What’s that assessment for and is it required?

The best place to start when trying to wrap your head around OSHA assessment requirements is to understand the intent behind each type. Here are the most commonly confused assessments:

• Risk Assessment (RA): REQUIRED by proxy through most regulations requiring hazard assessments, including the all-encompassing General Duty Clause. This assessment is a review of workplace hazards that involves reviewing injury, illness, and incident data; investigation results; facility, equipment, and personal protective equipment (PPE) inspections; employee interviews; and emergency information. RAs evaluate the probability, severity, and frequency of incidents and often include leading and lagging indicator reviews to determine effective mitigation.
• Process Hazard Analysis (PHA): REQUIRED per 1910 Subpart G: Occupational Health and Environmental Control, 1910 Subpart H: Hazardous Materials, 1910.119: Process Safety Management, and 1910 Subpart Z: Toxic and Hazardous Substances. This analysis is a review of operations and processes as they relate to hazardous chemicals and potential releases to identify what could potentially go wrong and what safeguards are needed to prevent catastrophic events.
• Job Hazard Analysis (JHA): REQUIRED by proxy through most regulations requiring hazard assessments, including the General Duty Clause. This analysis is a review of a job or task, step-by-step to determine potential exposures workers face as they interact with tools, equipment, and their environment. Often viewed synonymously with a JSA but includes a risk assessment component, is a higher-level analysis overview, and is typically performed at less frequent intervals than the JSA.
• Job Safety Analysis (JSA): REQUIRED by proxy through most regulations requiring hazard assessments, including the General Duty Clause. Very similar to a JHA, this analysis reviews specific steps to complete a job, the hazards involved with each step, and the protective measures required to mitigate each hazard. Some JSAs are utilized for additional purposes, such as lean management and quality control.
• PPE Assessment: REQUIRED per 1910.132(d)(1). Also referred to simply as “Hazard Assessment,” this assessment involves a review of hazards associated with processes or environment, chemicals or radiation, mechanical or electrical hazards, etc. that could cause injury or harm to any part of an employee’s body through absorption, inhalation, or physical contact. Once hazards are identified and it’s determined that engineering or administrative controls aren’t adequate protection, PPE is selected, purchased, and distributed to workers to ensure they're protected from exposures.

Documentation and Recordkeeping

Although OSHA doesn’t require JHAs, JSAs, or RAs to be documented, it does require documentation for PHAs and PPE assessments. An October 2020 letter of interpretation affirms that any time a siting study is completed to supplement a PHA, the findings must be documented. For the PPE assessment, 1910.132(d)(2) requires a written certification be completed affirming the PPE assessment was performed. The assessment itself isn’t required to be in writing, but at a minimum, the certification of the completion of the assessment does. The certification must include the specific workplace evaluated, the date of evaluation, the name of the person performing the assessment, and an identification of the document that will be used to certify the assessment completion.

There's a popular phrase among safety and regulatory professionals that's a great motivator for documentation. “That which wasn’t documented, was not done,” which means if ever audited, how would you demonstrate you’ve performed proper hazard assessments or analysis of your workplace without some form of documentation? You have to do the assessments anyway, so why not document your hard work?

A common question regarding assessment documentation is whether one document can be used for all requirements. Often, information gathered from JHAs and JSAs is used to complete PPE assessments and PHAs and RAs are completed in conjunction with one another. Each of the tools is unique in intent, however, OSHA doesn’t prohibit using one document for all assessment or analysis types. If opting to combine efforts, it’s imperative to ensure all components of each are included in the documentation to ensure overall compliance.

Keys to Remember

In some way or another, the information gleaned from assessments and analyses is required by OSHA. Though they don’t all need to be documented, the PPE assessment requires at least a written certification that the assessment was performed.