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Plumbing · United States

JHA for bathroom rough-in plumbing

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for bathroom rough-in plumbing 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 silica dust from concrete, brick, stone and tiles, electric shock from live wiring, disturbing asbestos and saw cuts and kickback.

JHA example: bathroom rough-in plumbing

This is a complete JHA for bathroom rough-in plumbing, with 6 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)
Bathroom rough-in plumbing · Plumbing · Example
Document JHA-001 · Rev 1

Job steps, hazards and controls

#Job stepHazardsRisk beforeControlsRisk after
1Isolate water to the area and confirm power is off to any circuits in the walls
  • Electric shock from live wiring
  • Stored energy
Critical
  • Isolate the power before any work. Do not work live. Elimination
  • Lock out and tag the disconnecting means with your own personal lock and tag so the circuit cannot be energized (29 CFR 1926.417). Engineering (guarding)
  • Test before you touch: prove dead at the point of work with a tested voltage tester. Engineering
  • Only qualified persons work on or near exposed energized parts. Administrative
  • Check for back feeds from solar, batteries and generators that can keep a circuit live after the main switch is off. Administrative
  • If energized work cannot be avoided, use an energized work permit, a safety observer and insulated tools, following NFPA 70E. Administrative
  • Wear insulated gloves, arc-rated clothing and a face shield when testing or working near live parts. PPE
  • Release or block all stored energy before work: release the pressure in pipes, tanks and hoses, bleed hydraulics, release springs, lower loads. Elimination
  • Lock out and tag all energy sources with personal locks. Engineering (guarding)
  • Put mechanical blocks or props under raised parts like buckets, tipper bodies and doors. Engineering
  • Test that the system is dead and nothing can move before you start. Administrative
  • Follow the maker's procedure, for example for garage door and roller door springs. Administrative
  • Wear safety glasses and gloves. PPE
Medium
2Check walls and floors for asbestos before cutting
  • Disturbing asbestos
Critical
  • 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
3Cut slab or wall chases with water suppression or dust extraction
  • Silica dust from concrete, brick, stone and tiles
  • Saw cuts and kickback
  • Loud noise
  • Hand-arm and whole-body vibration
Critical
  • Order materials cut to size, or use low-dust methods such as score and snap or a block splitter. Substitution
  • Cut outdoors or in a separate area, with other people well away and upwind. Engineering (guarding)
  • Use wet cutting or on-tool dust collection with a HEPA vacuum, as set out in Table 1 of 29 CFR 1926.1153. Engineering
  • Clean up with a vacuum or wet methods. Never dry sweep or use compressed air. Administrative
  • Have a written exposure control plan and a competent person for silica (29 CFR 1926.1153). Administrative
  • Workers who must wear a respirator 30 or more days a year get a free medical exam every 3 years (29 CFR 1926.1153(h)). Administrative
  • Keep blade guards fitted and working, and use the riving knife on table saws. Engineering
  • Use push sticks and clamps, and support long pieces so they do not pinch the blade. Engineering
  • Use a sharp, undamaged blade made for the material. Administrative
  • Stand to one side of the blade line, out of the kickback path. Administrative
  • Use quieter tools and methods, such as cut-to-size materials, low-noise machines and battery tools. Substitution
  • Keep noisy plant away from work areas, and use screens or distance between the noise and people. Engineering (guarding)
  • Keep tools maintained and use mufflers on compressors and generators. Engineering
  • Limit time on noisy tools and rotate workers. Administrative
  • Use low-vibration tools and methods, such as a breaker on an excavator instead of a hand jackhammer. Substitution
  • Keep tools sharp and well maintained, and use anti-vibration handles and seats. Engineering
  • Limit trigger time on high-vibration tools and rotate workers. Administrative
  • Keep hands warm and dry, and take regular breaks. Administrative
Medium
4Run waste and water pipes, working at floor level with knee pads
  • Lifting and carrying heavy loads
  • Repetitive work and awkward postures
  • Cuts from sharp edges
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
  • Use tools that cut the effort: powered screwdrivers, long-handled tools and extension poles for overhead work. Substitution
  • Set work up at waist height on benches or trestles where you can. Engineering
  • Use light tools with good grips, and keep blades and bits sharp. Engineering
  • Rotate tasks and take short breaks every hour on repetitive work. Administrative
  • Warm up before heavy physical work and report aches and pains early. 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
Medium
5Glue solvent joints with ventilation and no flames nearby
  • Hazardous chemicals
  • Flammable liquids and gases
High
  • 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
  • Use non-flammable or water-based products where you can. Substitution
  • Keep ignition sources away: no smoking, no hot work and no running engines near flammables. Engineering (guarding)
  • Store fuels and solvents in approved, closed containers in a ventilated area away from the work. Engineering
  • Refuel equipment outdoors with the engine off and cool. Administrative
  • Keep only what you need for the day on site. Administrative
  • Store gas cylinders upright, secured and outdoors. Administrative
  • Keep a suitable fire extinguisher where flammables are used or stored. Administrative
  • Wear chemical gloves and safety glasses when pouring or mixing. PPE
Medium
6Pressure test the pipework and clean up
  • Pressure testing
  • Poor housekeeping and waste
Medium
  • Test with water instead of air or gas where the system allows it. Never put water in refrigerant pipework, which is tested with dry nitrogen. Substitution
  • Keep people out of the test area with signs and barriers. Engineering (guarding)
  • Use a calibrated gauge and a relief valve set to protect the system. Engineering
  • Test to the pressure the system calls for and hold it for the set time. Never go over. Administrative
  • Release the pressure fully before tightening anything or fixing leaks. Administrative
  • Wear safety glasses or a face shield. PPE
  • 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
Low

PPE

Safety-toe boots (ASTM F2413)Safety glasses (ANSI Z87.1)N95 respiratorHearing protection (earmuffs or plugs)Knee padsWork glovesHalf-face respirator (P100 cartridges)CoverallsCut-resistant glovesChemical-resistant glovesSafety goggles (ANSI Z87.1)Face shield (ANSI Z87.1)

Plant and equipment

Power drillRotary hammerProPress toolHand toolsConcrete saw (cut-off saw)

Permits and plans

Lockout/tagout (1926.417)

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 bathroom rough-in plumbing

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 bathroom rough-in plumbing

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

The safe sequence of work

  1. Isolate water to the area and confirm power is off to any circuits in the walls
  2. Check walls and floors for asbestos before cutting
  3. Cut slab or wall chases with water suppression or dust extraction
  4. Run waste and water pipes, working at floor level with knee pads
  5. Glue solvent joints with ventilation and no flames nearby
  6. Pressure test the pipework and clean up

Hazards to watch on bathroom rough-in plumbing

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

Step 5Flammable liquids and gasesGasoline, solvents, thinners and propane catch fire or explode when vapor reaches a spark, flame or hot surface.
Step 6Pressure testingA pipe, fitting or cap fails under test pressure and blows apart, hitting people nearby.
Step 1Stored energyEnergy left in springs, hydraulics, compressed gas, raised loads or capacitors releases suddenly and crushes or injures workers.
Step 3Hand-arm and whole-body vibrationLong periods on jackhammers, grinders, compactors or riding plant cause white finger, numbness and back damage.
Step 2Disturbing asbestosIn buildings built before 1981, OSHA presumes pipe and boiler insulation, sprayed or troweled coatings, and asphalt and vinyl flooring contain asbestos, and many other older materials can too. Drilling, cutting or breaking it releases fibers that cause cancer years later.
Step 3Saw cuts and kickbackCircular saws, miter saws and table saws cut fingers and hands or throw material back at the user.
Almost certainLikelyPossibleUnlikelyRareHow bad it could be: First aid only to FatalityBA
Highest risk on bathroom rough-in plumbing: 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 work 6 feet or more above a lower level?
  • 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 a scaffold or rolling tower?

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 bathroom rough-in plumbing?

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for bathroom rough-in plumbing 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 bathroom rough-in plumbing?

Usually Safety-toe boots (ASTM F2413), Safety glasses (ANSI Z87.1), N95 respirator, Hearing protection (earmuffs or plugs), Knee pads, Work gloves, Half-face respirator (P100 cartridges), Coveralls, Cut-resistant gloves, Chemical-resistant gloves, Safety goggles (ANSI Z87.1), Face shield (ANSI Z87.1). The site rules may add more, so check with the general contractor.

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

Sources