Stopping Risky Behavior Through Job Safety Analysis Gary L. Visscher, Esq. Law Office of Adele L. Abrams P.C. www.safety-law.com 301-595-3520

Defining Job Safety Analysis (JSA) JSA is the same as Job Safety Analysis (JSA) – terms used interchangeably. JSA is a systematic process used to separate job into steps, identify hazards associated with each step, and develop controls for identified hazards. JSA becomes part of corporate safety program. JSA is a first step in emergency preparedness and maintaining a safe workplace.

Basic Definitions Job: Definite sequence of steps or separate activities that, together, lead to completion of a work assignment or goal Job Step: Single and separate activity that clearly advances a work assignment Hazard: Any condition that may result in occurrence of, or contribute to, an accident Accident: Unplanned event that results in injury and/or property damage

Uses of JSA Evaluate and analyze a new work assignment, procedure or equipment Develop “standard operating procedures” to be followed by all workers who perform a job Train new workers, refresh experienced workers, prepare for performance of jobs that are infrequent Anticipate high hazard or emergency situations and prepare contingency plans

Accident Causation Analysis Basic Causes: Management Safety Policy and Decisions; Personal Factors; Environmental Factors Indirect Causes: Unsafe Acts and Unsafe Conditions Direct Causes: Unplanned Release of Energy and/or Hazardous Material

Role of JSA in Accident Prevention JSA can remedy basic causes by establishing meaningful safety policies, enhancing worker safety awareness, and addressing personal and environmental factors before accident occurs. JSA can identify and eliminate unsafe acts (e.g., shortcuts) and conditions (e.g., lack of guards, improper PPE) JSA stresses protection of people when unplanned releases occur and can help to develop emergency procedures in advance of catastrophic event

Who Is Involved? JSA requires team approach supervisors, experienced employees, and new workers Everyone must be prepared to assist in recognition, evaluation and control of hazards and be accountable for implementation of JSA-identified safe work procedures Main participants should be those knowledgeable about the task and work area being assessed Top management must encourage participation, make JSA part of goals, and be prepared to take action and spend $ to address identified hazards requiring expenditures or engineering fixes.

Getting Started – The JSA Process Select job to be analyzed: Assign priority to high risk jobs, new jobs, those involved in past accidents, and those with process changes Worksite and national data review helpful Can use standard “risk matrix” (hazard, probability and severity) Develop list of jobs for each position title Separate job into basic steps: Each step describes what is done, in order performed Emphasize WHAT to do, not HOW to do it Use “action” words Name item or thing acted upon Most jobs require 10-15 steps (don’t be too detailed in each step, nor too broad)

Getting Started – The JSA Process Identify hazards associated with each step: Look for hazards associated with machines, tools, supplies, procedures and surroundings Ask if worker can – Contact energy source or hazardous material (electricity, chemical, gases, fumes, steam, water, heat/cold) Be struck by anything (moving or flying objects, falling material, mobile equipment) Strike against anything (stationary or moving objects, sharp or jagged edges) Be caught in, on or between anything (pinchpoints, moving or stationary objects) Slip, trip or fall (at same or lower level; obvious housekeeping hazards) Overexert (lift, push, pull, repetitive motion)

Getting Started: The JSA Process Eliminate or control each identified hazard: Environmental controls/changes Administrative controls Protective equipment/apparel Job procedures to minimize hazard potential Environmental or administrative controls usually require management authorization and may require monetary investments. Management must be prepared to make this investment PROMPTLY upon identification of hazard and notification of recommended action in order to minimize liability!!!!!

The JSA Form Sequence of Basic Job Steps Potential Hazards Company Name:_________________ Job Title:____________Date:______ PPE Required: __________________ Supervisor: ____________________ Analysis by: ____________________ Approved by: ___________________ Training Record Employees: Date: Sequence of Basic Job Steps Potential Hazards Recommended Action or Procedure 1.Put on protective equipment Improper fit, improper rating Check to make sure right equipment selected (e.g., flame retardant clothing and eyewear with side shields) 2. Check to ensure power off Electricity Stored energy Turn off power; apply locks and tags (LOTO); block against hazardous motion

The JSA Team JSAs developed by observing multiple workers perform the task and discussing work methods with a variety (old and new) to get input. Take care not to “build in” established but unsafe practices that are shortcuts used by “old-timers.” Supervisors must be involved, but workers should be active in process (including making and evaluating recommended solutions) to get maximum benefits Direct observation is critical Team can also video process for evaluation and discussion with workers and management (but watch legal pitfalls as tapes are discoverable by OSHA/MSHA)

Solutions Identified by JSA Environmental Controls/Changes – Involves changing work environment or reducing amount of energy or hazardous materials in workplace. Examples include: electrical system overhaul; accessways; protective shields and barriers; ventilation improvements; providing different tools, equipment or materials; noise reduction; lighting changes; modification of work area layout; equipment replacement.

Solutions Identified by JSA Administrative Controls – Includes job frequency reduction, preventative maintenance, better housekeeping. Goal is to reduce frequency with which high hazard jobs must be performed. PPE: Protective apparel, hard hats, eye, foot, hand and hearing protection, gloves, respirators, fall protection

Solutions Identified by JSA Job Procedures: JSA spells out what worker should (and should not) do. These should cover both routine procedures and safe practices for unusual and unplanned situations (e.g., fire, power failure, explosion, equipment breakdowns, release of chemicals). This helps create emergency contingency plan that can minimize loss of life and property.

Other Requirements Results should be IN WRITING (chart format) – can be kept in “SOP” binder so can be accessed by supervisors/workers before task is performed JSAs should be periodically reviewed to ensure still valid and being followed by workers (can be part of safety audit) JSAs should be revised whenever process or equipment changes, or new hazards (e.g., chemicals) introduced (responsibility of employees AND supervisors) JSAs must be site-specific to be of maximum value. Although they can be shared with other sites or companies in same industry, and this can help identify hazards you may have missed, do not use someone else’s “off the shelf” JSAs. This undercuts value of entire process by eliminating YOUR employees’ involvement.

JSA Application New Employee Training (50% of disabling claims involve employees in their 1st year) Task Training Refresher Training Identify jobs requiring HazCom Training Accident and “Near Miss” investigations and Root Cause Analysis (e.g., did worker(s) deviate from established procedures or take shortcuts?) Tool in Safety Audit Process

Legal Considerations Make sure information contained in JSA is technically accurate and compliant with applicable standards Since JSA is not mandated, these documents need not be produced during inspections (unless serving as documentation of mandated training or program evaluation) If JSA process identifies hazards requiring immediate action, then ACT! Failure to do so can lead to “willful” citations because management has documented knowledge of unsafe conditions If you share JSAs with third parties, you could have liability exposure for “negligent training”

JSA Benefits Establishes consistent, worksite-specific standard operating procedures Creates safety awareness at all levels of operation Empowers employees and increases their involvement Identifies and eliminates “bad habits” that may be ingrained in experienced workers who train others Reduces liability procedures in event of OSHA/MSHA inspection or accident investigation Documents training of workers Cut down on lost time and production, and damage to facility, materials or equipment SAVES LIVES!!!!!!

Gary L. Visscher, Esq. 301-595-3520 gvisscher@ymail.com QUESTIONS???? Gary L. Visscher, Esq. 301-595-3520 gvisscher@ymail.com