Are Your JSAs Good Enough? Don’t Wait for a Workplace Incident to Find Out
You already know that workplace accidents can have devastating consequences. You understand that effective EHS management must involve active identification and control of hazards, which is the primary intention behind risk assessments. You may even use job safety analysis (JSAs), to perform formal risk assessments that break down jobs into their constituent tasks in order to identify and mitigate the hazards for all steps. However, if you’re like many employers, you might also be struggling to effectively develop and use JSAs to their full effect.
The question of whether a JSA was "strong enough" comes up pretty fast in the aftermath of a workplace incident. Investigators want to know if the JSA identified the hazard that led to the injury, and if it assessed the severity of the risk and the controls needed to address it appropriately. And in worker’s compensation cases, JSAs can often be key pieces of evidence. For all of these reasons, you don’t want to wait until a workplace incident happens before you investigate how well your JSAs are working.
Let’s take a look at some of the ways you can ensure you are getting maximum protection out of your JSAs.
What Makes a JSA “Strong?”
More facilities have come to recognize the value of JSAs, and OSHA has published guidelines for their effective use. In general, effective JSAs have the following characteristics, they:
- Break the job down into tasks and identify all tasks necessary to complete the job. This includes frequently missed steps like set-up and clean-up. Remember, if a task isn’t identified, risks can’t be identified either.
- Consider and identify the hazards associated with each task, including factors like pinch points, chemical use/exposure, cut/laceration risks, ergonomic strains, and other categories of risks. This can be done most effectively by watching performance of the job tasks, taking note of all the places where risks of injury may exist.
- Identify controls for each hazard identified, and also establish a hierarchy of controls, with elimination or substitution used whenever possible (because they eliminate the risk) as a preference over engineering, administrative, or PPE controls, which just create barriers to risks.
- Are easy and clear to read and understand. If it’s not clear what hazards correspond to which tasks, or which controls correspond to which tasks, then the JSA fails its primary duty, and may not adequately prepare employees to understand and avoid risks. When it comes to communicating hazards, we want to remove as much ambiguity as possible.
- Were written with the direct involvement of the employee(s) who do the job. It’s good to not only codify this as standard practice, but also to think about how to document it. JSAs that fail often do so because there wasn’t enough input from the actual operators, as common-sense as it seems to involve them, and therefore the JSA didn’t correctly identify all steps in the job or the hazards. Lack of participation by the operators also can create a widespread view among employees that the JSAs lack validity, which can hamper workforce participation in EHS.
Your JSAs Need to be Living Documents
The other question, in many cases the question that comes up after an injury is “how was the JSA communicated to employees and made accessible to them?” It’s not enough just to have the JSAs written. Too often, employers spend a great deal of time and effort creating JSAs, and the documents then promptly disappear into a binder, or get filed onto a computer hard-drive and forgotten. But when this happens, the JSAs are not fulfilling their purpose. Their purpose is to be living documents that capture information about risks, document controls and inform the employees about both the hazards in their job tasks and the best means of avoiding them.
Employees need to know JSAs exist, know where they can access them, and most of all need to understand them. This points to the necessity for documented training. The importance of effective and well-documented training cannot be emphasized enough. In many situations following a serious accident, questions of liability hinge on the issue of whether training on the JSA was conducted, whether it adequately covered what needed to be covered, and whether the evidence sufficiently backs up our answers to these questions.
Try to think about your JSA program from the perspective of an outsider, who is seeing your facility for the first time. What would convince you that employees were aware of JSAs and understood how to use them to work safely? A good electronic Risk Analysis solution can help here by offering powerful control over your JSAs, making it easier than ever to develop good assessments as well as to communicate them, access them from a centralized location on the cloud, and track corrective actions. When combined with an Incident Management software solution, you’ll have the visibility and control you need over all aspects of incidents from reporting to tracking of corrective actions.
If you were objectively evaluating your JSA program, you’d also want documentation that employees were trained on all relevant JSAs to their jobs, and evidence that the employees understood the training, whether in the form of a signed statement or quiz results. Remember that training must be in a language and manner that employees understand if it is going to be effective. Consider the ways you might be able to do this easily and effectively in your workplace, and whether your training management system effectively administers and documents awareness of JSAs. The right kind of Training Management platform is crucial to train your workforce on the JSAs they need to understand to work safely, and to be able to document that training was completed.
In brief, it comes down to doing good JSAs based on the criteria discussed, and documenting employee training on them. But remember that maintaining a good JSA program is an ongoing and evolving process. For instance, if a workplace injury occurs, it should occasion a review of the relevant JSA to see if it had a shortcoming that may have contributed to the incident. In practice, this revisit doesn’t happen nearly as often as it should, but it’s the only way to ensure that the JSAs are doing everything they can to reduce risk.
If deficiencies are identified, the JSA should be revised as part of the corrective action for the incident, and workers should then be retrained on the revised document. Revision of JSAs followed by retraining should also occur whenever a change in a work process occurs that may introduce new hazards. Involve your workforce in a periodic review exercise for existing JSAs to make sure they still accurately capture the job tasks as performed today and address all associated risks.
Let VelocityEHS Help!
Do you need more information about effective incident management? VelocityEHS has created the e-book Incident Management 101: How to Create a Safer Workplace Through Better Hazard Identification, Incident Response, Investigation and Corrective Action, available for download here, that discusses all aspects of a good program from JSAs to Corrective Actions. Be sure to also explore our EHS software solutions and learn about some of the ways our Risk Analysis, Corrective Actions, Training Management and other products can help you establish the JSA program you need to maintain a world-class EHS culture with a strong focus on prevention.