Identification of Control Measures in A Job Safety Analysis
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Why Reevaluate Control Measures
When performing a job safety analysis, an important step is identifying preventive control measures to eliminate or mitigate potential hazards and their associated risks. Common preventive controls fall into such categories as permitting (legal/regulatory requirements), administrative (operating procedures), engineering (physical barriers/restraints), training, and PPE. However, another important step in the job safety analysis process is to reevaluate the JSA again, once the assumed control measures are in place.
Each preventive control measure becomes a part of the task, and has the ability to impact the task beyond its intended use. Sometimes this can be a positive impact. An unforeseen benefit of requiring N95 masks in an area of poor air quality might be the additional protection against transmission of cold and flu viruses between workers. Similarly, replacing an old piece of equipment with a newer tool with greater safety features may also have the added benefit of enabling workers to perform the task more efficiently or quickly.
Unintended Impacts of Control Measures
On the other hand, some safety or preventive control measures might introduce a new hazard to the work area. For example, if workers do not know how to properly use the newly acquired piece of equipment, the new tool has just introduced a new set of hazards even though it is considered a “safer” tool. Similarly, an on-site weld or repair job might be cordoned off to prevent unintentional hazardous contact with other workers in the area. However, if the area cordoned off happens to be the only fire escape route, this safety control measure has just created a new safety problem.
When adding preventive control measures into a job safety or activity hazard analysis, it is important to consider how those control measures will impact the job, beyond their intended use. The following “cheat sheet” lists a few questions to consider as JSAs are updated with new controls.
Permitting Controls
Questions to consider when adding required permitting controls:
- Is everyone who performs and oversees the work familiar with the new permitting control?
- Do any workers or overseers need additional training to properly operate under the new permitting control?
- Does the new control change HOW the task will be performed?
- Does the new control include any ADDITIONAL task requirements?
- Are the appropriate tools available to fulfill any new control stipulations (for example, a new regulatory requirement to use hand auger vs. drill in certain situations)?
- Does this job present any unique circumstances that may require additional planning in order to comply with the new permitting control?
- Will additional time be required to implement this control?
Administrative Controls
Questions to consider when adding administrative controls:
- Is everyone who performs and oversees the work familiar with the new administrative control?
- Do any workers or overseers need additional training to properly operate under the new administrative control?
- Does the new control change HOW the task will be performed?
- How will the new control impact the surrounding environment (non-human factors – indoor/outdoor space, air, other equipment, vegetation)?
- How will the new control impact other people outside the work zone (other workers, pedestrians, vendors, customers)?
- Will additional time be required to implement this control?
Engineering Controls
Questions to consider when adding engineering controls:
- Is everyone who performs and oversees the work familiar with the new engineering control?
- Is everyone who performs and oversees the work properly trained in the use of the new control?
- Who will be responsible for implementing the control?
- Is the team trained to recognize if the control is working or not working properly?
- What is the procedure for stopping work if the control fails?
- How does the control measure impact or change the way in which the work is performed?
- Will additional time be required to perform the work with the new control measure fully implemented?
- How does the new control impact the surrounding environment (non-human factors – electrical system, indoor/outdoor space, air, other equipment, vegetation)?
- Does the new control impact other people outside the work zone (other workers, pedestrians, vendors, customers)?
- Is additional PPE needed to utilize the new control?
Training Controls
Questions to consider when adding training controls:
- Is everyone who performs and oversees the work familiar with the new training control?
- Has everyone who performs and oversees the work received the new training?
- In what ways does the new training impact or change how the job is performed?
- Do any additional procedural steps need to be put in place to accommodate other impacts of the new training?
- How often will training refreshers be offered or required?
- Do all workers and overseers have the authority and ability to stop work if they see another worker performing contrary to the new training?
- Will additional time be required to perform the job as workers and overseers become familiar with implementing the new training?
PPE Controls
Questions to consider when adding PPE controls:
- Is everyone who would perform and oversee the work qualified medically to use the new PPE?
- Is everyone who performs and oversees the work familiar with the new PPE control?
- Is everyone who performs and oversees the work properly trained in the use of the new PPE control?
- How does the PPE control impact the performance of the job?
- Do changes need to be made to how the job is performed in order to accommodate the PPE?
- Will additional time be required to don the PPE, perform a fit-check, and remove the PPE throughout the duration of the job?
- Does the new PPE have any impact on the surrounding environment (non-human factors – electrical system, indoor/outdoor space, other equipment)?
- Does the new PPE have any impact on people outside the workzone?
- Does the new PPE present any additional challenges to the worker to communicate (for example, protective ear- or eye-wear, masking)?
- Does the new PPE present any additional challenges to the worker’s health and safety (for instance, heat hazard risks due to FRP layers, inability to hear or see nearby potential hazards due to ear or eye protection layers)?
- Does the environment have the ability to adversely impact the new PPE (steel-toed shoes vs. safety-toed shoes in an area with potential electrical hazards)?
- Is there a procedure in place for removing a worker’s protective gear or full body suit in an emergency situation?
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Job safety is an ever-evolving concern, requiring active vigilance. It is exciting to look back and see how far job safety has come over the past 100 years, and an inspiration as we consider how to keep working with greater safety into the future.
JSAs are a useful tool that can aid the identification of changed conditions, which can help a work team to develop and agree on revised mitigations at their worksite. Those mitigation revisions can then be immediately documented with a management of change (MOC) annotation right on the JSA. That facilitates helping everybody to complete their tasks safely, in an efficient manner. Performing these MOC steps during reviews helps to keep all team members engaged in thinking about their current work tasks and helps eliminate potential hazards. A JSA worksheet provides employers so much value so inexpensively, it’s difficult to understand why anyone would not use a Job Safety Analysis for every project task.
Additional Resources
Additional resources for developing and improving your job safety or activity hazard analysis:
- US OSHA – Job Hazard Analysis: Job Hazard Analysis (osha3071.pdf)
- US OSHA – On-Site Consultation (a free service for small and medium sized businesses): Occupational Safety and Health Administration (osha.gov)
- Canadian Centre for Occupational Health and Safety (CCOHS) – Job Safety Analysis: Job Safety Analysis (ccohs.ca)
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