JHA questions answered

No, OSHA has no general standard that requires a written job hazard analysis for construction work. OSHA recommends JHAs in its publication OSHA 3071 and says the OSHA standards for your industry are mandatory and should be built into the analysis. Separately, 29 CFR 1926.20(b) requires employers to run the safety programs needed to comply with the construction standards, including frequent and regular site inspections by competent persons.

Source: OSHA 3071: Job Hazard Analysis

There is no real difference: a job hazard analysis (JHA) and a job safety analysis (JSA) are two names for the same technique. Both break a job into steps, list the hazards in each step and set controls for each hazard. OSHA 3071 is titled Job Hazard Analysis but also uses the phrase job safety analysis for the same process.

Source: OSHA 3071: Job Hazard Analysis

OSHA recommends reviewing a JHA periodically, and especially after an injury or illness on that job. A review can find hazards missed the first time even when the job has not changed, and jobs that are new or have changed should be analyzed again. Any time you revise a JHA, train every affected employee on the new methods, procedures or protective measures.

Source: OSHA 3071: Job Hazard Analysis

OSHA 3071 lists five starting steps: involve your employees, review your accident history, do a preliminary job review, list and rank the hazardous jobs, then outline the steps of each job. For each step you then ask what can go wrong, what the consequences are, how it could happen and how likely it is. Finally you choose controls, preferring engineering controls that physically remove the hazard over administrative controls and PPE.

Source: OSHA 3071: Job Hazard Analysis

A supervisor or employer should do the JHA together with the employees who actually perform the job. OSHA says workers have a unique understanding of the job, so they should be included in every phase, from listing the steps to choosing the solutions. For many different or complex processes, OSHA suggests getting professional help from your insurer, a safety consultant or OSHA consultation services.

Source: OSHA 3071: Job Hazard Analysis

Start with the jobs that have the highest injury or illness rates. OSHA 3071 also puts priority on jobs that could cause severe or disabling injuries even with no accident history, jobs where one simple human error could cause a severe accident, jobs that are new or have changed, and jobs complex enough to need written instructions.

Source: OSHA 3071: Job Hazard Analysis

An AHA is the U.S. Army Corps of Engineers version of a JHA, required under the EM 385-1-1 safety manual on USACE contracts. It lists the work sequence, the hazards, the controls, the equipment, the training and the inspections for an activity, and names the competent or qualified persons involved. Work cannot begin until the AHA has been accepted by the government representative and discussed with everyone doing the work.

Source: USACE EM 385-1-1, Section 01.A.13 (2008 edition; current edition March 2024)

No, federal OSHA has no standard that requires toolbox talks by name. What it does require, in 29 CFR 1926.21(b)(2), is that employers instruct each employee in recognizing and avoiding unsafe conditions and in the regulations that apply to their work, and toolbox talks are a common way to do that. Some state plans go further: Washington requires crew leader and crew safety meetings at the start of each job and at least weekly after that.

Source: 29 CFR 1926.21: Safety training and education

Federal OSHA sets no retention period for toolbox talk records. Washington State requires minutes of crew safety meetings to be kept for at least one year (WAC 296-155-110), so one year is a sensible minimum anywhere. Your GC, insurer or contract may require longer.

Source: WAC 296-155-110: Accident prevention program (Washington)

Federal OSHA has no general rule that every construction employer must have a single written safety program. Instead, 29 CFR 1926.20(b) requires the programs needed to comply with the standards, and specific standards require written documents, such as a silica exposure control plan or a hazard communication program. Some state plans require one: Washington requires a written accident prevention program tailored to the work (WAC 296-155-110).

Source: WAC 296-155-110: Accident prevention program (Washington)

A competent person is someone who can identify existing and predictable hazards on the job and has the authority to take prompt corrective action to eliminate them. Both parts are needed: knowing the hazards and having the power to fix them. Several construction standards, including excavations, scaffolds and silica, require a competent person to inspect the work.

Source: 29 CFR 1926.32: Definitions

Fall protection is required in construction at 6 feet or more above a lower level. At that height, unprotected sides and edges need guardrails, safety nets or a personal fall arrest system (29 CFR 1926.501(b)(1)). Scaffolds have their own rule: workers on a scaffold more than 10 feet above a lower level must be protected (29 CFR 1926.451(g)(1)).

Source: 29 CFR 1926.501: Duty to have fall protection

Only if you use the fall protection plan option in 29 CFR 1926.502(k), which is allowed only for leading edge work, precast concrete erection and residential construction. You must be able to show that guardrails, nets or personal fall arrest are infeasible or create a greater hazard. The plan must be written by a qualified person for that specific site, kept up to date and kept at the job site.

Source: 29 CFR 1926.502: Fall protection systems criteria and practices

A trench or other excavation needs a protective system once it is 5 feet deep or more, unless it is dug entirely in stable rock. A shallower excavation also needs protection if a competent person examining the ground sees signs of a possible cave-in. Protective systems include sloping, benching, shoring and trench shields.

Source: 29 CFR 1926.652: Requirements for protective systems

The Focus Four are the four construction hazards OSHA highlights in its outreach training: falls, caught-in or -between, struck-by, and electrocution. Each one has its own lesson in the OSHA 10-hour and 30-hour construction courses.

Source: OSHA: Focus Four Hazards

Contact 811 a few business days before any digging, even small jobs like setting a post or planting a tree. 811 is the free national before-you-dig service that has utilities mark their buried lines. Wait until every utility has responded and marked, then dig carefully around the marks; state laws on timing vary, so check your state 811 center.

Source: 811: Before you dig

A work-related death must be reported to OSHA within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours. You can report by phone to the nearest OSHA area office, by calling 1-800-321-OSHA (6742), or online. A death only has to be reported if it happens within 30 days of the incident, and a hospitalization, amputation or eye loss if it happens within 24 hours of it.

Source: 29 CFR 1904.39: Reporting fatalities, hospitalizations, amputations, and losses of an eye

Not by federal OSHA: the 10-hour and 30-hour Outreach courses are voluntary under federal rules. OSHA notes that some states have passed laws requiring the training, and employers, unions and contracts can require it too. For example, New York requires every worker on public work contracts of $250,000 or more to finish an OSHA-approved 10-hour construction course before starting work (Labor Law 220-h).

Source: OSHA Outreach Training Program FAQs

No, OSHA construction and general industry Outreach cards do not expire. OSHA also says the card is not a certification or license; it shows the person completed the course. Some states, employers or contracts may still require refresher training.

Source: OSHA Outreach Training Program FAQs

The employer must provide required PPE at no cost to employees (29 CFR 1926.95(d)). The main exceptions are non-specialty safety-toe boots and non-specialty prescription safety glasses that workers may wear off the job, plus everyday clothing and ordinary weather gear like winter coats and rain gear. Employers must also pay for replacement PPE unless the worker lost it or damaged it on purpose.

Source: 29 CFR 1926.95: Criteria for personal protective equipment

Yes, any construction employer covered by the silica standard must have a written exposure control plan (29 CFR 1926.1153(g)). The plan describes the tasks that create silica dust, the controls and respirators for each task, housekeeping methods and how access is restricted. It must be reviewed at least once a year and implemented by a competent person who inspects the site.

Source: 29 CFR 1926.1153: Respirable crystalline silica

OSHA 300 logs, the 300A annual summary and the 301 incident reports must be kept for 5 years after the end of the year they cover (29 CFR 1904.33). During those 5 years you must update the 300 log if you learn of new recordable cases. Employers with 10 or fewer employees all last year are generally exempt from keeping the log, but they must still report serious injuries and deaths.

Source: 29 CFR 1904.33: Retention and updating

Post the 300A annual summary by February 1 and keep it up until April 30. It covers the previous calendar year and must be certified by a company executive, such as an owner or corporate officer.

Source: 29 CFR 1904.32: Annual summary

Yes, unless you run an assured equipment grounding conductor program instead (29 CFR 1926.404(b)(1)). The rule covers 120-volt, single-phase, 15 and 20 amp receptacles that are not part of the building's permanent wiring. If you choose the assured grounding program, it must be written, run by a competent person, and include recorded tests at least every 3 months.

Source: 29 CFR 1926.404: Wiring design and protection

A work-related injury or illness is recordable if it causes death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness. A significant injury or illness diagnosed by a doctor or other licensed health care professional is also recordable, even without those outcomes.

Source: 29 CFR 1904.7: General recording criteria