspections
Stage 1: Establish a routine self-inspection program that ensures S&H inspections are performed as often as necessary. Train company employees in the recognition and avoidance of hazards in their work area
Stage 2: Develop a system for scheduling routine self-inspections of the workplace; conduct inspections with S&H staff. The entire site must be self-inspected as often as necessary, but never less than weekly. Require subcontractors to adopt similar policies.
Stage 3: Conduct routine self-inspections covering entire worksite as often as necessary, but at least weekly. Ensure subcontractor processes implement similar self-inspection processes.
Incident and Accident Investigation
Your company should conduct an investigation for all injury accidents, property-damage incidents and non-injury near misses. Be sure to adequately document all reports. Only those who are properly
trained and trusted should conduct investigations involving injury or property damage.
The primary goal of conducting an investigation is to determine the “root cause(s),” or system weakness in the “6-Ps” of the CSMS: plans, programs, policies, processes, procedures and practices.
Uncovering the root causes will best help to prevent the risk of a future incidents and accidents on the worksite.
Investigation reports should help determine injury and illness trends over time, so that patterns with common root causes can be identified and prevented. Investigations should not place blame.
Accidents and “near-miss” incidents should be investigated by qualified and trained persons in your company. It’s important that the person also be one who is trusted by employees.
The reports should be reviewed by the executive in charge your company (or the person in your company that has the power and ability to address the findings of the report) and the Safety Committee within a
specified amount of time after an accident/incident. (More on this topic in course 702).
OSHA Challenge: Investigation of Accidents and Near-Misses
Stage 1: Develop and implement requirements to report and investigate incidents/accidents. Investigate accidents and prepare and maintain written reports of investigations. Involve employees in the investigations. Require subcontractors, if applicable, to adopt and begin implementing similar systems.
Stage 2: Company and subcontractors expand investigation activities to include near misses and make findings available to employees.
Stage 3: Continue reporting and investigating accidents/incidents and near-misses.
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