Chapter 32
JOB HAZARDS ANALYSIS
Contents
Approved by John Seabury
Revised 07/10
32.1
Introduction
32.2
Definitions
32.3
Policy
32.4
Scope
32.5
Job Hazards Analysis Process
32.6
Responsibilities
32.6.1
Division Directors
32.6.2
Division Safety Coordinators
32.6.3
Work Leads
32.6.4
Facilitators
32.6.5
Workers
32.6.6
Division Liaisons
32.6.7
EH&S Division Director
32.7
Standards
32.8
Related PUB-3000 Chapters
32.9
References
32.10
Appendices
Appendix
A. JHA Process Equivalence Worksheet
Appendix
B. JHA Process Flowchart
Appendix
C. Job Hazards Analysis Process
Appendix
D. Task-based Job Hazards Analysis Template
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32.1 Introduction
This Chapter establishes the policy, processes,
and procedures to be used to identify activity level hazards and controls
through use of a Job Hazards Analysis process at LBNL.
The Job Hazards Analysis (JHA) process
provides a documented mechanism to answer the question “How do I know that I’m
doing my job safely?” Job Hazards Analysis addresses the five core functions
of Integrated Safety Management[1],
namely
- Plan the Work by describing the Work and the tasks to be performed;
- Analyze the Hazards of the
Work;
- Determine the Controls necessary
to safely perform the Work;
- Perform the Work utilizing
the prescribed Controls; and
- Provide Feedback and
Continuous Improvement to enhance safety by periodically reviewing the
JHA.
The Job Hazards Analysis process as outlined
in this Chapter never substitutes for otherwise executing Work in a fashion
fully conformant with Integrated Safety Management principles.
The Job Hazards Analysis process will be
introduced during FY2008. It uses a similar question-response format as the Job
Hazards Questionnaire, but replaces it entirely.
32.2 Definitions
- Commonly Performed by the General Public: An activity
with hazards commonly accepted by the public, the control of which requires
little or no specialized guidance or training to perform the work safely.
- Control: A control is a
device, procedure, or practice that reduces the likelihood that a hazard will
cause harm, or that reduces the severity of the harm. Controls include
substitution of materials or methods, engineered barriers, administrative
procedures (e.g., training) and personal protective equipment.
- Current: A JHA is current if
it is authorized and it accurately reflects the Work at the time the Work is conducted. JHAs are
maintained “current” by reviewing, updating and reauthorizing at least
annually, and whenever a significant change in the Work occurs.
- Exposure Assessment: A more detailed review of a worker’s exposure(s). These Assessments are generally more rigorous than Hazards Assessments and may be either quantitative, semi-quantitative, or qualitative. These assessments are generally conducted by an ES&H Professional, which may include LBNL Industrial Hygienists, Safety Engineers, or in some cases, others. These assessments may be conducted for representative employees and are not required to be conducted for each individual. In cases where an individual’s exposure is not monitored, relevant exposure information is available upon request.
- Hazard: A hazard is the
potential to cause harm. Hazards are associated with tasks; if hazards are not
controlled, they can cause illness or injury.
- Hazard Assessment: A preliminary evaluation (or screening) of an activity to determine if a more comprehensive Exposure Assessment is required. Hazard Assessments can be performed by Work Leads, Supervisors, workers or an EH&S professional. Hazard Assessments are one form of Baseline Exposure Assessment.
- Job Hazards Analysis (JHA): Job Hazards Analysis
(JHA) is the process that results in a worker hazard and control description
(Hazards Profile) and Work Authorization document prepared according to the
requirements of this Chapter. JHA includes the following elements:
- A description of the Work to
which the JHA applies.
- Descriptions of
- The tasks
incorporated into that Work;
- The hazards
associated with those tasks; and
- The controls required
to mitigate those hazards, using exposure assessment as necessary to evaluate
exposures and controls.
- Signatures
of the Work Lead authorizing the Work (as analyzed by the JHA with the hazards
mitigated by the specified controls) and the Worker indicating review of the
analysis and understanding of safety requirements of the Work.
- The duration for which the work is authorized. The maximum duration of a JHA Work Authorization is one
year from the date of the Work Lead’s authorizing signature.
- Significant: A change in Work is significant if additional tasks
and/or new hazards have been introduced, or additional controls are necessary
to control the hazards.
- Supervisor: A supervisor is
defined in the Higher Education Employer-Employee Relations Act (see PUB-3000, Chapter 1).
- Task: A task is a discrete element of Work.
Work is a collection of tasks.
- Work: Work includes all LBNL activities undertaken
by Staff, independent of sponsor, program, or location of activities (see PUB-3000, Chapter 1).
- Worker: A Worker is anyone
who performs Work at or for LBNL, including subcontractors and guests (see PUB-3000, Chapter 1).
- Work Lead: A Work Lead is
anyone who directs, trains, and/or oversees the Work and activities of one or
more Workers. Work Leads provide instruction on working safely and the
precautions necessary to use equipment and facilities safely and effectively.
A Worker’s default Work Lead is his/her Supervisor, but the Supervisor may
designate another person to be the Work Lead. Work Leads authorize Work with the
concurrence of the Worker’s Supervisor.
32.3 Policy
- Every Worker must be either directly
supervised[2] or have
a current Work Authorization resulting from a job hazards analysis process. The
job hazards analysis is performed using the electronic Individual Baseline JHA
process described in this Chapter.
Exception: Workers working at non-LBNL
facilities having local health and safety programs, including UC Berkeley spaces, must conform to the requirements
of their host institution[3].
If there are no local health and safety programs, Workers must conform to the
LBNL requirements stated herein.
Exception: For certain specific
applications, Workers who are LBNL Guests may use an alternate Individual Baseline
job hazards analysis and work authorization process that is equivalent to the
LBNL institutional JHA program described in this Chapter. The determination of
equivalence is made by the EH&S Division Director after evaluating the
information submitted per Appendix A [4].
- Every Worker must have one or more current
Task-based Work Authorizations to authorize unpredictable, short-term, or
unusual Work that is not included in the Individual Baseline JHA. Task-based
Work Authorizations can be obtained through:
- Use of the Task-based JHA process described in this
Chapter, including use of attached forms, or
- Use of an equivalent Task-based JHA process as described
in the Division ISM Plan, and approved by the EH&S Division Director per
the requirements of Appendix A.
Task-based Work Authorizations are not
required if all the Work is covered by the Worker’s Individual Baseline JHA.
- Workers must complete the Job Hazards Analysis
and have the Work authorized before beginning work, and review/update it at least
annually from the date of Work Lead authorization, and as the job changes
significantly.
Work may not be conducted unless the
applicable and authorized Work Authorization(s) exist.
Exception: If a Worker does not have a current Work
Authorization, he/she may perform Work that has been analyzed for someone else,
provided that
- he/she is directly supervised
by that person,
- that person has been
authorized to perform the described Work, and
- both adhere to the controls
specified for that Work[5].
This exception only
applies to the first 30 days of Work; after that time Workers must have the
Work Authorization in place in order to perform the Work.
- The Job Hazards Analysis must include all Work
that is more hazardous than that “Commonly Performed by the General Public.”
32.4 Scope
This Chapter applies to all staff, guests,
visitors, and others who perform work at LBNL. Workers shall conduct Job
Hazards Analysis as required by this Chapter whenever they prepare a new, or
review/revise an existing, Work Authorization.
Subcontractors, including service vendors and
construction subcontractors, must comply with the requirements of their
subcontracts. In addition, construction subcontractors must comply with the
requirements of PUB-3000,
Chapter 10, and non-construction subcontractors must comply with the
requirements of PUB-3000, Chapter 31.
32.5 Job Hazards Analysis Process
There are two broad categories of Job Hazards
Analyses: Individual Baseline and Task-based. A Worker’s Job Hazards Analysis
consists of his/her Individual Baseline JHA and any applicable Task-based JHAs.
- Individual Baseline Job
Hazards Analysis: Identifies the tasks, hazards, and controls that the
Worker encounters on a regular or routine basis as part of normal Work
assignments. Individual Baseline JHAs are created and authorized through a
software
system sponsored by EH&S.
- Task-based Job Hazards
Analysis: Identifies the tasks, hazards, and controls that apply to
specific processes or Work conditions that fall outside of the Individual
Baseline JHA. Task-based JHAs are generally used for work that is
unpredictable, short-term, or unusual. Task-based JHAs are created and
authorized through paper-based systems often residing within an individual
Division.
The Job Hazards Analysis process consists of:
- Identifying Workers for whom
an Individual Baseline JHA will be completed;
- Identifying the scope of the
Work to which the JHA will apply;
- Deciding whether a Task-based
JHA is needed in addition to the Individual Baseline JHA, and identifying
to which Workers it will apply;
- Collecting Work-related data
to enable identification of tasks, hazards, and controls making up the
Work;
- Preparing a Hazards Profile
consisting of the tasks, hazards and controls through the use of the Job
Hazards Analysis software (Individual Baseline JHA) or other process (Task-based
JHA);
- Holding a JHA Development
Work Session between the Worker and Work Lead to discuss, modify (if
necessary) and validate the Hazards Profile; and
- Signing the Work
Authorization form. The Work Lead’s signature (electronic for Individual
Baseline JHA, wet for Task-based JHA) confirms that the Hazards Profile has
been discussed with the Worker, that readiness review indicates that work
may safely proceed, and that he/she authorizes the work to proceed subject
to the controls specified on the Work Authorization. The Worker’s
signature indicates that he/she has reviewed the analysis of the work, and
that he/she understands the applicable safety requirements (controls)
stated on the Work Authorization.
The Job Hazards Analysis process is
illustrated by Appendix
B: Job Hazards Analysis Process Flowchart. Additional details are available
in Appendix C: Job Hazards Analysis Process.
32.6 Responsibilities
32.6.1 Division Directors
- Assure that the JHA process
is implemented within the Division.
- Assure that Job Hazards
Analyses are completed as required.
- Assure that Facilitator(s)
are available to assist Work Leads in completing Job Hazards
Analyses. Note: Facilitators are trained by the EH&S Division.
32.6.2 Division Safety Coordinators
- Assist in the preparation of
Job Hazards Analyses, as requested by the Division Director.
- Act as Facilitator as
requested by the Division Director
- Act as conduit between
division Work Leads and EH&S for coordination of exposure assessments,
as requested.
32.6.3
Work Leads
- Prepare Task-based,
Individual Baseline, and Work Group Baseline JHAs (if appropriate) for
their direct-report Workers.
- Utilize the JHA process as a
mechanism to authorize Work under their control when the tasks, locations,
hazards, and controls have been properly analyzed.
- Consult with new Workers, or
Workers whose tasks have changed, to assure that their Hazards Profiles accurately
describe the tasks, hazards, and controls inherent in the Work.
- Ensure that Hazard Profiles are
updated and reauthorized annually or more frequently if required.
- Stop authorized Work when
hazards and controls change, and do not reinitiate Work until the Hazard
Profiles for all Workers performing that Work have been updated and
reauthorized, and the required controls are in place.
32.6.4
Facilitators
- Assist Work Leads in
completion of Job Hazards Analyses, as requested.
32.6.5
Workers
- Complete the JHA upon initial appointment, whenever there is a change in job assignment
that presents new hazards, and on an annual basis. The system is
accessible via the internet, and Workers may begin this process prior to
arriving on-site.
- Engage the Work Lead in
consultation to develop their draft Hazards Analysis to a final Work
Authorization by verifying Work locations, tasks, hazards, and controls.
- Perform Work only as analyzed
in and authorized by the Work Authorization.
- Stop Work when the tasks,
hazards, and/or required controls differ from those authorized in the Work
Authorization. Do not begin work until the Hazards Analysis accurately
describes the Work and has been re-authorized.
- Continually review work and
assure that the JHA has analyzed and authorized it appropriately. Engage
the Work Lead to modify the Hazards Profile and Work Authorization as
appropriate.
32.6.6 Division Liaisons
- Act as primary representative
of EH&S Division to the Division Safety Coordinator, Facilitator, and
Work Lead for assisting with Job Hazards Analysis.
- Act as Facilitator as
requested by client Divisions.
- Obtain assistance from
EH&S subject matter experts, as necessary, to properly identify
hazards and controls for tasks (including obtaining assistance with
Exposure Assessments) as requested by the Work Lead or Division Safety
Coordinator.
32.6.7 EH&S Division Director
- Approve alternative job hazards analysis processes.
- Maintains software,
procedures, and other support tools necessary to prepare JHAs.
32.7 Standards
- 10 CFR 851.21, Hazard
Identification and Assessment
32.8 Related PUB-3000 Chapters
- General Policy and
Responsibilities (Chapter
1)
- Safe Work Authorizations (Chapter 6)
- Construction Safety Manual
Administrative Policies (Chapter
10)
- EH&S Training (Chapter 24)
- Non-Construction Safety Assurance for Subcontractors, Vendors, and Guests at LBNL Facilities (Chapter 31)
32.9 References
- Occupational Safety and Health
Administration (2002), Job Hazard Analysis – OSHA 3071, US Department of
Labor
32.10 Appendices
- Job
Hazards Analysis process is a regulatory requirement for all DOE Contractors;
see 10CFR 851.21
- Directly
Supervised” means under
line of sight supervision by an LBNL employee. The person supervising the
work is considered to be the Safety Line Manager for the work and is responsible
for assuring that it is conducted in a safe and healthful manner in compliance
with LBNL requirements. As noted below, "Directly Supervised" is an alternative for a current Work Authorization only during the first 30 days of Work.
- Workers
must identify that they are working at another location by entering the LBNL
Job Hazards Analysis software system, and indicating that they are working at a
non-LBNL location. The Worker's Supervisor confirms the Worker's presence at the alternate location and aiuthorizes that Work.
- Examples
of Individual Baseline job hazards analysis and work authorization processes
for use by LBNL Guests that may be equivalent to the JHA process outlined in
this Chapter include Construction Job Hazards Analysis (PUB-3000, Chapter 10),
Subcontractor Job Hazards Analysis (PUB-3000, Chapter 31), and ALS
Experiment Summary Sheet.
- Work that is authorized by a formal authorization as
defined in PUB-3000,
Chapter 6, may be
subject to different requirements regarding untrained work. In that case, the
requirements of the Formal Authorization prevail.