Roofing · United States

JHA for gutter replacement

By SiteSortedBuilt from OSHA standards and guidance · How we write and check theseUpdated November 9, 2026

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for gutter 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, aerial lift tip-over or crush and scaffold collapse or fall from scaffold.

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JHA example: gutter replacement

This is a complete JHA for gutter 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)

Replace gutters and downspouts · Roofing · Example

Document JHA-001 · Rev 1

Job steps, hazards and controls

#	Job step	Hazards	Risk before	Controls	Risk after
1	Barricade the area below and check for power lines near the gutter line	Public entering the work area Contact with overhead power lines Falling tools and materials	High	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 Ask the utility to de-energize, move or insulate the lines before work starts. Elimination Use non-conductive (fiberglass) ladders near any power lines. Substitution Mark the safe distance with flags, tape or warning lines and keep all equipment and people outside it. Engineering (guarding) Keep equipment at least 10 feet from lines up to 50 kV once the utility confirms the voltage, more for higher voltages, and 20 feet when the voltage is unknown (29 CFR 1926.1408). Administrative Use a dedicated spotter whenever equipment moves or raises anything near lines. Administrative Treat all lines as energized. If equipment touches a line, the operator stays in the cab and everyone else keeps well away. 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 Falling tools and materials: see step 5 for the full controls Administrative	Medium
2	Check old gutters, fascia and eaves sheeting for asbestos, and old paint for lead, before cutting	Disturbing asbestos Lead paint dust and fumes	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 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	Medium
3	Set up a mobile scaffold, aerial lift or roof edge protection; use a secured ladder only for short, light work with three points of contact	Falling from height Falling from a ladder Aerial lift tip-over or crush Scaffold collapse or fall from scaffold	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 Use a platform ladder, mobile scaffold or aerial lift for longer jobs instead of a straight ladder. Substitution Use Type I, IA or IAA ladders in good condition. Tag and remove any damaged ladder. Engineering Set extension ladders at a 4 to 1 angle on firm, level ground, secured, and reaching 3 feet above the landing. Engineering Use ladders only for short, light work. Do not carry heavy or awkward loads up a ladder. Administrative Check the ground before setting up. Use outriggers and spreader pads, and keep clear of trenches, pits and slopes. Engineering Use a platform with tilt alarm and secondary guarding (anti-entrapment) where there is an overhead crush risk. Engineering Only trained and authorized operators use aerial lifts and scissor lifts (29 CFR 1926.453 for boom lifts, 1926.452(w) and 1926.454 for scissor lifts). Administrative Do a pre-start check each day. Keep a trained person on the ground who can lower the platform in an emergency. Administrative Never exceed the safe working load, climb on the rails or use a ladder in the basket. 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	Medium
4	Clean out the old gutter with gloves on, watching for sharp edges and wasp nests. Wet down any bird or possum droppings and wear a dust mask if there are a lot	Cuts from sharp edges Bites and stings	Medium	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 Check work areas before starting, and get pest control to remove nests. Elimination Look before you reach into dark spaces. Administrative Ask owners to keep pets away from the work area. Administrative Know who has allergies and keep their medication, such as an epinephrine auto-injector, close by. Administrative Wear gloves, long sleeves and boots. Use insect repellent outdoors. PPE	Medium
5	Cut old gutters into short lengths and lower them down; never drop them	Lifting and carrying heavy loads Cuts from sharp edges Falling tools and materials	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 Cuts from sharp edges: see step 4 for the full controls 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
6	Check the fascia is sound and replace any rotten sections before fixing brackets	Falling from height Injury from power tools Wood and MDF dust	Critical	Have a rescue plan so a worker hanging in a harness can be brought down within minutes. Administrative Wear a full body harness with a shock-absorbing lanyard, clipped on at all times when using fall arrest. PPE Falling from height: see step 3 for the full controls Administrative 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 Buy pre-cut or pre-finished lumber where you can. Substitution Cut outdoors or in a well-ventilated area away from others. Engineering (guarding) Use saws and sanders with dust collection connected to a HEPA vacuum. Engineering Clean up with a vacuum, not a broom or compressed air. Administrative Wear an N95 respirator for cutting and sanding. PPE	Medium
7	Fix brackets to the right fall, then fit the new gutter and downspouts, keeping tools tethered at height	Injury from power tools Cuts from sharp edges Falling tools and materials Sun exposure (UV)	High	Wear safety glasses and hearing protection. Do not wear loose gloves on drills or other rotating tools. PPE Injury from power tools: see step 6 for the full controls Administrative Cuts from sharp edges: see step 4 for the full controls Administrative Lower materials with a hoist, chute or rope. Never throw or drop anything down. Administrative Wear a hard hat anywhere objects could fall. PPE Falling tools and materials: see step 5 for the full controls Administrative Plan outdoor work for early morning or late afternoon when UV is lower. Elimination Put shade covers over fixed work areas. Engineering Check the UV index each day. Use sun protection when it is 3 or higher. Administrative Check your skin regularly and see a doctor about any new or changing spots. Administrative	Medium
8	Seal joints and connect downspouts to the storm drain system	Hazardous chemicals Lifting and carrying heavy loads	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 Rotate tasks and take breaks on long lifting jobs. Administrative Wear gloves for grip and safety boots to protect your feet. PPE Lifting and carrying heavy loads: see step 5 for the full controls Administrative	Medium
9	Water test the gutter, clean up swarf and offcuts, and remove access equipment	Poor housekeeping and waste Slips and trips	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 Plan walkways and keep them clear of materials, hoses and leads. Elimination Run cords and hoses overhead on hooks or stands, or along walls, not across walkways. Engineering Fill or cover holes, and lay boards or mats on muddy access paths. Engineering Clean up offcuts, packaging and spills as you go, not at the end of the day. Administrative Keep work areas, stairs and access paths well lit. Administrative Wear safety boots with good grip, laced up. PPE	Low

PPE

Safety-toe boots (ASTM F2413)Cut-resistant glovesSafety glasses (ANSI Z87.1)Sun protection (sunscreen, hat, long sleeves)High-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways)Hard hat (ANSI Z89.1)Half-face respirator (P100 cartridges)CoverallsWork glovesPersonal fall arrest system (harness)Hearing protection (earmuffs or plugs)N95 respiratorChemical-resistant glovesSafety goggles (ANSI Z87.1)

Plant and equipment

Extension ladderMobile (rolling) scaffold: Erected under a competent person (29 CFR 1926.451)Scissor lift: Trained operator: OSHA treats scissor lifts as mobile scaffolds (29 CFR 1926.452(w), 1926.454); ANSI A92.24 training and familiarizationHand toolsPower drill

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 gutter replacement

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

Word template (.docx)PDF template

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 gutter replacement

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

JHA read, explained and signed by everyone on the job
Guardrails, nets or fall arrest in place before anyone works at 6 ft or more
Ladder inspected, secured and extending 3 ft above the landing
Scaffold inspected by a competent person this shift
Aerial lift pre-start inspection done and the operator is trained and authorized
Overhead lines identified and safe distances marked
Asbestos register or survey checked for the work area
Exclusion zone below the work and public kept out
Weather checked: water, shade and rest breaks planned
First aid / CPR person, first aid kit and emergency number (911) confirmed
PPE checked and worn: safety-toe boots (ASTM F2413), cut-resistant gloves, safety glasses (ANSI Z87.1), sun protection (sunscreen, hat, long sleeves)

The safe sequence of work

Barricade the area below and check for power lines near the gutter line
Check old gutters, fascia and eaves sheeting for asbestos, and old paint for lead, before cutting
Set up a mobile scaffold, aerial lift or roof edge protection; use a secured ladder only for short, light work with three points of contact
Clean out the old gutter with gloves on, watching for sharp edges and wasp nests. Wet down any bird or possum droppings and wear a dust mask if there are a lot
Cut old gutters into short lengths and lower them down; never drop them
Check the fascia is sound and replace any rotten sections before fixing brackets
Fix brackets to the right fall, then fit the new gutter and downspouts, keeping tools tethered at height
Seal joints and connect downspouts to the storm drain system
Water test the gutter, clean up swarf and offcuts, and remove access equipment

Hazards to watch on gutter replacement

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

Step 4Bites and stingsSnakes, spiders, wasps, ticks and dogs bite or sting workers in attics, crawl spaces and yards.

Step 6Wood and MDF dustSawing and sanding lumber, MDF and treated wood makes fine dust that causes asthma, skin problems and some cancers.

Step 3Aerial lift tip-over or crushThe platform tips on soft or sloping ground, the worker is crushed against a beam or ceiling, or is thrown out of the basket.

Step 2Lead 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 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 7Sun exposure (UV)Long hours in the sun cause sunburn, eye damage and skin cancer.

Highest risk on gutter 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 work on a roof?
Is there a skylight, fiberglass panel or other fragile roofing?
Will you cut, grind or drill concrete, brick, stone, tile or fiber cement?
Will you use chemicals, solvents, glues, paints or fuels?
Will people be living or working in the building while you work?

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)
Scissor lift: Trained operator: OSHA treats scissor lifts as mobile scaffolds (29 CFR 1926.452(w), 1926.454); ANSI A92.24 training and familiarization

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: 29 CFR 1926.1408 and 1926.416; 29 CFR 1926.501(c); 29 CFR 1926.1101 and 40 CFR 61 Subpart M (NESHAP); 40 CFR Part 745 (RRP rule) and 29 CFR 1926.62; 29 CFR 1926 Subpart M; 29 CFR 1926 Subpart X; 29 CFR 1926.453 (boom lifts); 1926.452(w) and 1926.454 (scissor lifts); 29 CFR 1926 Subpart L; 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 gutter replacement?

OSHA expects employers to find and control hazards on every job, and many general contractors require a written JHA for gutter 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 gutter replacement?

Usually Safety-toe boots (ASTM F2413), Cut-resistant gloves, Safety glasses (ANSI Z87.1), Sun protection (sunscreen, hat, long sleeves), High-visibility safety apparel, ANSI/ISEA 107 Class 2 or 3 (Type R near roadways), Hard hat (ANSI Z89.1), Half-face respirator (P100 cartridges), Coveralls, Work gloves, Personal fall arrest system (harness), Hearing protection (earmuffs or plugs), N95 respirator, Chemical-resistant gloves, Safety goggles (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)