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Glazing · United States

JHA for window replacement

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for window replacement before you start.

A JHA breaks the job into steps, lists the hazards in each step and the controls that protect the crew, and the crew signs it. The main hazards are falling from height, disturbing asbestos, scaffold collapse or fall from scaffold and falling through a floor opening or void.

JHA example: window replacement

This is a complete JHA for window replacement, with 9 job steps. Open it in the builder to add your site, crew and signatures, change anything, and download a PDF. Or download the free Word template below and fill it in by hand.

Job Hazard Analysis (JHA)
Window installation · Glazing · Example
Document JHA-001 · Rev 1

Job steps, hazards and controls

#Job stepHazardsRisk beforeControlsRisk after
1Check frames and paint for lead and asbestos
  • Lead paint dust and fumes
  • Disturbing asbestos
Critical
  • Test old paint for lead before you sand, scrape, cut or heat it. Elimination
  • Use wet scraping, chemical strippers or shrouded tools with extraction instead of dry sanding. Never burn off lead paint with an open flame. Substitution
  • Seal off the work area with plastic sheeting and keep residents, children and pets out. Engineering (guarding)
  • Clean up with a HEPA vacuum and wet wipes. Never dry sweep. Engineering
  • In homes and child-occupied facilities built before 1978 (such as child care centers, preschools and kindergarten classrooms), work that disturbs more than 6 sq ft inside or 20 sq ft outside is done by an EPA Lead-Safe Certified firm with a certified renovator (RRP rule). Administrative
  • Do an initial lead exposure assessment and protect workers as if over the limit until results are in. Over 50 micrograms per cubic meter, follow a written lead compliance program (29 CFR 1926.62(d), (e)). Administrative
  • Never torch painted surfaces, keep heat guns below 1,100 degrees F, and use sanders, grinders or planers only with a shroud and HEPA vacuum attachment (40 CFR 745.85(a)(3)). Administrative
  • Provide a clean change area and handwashing, and keep food, drink and tobacco out of the work area (29 CFR 1926.62(i)). Administrative
  • Wash hands and face before eating, drinking or smoking. Change out of dusty clothes before going home. Administrative
  • Wear a NIOSH-approved respirator with N100 or P100 filters, disposable coveralls and gloves. PPE
  • Treat insulation, surfacing and resilient flooring in buildings built before 1981 as asbestos unless testing shows otherwise, and get the owner's asbestos survey before you start. Elimination
  • Seal off the work area and keep everyone else out. Engineering (guarding)
  • If asbestos must be disturbed, keep it wet, use hand tools not power tools, and clean up with a HEPA vacuum. Engineering
  • Follow 29 CFR 1926.1101: competent person, work class, regulated area and exposure monitoring. Administrative
  • Commercial renovation and any demolition need a NESHAP asbestos inspection first, and demolition needs written notice to the state or EPA 10 working days before work starts (40 CFR 61 Subpart M). Administrative
  • Roofing felts, cement shingles and siding, roof coatings and old panel backboards can also contain asbestos. Test them or treat them as asbestos; asbestos roofing is removed intact with hand tools by trained workers (29 CFR 1926.1101(g)(8)). Administrative
  • Stop work straight away if you find suspect asbestos. Do not touch it and tell your supervisor. Administrative
  • Wear a fit-tested NIOSH-approved respirator suited to the work class, and disposable coveralls. PPE
Medium
2Protect occupants and furnishings and set exclusion areas inside and out
  • Working in an occupied home or building
  • Public entering the work area
High
  • Plan noisy, dusty or risky work for when the building is empty. Elimination
  • Close off the work area with barriers, plastic sheeting or locked doors, and put up signs. Engineering (guarding)
  • Keep fire exits and paths clear at all times. Administrative
  • Tell occupants before you turn off power, water or gas, and before noisy or dusty work. Administrative
  • Lock away tools, chemicals and materials each day, out of reach of children. Administrative
  • Clean up dust and debris at the end of each day. Administrative
  • Fence off the site with secure temporary fencing and lock the gates when you leave. Engineering (guarding)
  • Give pedestrians a safe, marked path around the work, with ramps for strollers and wheelchairs. Engineering (guarding)
  • Use hoarding, covered walkways or catch fans where work is above public areas. Engineering
  • Put signs at each entry: site name, contact number and "No unauthorized entry". Administrative
  • Make the site safe at the end of each day: cover holes, lower plant, remove ladders and lock tools away. Administrative
  • Use a spotter when moving plant or materials across public paths. Administrative
Low
3Set up access for upper floor windows and barricade below
  • Falling from height
  • Scaffold collapse or fall from scaffold
  • Falling tools and materials
Critical
  • Do the work from the ground where you can, for example pre-assemble on the ground or use extension poles. Elimination
  • Install guardrails or edge protection on all open edges before work starts. Engineering (guarding)
  • Use a scaffold, mobile work platform or aerial lift instead of working off a ladder. Engineering
  • Where edge protection is not practical, use a fall restraint or fall arrest system on a rated anchor point. Engineering
  • Provide fall protection at 6 feet or more and train workers to recognize fall hazards (29 CFR 1926.503). Administrative
  • Have a rescue plan so a worker hanging in a harness can be brought down within minutes. Administrative
  • Scaffold is built, moved and taken down under the supervision of a competent person. Engineering
  • Fit guardrails, mid rails and toe boards on every platform more than 10 feet above a lower level, or use personal fall arrest (29 CFR 1926.451(g)(1)). Engineering
  • Use mobile scaffolds only on firm, level ground with casters locked, and guy, tie, brace or fit outriggers once the height is more than 4 times the base width (29 CFR 1926.451(c)(1)). Never move one with anyone on it. Engineering
  • Every worker on the scaffold is trained by a qualified person (29 CFR 1926.454). Administrative
  • A competent person inspects the scaffold before each shift and after anything that could affect it (29 CFR 1926.451(f)(3)). Administrative
  • Do not overload platforms. Know the rated load (light, medium or heavy duty) and stack materials over the legs, not mid-span (29 CFR 1926.451(f)(1)). Administrative
  • Barricade and sign the drop zone under overhead work so nobody walks beneath. Engineering (guarding)
  • Fit toe boards, kick plates and mesh screens on scaffolds and edges. Engineering
  • Use catch fans, debris netting or covered walkways where people pass below. Engineering
  • Tether hand tools when working at height. Engineering
  • Keep platforms tidy. Do not stack materials near edges or above toe board height. Administrative
Medium
4Remove beads and old glass first, wearing cut gloves
  • Glass handling and breakage
  • Cuts from sharp edges
High
  • Use suction lifters, glass trolleys or a glazing robot for large panes. Engineering
  • Store glass upright on racks and secure it. Never lay it flat or lean it loosely. Engineering
  • Glass handling and breakage: see step 7 for the full controls Administrative
  • Deburr or cover sharp edges, and fit edge protectors on exposed sheet metal. Engineering
  • Use knives with retractable or self-retracting blades. Engineering
  • Cut away from your body and keep your other hand clear. Administrative
  • Put used blades in a blade bin or sharps container. Administrative
  • Use two people to handle large sheets of metal or glass. Administrative
  • Wear cut-resistant gloves and long sleeves. PPE
Medium
5Remove the old frame, guarding the open hole
  • Falling through a floor opening or void
  • Lifting and carrying heavy loads
Critical
  • Cover every hole with a secured cover marked "HOLE" or "COVER" that can hold twice the weight it may carry. Engineering (guarding)
  • Put guardrails with toe boards around stairwells, elevator shafts, floor holes and open edges. Engineering (guarding)
  • Install stairs early and fit temporary handrails as soon as they go in. Engineering
  • Never remove a cover or guardrail without approval. Put it back straight away. Administrative
  • Inspect covers and barriers daily and after other trades have been through. Administrative
  • Keep lighting good enough to see openings, especially on lower floors and in the evening. Administrative
  • Use a harness clipped to a rated anchor when working right next to an open void. PPE
  • Plan to avoid carrying: have materials delivered, and old items picked up, as close as possible to where they are used. Elimination
  • Use lighter or smaller loads: order smaller bags and shorter lengths, and drain or break down old items before moving them. Substitution
  • Lifting and carrying heavy loads: see step 7 for the full controls Administrative
Medium
6Check the opening and lintel, and prop it if it is not sound
  • Structural collapse during alterations
High
  • Get an engineer to check before removing any wall, beam, post or bracing that may be load-bearing. Elimination
  • Keep everyone clear of the area under and next to the work. Engineering (guarding)
  • Install temporary props, needles or shoring as designed before removing any support. Engineering
  • Follow the engineer's sequence. Do not change it without approval. Administrative
  • Check props daily. Do not remove them until the permanent support is in and approved. Administrative
  • Wear a hard hat and safety boots. PPE
Medium
7Lift new windows with two people or suction lifters
  • Lifting and carrying heavy loads
  • Glass handling and breakage
High
  • Plan to avoid carrying: have materials delivered, and old items picked up, as close as possible to where they are used. Elimination
  • Use lighter or smaller loads: order smaller bags and shorter lengths, and drain or break down old items before moving them. Substitution
  • Use trolleys, pallet jacks, hoists, vacuum lifters or plant instead of carrying by hand. Engineering
  • Use a two-person lift for anything heavy, long or awkward. Plan the route first and clear it. Administrative
  • Keep the load close, back straight and no twisting. Turn with your feet. Administrative
  • Rotate tasks and take breaks on long lifting jobs. Administrative
  • Wear gloves for grip and safety boots to protect your feet. PPE
  • Use suction lifters, glass trolleys or a glazing robot for large panes. Engineering
  • Store glass upright on racks and secure it. Never lay it flat or lean it loosely. Engineering
  • Use two or more people for large panes, and clear the carry route first. Administrative
  • Mark new glass with tape or stickers so nobody walks into it. Administrative
  • Clean up broken glass straight away into a marked container. Administrative
  • Wear cut-resistant gloves, arm guards, safety glasses and safety boots. PPE
Medium
8Fix, pack, seal and flash the window
  • Injury from power tools
  • Hazardous chemicals
Medium
  • Keep all guards fitted and working. Never tie back or remove a guard. Engineering
  • Clamp or secure the work piece. Do not hold it by hand. Engineering
  • Only trained, competent people use power tools, following the maker's instructions. Administrative
  • Check tools before use. Unplug or remove the battery before changing blades or bits. Administrative
  • No loose clothing, jewelry or long hair near spinning parts. Administrative
  • Wear safety glasses and hearing protection. Do not wear loose gloves on drills or other rotating tools. PPE
  • Choose the least harmful product that does the job, for example water-based instead of solvent-based. Substitution
  • Use chemicals in well-ventilated areas, or use fans and extraction in closed rooms. Engineering
  • Read the Safety Data Sheet (SDS) and labels before use, following OSHA Hazard Communication. Administrative
  • Keep chemicals in labeled containers. Never pour them into drink bottles. Administrative
  • Store chemicals away from heat, food and drink, and keep products that react with each other apart. Administrative
  • Have eye wash and a spill kit nearby, and wash hands before eating. Administrative
  • Wear chemical-resistant gloves and safety glasses or goggles as listed on the SDS. PPE
  • Use a respirator with the right cartridge if the SDS calls for one. PPE
Medium
9Make good, then clean up broken glass and waste
  • Poor housekeeping and waste
  • Cuts from sharp edges
Medium
  • Order materials to size and send packaging back where you can. Elimination
  • Put dumpsters and waste chutes close to the work. Engineering
  • Clean as you go, and do a full clean up at the end of each day. Administrative
  • Keep exits, stairs and walkways clear at all times. Administrative
  • Stack materials neatly on level ground, away from edges. Administrative
  • Wear gloves when handling waste. PPE
  • Cuts from sharp edges: see step 4 for the full controls Administrative
Low

PPE

Safety-toe boots (ASTM F2413)Cut-resistant glovesSafety glasses (ANSI Z87.1)Hard hat (ANSI Z89.1)Half-face respirator (P100 cartridges)CoverallsWork glovesN95 respiratorHigh-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways)Hearing protection (earmuffs or plugs)Chemical-resistant glovesSafety goggles (ANSI Z87.1)

Plant and equipment

Power drillMobile (rolling) scaffold: Erected under a competent person (29 CFR 1926.451)Hand toolsPlatform ladder

Permits and plans

Written fall protection plan (only where guardrails, nets or personal fall arrest are not feasible, 1926.502(k))

Emergency

Call 911. Add the nearest hospital, the assembly point and the first aid / cpr person for your site.

Sign-off

Supervisor and every worker sign to confirm they have read and understood this JHA.

Free JHA template for window replacement

Word (.docx) and PDF, Letter landscape, no email needed. Fill in your site details, then print or send it.

Make yours in 2 minutes

Same document, filled in for your job. Answer a few yes or no questions, the crew signs on the phone, and you send the PDF.

Start this JHA

Pre-start checklist for window replacement

Tick these off before work starts. They come from the hazards, permits and equipment in this job.

The safe sequence of work

  1. Check frames and paint for lead and asbestos
  2. Protect occupants and furnishings and set exclusion areas inside and out
  3. Set up access for upper floor windows and barricade below
  4. Remove beads and old glass first, wearing cut gloves
  5. Remove the old frame, guarding the open hole
  6. Check the opening and lintel, and prop it if it is not sound
  7. Lift new windows with two people or suction lifters
  8. Fix, pack, seal and flash the window
  9. Make good, then clean up broken glass and waste

Hazards to watch on window replacement

The hazards most specific to this job, and the step where each one comes up.

Step 1Lead paint dust and fumesHomes and child-occupied facilities built before 1978 may have lead paint. Sanding, scraping or heating it releases dust that poisons workers and children.
Step 4, 7Glass handling and breakageGlass panes break while being moved or fitted, causing deep cuts, or heavy panels fall and crush.
Step 3Scaffold collapse or fall from scaffoldA scaffold that is badly built, overloaded or altered collapses or tips, or a worker falls from an unguarded platform.
Step 2Working in an occupied home or buildingResidents, staff or children wander into the work area and get hurt, or the work blocks exits or cuts off power or water while people are inside.
Step 6Structural collapse during alterationsRemoving a wall, beam, post or bracing makes part of the building fall on workers.
Step 5Falling through a floor opening or voidA worker steps into an open hole, stairwell, elevator shaft or floor opening and falls to the level below.
Almost certainLikelyPossibleUnlikelyRareHow bad it could be: First aid only to FatalityBA
Highest risk on window replacement: Critical before controls (B), down to Medium after controls (A), on the United States 5 by 5 risk matrix (likely and fatality becomes unlikely and serious injury).

What changes on your site

This example covers the job itself. Your site may add more. Add controls for any of these that apply (the builder asks you these as yes or no questions):

  • Will anyone use a ladder or stepladder?
  • Will anyone work on a roof?
  • Is there a skylight, fiberglass panel or other fragile roofing?
  • Will you use an aerial lift (scissor lift or boom lift)?
  • Will you cut, grind or drill concrete, brick, stone, tile or fiber cement?

Licences and legal requirements in United States

Equipment on this job that needs a licence, ticket or training:

  • Mobile (rolling) scaffold: Erected under a competent person (29 CFR 1926.451)

OSHA requires employers to find and fix hazards and to train workers on them. A JHA breaks the job into steps, lists the hazards in each step and the controls that protect the crew. General contractors often require one before you start.

Rules that apply: 40 CFR Part 745 (RRP rule) and 29 CFR 1926.62; 29 CFR 1926.1101 and 40 CFR 61 Subpart M (NESHAP); 29 CFR 1926 Subpart M; 29 CFR 1926 Subpart L; 29 CFR 1926.501(c); 29 CFR 1926 Subpart I; 29 CFR 1926.59 Hazard Communication.

Why JHAs get rejected

General contractors send documents back for these reasons. This example avoids them, but check yours too.

  • Generic steps such as "work safely" or "use PPE" with no task-specific hazards or controls.
  • No OSHA standards referenced for the hazards that have them, such as fall protection, ladders, scaffolds or silica.
  • No competent person named for fall protection, excavation, scaffolds or silica where those hazards exist.
  • Equipment listed without inspection requirements, and no training listed for the people using it.
  • Respirators listed with no respiratory protection program, medical clearance or fit test.
  • Controls rely only on PPE when engineering controls such as guardrails, wet cutting or extraction are feasible.
  • No crew sign-off, or no date and revision when the job has changed.

Questions

Do I need a JHA for window replacement?

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for window replacement before you start.

Who signs the JHA?

The supervisor or competent person who prepared it signs, and every crew member signs to show they were trained on the hazards and controls before the job starts. Many general contractors also sign to accept it.

How long do I keep it?

Keep this JHA on site during the job, and keep it with the training and inspection records for at least 1 year after the job (longer if your state plan or general contractor requires it). OSHA does not set a retention period for JHAs themselves.

What PPE is needed for window replacement?

Usually Safety-toe boots (ASTM F2413), Cut-resistant gloves, Safety glasses (ANSI Z87.1), Hard hat (ANSI Z89.1), Half-face respirator (P100 cartridges), Coveralls, Work gloves, N95 respirator, High-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways), Hearing protection (earmuffs or plugs), Chemical-resistant gloves, Safety goggles (ANSI Z87.1). The site rules may add more, so check with the general contractor.

More glazing JHAs

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Toolbox talks for this job

Blank JHA template: free JHA templates. Also for other countries: Australia (SWMS) · United Kingdom (RAMS) · Canada (FLHA)

Sources