As statistics show, one of the root causes of workplace accidents, injuries, and illnesses is the failure to identify and address hazards that exist, or which could have been anticipated. As such, conducting comprehensive assessments and establishing the policies for a proactive and ongoing process are critical components of any workplace compliance program.
At Hendershot, Cannon & Hisey, P.C., our Texas OSHA lawyers work with a range of employers in matters involving both reactive defense to violations and proactive counsel for ensuring compliance. Because achieving a safe and healthy workplace is no easy feat amid the dense laws and regulations with which employers must comply, we understand the critical role we play in helping clients reduce exposure to accidents, citations, and the adverse consequences they can create.
One essential way we do this is to work closely with clients in helping them understand what they should be evaluating in terms of workplace conditions. Generally, this involves taking steps that comprehensively address all matters of safety in the workplace, including steps to:
- Collect and review information about workplace hazards (present or likely to be present)
- Conduct initial and periodic assessments to identify new or recurring hazards
- Investigate past incidents, including accidents and near-misses, to identify areas for improvement
- Group similar incidents to identify trends
- Evaluate hazards associated with policies for emergencies or non-routine situations
- Prioritize corrective actions based on assessments of potential incidents that may result from identified hazards
- Establish policies and processes to ensure compliance on a proactive basis
As part of our comprehensive approach to workplace safety and OSHA compliance, we assist employers in conducting job hazard analyses that provide targeted insight into all aspects of job-related duties and any hazards that may exist.
Job Hazard Analysis
OSHA works to ensure employers are actively assessing the safety of their work environments not only by requiring documented job hazard assessments for a range of workplace issues – from personal protective equipment and ventilation to noise exposure and hazardous materials – but also by providing guidelines to effectively identify hazards and implement controls. This includes a Job Hazard Analysis, or Job Safety Analysis, which is a technique that focuses on job tasks so hazards can be identified before they occur.
A job hazard analysis consists of multiple steps for evaluating the relationship between employees, job tasks, tools, and the work environment. Results obtained from an analysis can help employers eliminate or control any risks to employees, as well as potential risks involving OSHA inspections and citations. Below, we discuss the essential elements of an effective job hazard analysis.
Jobs to Assess & Prioritization
All types of jobs can be evaluated using a job hazard analysis, which can create some difficulties in larger workplaces. For efficiency, and to ensure the most dangerous positions are addressed first, priority should be given to certain jobs, including:
- Jobs or duties with the highest injury / illness rates
- Jobs that pose the greatest risks of severe harm (whether past incidents have occurred or not)
- Jobs or tasks where a single human effort may lead to severe harm
- New jobs within the workplace, or jobs with substantially changed in procedures and processes
- Complex jobs and tasks requiring written instructions
Understand the Goals
Creating and implementing a job hazard analysis should begin with a focus on the primary goals, which include:
- Break job tasks into steps
- Identify potential hazards associated with each step
- Create strategies to eliminate or reduce hazards
Breaking Jobs Into Steps
Jobs can be broken down into essential tasks or steps, which makes it easier for employers to identify and evaluate hazards. Generally, job tasks should be broken down into no more than 10 steps using a few key actions:
- Observe an employee while they perform the job and list each step as it occurs.
- Begin each step using an action verb (i.e. Place, Remove, Lift, etc.)
- Be careful of making steps too vague or too overly detailed.
- Consider recording the task or taking photos of each step taken.
- Review each step with workers to obtain their input.
Think of a job hazard analysis as form of detective work. This can help you understand what you specifically want to discover, whether the hazard be environmental, chemical, biological, or otherwise. OSHA recommends asking the following questions when identifying hazards in each step of a job:
- What could go wrong?
- Would there be consequences?
- How would that occur?
- Are there any contributing factors?
- How likely is the hazard to occur?
Creating Strategies to Address Hazards
Job hazard assessments provide the information employers need to make actionable changes. As such, performing a complete and accurate analysis of job tasks is only part of the overall goal. All information about hazards should be clearly organized, prioritized, and evaluated based on the control methods that can be used to address them. This may involve changes to anything from engineering procedures (which could change the machines used for a certain task) to administrative controls.
When creating and implementing any plan to address hazards, promote workplace safety, and ensure compliance with applicable regulations, a comprehensive approach and experience can make all the difference. At Hendershot, Cannon & Hisey, P.C., we guide employers step-by-step through job hazard assessments, help them understand and address the regulations that apply, and assist in creating proactive policies that protect their workers and their compliance interests. For more information about our OSHA law services, call (713) 489-2028 or contact us online.