By Drew Hinton, President/CEO of Arrow Safety, LLC
and Sospes Safety Contributor
HAZARD ASSESSMENT: Practicing New Thinking
According to OSHA, one of the “root causes” of workplace injuries, illnesses, and incidents is the failure to identify or recognize hazards that are present, or that could have been anticipated. The trick is learning to not only identify the obvious hazards, but to spot the hidden hazards, as well. To do so, you need to anticipate the possible outcomes of your actions. For example, imagine walking around a corner with your hands full. Ask yourself: “What could go wrong here?”.
For starters, you might run into another worker coming around the corner or drop what you’re carrying and trip over it. To prevent these incidents, you could go around the corner with a wider berth or ask someone to help you carry your load. In another scenario, let’s say you’re welding on a piece of stainless steel. Not only do you have the ultraviolet (UV)/radiation and thermal hazards produced by the welding itself, but you also have the likelihood of producing airborne hexavalent chromium (CrVI) as a byproduct, which is a human carcinogen.
Practicing this type of thinking can help eliminate other – sometimes more dangerous – incidents from occurring. Is a Hazard Assessment Required by Law? Yes, but the extent of the analysis depends on your industry and type of work being performed. Some of the regulatory standards specifically mentioning a hazard assessment are:
- 29 CFR 1910.132 – “The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).”
- 29 CFR 1910.1030 – “Each employer having an employee(s) with occupational exposure as defined by paragraph (b) of this section shall establish a written Exposure Control Plan designed to eliminate or minimize employee exposure. The Exposure Control Plan shall contain at least the following elements: The exposure determination…”
- 29 CFR 1910.146 – The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces.”
- 29 CFR 1926.501 – “The employer shall determine if the walking/working surfaces on which its employees are to work have the strength and structural integrity to support employees safely.”
Workplace Hazard Identification and Assessment
One resource I like to reference for assistance in hazard identification is NFPA 350: Guide for Safe Confined Space Entry and Work. Although this standard is considered a voluntary consensus standard and not legally enforceable for most of the United States, it has some great information that many OSHA regulations fail to mention. For example, NFPA 350 groups workplace hazards into seven different categories:
In addition, NFPA 350 goes on to state that proper hazard identification involves a three-stage process, as shown below:
- The hazard anticipation (pre-plan) stage starts with recognizing and understanding actual and potential hazards and identifying resources that might be needed.
- The hazard identification stage confirms anticipated hazards and recognizes additional potential hazards.
- The hazard evaluation stage determines the risk of each hazard identified and the recommended elimination, mitigation, and/or control measures. After all hazards have been identified and all risks have been assessed, the appropriate means to eliminate, mitigate, or control hazards should be implemented using the hierarchy of controls.
When performing new or non-routine tasks, be sure to complete a job safety analysis (JSA) so that these hazards can be documented and communicated to all affected personnel. The completed JSAs should be turned in to your company’s EHS Dept. upon completion and kept on file for a proper review and communication with other potentially affected employees. If you are unsure if you need to complete a JSA or if you have questions about completing a JSA, contact your immediate supervisor and/or your company’s EHS Dept.
Hazards may seem innocent, but as the old saying goes – “complacency kills”. Not taking the time to properly identify the hazards before performing work can prove to be costly. A thorough hazard assessment program involves active communication from multiple personnel, including EHS personnel, affected workers, and company management. Once the hazards are identified and evaluated, a proper plan of action can be developed to assist with reducing your employees’ overall exposure(s). For a free job safety analysis (JSA) template, contact Arrow Safety and we will send you one that can be customized to fit your organization.