Excellence in Job Hazard Analysis

Final - June 14, 2007

Word Version of this document

Introduction

In 2006 DOE sponsored and endorsed the implementation of Human Performance Improvement (HPI), based on the nuclear industry model, into the DOE community. It has been adopted by the work management subgroup as another tool to use in integration of Integrated Safety Management, Job Hazard Analysis, and Work Control. This Job Hazard Analysis Excellence document was originally developed by the work management subgroup in 2004 to improve hazard analysis in work planning processes. HPI concepts are being introduced and integrated in this revision.

An interesting product of the in depth look at Job Hazard Analysis is a comparison of injuries being reported that indicate the majority of injuries will never be reduced by focusing on Job Hazard Analysis. It is the behavior of the people that influences the injury rates. There is a common misconception that better Job Hazard Analysis will improve our safety statistics. The reality is that most injuries occur without relationship to a planned work activity, they occur as part of routine work activities.  

A review at one site shows that only 16% of all reported injures occurred as part of a planned work activity. Of that 16% none of the injuries occurred due to direct hazards associated with the work. The injuries occur in travel to or from the job site, or by personnel who are staging for the work or are supporting the work from a distance. For this reason it is important to have a general hazards analysis that addresses worker behavior as well as identifies hazards and controls that are the source of injuries to personnel. This is where the implementation of HPI concepts can become a major player in reducing events and injuries.

Overview

This document is meant to be an aid for all DOE facilities to use in implementation of a consistent set of principles while developing or improving its processes for Job Hazard Analysis and its integration into the work planning process. The goal is to have an efficient method of involving the workers in work planning and hazard analysis, resulting in safely performed work.

In keeping with the core function of ISMS, Excellence in Job Hazard Analysis includes Defining the Scope, Identifying the Hazards, Analyzing Hazards and Developing Controls, Perform Work, and Feedback/Lessons Learned. Use of common terms and definitions is a key to consistent implementation. The key points and defined terms in each of these areas are included where necessary for common understanding.

Use of Critical Task Concept

Human performance Improvement is a key concept leading to excellence in Job Hazard Analysis. The critical task and its relationship to the rest of the tasks in a specific work scope bring focus to the uncommon hazards associated with the tasks to be performed. If we do not focus on the critical tasks and try to apply too much rigor to all the tasks identified we may end up blending too many general hazard controls into instructions intended to be performed by trained and qualified personnel.

The use of a critical task concept leads to efficiency in the resources used for Job Hazard Analysis. It provides a foundation for a more precise and user friendly set of instructions or procedure that clearly identifies the hazards workers are not use to working with or may not be expecting during the performance of their work.   

Employee Involvement 

All Employees

There are four key components to worker behavior that support improved safety during every job. They include:

·         Pay attention to your surroundings while you are working. You should stop what ever you are doing if your attention is drifting to something else. You should let people know if there is any reason that you may not be able to give 100% of our attention to your work. You should make sure that distractions and horse play at work is not acceptable.

·         Keep situational awareness while you are working. Know when you can allow your attention to drift and when you can’t.  You should pay attention to your surroundings at all times not just at work. You should be looking for error traps or error likely situations brought on by the environment, house keeping, or the location at the worksite as well as that of your shops and travel paths. This is where you don the PPE necessary for the hazards that you may face (Gloves, Safety Glasses, Safety Shoes, Long Sleeve Shirts etcetera).

 ·         Assess your physical capabilities. You need to know when you should be stretching or taking more time to move or lift something. You may need to use more people to help with a task. Everyone is getting older and needs to pay attention to the limitations of their physical condition. Only you know if the task you are getting ready to do is too much for you to handle. It is expected that if you have any doubts about your ability to physically perform a task that you work with your supervisor and get the right help or equipment to perform the task safely. 

·         Use deliberate speed in doing your work. It will provide more time to pay attention and understand your situation either at the job site, at the office, or somewhere in between. 

Once these concepts are understood and practiced by the workforce, it can be supported by a general hazards analysis that everyone should be trained on as part of working at the site. The general hazards analysis should include controls for the following hazard types:

·         Lifting

·         Moving

·         Insects, wildlife

·         Sharp Objects

·         Slippery surfaces

·         Trip Hazards

·         Stairs or Steps

·         Uneven surfaces

·         Ergonomics for the field

·         Ergonomics for the office

In order to focus on the hazards associated with the actual work being performed these hazards should not be addressed separately in work instructions or procedures, but should be covered as part of annual refresher training and safety topics for staff meeting or pre-job briefings.

Workers and Supervisors 

Multi-disciplinary teams are needed to support all functions of an integrated safety management system, including hazard analysis.  A team based approach allows the identification and analysis of all hazards to be performed concurrently. 

Line management, planners, workers, and subject matter experts are a part of the multi-disciplinary team.  Team involvement is based on a graded approach involving complexity of the work and the degree of work hazards. Each member of the team has a defined responsibility and function.

A solid JHA process uses the workers and subject matter experts in Industrial Safety, Industrial Hygiene, Environmental Controls, and Radiological Controls, as appropriate, in a graded approach to accomplish the elements of a Job Hazard Analysis.

·         Workers and supervisors identify the tasks necessary to perform a scope of work.

·         Workers and Supervisors identify the critical tasks associated with the work.

·         Workers use their experience and knowledge to review the tasks and identify known hazards.

·         Workers and Supervisors focus on the critical tasks to ask thought provoking questions about the task to help in hazard identification.

·         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 determine the method that should be used to communicate the controls to the workers in the development of instructions or procedures.

·         As new controls are identified, there may be new tasks that need to be evaluated to determine if new hazards are introduced; therefore, the process is iterative.

Excellence in Job Hazard Analysis requires an environment in which individuals and leaders understand and support the following:

·         A task specific hazard must start with a detailed understanding of the task

·         SMEs and workers must have the same mental picture of:

o    The tools being used to perform a task

o    How the tool(s) is/are being used to perform a task

o    Where the worker is using the tools to perform the task

·         Identification of hazards is a three part process:

o    Identification of hazards for the task

o    Identification of location hazards

o    Identification of conditional hazards

·         JHA tools are intended to remind people of hazard types applicable to a task, not to replace the thought process during the job hazard analysis. (Simplicity may be the best answer.)  

·         Hazard controls may be communicated to the workers through:

o    Training and qualification

o    Precautions at the beginning of an instruction or procedure

o    Warnings or Caution statements immediately prior to an instructional step

o    Detailed steps in a work instruction or procedure.

·         Efficient work processes use a graded approach in involvement of workers and SMEs in the Job Hazard Analysis process

·         Feedback and lessons learned can be key elements in reducing rework or duplication of work in JHA.

Facilitation Training

As the number of people on a team grows it is easy to become less focused on the task at hand. Discussions can go in directions that while they may be important to the person are ineffective and inefficient for a group of people. It is important that the person leading the discussion of the team understands the dynamics in team approach and can facilitate the meeting effectively.

Facilitator training is often overlooked and is thought of as unnecessary for personnel leading the job hazard analysis or planning meetings, but would serve the company well. A well run meeting ran by someone with good facilitation skills will induce less frustration of the workers and the effectiveness and outcomes typically meet expectations.

Inclusion of Hazard Analysis as part of Technical Training 

Hazard analysis training should be part of the technical training for employees that participate in the hazard analysis process.  The training should encompass the hazard analysis process, workplace hazards and controls, and team members’ roles, responsibility and function, and, if applicable, the tool used to document the hazard analysis.  Workplace hazards should be specific for the particular workplace and not a description of general industrial hazards.  

Risk Verses Complexity and the Graded Approach

During the workshop representatives explained how each facility performs JHA and work planning, and it became clear that there were significant differences in the interpretation of high, medium, and low risk work. It is important that each facility identifies a graded approach to the way it addresses the JHA and work planning. Too much rigor and efficiency goes down resulting in prohibitive costs, while too little rigor can lead to inappropriate or missed hazard controls and increased safety statistics.

Risk is defined as “to expose to a chance of loss or damage,” and Complexity is defined as “the quality of being intricate and compounded.”  

Risk can be quantified in some areas, such as Radiological or Industrial Hygiene, by use of limits and quantities. Industrial safety is a little more subjective. For this reason it is a good idea to develop and use standards for addressing approaches to eliminating or mitigating risk or hazards. Subject matter experts help in application of the standards for situational or location hazards as part of the JHA for specific work activities.

Risk by itself without complexity may be handled through the use of standards and procedures and a review/approval process of instructions that increases incrementally as the risk for the hazards analyzed by the facility goes up.

Complexity with or without risk factored in may require an entirely different strategy in the graded approach application. The work may become more complex with increases in the numbers of work hazards, workers, conflicting controls, or permits required.

The following is an example of how risk and complexity may be addressed as a combined approach to the rigor needed and subject matter expert involvement in the Job Hazard Analysis and work planning.

·         Low Risk and Low Complexity – Worker is trained to perform the work and recognizes specific hazards and how to control them without assistance of SMEs.

·         Medium Risk and Low Complexity – Worker is trained to perform the work but may want to have oversight by supervisor to help in ensuring that workers recognize and control the hazards. SMEs should have reviewed the hazards associated with these tasks and included the controls as part of the qualification and training of the workers or as controls in the procedures the workers are using.

·         High Risk and Low Complexity – Workers may require assistance of SMEs in eliminating or mitigating the risks the first time, and then these controls are captured in procedures or standards that are followed step by step as extra assurance that the risks are eliminated or mitigated. Review or approval of the follow-on work plans by SMEs provides another level of assurance.

·         Low Risk and High Complexity – Workers and supervisors use detailed work instructions and need SME involvement initially to analyze the tasks. Future performance of the same work may be by procedure and does not require SME review each time.

·         Medium Risk and High Complexity – Workers require involvement by SMEs in support of review of tasks and identification of hazards and controls required to perform the work. Oversight by supervisors or SMEs during the performance of the work may be warranted.

·         High Risk and High Complexity - Workers require involvement by SMEs in support of review of tasks and identification of hazards and controls required to perform the work. Oversight by supervisors or SMEs during the performance of the work is warranted. Management review of the plan is recommended to determine if the workers and SMEs have thought through the work, have performed reasonable efforts to eliminate or reduce the hazards, and have found no reasonable way to reduce the risk level.

The key to a successful graded approach is to ensure that as changes to the process are developed to accommodate increases in risk or complexity, there is value added, providing improved assurance that the probability of unidentified hazards decreases, while identified hazards are eliminated or controlled.

Skill of the Craft

Skill of the Craft acknowledges workers are trained and experienced in performing identified tasks, thus eliminating or minimizing hazards associated with performing those tasks.

The key to using skill of the craft in the graded approach is to ensure that eventually all tasks included in the skill of the craft category have been identified.  A qualification or training program should include documentation of these items: Identify the hazards, perform the analysis, determine the controls, and train the worker to perform the task using the controls. If this traceability cannot be shown for each task then we should be wary of including the tasks as part of the Skill of the Craft activities.

Another aspect of using Skill of the Craft is to ensure the workers are trained in dealing with situational and location hazards.  It is an oversight to think that a worker trained to safely perform a task is also aware of and understands how to handle hazards brought on by changing conditions or location-specific hazards unless the same traceability can be shown to the training or qualification for conditional or location-specific hazards.

Training or qualification programs are just a part of the equation for use of Skill of the Crafts.  Frequency and complexity of performance need to be factored into the decision to allow workers to perform work without further instruction or oversight. This is where management and supervisor understanding of their people’s performance at the shop level is imperative for appropriate use of Skill of the Craft.

Forward

In the following sections of this document, each element description includes a brief summary of the concept contained in the element, a discussion of the mechanisms recommended for use by contractors to implement the element, and how the various attributes that make up the element should be managed.

Define Scope

Concept

This element describes the processes and tools that should be in place to determine the total scope of work, which is an essential step in performing effective Hazard Analysis. In order for the scope to be sufficient for a Job Hazard Analysis to be effective, the scope must provide each employee the same mental picture of the activities required to accomplish the tasks within the scope of the activity.

Mechanics

Defining the scope of work entails more than describing the task.  

A Walkdown Checklist that includes the following items should be used to fully determine a scope of work:   

o    Identification of work activity description, expected outcome, and contingencies*

o    Research of feedback mechanisms to ensure continuous improvement.*

o    Performance of an activity Task Breakdown through discussion with supervisors and workers*

o    Identification of work location environment hazards such as, Radiation Area, Outside work, etc.

o    Identification of the critical tasks.

o    Identification of work activity hazards/impact

o    Identification of work method, tools, and equipment to determine:

§  What tools or equipment are to be used

§  How the tools or equipment will be used

§  Where the tools or equipment will be used

§  The interaction between tools, materials, equipment, personnel, procedures, etc. required to complete scope of work

o    Identification of work waste streams

o    Identification of facility system impacts

o    Utilization of  worker involvement

o    Application of hierarchy of controls (eliminate the hazard, engineer the hazard out, administratively control the hazard, use PPE)

*         These activities may be performed prior to the walkdown to improve efficiency and effectiveness.  

The walkdown for defining scope should include worker and SME involvement.  Additional functional area team members should also participate as appropriate.

In order not to get bogged down by discussions on common tasks and hazards it is important to determine if there are critical tasks associated with the scope of work.

CRITICAL TASK is defined as:

Steps performed that interface with a structure, system, or component and are irrecoverable or irreversible with potential for direct impact on plant condition or personnel.  To be considered a critical task two conditions must be satisfied: 

• The state of the plant, system or component or the well being of the individual depends solely on the individual worker.

• The outcome of the error is intolerable for personnel safety or the plant (Independent of when the consequences are realized).

Management

Periodic management assessments should be performed to ensure adequate work scoping.  These assessments should include the following Lines of Inquiry (LOI):

o    Ensure facility walk down performance expectations have been established (depth commensurate with complexity.)

o    Where possible, existing hazard analysis information is used as a tool for continuous improvement, by revision, or by cloning as appropriate.

o    Critical tasks are identified appropriately in accordance with its definition.

o    The work is effectively broken down into manageable tasks where the hazards and hazard controls can be effectively identified and communicated considering:

§  location specific hazards

§  craft specific hazards

§  work order task, or procedure section, specific hazards.

o    Work scope is clearly defined including the approach to work and co-located (non-task related) hazards

o    Thought is given and/or action is taken to eliminate hazards, or otherwise adhere to the Hierarchy of Controls methodology.

o    Feedback is used in determining scope of work.

Hazard Identification

Concept

This element describes the processes and methodologies for identifying hazards.  Safe and efficient work performance combines the effort of planning, craft training, site safety culture, and work ethic to produce a predictable, positive result.  Safe performance of work should always include a review of the types and severity of the hazards to determine the most effective hazard controls.

Identifying hazards associated with all tasks is important and needs to be factored into the way people perform their work using different methods of implementation. For most tasks the hazards will be well understood and common at that facility. This is where established standards and controls, once people are trained to them, should not take a lot of planning time. Most time and energy in planning should focus on critical steps and ask thought provoking questions based on Error Likely situations or Error Precursors.

Mechanics

Effective hazards identification should include:

·         Review of the entire job scope and break each activity down into steps/tasks

o    Describe and list each task in sequence

·         Identify any outside influences for each task

o    Beside each task, write down the materials, equipment, processes, site factors, operational factors, and environmental factors that could cause an accident or health effects.  People factors may also be relevant

·         Identify the critical task hazards

Thought provoking questions for critical tasks should be included in the analysis or discussion by Planners, Supervisors, Workers, and SMEs to determine if there are hazards beyond those that are common place to the team. A short list of thought provoking questions based on error likely situations may include:

·         How could mistakes be made during this critical task?

·         What is the worst thing that can go wrong based on our actions during the critical tasks?

·         What can be done to prevent mistakes or things going wrong during the critical tasks?

·         Are we doing something differently than we routinely do it?

§  Is there a good reason, if not, do it the way we always do it.

§  If we need to do it differently, have we thought through the possible hazards and controls introduced.

·         Are there time critical tasks (once started they must finish one continuous set of subtasks in a specific order)?

§  Can we break down the tasks to keep them from being simultaneous?

§  Can we use more people?

§  Can we provide review just prior to performance?

·         Are the controls identified compatible with the rest of the controls? 

These questions may be included as a checklist for use during discussions.

When identifying potential common hazards, a checklist may be used to ensure that all known hazards have been considered. The checklist can include a list of commonly found hazards as well as behaviors that may result in accidents.

Common hazard types that should be identified in a checklist:

• Biological                         
• Chemical
• Fire/explosion
• Electrical
• Multiple energy source equipment (i.e. electrical, steam, gas, etc.)
• Ergonomics
• Excavation
• Wall/floor/ceiling penetration
• Fall (Slip/Trip)
• Fire/heat
• Mechanical
• Moving parts of machinery, tools, and equipment (i.e. pinch and nip points)
• Noise
• Material falling from height, rolling, shifting, or caving-in
• Pressure systems (i.e. steam boilers and pipes)
• Ejection of material
• Radiation
• Temperature extremes
• Toxic substances
• Visibility
• Weather
• Environmental

Common potentially high-risk behaviors that should be identified in a checklist:

• Lifting and other manual handling operations
• Working at heights (i.e. work done from scaffolds or ladders)
• Others working above or below the work area
• Use of bridge cranes or man lifts
• Working on or near energized equipment/components
• Hazards caused by working alone or in isolated workplaces
• Operating vehicles (i.e. forklifts, backhoes, trucks, etc.)

·         Working within a confined space

Other sources that can be used to identify safety hazards:

·         Material Safety Data Sheets (MSDSs)

·         Lessons Learned

·         Subject Matter Experts (SMEs)

·         Area/facility personnel that have a knowledge of facility hazards and operations

·         Accident and incident reports

·         First aid statistical records

·         Behavior Based Safety (BBS) reports

·         Health and safety committee meeting minutes

·         Previous inspection reports

·         Previous JHAs

·         Work procedures

·         Safety manuals

·         Equipment manuals

·         Maintenance/repair records

Because the controls for an activity depend on both the types and severity of the hazards, it is important to re-evaluate the activity whenever:

·         New hazards are introduced (e.g. job scope changes)

·         Changes decrease the effectiveness of identified controls

·         Changes impact nearby activities

When there are changes in the work, the hazards shall be reviewed to confirm that they are within the scope of what was previously analyzed and that the ES&H controls remain adequate.

Additionally, any relevant Lessons Learned should be reviewed and incorporated into the hazards identification process.

Management

Periodic management assessments should be performed to ensure adequate identification of hazards.  These assessments should include the following Lines of Inquiry (LOI’s):

1.    Review of the job scope against the JHA(s) to assure that the work has been broken down into discrete steps/tasks.

2.    Review of the tasks to assure that risk factors have been appropriately identified.

3.    Review of the risk factors and associated hazards for appropriate alignment.

4.    Did the workers utilize resources (i.e. MSDSs, Lessons Learned, etc.) other than a visual review at the job site to identify hazards?

5.    Did the workers discuss the critical tasks and ask thought provoking questions about the critical tasks.

6.    Did the workers consult with one another, SMEs, and facility/area personnel to assist with the identification of hazards?

7. Observation of the work to assure that all potential hazards were identified and mitigated through appropriate controls.
8. Review/comparison of prior JHAs for similar work with respect to identified hazards.

Hazard Controls

Concept

This element describes the processes of Job hazard analysis and control selection which takes place after hazards have been identified. The hazard analysis assesses each aspect (step) of a task and addresses the items which could result in an injury to an individual by focusing on the relationship between the worker, the task or activity, the tools, and the work environment. The objective of the analysis is to determine the controls necessary to eliminate or reduce the hazards to an acceptable risk level. This involves an evaluation of the mechanics of any operation, identifying what can go wrong, and how to do it safely (controls). Another key element is communicating the hazards and related controls to the worker (e.g. Pre-Job Briefings, Work Instructions).

HPI concepts should be used to ensure we are not putting error traps into our work documents. A common mistake is to put controls into specific work documents that are performed everyday by workers and are required by other procedures or expectations. This may lead to workers skimming through the instructions thinking they know what they say and sets them up to miss important controls for critical tasks that are specific to that work and needed to ensure the work is performed safely. It is important to provide clear direction at the right level of detail for the critical tasks and not to have them blended in with a lot of general control statements. Write the instructions for the worker and supervisor, not the auditor, and SMEs.

Hazard Control Measures

The order of precedence and effectiveness of hazard control is the following:

·         Engineering controls

·         Administrative controls

·         Personal protective equipment

Engineering controls should be used when ever feasible to eliminate or mitigate the hazard. Engineering controls include the following:

·         Elimination/minimization of the hazard – Designing the facility, equipment, or process t remove the hazard, or substituting processes, equipment, materials, or other factors to lesson the hazard;

·         Enclosure of the hazard using enclosed cabs, enclosures for noisy equipment, or other means;

·         Isolation of the hazard with interlocks, machine guards, blast shields, welding curtains, or other means; and

·         Removal or redirection of the hazard such as with local and exhaust ventilation.

Administrative controls should be predetermined and designed for use in conjunction with engineering controls. Administrative controls include the following:

·         Written operating procedure, work permits, and safe work practices;

·         Exposure time limits (used most commonly to control temperature extremes, radiation, and ergonomic  hazards);

·         Monitoring the use of highly hazardous material;

·         Buddy system; and

·         Training

Personal Protective Equipment 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; and

·         During emergencies when engineering controls may not be feasible.

     Examples of Personal Protective Equipments include the following:

·         respirators

·         hearing protection

·         protective clothing

·         safety glasses

·         hard hats

Use of one hazard control method over another higher in the control precedence may be appropriate for providing interim protection until the hazard is abated permanently. In reality, if the hazard cannot be eliminated entirely. The adopted control measure will likely be a combination of all three items instituted simultaneously.

Mechanics

Review Feedback, Lessons Learned, and Accident History

Previously documented feedback, lessons learned and accident history should be reviewed as early in the planning process as possible. It is here you will find your worksite history of accidents and illnesses, required repairs and replacements, and near misses. These events are indicators that the previously implemented hazard controls (if any) may not be adequate and deserve more scrutiny.

Conduct preliminary work site reviews

Walk down the location where the task will be performed early in the planning process to identify any potential hazards. When ever possible the site reviews should include worker, planner and SMEs. . During the site review consider all the steps or actions required to complete the task. Look for hidden hazards; consider the “What Ifs?”  Discuss with your employees the identified hazards and brainstorm with them for ideas to eliminate or ways to control those hazards. Be alert for hazards that may be introduced as a result of selected controls (e.g. ear protection that would impair the ability to hear emergency alarms). If any hazards exist that pose an immediate danger to an employee’s life or health, take immediate action to protect the worker. Any problems that can be corrected easily should be corrected as soon as possible. Do not wait to complete your analysis.  This will allow you to focus on the hazards that need more study (normally associated with critical tasks) because of their complexity to determine the best methods to eliminate or control.

Review the job steps

Nearly every job can be broken down into job tasks or steps. Reviewing these job tasks or steps with the employees will help ensure nothing has been omitted.

Involve employees

It is very important to involve employees in the analysis and control selection process. This includes not only the environment, safety and health experts, but also the hands-on workers as well. Each have a unique understanding of the job, and this knowledge is not only valuable for finding hazards, but also helps minimize oversights, and ensures a quality analysis and selection of controls. This also gets workers to “buy in” to the solutions because they will share ownership in their work management and safety programs.

In addition to subject matter experts from environment, safety, and health disciplines, the worker brings knowledge of the job scope (e.g., via walk down, past performance, personal experience, lessons learned) which is helpful in establishing what could go wrong at each step of the activity. We need to understand the job we are analyzing. This requires careful examination. Discussion and review of the tasks between the work supervisor, workers and subject matter experts should produce enough information to evaluate the hazards without getting overly detailed. The more familiarity the group has with the job, activity, task, or steps, the less complex the evaluation is likely to be. This will also reduce the probability of conflicting controls and assist in getting only those controls actually necessary applied at the appropriate steps in the work instructions.

 The analysis should consider each step in the work activity and anticipate what the worker(s) might encounter during the particular job that is being analyzed. The analysis should consider the work environment, the materials and equipment that are to be used, and the work procedures themselves. Most activities can be viewed in manageable tasks to produce the most effective analysis. Some judgment will be needed; hence, the purpose for selecting knowledgeable individuals to review the work.

To gain a full understanding of the hazard, those analyzing the job should ask such questions as:

NOTE: This is not intended to represent a complete list.

• Where is the job happening (environment?)

• Is there any relevant history or lessons learned?

• What is happening?
   
• What can the task go wrong (include contingent events)?
   
• How could an event happen?
   
• What are the consequences?
   
• How could they happen?
   
• Do I take into consideration the following hazards?

a.    striking against or being struck by an object

b.    getting caught in or between objects

c.    use of tools, machines, or equipment

d.    housekeeping

e.    lifting, pushing, pulling motions

f.     organization in flow of work

g.    reviewing hazards indirectly associated with the work scope (or exterior to the primary work environment boundaries) that may also be encountered (e.g., an exposure present near a lockout/tagout isolation point that is not in the vicinity of the work; adjacent or collocated work activities)

h.    adjacent activity that could initiate a hazard

The review discussed above should take very little time for those hazards and tasks that are familiar with the workforce. The review of the critical tasks is where the focus of the people involved in the analysis should be. This is not meant to mean that the review of the common hazards and tasks is not to be included but that by focusing on the critical tasks and the thought provoking questions for these tasks the team will minimize the probability of events or significant injuries that are intolerable to the company, and its customers.

Documentation of Hazard Analysis and Controls

Hazards and controls are communicated to workers via work instructions, procedures, job briefs, etc.  What is not often communicated or documented is the reasoning why controls were selected. Many times a control for a hazard is very straight forward (i.e., eye protection when using a drill), however, there are times when the decision to select a particular control is not as straightforward and is based on conditions, or situations, at that given time, or the expertise of the subject matter expert.  A sound and thorough explanation of the thought process and influencing factors that lead to the decision to implement a particular control should be documented in the hazard analysis process.   Capturing the information will improve the consistency in the hazard analysis process, confidence in the product, and will be available for future references.

Information obtained from identification and analysis is of little value unless relevant and necessary hazard control measures recommended in the analysis are incorporated into the tasks instructions. If a team performed the analysis they should identify the method the controls should be placed into instructions or procedures. Examples of this would be as follows:

·         Controls within the qualification or training of the worker that are often used do not need to be discussed in the work instructions. 

·         Controls within the qualification or training of the worker but are seldom used and are applicable to the entire work activity should be placed in the precautions as a reminder that the hazard exists and the workers are expected to take the appropriate actions. 

·         Controls within the qualification and training of the workers but are for hazards that are introduced at specific steps or by specific actions during the job should have a warning or caution statement immediately prior to the step but require no detailed instructions to mitigate in the work instructions. 

·         Controls not within the qualification and training of the workers for hazards should have detailed instructions for how the workers are to mitigate the hazard and should be in the work instructions in a way that prevents or mitigates the hazard.

Field or Pre-Job Briefing Changes

It is not unusual for a change (e.g., addition, deletion, modification) to be necessary for a JHA hazard/control, because at a particular time when the activity is performed, current field conditions may vary. Several options can be used for making field and pre-job changes to a JHA based on current conditions.

• It is important to document these changes! Consider use of a form such as a "Work Review and Change Request":  This type of form provides the documentation when hazards/controls do not apply or if new hazards/controls are identified. Other change items can also be documented on this type of form. Supervisors can sign the form, as can subject matter experts, if their agreement is necessary. Supervisors can also note on the form that workers were briefed to the change.

A blank Work Review and Change Request form containing the task information can be used in the Pre-job Briefing, walk down, or in the field. Supervisors may manually enter any required changes. The document can then be filed with the work package. If desired, the information could later be entered into the JHA report.

·         In cases where significant hazard/control changes are indicated, the supervisor should halt or stop the work and conduct a formal review of the JHA for a formal revision of the JHA prior to commencing work.

The most important considerations are that the changes be documented as field changes, and that the system for making such changes be written in Company/Project/Facility guidance, instruction, or procedure.</