What is a JHA (Job Hazard Analysis)?

OSHA's guide, OSHA 3071 Job Hazard Analysis, defines it as a technique that focuses on job tasks as a way to identify hazards before they occur, looking at the relationship between the worker, the task, the tools and the work environment. Once uncontrolled hazards are found, you take steps to eliminate or reduce them to an acceptable risk level.

OSHA calls the JHA one part of a wider safety and health management system, and notes it is also a useful tool for training new employees in the steps of a job.

The sample form in OSHA 3071 has these fields: job title, job location, analyst, date, task number and description, hazard type, hazard description, consequence, hazard controls, and a rationale or comment. Most contractors add the crew names and signatures, the equipment used, and the competent person.

OSHA says a good hazard description covers where it is happening, who or what it is happening to, what triggers it, what the outcome would be, and any other contributing factors. For a roofer that might read: on the eave of a steep tile roof, a roofer carrying tiles slips on a wet tile and falls 14 ft to the driveway; rushing to beat the rain makes it more likely. Written that way, the controls almost suggest themselves.

No federal OSHA standard requires a construction employer to complete a document called a JHA. The legal duties it helps you meet are these:

• OSH Act Section 5(a)(1), the General Duty Clause: provide a workplace free from recognized hazards that are causing or are likely to cause death or serious physical harm.
• OSH Act Section 5(a)(2): comply with OSHA standards. OSHA 3071 tells you to consult the standards for your industry when doing a JHA, because compliance with them is mandatory.
• 29 CFR 1926.20(b)(1) and (2): run the programs needed to comply, including frequent and regular inspections of job sites, materials and equipment by competent persons.
• 29 CFR 1926.20(b)(4): only let employees qualified by training or experience operate equipment and machinery.
• 29 CFR 1926.21(b)(2): instruct each employee in recognizing and avoiding unsafe conditions and in the regulations that apply to their work.

Even though OSHA does not require one by name, general contractors, owners and insurers often make a JHA a condition of the subcontract. Federal projects run by the US Army Corps of Engineers use a version called an activity hazard analysis (AHA).

OSHA 3071 says to give priority to jobs with the highest injury or illness rates, jobs that could cause severe or disabling injuries even without a history of accidents, jobs where one simple human error could lead to a severe injury, jobs that are new or have changed, and jobs complex enough to need written instructions. Roofing, trenching, steel erection and work near power lines all fit.

Many states run their own OSHA-approved state plans, which may have standards that differ from the federal ones. Check your state plan if you work in one.

OSHA 3071 is written for employers, foremen and supervisors, and its first step is to involve your employees, because they understand the job and will buy in to the solutions. In practice a foreman or competent person writes the JHA with the crew, and the workers sign to show it was reviewed with them.

OSHA 3071 suggests professional help if your employees are involved in many different or complex processes.

OSHA 3071 says to review the JHA periodically, even if the job has not changed, because a review can find hazards missed the first time. It is particularly important to review it after an illness or injury on that job, and to discuss any close call with everyone who does the job. Any time you revise a JHA, train all affected employees in the new methods, procedures or protective measures.

On site, that means updating the JHA when the scope, the crew, the equipment or the conditions change, and re-briefing before work continues.

No OSHA standard sets a retention period for a JHA itself. Keep it on site during the job, and keep it afterwards with the training and inspection records it relates to, which some standards and state plans do require you to keep. Your general contractor or insurer may set a longer period in the contract.

These names describe very similar documents. OSHA 3071 itself switches between job hazard analysis and job safety analysis. The AHA is the format used on Army Corps of Engineers work under its safety manual, EM 385-1-1.

Most rejected JHAs fail for the same reasons.

• Steps so broad they say nothing (install roof) or so detailed nobody reads them. OSHA 3071 warns against both.
• Hazards written as one word (falls) with no description of how harm happens.
• Controls that are only PPE or "be careful", when engineering controls are feasible.
• No OSHA standard referenced where one applies, such as fall protection or silica.
• No crew involvement or signatures.
• Never updated after an injury, near miss or change in the job.