Hazard assessment

Scope

Hazard assessment refers to an evaluation of the workplace to identify sources of hazards or potential hazards to workers. A few OSHA regulations require that a particular hazard assessment be performed. For instance, at 1910.132(d), OSHA requires that the “employer shall assess the workplace to determine if hazards are present, or are likely to be present” that would require the use of personal protective equipment (PPE). However, most types of hazard assessment, such as a job hazard analysis or comprehensive safety audit, are not addressed in the OSHA regulations, but are viewed as best practices.

Regulatory citations

• 29 CFR 1910.132 — General requirements (PPE)
• 29 CFR 1910.119 — Process safety management of highly hazardous chemicals (PSM)

Key definitions

• Audit: An approach usually consisting of records review, inspection, and interviews, to identify what is and isn’t working in the overall safety and health management system. Other than the PSM standard, OSHA does not specifically require employers to audit their safety and health management systems.
• Change analysis: A systematic process for evaluating potential changes prior to their implementation to identify safety and health hazards/controls.
• Hazard: A hazard is the potential for harm. In practical terms, a hazard often is associated with a condition or activity that, if left uncontrolled, can result in an injury or illness.
• Inspection: A visual look at an area or facility to identify hazardous conditions.
• Job hazard analysis (JHA): A popular hazard assessment method, also called Job Safety Analysis, where tasks are broken down into their individual steps to identify hazards and controls.
• PPE hazard assessment: A required assessment of the workplace to determine the need for personal protective equipment (PPE).

Summary of requirements

Following are some requirements and best practices regarding hazard assessment:

• Conduct the required PPE hazard assessment and certify it as such in writing (see 1910.132(d)).
• If your operations are covered by OSHA’s Process Safety Management of Highly Hazardous Chemicals standard, 1910.119, make certain to review the hazard assessment requirements for covered processes.
• Implement a safety suggestion box.
• Identify health hazards. Hazards such as musculoskeletal (ergonomic), heat, and exposure to toxics, are often overlooked in the hazard assessment process.
• Identify hazards associated with emergency and non-routine situations.
• Set-up a change analysis program. Anytime something new is brought into the workplace, whether it be a piece of equipment, different materials, a new process, or an entirely new building, new hazards may unintentionally be introduced. Before considering a change for a worksite, the situation should be analyzed thoroughly. Change analysis helps in heading off a problem before it develops. You may find change analysis useful when:
  • Building or leasing a new facility
  • Installing new equipment
  • Using new materials
  • Starting up new processes
  • Staffing changes occur
• Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control.
• Remember it takes a multi-pronged approach to maximize hazard assessment. A walkthrough by a safety committee may be very good at identifying a blocked fire extinguisher or missing machine guard, but may not be good at identifying ergonomic hazards. Similarly, a JHA may be a good tool for identifying ergonomic hazards, but may not help identify a blocked fire extinguisher.
• Control identified hazards. Once an employer has a good understanding of what creates the hazards and has given the most serious hazards priority, he or she is ready to make recommendations to prevent them. In general, the following actions can be taken:
  • Find a new method of doing the job (i.e., analyze various ways of reaching the safest possible method. Consider work-saving tools and equipment.)
  • Change or modify the physical conditions that create the hazards.
  • Eliminate hazards still present by changing work procedures.
  • Reduce the necessity of doing a job or the frequency with which it must be performed. (Reducing job frequency contributes to safety only in that it limits exposure. Make every effort to eliminate hazards and to prevent potential accidents through changing physical or environmental conditions.)
  • Provide adequate and effective personal protective equipment (PPE) for your employees, at no cost to them.
• Catch hazards that were initially missed. After hazards are recognized and controls are put in place, additional analysis tools can help ensure that the controls stay in place and other hazards don’t appear. These other tools include:
  • Worker reports of hazards — The workplace must not only encourage reporting, but must value it. It is often helpful to establish multiple ways to report hazards so that, depending on comfort level and the nature of the issue, there are several avenues to get concerns addressed. Examples include talking to the supervisor or a safety committee member, as well as a suggestion box or voice mailbox.
  • Accident and incident investigations — Accident/incident investigation is another tool for uncovering hazards that were missed earlier or that slipped by the planned controls. But it’s only useful when the process is positive and focuses on finding the root cause, not someone to blame!
  • Injury and illness trend analysis — Another effective technique is analysis of injury and illness trends over time, so that patterns with common causes can be identified and prevented. Reviewing injury and illness forms is the most common form of pattern analysis, but other records of hazards can be analyzed for patterns. Examples are inspection records and worker hazard-reporting records.
  • Inspections — for safety hazards. Routine site safety and health inspections are designed to catch hazards missed at other stages. This type of inspection should be done at regular intervals, generally on a weekly basis. In addition, procedures should be established that provide a daily inspection of the work area. You can use a checklist already developed or make your own, based on past problems, standards that apply to your industry, input from everyone involved, and your company’s safety practices or rules.