Conducting the Job Hazard Analysis

Before you actually begin, take a look at the general conditions under which the job is performed and develop a checklist. Below are some sample questions you might ask.

• Are there materials on the floor that could trip a worker?
• Is lighting adequate?
• Are there any live electrical hazards at the jobsite?
• Are there any explosive hazards associated with the job or likely to develop?
• Are tools, including hand tools, machines and equipment in need of repair?
• Is there excessive noise in the work area, hindering worker communication?
• Is fire protection equipment readily accessible and have employees been trained to use it?
• Are emergency exits clearly marked?
• Are trucks or motorized vehicles properly equipped with brakes, overhead guards, backup signals, horns, steering gear and identification, as necessary?
• Are all employees operating vehicles and equipment properly trained and authorized?
• Are employees wearing proper personal protective equipment for the jobs they are performing?
• Have any employees complained of headaches, breathing problems, dizziness, or strong odors?
• Is ventilation adequate, especially in confined spaces?
• Have tests been made for oxygen deficiency and toxic fumes?

Naturally, this list is by no means complete because each worksite has its own requirements and environmental conditions. You should add your own questions to the list. You might also take photographs of the workplace, if appropriate, for use in making a more detailed analysis of the work environment.

Involve Your Employees

It is very important to involve your employees in the hazard analysis process. They have a unique understanding of the job, and this knowledge is invaluable for finding hazards. Involving employees will help minimize oversights, ensure a quality analysis, and get workers to "buy in" to the solutions because they will share ownership in their safety and health program.

Review Your Accident History

Review your worksite's history of accidents and occupational illnesses that needed treatment, losses that required repair or replacement, and any "near misses," that is, events in which an accident or loss did not occur, but could have. These events are indicators that the existing hazard controls (if any) may not be adequate and deserve more scrutiny.

Conduct a Preliminary Job Review

Discuss with your employees the hazards they know exist in their current work and surroundings. Brainstorm with them for ideas to eliminate or control those hazards. If any hazards exist that pose an immediate danger to an employee's life or health, take immediate action to protect the worker.

Any problems that can be corrected easily should be corrected as soon as possible. Do not wait to complete your job hazard analysis. This will demonstrate your commitment to safety and health and enable you to focus on the hazards and jobs that need more study because of their complexity. For those hazards determined to present unacceptable risks, evaluate types of hazard controls.

List, Rank, and Set Priorities for Hazardous Jobs

List jobs with hazards that present unacceptable risks, based on those most likely to occur and with the most severe consequences. These jobs should be your first priority for analysis.

Break Down the Job

Nearly every job can be broken down into job tasks or steps. When beginning a job hazard analysis, watch the employee perform the job and list each step as it is taken. Be sure to record enough information to describe each job action without getting overly detailed.

Avoid making the breakdown of steps so detailed that it becomes unnecessarily long or so broad that it does not include basic steps. You may find it valuable to get input from others who have performed the same job.

Later, review the job steps with the employee to make sure you have not omitted something. Point out that you are evaluating the job itself, not the employee's job performance. Include the employee in all phases of the analysis — from reviewing the job steps and procedures to discussing uncontrolled hazards and recommended solutions.

Sometimes, in conducting a job hazard analysis, it may be helpful to photograph or videotape the worker performing the job. These visual records can be handy references when doing a more detailed analysis of the work.

Job Hazard Analysis

Job-related injuries occur every day in the workplace. Often these injuries occur because employees have not been trained, or over time, have gotten lax in following safe job procedures. One way to prevent workplace injuries is to establish proper job procedures and train all employees in safer and more efficient work methods.

Establishing proper job procedures is one of the benefits of conducting a job hazard analysis.

• Carefully studying and recording each step of a job.
• Identifying existing or potential job hazards (both safety and health).
• Determining the best way to perform the job to reduce or eliminate these hazards.

Improved job methods can reduce costs resulting from employee absenteeism and workers' compensation, and can lead to increased productivity.

The job procedures are for illustration only and do not necessarily include all steps, hazards or protections for similar jobs in industry. In addition, standards issued by OSHA should be referred to as part of your overall job hazard analysis. There are OSHA standards that apply to most job operations, and compliance with these standards is mandatory.

Although this section is designed for use by managers and supervisors, employees also are encouraged to use the information contained here to analyze their own jobs, be aware of workplace hazards, and report any hazardous conditions to their supervisors.

What is a Job Hazard Analysis?

The hazard of a job creates 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. Identifying job hazards and eliminating or controlling them as early as possible will help prevent injuries and illnesses.

A job hazard analysis is a technique that focuses on job tasks as a way to identify hazards before they occur. It focuses on the relationship between the worker, the task, the tools, and the work environment. Ideally, after you identify uncontrolled hazards, you will take steps to eliminate or reduce them to an acceptable risk level.

Job Hazard Analysis is a Valuable Safety Tool

Every day, workers are injured or killed in U.S. workplaces. You can help prevent workplace injuries and illnesses by looking at your workplace operations, establishing proper job procedures, and ensuring that all employees are trained properly. One of the best ways to determine and establish proper work procedures is to conduct a job hazard analysis. A job hazard analysis is one component of the larger commitment of a safety and health management system.

Value Seen through Results

Employers can use the findings of a job hazard analysis to eliminate and prevent hazards in their workplaces. This is likely to result in:

• Fewer worker injuries and illnesses;
• Safer, more effective work methods;
• Reduced workers' compensation costs; and
• Increased worker productivity.

The analysis also can be a valuable tool for training new employees in the steps required to perform their jobs safely. For a job hazard analysis to be effective, management must demonstrate its commitment to safety and health and follow through to correct any uncontrolled hazards identified. Otherwise, management will lose credibility and employees may hesitate to report dangerous conditions that threaten their safety.

Selecting Jobs for Analysis

A job hazard analysis can be performed for all jobs in the workplace, whether the job is "special" (non-routine) or routine. Even one-step jobs, such as those in which only a button is pressed, can and perhaps should be analyzed by evaluating surrounding work conditions.

To determine which jobs should be analyzed first, review your job injury and illness reports. Obviously, a job hazard analysis should be conducted first for jobs with the highest rates of accidents and disabling injuries. Priority should go to the following types of jobs:

1. Jobs with the highest injury or illness rates;
2. Jobs with the potential to cause severe or disabling injuries or illness, even if there is no history of previous accidents;
3. Jobs in which one simple human error could lead to a severe accident or injury;
4. Jobs that are new to your operation or have undergone changes in processes and procedures; and
5. Jobs complex enough to require written instructions.

Also, jobs where "close calls" have occurred should be given priority. Analyses of new jobs and jobs where changes have been made in processes and procedures should follow. Eventually, a job hazard analysis should be conducted and made available to employees for all jobs in the workplace.

Building Owner Responsibilities | Asbestos

Q.	Does a building owner have any responsibility under the standard even though the employees at risk may not be the owner's direct employees?
A.	Yes. The building and/or facility owner must notify contractors and tenants of the presence of ACM/PACM, even though the employees at risk are not the owner's direct employees. OSHA has the authority to require building owners who are "statutory employers" to take necessary action such as notifying other employers, and to protect employees other than their own. They also have the responsibility to identify and label ACM/PACM when required. Homeowners are not considered "building owners" when they have work done in their private homes.
Q.	When shipyard vessels undergoing repair are foreign-owned, who is considered the "building owner?"
A.	When a foreign-owned vessel is repaired in an American shipyard, the employer is either the shipyard or an outside primary contractor. They must either treat materials defined as PACM as asbestos-containing or sample the suspect material and analyze it to determine whether or not it contains asbestos.
Q.	Does a long term lessee of a building have the same responsibilities as a "building owner"?
A.	"Building owner" has been defined to include lessees who control the management and recordkeeping functions of a building/facility/vessel. It is not OSHA's intention to exempt the owner from notification requirements by allowing a lessee to comply. Rather, when the owner has transferred the management of the building to a long-term lessee, that lessee is the more appropriate party to receive, transmit, and retain information about in-place asbestos. When the lease is terminated, the records are to be transferred to the building owner.
Q.	Can building owners use building records to rebut the presumption of asbestos containing materials (PACM)?
A.	Generally, building records must be relied upon to rebut the presumption of asbestos containing material (PACM). If an employer had an AHERA asbestos survey, such a survey would be accepted. However, for non-PACM materials, building owners and employers may use all sources of information including building records to show that the materials do not contain asbestos.
Q.	What materials must be presumed to contain asbestos?
A.	Thermal System Insulation (TSI) and sprayed on and troweled on surfacing materials installed no later than 1980. (Note: In addition, resilient flooring material installed no later than 1980 shall be identified as asbestos-containing). Other building/facility areas and material would not be exempt from the standard's control requirements; however, they would not be presumptively considered to contain asbestos.
Q.	Do the standards require any particular qualifications of the person who designates materials as PACM?
A.	The person who designates materials as PACM is not required to have any technical training. The evaluation is not to determine if the material is or is not asbestos, rather it is to identify thermal system insulation and surfacing materials. The process does not require technical training. Thermal system insulation, and sprayed on or troweled on surfacing material are easily recognized and identified.
Q.	Are the sign and label requirements the same in the General Industry standard as they are in the Construction and Shipyard standards?
A.	Yes, the three standards contain the same provisions.

Q:	If construction of a building began before 1981 but was not completed until several years later, is the owner responsible for presuming asbestos exists in the entire building?
A:	The CSHO will need to evaluate this on a case-by-case basis. Generally speaking, the focus would be on areas that contain suspect materials in those areas built before 1981.
Q.	How has the definition of repair and maintenance changed?
A.	Repair and maintenance is now considered Class III work if it involves less than one glovebag of material, regardless of the time it takes to do the job. If the job involves more than one glovebag of TSI or surfacing material then it is a Class I job. If the job involves more than one bag of other ACM then it is a Class II job.
Q.	What are some examples of activities that may be classified as Class III?
A.	These activities may include: maintenance/repair of boilers, air handling units, heat exchangers, and tanks; repair/replacement of pipe insulation including cutting away of small amounts of ACM (that which fits into a standard glovebag or disposal bag); valve or gasket replacement, or activities above suspended ceilings such as connections and/or extensions for telecommunication/computer networks; adjustment/repair of HVAC systems and; testing/cleaning/replacing smoke or heat detectors when connected to ceilings containing ACM. Class III work involves a "disturbance."

Flooring Operations | Asbestos

Q.	When must an employer presume that flooring material contains asbestos?
A.	A 1988 EPA survey reported that 42 percent of public and commercial buildings within the U.S. contain asbestos-containing flooring material. The standard requires that employers presume that floor tile and resilient flooring found in buildings constructed no later than 1980 contains asbestos and take the specific precautions required unless the employer demonstrates that the flooring materials do not contain asbestos, by using recognized analytical techniques.
Q.	What work practices are prohibited or restricted in floor maintenance?
A.	(1) Sanding of asbestos-containing flooring material is prohibited; (2) stripping of finishes must be conducted using low abrasion pads at speeds lower than 300 rpm and wet methods; and (3) burnishing or dry buffing may be performed only on asbestos-containing flooring which has sufficient finish so that the pad cannot contact the asbestos-containing material.
Q.	What work practices must be used when removing floor tile?
A.	The floor must first be HEPA-vacuumed. The floor tiles then must be carefully pried up individually after being wetted. Misting is sufficient if the tiles are removed intact. After removal, each tile must be placed in an impermeable trash bag or other impermeable waste container.

Q.	If the wetting agent contains a hazardous substance, what other precautions must the employer take?
A.	The employer may be responsible for compliance with other standards such as the Hazard Communication standard. The employer shall obtain a material safety data sheet for the substance and follow the recommendations for the use of personal protective equipment and provide training.
Q.	If floor tiles are broken during removal, are they no longer "intact?"
A.	Not necessarily. Some incidental breakage of floor tiles is to be expected. Under the standard, material is not intact only if it has crumbled, been pulverized, or has otherwise deteriorated so that the asbestos fibers are no longer likely to be bound with their matrix. Therefore, the incidental breakage of tiles does not by itself mean that the material is not intact.
Q.	How are tiles to be removed when they cannot be removed by careful prying?
A.	The tiles may be heated to soften the adhesive holding them to the substrate. When tiles are removed intact using heat, wetting may be omitted.
Q.	How are tiles to be removed when they cannot be removed by either careful prying or heating?
A.	Aggressive techniques such as mechanical chipping can be used if a competent person evaluates the worksite and determines that additional precautions required by the standard are properly installed and operated. This may include negative pressure enclosures.
Q.	How must residual adhesive be removed?
A.	The standard does not require removal of residual adhesive, but it is often necessary to remove or smooth residual adhesive to prepare the surface for installation of a new floor. Wet methods must be used when removing residual adhesive. The adhesive must either be wet-scraped manually or removed using a low speed floor machine and wetted sand or a removal solution. The adhesive residues must be placed in an impermeable trash bag or other impermeable container while still wet. Remaining water or dirt in the area must then be HEPA vacuumed.
Q.	What work practices must be used when removing resilient sheet flooring?
A.	The material must not be ripped up. The floor shall first be HEPA vacuumed. The sheet flooring shall then be removed in strips four to eight inches wide. As a strip is removed, the point of separation must be constantly misted to minimize fiber release. A strip must be rolled up as it is removed and the roll placed in an impermeable trash bag or other impermeable container. Residual felt and adhesive is then removed by wet scraping, and the floor is HEPA vacuumed.
Q.	When must flooring removal jobs be monitored for asbestos levels?
A.	Most jobs will not require monitoring. Monitoring is only required if compliant work practices are not followed, if the material is not removed intact, or if the employees are not properly trained in accordance with the standard.
Q.	What level of training is required for competent persons for flooring removal operations?
A.	When flooring removal jobs are conducted using compliant work practices and the material is removed intact, the competent person must have completed at least 12 hours of training. If the material is not removed intact, the competent person must have completed a training course that meets the requirement for a Class II competent person.
Q.	Must respirators be worn when floor tiles are removed using heat?
A.	The standard generally requires that respirators be worn when Class II work, including floor tile removal, is not performed using wet methods. However, the standard allows wetting to be omitted when floor tiles are removed intact using heat. Since the use of heat to remove floor tiles provides the same level of protection against fiber release as the use of wetting, the omission of wetting does not require respirators to be worn when heat is used and the tiles are removed intact. Respirators would only be needed if their use is required under another provision of the standard.

Brake and Clutch | Asbestos

Q.	Are the appendices on brake and clutch repair (Appendix F for General Industry and Appendix L for Shipyard employment) mandatory?
A.	Yes.
Q.	What are the two "preferred" methods for brake and clutch repair?
A.	The two "preferred" methods are the low pressure/wet-cleaning method and the negative pressure enclosure/HEPA vacuum system.
Q.	Is the solvent spray method prohibited?
A.	No. The solvent spray method is an "equivalent" method that may be used when proper work practices are followed.
Q.	What are the work practices that must be used when an employer chooses the spray/solvent can method?
A.	An employer who uses an "equivalent" method must follow detailed written procedures. At a minimum, the solvent spray method should include the following procedures: (1) the solvent shall be used to first wet the brake and clutch parts; (2) the brake and clutch parts shall be wiped clean with a cloth; (3) the contaminated cloth shall be placed in an impermeable container, and then either disposed of properly or laundered in a way that prevents the release of asbestos fibers in excess of 0.1 fiber per cubic centimeter of air; (4) any spilled solvent or dispersed asbestos shall be cleaned up immediately and not allowed to dry, either with a cloth or a HEPA vacuum. Dry brushing during solvent spray operations is prohibited.
Q.	What other precautions are required when solvents are used?
A.	The solvents typically used in brake and clutch work are hazardous chemicals, and the employer must therefore comply with the Hazard Communication standard. If the solvents used are flammable, appropriate precautions against fire and explosion must be taken.
Q.	If the employer chooses to use one of the two "preferred" methods or an "equivalent" method, does the employer have to conduct exposure monitoring?
A.	No.
Q.	Does Appendix F that covers brake and clutch work practices also cover brake and clutch work done on large stationary equipment like printing presses?
A.	No, the Appendix is only intended for automotive work. For other asbestos jobs as described above, the employer must use work methods that reduce the exposures to below the PELs.
Q.	What type of "aqueous" solution is allowed when the low pressure/wet cleaning method is used?
A.	The intent of the standard was to ensure that the asbestos is sufficiently wet so that exposures are kept well below the PELs. The solution can consist only of water, or water mixed with an organic solvent, or a detergent. It is important to note the potential danger of solvent use in these operations. The use of solvents, which are often flammable and may also present a health hazard, must be undertaken with great care. The employer must also be in compliance with the Hazard Communication standard.

Q.	Are other methods allowed for employers who do brake and clutch work infrequently?
A.	Yes, for those shops in which brake work is infrequent, OSHA has determined to allow the use of a wet control method as a "preferred" method. Therefore, in facilities in which five (5) or fewer brake "jobs" (five brake "jobs" is equivalent to five vehicles) or 5 clutches, or some combination totaling 5, are repaired each week, the mechanic/technician may control potential asbestos exposure through the use of a pump sprayer (bottle) containing water or amended water to wet down the drum or clutch housing before it is removed and to control fiber release during subsequent activities. The mechanic may use other implements to deliver the water such as a garden hose; however, the resulting wastewater generated must be captured and properly disposed of without allowing it to dry on any surfaces. The spray should be controlled through the use of low pressure to the extent feasible. OSHA anticipates that the use of a spray bottle will be adequate to control the dust without generating a large volume of wastewater. However, any waste water generated must be disposed of properly.
Q.	What provisions are required to perform a brake inspection?
A.	The extent to which an "inspection" is different from the other brake servicing depends on whether and how the drum is removed. Most inspections of brake shoes involve removing the drum which may contain a substantial number of asbestos fibers. Precautions must be taken against the release of those fibers into the workplace. If the drum is carefully pulled back just far enough to observe the brake shoe and brake components, it is sufficient to thoroughly wet the exterior and around the seam between the brake drum and backing plate. Any dislodged material must be immediately cleaned up in accordance with 1910.1001(k). Blows to the drum with a hammer or similar implement to dislodge a rusted-in-place or frozen drum may cause asbestos fibers to be released. For such cases, in shops performing 6 or more brake jobs per week, an enclosure must be installed around the drum to capture the dust or the drum interior and contents must be thoroughly wetted prior to striking or forcibly removing the brake drum. As with other brake servicing, this must be done using a preferred or equivalent method. When using the equivalent spray can method, first wet the interior and contents of the drum before striking it. Then, carefully pull the drum back just enough to allow another application of solvent and thoroughly wet the interior before removal of the drum. There should be no visible dust created during drum loosening and removal.

Methods of Compliance | Asbestos

Q.	What are the three basic controls required initially in ALL operations covered in the Construction standard?
A.	Regardless of the exposure levels the controls required are: use of HEPA filtered vacuums when the source of the dust/debris is damaged ACM or disturbance of ACM or PACM; use of wet methods to control asbestos fiber dispersion; and prompt disposal of asbestos contaminated waste materials. These provisions apply to, for example, employers who install asbestos-containing material (no Class designation), clean up asbestos-containing debris at a construction site (Class IV), repair a boiler covered with asbestos-containing TSI (Class I or III), and remove asbestos-containing surfacing material (Class I). Certain roofing operations, however, are not subject to these requirements.
Q.	When does OSHA consider the use of wet methods infeasible?
A.	An employer can demonstrate infeasibility if he/she can show that wet methods cannot be used due to conditions such as electrical hazards, hot surfaces, and the presence of technical equipment which cannot tolerate moisture.
Q.	What is required for the disposal of asbestos-contaminated waste?
A.	All asbestos-contaminated waste must be promptly disposed of in leak-tight containers.
Q.	What is meant by the term "air sweeping"?
A.	Where the exposure is expected to be above the PELs, OSHA requires ventilation that moves contaminated air away from employees toward a HEPA filtered exhaust device. It does NOT mean that a general building ventilation system to vent asbestos contaminated air, would be acceptable under the standard.
Q.	Is the negative pressure enclosure the only effective system for larger removal operations?
A.	Negative pressure enclosure systems are effective in many circumstances in protecting workers both within and outside the enclosure. Other systems such as glove bags and mini-enclosures can be equally effective.
Q.	What is the major difference between the negative pressure enclosure and negative air ventilation?
A.	The negative pressure enclosure system is primarily designed to keep asbestos from contaminating the building. The air pressure inside the enclosure is less than outside the enclosure. Negative air ventilation draws clean air from outside the enclosure at sufficient quantities and at strategic locations, so as to provide clean air in the worker's breathing zone and is part of the negative enclosure system.
Q.	If an employer has a variety of work activities, how does one decide which class to follow?
A.	The classes are exclusive. For example, the stripping of 50 linear feet of thermal system insulation, whether or not it has been positively identified as asbestos containing material, is Class I, for it is the removal of PACM. Repair of a valve covered by ACM is Class III, since "removal" is not taking place, if less than one glove bag of ACM has been disturbed. Removal of flooring material containing ACM is Class II. If more than one "class" of work occurs simultaneously, the work must be performed according to the highest hazard classification.
Q.	Is all asbestos activity designated by "class"?
A.	All asbestos work under the Construction and Shipyard standards is not in the "class system." The installation of new asbestos-containing products does not carry a class designation, and thus the class-specific requirements do not apply to that activity. For work that does not readily fall into one of the four classes, the employer must comply with the PEL. Work covered by the General Industry standard is not included in the "class system."

Q.	Is misting considered a "wet method"?
A.	Wet methods encompass a range of work practices. For example, when removing material which is bound in a matrix, misting may be appropriate. Removing ACM or PACM which is not so bound, or where deterioration of the ACM has occurred, would require more aggressive wetting.

Exposure Assessment | Asbestos

Q.	What is included in the new "exposure assessment" requirements in the Construction and Shipyard standards?
A.	The "exposure assessment" predicts exposure and evaluates potential controls. In most cases, the exposure assessment will include both past and current monitoring. Monitoring results must be considered, but do not necessarily constitute an adequate "assessment" if they would not represent all representative employee exposures during the entire job. The assessment must review relevant controls, conditions and factors that influence the degree of exposure. These include, but are not limited to, quality of supervision and of employee training, techniques used for wetting the ACM, placing and repositioning the ventilation equipment and impacts due to weather conditions. The assessment must be based on a review of all aspects of the employer's performance doing similar jobs.
Q.	Do all employers need to conduct an "initial exposure assessment" under the Construction standard?
A.	In general, all employers who have a workplace covered by this standard are to conduct an "initial exposure assessment" at the beginning of each asbestos job [paragraph (f)(2)]. Exceptions to this requirement exist only for most Class IV work. Even employers who are planning to install full negative pressure enclosures with air flushing technology must conduct initial exposure assessments. Employers may base assessments of similar jobs on prior assessments of repetitive, routine jobs.
Q.	Is it more difficult than before to base an initial exposure on "historic data"?
A.	Yes, the standard establishes specific evaluation criteria for data. This criteria included the experience and training of the crews and the historic data must be updated annually. It is important to note that historic data is usually that data generated by an individual employer, whereas objective data is related to a product, material, or activity and may be derived from other employers' (such as the manufacturer of the product) data.
Q.	Explain "objective data."
A.	The use of objective data grants a monitoring exemption and may be used as a basis for a "negative exposure assessment." The employer using "objective data" must demonstrate that the product or material containing asbestos minerals or the activity involving such product or material cannot release airborne fibers in concentrations in excess of the PEL under those work conditions having the greatest potential for releasing asbestos. The employer may use data derived from other employers' jobs. The data should reflect worst case conditions in a variety of occupational settings.
Q.	When can "objective data" be relied on for a negative exposure assessment?
A.	For any specific asbestos job (combination of activity and product) performed by employees who have been trained in compliance with the standard the employer must demonstrate that, under worst case conditions, statistically there is a high degree of confidence that an exposure above the permissible exposure limit will not occur.
Q.	How would an employer who performs repetitive work complete exposure assessment?
A.	An employer may evaluate repetitive operations with highly similar characteristics, as one job, such as cable pulling in the same building, so long as the data used also reflect repetitive operations of the same duration and frequency.
Q.	Did OSHA adopt a clearance level?
A.	OSHA has not included a provision for a specific "clearance level" in the revised standards.