Who’s requiring JSA now?

by jsabuilder | January 23, 2012 8:46 pm

[1]This quarter’s Case Study is replaced by an overview of regulatory requirements pertaining to job safety analysis.

Job safety analysis (JSA), job hazard analysis (JHA) and activity hazard analysis (AHA) are accepted techniques for analyzing workplace/job hazards and implementing controls to eliminate or minimize the hazard to workers; and in some instances are required. The following provides an overview of some of these requirements.

The most recent JSA regulatory requirement is 30 CFR 250.1911 (b) of the Bureau of Safety and Environmental Enforcement (BSEE) Final Rule for 30 CFR Part 250 Subpart S – Safety and Environmental Management Systems[2]. This new rule, effective November 15, 2011, governs safety of offshore oil and gas exploration and production facilities. The rule requires the following:

Ҥ 250.1911 What criteria for hazards analyses must my SEMS program meet?

You must ensure the development and implementation of a hazards analysis (facility level) and a job safety analysis (operations/task level) for all of your facilities…”

“b) Job Safety Analysis (JSA). You must develop and implement a JSA for OCS activities identified or discussed in your SEMS program.

(1) You must keep a copy of the most recent JSA (operations/task level) at the job site and it must
be readily accessible to employees.

(2) Your JSA must identify, analyze, and record:

(i) The steps involved in performing a specific job;

(ii) the existing or potential safety and health hazards associated with each step; and

(iii) the recommended action(s)/procedure(s) that will eliminate or reduce these hazards and the risk of a workplace injury or illness.

(3) The supervisor of the person in charge of the task must approve the JSA prior to the commencement of the work.”

Clearly the BSEE recognizes the importance of and is requiring offshore operators to incorporate JSAs into their Safety and Environmental Management System (SEMS).

The US Army Corps of Engineers (USACE) in their safety and health requirements manual EM381-1-1 also requires that contractors and USACE personnel perform an Activity Hazard Analysis (AHA). USACE EM 385-1-1, Section 01.A.13[3] states:

01.A.13 Contractor-Required AHA. Before beginning each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or subcontractor is to perform the work, the Contractor(s) performing that work activity shall prepare an AHA. In addition, all operations, materials, and equipment shall be evaluated to determine the presence of hazardous environments or if hazardous or toxic agents could be released into the work environment . . .

a. AHAs shall define the activities being performed and identify the work sequences, the specific anticipated hazards, site conditions, equipment, materials, and the control measures to be implemented to eliminate or reduce each hazard to an acceptable level of risk.

b. Work shall not begin until the AHA for the work activity has been accepted by the GDA and discussed with all engaged in the activity, including the Contractor, subcontractor(s), and Government on-site representatives at preparatory and initial control phase meetings.

c. The names of the Competent/Qualified Person(s) required for a particular activity (for example, excavations, scaffolding, fall protection, other activities as specified by OSHA and this manual) shall be identified and included in the AHA. Proof of their competency/qualification shall be submitted to the GDA for acceptance prior to the start of that work activity.

d. The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or change of competent/qualified person(s).

Lastly, OSHA’s Voluntary Protection Programs (VPP)[4] require that companies wanting to obtain their VPP certification incorporate JHA process into their “Safety and Health Management System.” Under “Management Leadership and Employee Involvement,” VPP[5] requires that companies’ exhibit “Employee Involvement”; specifically,

“The site culture must enable and encourage effective employee involvement in the planning and operation of the safety and health management system and in decisions that affect employees’ safety and health…..Examples of acceptable employee involvement include but are not limited to….analyzing job/process hazards;”

And for “Worksite Analysis” VPP requirements state:

“The successful management of workplace hazards begins with a thorough understanding of all hazardous situations to which employees may be exposed and the ability to recognize and correct all hazards as they arise. This requires….

Routine examination and analysis of safety and health hazards associated with individual jobs, processes, or phases and inclusion of the results in training and hazard control programs. This may include job hazard analysis and/or process hazard review. In construction, the emphasis must be on special safety and health hazards of each craft and each phase of work.”
While this analysis is not an exhaustive overview of regulatory requirements, it nevertheless is intended to show a consistency in requirements. Job safety analysis should encourage employee involvement, examine the hazards associated with each job step, recommend controls (engineering, administrative, PPE, training and permits) to eliminate or minimize hazards, and record the JSA and make it accessible to employees.

Sign up and create your JSA!

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