Whether you call it a JSA (Job Safety Analysis) or a JHA (Job Hazard Analysis), conducting regular inspections for safety is crucial for any work environment. Safety isn’t just important for the wellbeing of your employees, it’s also the law. If you are hiring for a new position, then it would probably be a good idea to conduct an initial JHA followed by routine annual inspections. In this blog, we would like talk about Job Hazard Analysis and go over topics such as: who needs to conduct them, why you need to conduct them, and how to conduct a JHA for warehouses.
Who Needs to Conduct a JHA?
Under the OSHA act, “employers are responsible for providing a safe and healthful workplace.” What exactly does OSHA mean when they say, employers? Put simply, any employers that have one or more employee must observe and comply with OSHA regulations. Even tribal employers are subject to OSHA regulations. In fact, the only individuals who do not need to follow OSHA regulations are self-employed contractors. In short, if you are a warehouse manager, supervisor, or business owner, and you have at least one employee, then complying with OSHA regulations is part of your responsibility. One way to maintain compliance with OSHA regulations is to conduct initial and routine JHA’s.
Why Conduct a JHA For Your Warehouse?
The purpose of conducting a JHA is to ensure that your warehouse complies with OSHA laws and regulations. If your warehouse violates any regulations, OSHA has the power to shut down your operations, lock the doors to your organization, and throw away the key. There are many laws that are specific, and we encourage readers to conduct further research. However, one of the most important sections to take note of would be section 5 of the General Duty Clause (GDC). Section 5 states:
“(a) Each employer —
(1) shall furnish to each of his employee’s employment and a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;
29 USC 654
(2) shall comply with occupational safety and health standards promulgated under this Act.
(b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which is applicable to his own actions and conduct.”
Probably the most notable phrase for employers to pay attention to is the phrase recognized hazards. This is a catch-all blanket statement that gives OSHA the final say to define a specific hazard. If there isn’t a specific regulation for a workplace hazard, OSHA can use this term to cover it and hold employers responsible for controlling that hazard.
Moreover, this section requires all employees to follow such regulations and policies or risk progressive discipline from the employer.
How to Conduct a JHA:
The steps required to perform a successful JHA are relatively simple. OSHA recommends that you involve your employees because they have a unique understanding of the job. Here is a process diagram to show how everything breaks down:
First, start by separating the job selected into basic steps. Then, look for any hazards that may appear in any of the steps. In a warehouse setting, a hazard may be a lack of safety railings in a loading dock. If the job in question requires that the employee loads and unloads shipments in a loading dock lacking safety railings, then this poses a huge safety risk.
Second, Identify and document the hazards in each of the broken-down steps. Eventually, safety controls, policies, and procedures will need to be developed and implemented based on the documented hazards.
After the hazards have been identified and documented, begin developing controls. The hierarchy of controls should be as follows: Engineered, Work Practice, and Administrative.
In the case described previously, the first engineered control should be to install safety railings in the loading dock. After the railings have been installed, work practice controls should be established. Do this by training employees to be aware of their surroundings and footing as they load and unload shipments in the loading docks. After the employees have been trained to work safely, develop administrative controls by creating process and procedures for the job in question. Require that all employees follow these procedures and obtain written acknowledgment from them. Do not forget to document all the steps taken before completing the JHA.
For greater detail on how to conduct a JHA please refer to the Job Hazard Document published by OSHA.
Occupational Safety and Health Administration. (2017, March 24). Job Hazard Analysis. Retrieved from osha.gov: https://www.osha.gov/Publications/osha3071.pdf
Occupational Safety and Health Administration. (2017, March 24). OSHA Law & Regulations. Retrieved from osha.gov: https://www.osha.gov/law-regs.html
Occupational Safety and Health Administration. (2017, March 03). SEC. 5. Duties of GDC. Retrieved from osha.org: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=OSHACT&p_id=3359
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