Employers intuitively understand the need to provide for workplace inspections and corrective actions, but knowing exactly where to start can be a bit of a challenge. It is tempting to want to set your sights high and target zero incidents right out of the gate, but unless you have perfected the basic hazard assessments first, anything beyond that is likely not achievable or realistic for your organization.

Determining OSHA safety assessment requirements can be confusing and challenging. It’s important to stay focused on the benefits of these proactive assessments. You simply cannot fix what you are not looking for.

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, latent, or that could have been anticipated. Proactive hazard assessments are no-debate elements within any effective safety and health program.

Here are five examples of acceptable OSHA-compliant assessments to make sure you get right before striving for bigger things within your safety program.

1. Job Safety Analysis (JSA) or Job Hazard Assessment (JHA)

The Job Safety Analysis (JSA) or Job Hazard Assessment (JHA) serves as the focal point of the entire safety management system. The JSA 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. Where a Physical Demands Analysis (PDA) can be utilized to prevent risks prior to hiring, the JSA serves to prevent and control risks after hiring.

Benefits of a JSA include:

  • Supervisor and employee training
  • Outline of compliance requirements
  • Reductions to workers’ comp costs
  • Increase in worker productivity
  • Demonstration of employer commitment to health and safety
  • Identification and prevention of uncontrolled hazards
  • Enhancement of management credibility and trust
  • Identification of frequency and severity of work tasks

Scope

OSHA does not explicitly require a JSA or a JHA. However, OSHA does view them as a best practice, and they can demonstrate good faith efforts in managing an overall worksite analysis process. OSHA cannot cite you for not performing a JSA, but they can cite you for the consequences thereafter.

Potential citations

  • JSAs: None
  • 5(a)(1) General Duty Clause

2. Personal Protective Equipment (PPE) Certification

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). This certification is applicable within the general, construction, maritime, and agriculture industries.

Benefits of a PPE Certification include:

  • Prevention of injuries from improper fit
  • Limitation of waste from ineffective or improperly used PPE
  • Considerable cost savings

Scope

  • Eye/face
  • Head
  • Hand
  • Foot
  • Respirator protection
  • Electrical protective equipment
  • Personal fall protection

Potential general industry citation examples

  • 1910.132 — General requirements
  • 1910.133 — Eye and face protection
  • 1910.134 — Respiratory protection
  • 1910.135 — Head protection
  • 1910.136 — Foot protection
  • 1910.137 — Electrical protective equipment
  • 1910.138 — Hand protection
  • 1910.140 — Personal fall protection systems

3. Fall Protection

The revised Walking-Working Surfaces rule requires that fall protection systems are used when employees are working four feet or more above a lower level or when they are working over dangerous equipment and machinery – regardless of the fall distance. The revised rule provides more flexibility for general industry employers looking to implement personal fall protection systems. 

Scope

  • General
  • Construction
  • Maritime
  • Agriculture

Potential general industry citation examples

  • 29 CFR 1910.28 — Duty to have fall protection and falling object protection
  • 29 CFR 1910.29 — Fall protection systems and falling object protection — criteria and practices
  • 29 CFR 1910.30 — Training
  • 29 CFR 1910.140 — Personal fall protection systems
  • 29 CFR 1926, Subpart L — Scaffolds
  • 29 CFR 1910.67 — Vehicle-mounted aerial lifts
  • 29 CFR 1910.268 — Telecommunication work
  • 29 CFR 1910.269 — Electric power transmission and distribution work

Of the above citations, 29 CFR 1910.30 is always in OSHA’s top 10 every year in the construction industry, but it is also a main focus for OSHA inspectors in other industries including general, agricultural, and maritime.

4. Facility Plant & Equipment

Commonly known as the “General Duty Clause” or OSHA 5(a)(1) clause, this requires each employer to furnish to each of their employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to their employees.

Scope

  • General
  • Construction
  • Maritime
  • Agriculture

Potential general industry citation examples

  • OSHA General Duty Clause or relevant standard

5. Safety Programs & Training

In the past, compliance officers have evaluated employers’ safety and health programs, but those evaluations have not always required thorough documentation in case files. More detailed evaluation and documentation is now required to meet the Agency’s need to assess such programs accurately and to respond to workplace compliance conditions accordingly.

Scope

  • General
  • Construction
  • Maritime
  • Agriculture

Potential citations

  • Effective Fall Protection Not Provided
  • Powered Industrial Truck Training Not Provided
  • Lockout Tagout Procedures Not Provided or Effective
  • Unsafe actions and behaviors that present the possibility of a fatality or catastrophic injury not effectively prevented or controlled

Ace your next OSHA inspection with help from Fit For Work

If your business is in need of a safety compliance easy button, we can help. All of the above assessments factor into every OSHA investigation – which is why Fit For Work includes each of them in our Safety Subscription service model. We partner with organizations like yours all across the country to find the gaps, get you to compliance, and make sure you stay there. Whether you’re in need of a Job Safety Analysis or expert-led OSHA training, we have the resources needed to lead you through the process from start to finish.

Contact us today begin identifying and mitigating hazards to ensure your business is more than ready for your next inspection.

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