Chapter 32
JOB HAZARDS ANALYSIS

Contents

Approved by John Seabury
Revised 07/08

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
Appendix E. Exposure Assessment

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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 identifying the Scope of 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

1. 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:


1. A description of the Work to which the JHA applies (the Scope).


2. Descriptions of


1. The tasks incorporated into that Work;


2. The hazards associated with those tasks; and


3. The controls required to mitigate those hazards, using exposure assessment as necessary to evaluate exposures and controls.


3. 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.


4. A duration for which the 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.


2. Work: Work includes all LBNL activities undertaken by Staff, independent of sponsor, program, or location of activities (see PUB-3000, Chapter 1).


3. Worker: A Worker is anyone who performs Work at or for LBNL, including subcontractors and guests (see PUB-3000, Chapter 1).


4. 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.


5. Supervisor: A supervisor is defined in the Higher Education Employer-Employee Relations Act (see PUB-3000, Chapter 1).


6. Task: A task is a discrete element of Work. Work is a collection of tasks.


7. 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.


8. 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.


9. Current: A JHA is current if 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.


10. 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.


11. Commonly Performed by the General Public: An activity with hazards commonly accepted by the public, the control of which requires little or no guidance or training to perform the work safely.

32.3 Policy

1. 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 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].

2. 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:


1. Use of the Task-based JHA process described in this Chapter, including use of attached forms, or


2. 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.

3. Workers must complete the Job Hazards Analysis and have the Work authorized within 30 days of initial LBNL access badge activation or change in work (as applicable), and review/update it at least annually from the date of Work Lead authorization, and as the job changes significantly. See PUB-3000, Chapter 24 for additional information.


4. Work may not be conducted unless the applicable and authorized Work Authorization(s) exist.

   Exception: If a Worker does not have a 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.

   Exception: The JHA program will be introduced during FY2008. Work Authorizations as required by the procedures in this chapter (Individual Baseline or Task-based) are not required until the JHA system triggers the need, or until September 30, 2008, whichever comes first. Work Authorizations as required by PUB-3000, Chapters 10 and 31 are subject to the implementation requirements therein.

5. 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.

1. 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.


2. 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:

1. Identifying Workers for whom an Individual Baseline JHA will be completed;


2. Identifying the scope of the Work to which the JHA will apply;


3. Deciding whether a Task-based JHA is needed in addition to the Individual Baseline JHA, and identifying to which Workers it will apply;


4. Collecting Work-related data to enable identification of tasks, hazards, and controls making up the Work;


5. 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);


6. Holding a JHA Development Work Session between the Worker and Work Lead to discuss, modify (if necessary) and validate the Hazards Profile; and


7. 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 within 30 days of 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 Division Task-based JHA procedures.


• 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)

32.9 References

• Occupational Safety and Health Administration (2002), Job Hazard Analysis – OSHA 3071, US Department of Labor

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


• Appendix E. Exposure Assessment

1. Job Hazards Analysis process is a regulatory requirement for all DOE Contractors; see 10CFR 851.21 Deficiencies in Work Planning, addressed by the JHA, were also noted as findings in two independent reviews of LBNL Integrated Safety Management during FY2006.


2. 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.


3. Workers must identify that they are working at another location by entering the LBNL Job Hazards Analysis software system, indicating that they are working at a non-LBNL location, and agreeing to follow that location/institution’s local requirements.


4. 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), ALS Experiment Summary Sheet, Alameda County Fire Department Safety Program, and US Department of Energy EH&S program.


5. 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.

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