JSA = THA
The National Safety Council has an interesting article in their current magazine regarding Job Safety Analysis (JSA), sometimes called a Job Hazard Analysis (JHA). The article leads with an account of a day when, in preparation for a particularly hazardous task, a demolition crew skipped their daily JSA talk. The person being interviewed was the safety consultant for the job. Something went wrong during the task, and he almost lost his life from the resulting injury.
The article continues in a discussion of JSAs, and further defines them as being Task Hazard Analyses (THAs) as the purpose is really to examine tasks being performed by employees, review the steps taken to complete the task, and evaluate how to perform these steps safely.
OSHA, in 29 CFR Part 1910.132(d) requires employers to “…assess the workplace to determine if hazards are present or are likely to be present, which necessitate the use of personal protective equipment.” Cal/OSHA, in the Construction Industry Safety Orders says this (8 CCR 1511(b): “Prior to the presence of its employees, the employer shall make a thorough survey of the conditions of the site to determine, so far as practicable, the predictable hazards to employees and the kind and extent of safeguards necessary to prosecute the work in a safe manner….”
SCM thinks OSHA and Cal/OSHA are on the correct path, but they are missing a few steps and turns. Remember the Hierarchy of Controls? If you need a refresher, here’s a link to an explanation from the CDC https://www.cdc.gov/niosh/topics/hierarchy/default.html. Elimination and substitution of lesser hazards are at the top of the hierarchy because they provide the greater level of safety for employees. PPE is the bottom, providing the least amount of safety. We recommend these steps be considered in the preparation of a JHA or THA:
1. Do a pre-job walk/analysis. Look at and think about the tasks that must be accomplished to get the job done. List them and include why it is hazardous. Ask if the task includes work at heights, use of a power tool, work that must be done outdoors in extreme heat or cold, for example.
2. Talk to your employees. Get their input on the tasks being done. How has it been hazardous or potentially hazardous for them? What have they done to make it easier and safer? Write down their thoughts.
3. Use the hierarchy of controls. How many of the steps to complete the task(s) can be done in a way that eliminates the hazard or substitutes a lesser hazard? One SCM client had work that needed to be done on an elevated platform that could only be reached by climbing a fixed ladder. Rather than have employees and contractors try to get up a narrow ladder, dragging their tools, the client used a manlift as an elevator, providing safer access to the platform. Another, after talking to their employees, realized that painting the side of a building in the afternoon was not a good idea, as it was much warmer then. They were able to reschedule the task for in the morning, when it was cooler and therefore safer. How can you use the suggestions of your employees to be innovative and make the task safer?
4. Review the THA with the affected employees. Remind them of the work to be done, and the steps that will be taken to help them do the job safely. Do the review as close as possible to the time the task will be starting, so that the information is fresh in their minds.
Work can be, and usually is, done safely. A little extra preparation with a JHA/THA helps you to provide a safe work place for all employees.