How to write a JHA, step by step

This guide builds a JHA for one real job: replacing about 40 damaged concrete roof tiles on a two-story house. The eave is about 14 ft above a concrete driveway, the roof is steep, and a service drop comes in at the front corner. A foreman and two roofers will do the work.

The steps follow OSHA 3071, OSHA's own JHA guide. OSHA does not require a particular form.

OSHA 3071 starts here. The people who do the job know where it goes wrong, and involving them makes the controls more likely to be followed. Walk the roof job with the roofers before writing anything.

Look at past injuries, damage and near misses on similar jobs. For the roof crew: a ladder that slid on a smooth driveway last year, and a tile that slid off the roof near a homeowner. These show where existing controls may not be enough.

Talk through the hazards the crew already knows about and fix anything easy straight away. OSHA 3071 says if any hazard poses an immediate danger to life or health, act at once, without waiting for the JHA. For the roof job, the cracked ladder foot gets replaced before anything else.

Watch the work, or talk it through, and list each step in order. OSHA 3071 warns against steps so detailed the list becomes unnecessarily long, or so broad it leaves out basic steps.

• 1. Barricade the driveway and check the weather and the service drop.
• 2. Set and secure the ladder; install the ridge anchor and roof brackets.
• 3. Walk to the damaged area and remove broken tiles.
• 4. Cut replacement tiles.
• 5. Set new tiles and re-point the ridge.
• 6. Clean up and take down access equipment.

For each step, OSHA 3071 asks: what can go wrong, what are the consequences, how could it happen, what else contributes, and how likely is it? A good hazard description says where it happens, who is exposed, what triggers it and what the outcome would be.

OSHA's recommended practices use the NIOSH hierarchy, from most to least effective: elimination, substitution, engineering controls, administrative controls, then PPE. OSHA says to pick controls that are the most feasible, effective and permanent, avoid controls that create new hazards, and combine them when no single method fully protects workers. OSHA 3071 makes the same point: engineering controls that physically change the work beat procedures, which beat PPE.

Then check the OSHA standards that apply, because compliance with them is mandatory. For this job:

• Falls: in residential construction, workers 6 ft or more above a lower level need guardrails, safety nets or personal fall arrest, unless the employer shows these are infeasible and uses a fall protection plan (29 CFR 1926.501(b)(13)). Control: ridge anchor and personal fall arrest for every roofer, plus roof brackets and planks.
• Ladder: side rails at least 3 ft above the landing, or the ladder secured at the top with a grab device (1926.1053(b)(1)); set at about 1 to 4 (1926.1053(b)(5)(i)). Control: tie off the top and foot the base on the driveway.
• Silica: for handheld power saws, Table 1 calls for a saw with an integrated water delivery system feeding water to the blade; outdoors, no respirator is required for 4 hours or less a shift and APF 10 above that (1926.1153). Control: wet cutting at a ground station.
• Falling objects: barricade the driveway and keep the homeowner out of the drop zone.
• Service drop: keep ladders and tools clear and ask the utility to cover the line if work must be close.

OSHA 3071 asks you to judge how likely each hazard is; it does not require a score. Many GCs ask for one. A 5x5 matrix multiplies likelihood by severity: 1 to 4 Low, 5 to 9 Medium, 10 to 14 High, 15 to 25 Critical. These bands are common practice, not an OSHA rule.

For the fall from the eave: Likely (4) x Fatality (5) = 20, Critical, before controls. With personal fall arrest correctly anchored and used: Unlikely (2) x Fatality (5) = 10, High. Adding roof brackets and planks along the eave takes it to Rare (1), a score of 5, Medium. Severity stays the same.

Go through the JHA with every worker before starting and get signatures. Make sure a competent person is named for the inspections 1926.20(b)(2) requires, and that each worker has the training 1926.21(b)(2) calls for. Review the JHA after any injury or near miss and whenever the job changes, then retrain the crew on what changed, as OSHA 3071 advises.

General contractors and safety reviewers usually look for these points.

• Steps, hazards and controls are specific to this job and site.
• OSHA standards are cited where they apply (fall protection, ladders, scaffolds, silica).
• A competent person is named for fall protection and any other discipline involved.
• Equipment is listed with inspection requirements, and training is listed for the people using it.
• Respirators, if used, are backed by a respiratory protection program and fit testing.
• The crew signed, and the JHA has a date and revision number.