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OSHA believes that a crucial part of any effective safety and health program is a proactive, ongoing process to identify and assess hazards in the workplace. Like the lions, tigers, and bears of the Wizard of Oz, regulatory assessments can be scary and confusing. Understanding the intent of each kind of assessment and what OSHA requires will alleviate the fear and confusion.
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:
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.
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.
OSHA believes that a crucial part of any effective safety and health program is a proactive, ongoing process to identify and assess hazards in the workplace. Like the lions, tigers, and bears of the Wizard of Oz, regulatory assessments can be scary and confusing. Understanding the intent of each kind of assessment and what OSHA requires will alleviate the fear and confusion.
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:
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.
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.