12.6 Job Hazard Analysis (JHA), the HAZWOPER Site Safety and Health Plan (HASP) & Required Written Programs

Job Hazard Analysis (JHA), the HAZWOPER Site Safety and Health Plan (HASP) & Required Written Programs

Chapter 12 has covered exposure limits, toxicology, the hierarchy of controls, PPE, and monitoring instrumentation. This section is where those pieces are assembled into the two documents the CHMM blueprint asks about directly: the analysis that identifies the tasks of a job, the hazards of those tasks, and the control of those hazards, and the basic elements of an OSHA-compliant site safety plan.

1. Job Hazard Analysis (JHA)

A Job Hazard Analysis — also called a Job Safety Analysis (JSA) or Activity Hazard Analysis (AHA) — is a systematic study of a specific job that identifies the hazards associated with each step and specifies the controls that eliminate or reduce them. OSHA's guidance publication 3071 is the canonical reference; no single standard mandates a JHA universally, but many standards require its substance (for example, the PPE hazard assessment under 29 CFR § 1910.132(d), the process hazard analysis under § 1910.119(e), and the task-by-task hazard analysis inside the HASP under § 1910.120(b)(4)(ii)(A)).

The five steps, in order

Step 1 — Select and prioritize the job. Rank candidate jobs by:

• injury and illness history (including near misses and first-aid-only events);
• potential for severe consequence even if frequency is low — a low-frequency, fatality-potential task outranks a high-frequency sprain-potential task;
• newly created jobs, and jobs whose process, chemistry, equipment, or staffing has changed;
• jobs performed rarely enough that skill degrades between performances;
• complexity, and jobs subject to a specific standard.

Step 2 — Break the job into sequential basic steps. Aim for roughly 8 to 15 steps, each starting with an action verb ("open the drum bung," "insert the transfer wand," "start the pump"). Too few steps hides hazards inside a vague description; too many turns the document into a motion study nobody reads. Observe the job being performed by an experienced employee and involve that employee in writing it — this is the single strongest predictor of whether the finished JHA is used.

Step 3 — Identify the hazards of each step. Prompt against a fixed checklist rather than relying on memory: contact with or struck-by; caught in, on, or between; fall from elevation or same level; energy release (electrical, hydraulic, pneumatic, thermal, chemical, gravitational, stored spring); chemical exposure by inhalation, dermal, ingestion, or injection; fire and explosion (ignition source plus flammable range); oxygen deficiency or enrichment; ergonomic loading; noise; radiation; and environmental release.

Step 4 — Determine preventive measures using the hierarchy of controls. Apply the hierarchy from Section 12.3 in order: elimination, substitution, engineering controls, administrative controls, PPE. A JHA whose control column reads "wear gloves" for every row has skipped the first four tiers and will be cited as inadequate in any credible audit.

Step 5 — Document, train, and revise. The finished JHA is a training document. Review and revise it after any incident or near miss on that job, after a process or equipment change, after a change in the chemicals used, and on a periodic cycle (annually is typical).

Worked JHA extract — drum transfer of a flammable solvent

Risk ranking

Where a facility must triage findings, score each hazard as Risk = Severity × Probability on a matrix (commonly 1–5 on each axis, sometimes with an exposure-frequency factor), then apply a decision rule — for example, any score in the red band stops the job until a control is installed, the amber band requires a documented interim control and a scheduled permanent fix, and the green band is managed by procedure. The matrix does not make the decision; it makes the decision auditable.

2. Core Components of a Standard Operating Procedure (SOP)

An SOP converts a control decision into a repeatable, auditable work method. A complete SOP is proportionate to the hazard and normally includes:

1. Document control: unique title/number, revision, effective date, page control, owner, technical/EHS review, approval, and superseded-version handling.
2. Purpose and scope: the operation, equipment, materials, locations, operating modes, and exclusions covered.
3. Roles and qualifications: who may perform, supervise, authorize deviations, issue permits, maintain equipment, and respond to abnormal conditions; prerequisites include training, medical clearance, and permits.
4. Hazards and controls: chemical/physical hazards, incompatibilities, exposure limits, energy-isolation points, engineering controls, required PPE, monitoring, and prohibited conditions. Reference the current SDS, PHA/JHA, permit, and drawings rather than copying stale data.
5. Materials and readiness: tools, compatible containers, calibrated instruments, labels, inspection checks, utilities, ventilation, spill equipment, and pre-start acceptance criteria.
6. Sequential procedure: numbered action steps with normal ranges, hold points, independent verifications, and records. State what to observe and what limit stops the step; “operate safely” is not an instruction.
7. Abnormal, shutdown, and emergency actions: alarms, loss of power/ventilation/containment, spill or exposure response, emergency shutdown, evacuation/notification, and restart authorization. Do not blur an incidental-spill SOP with the emergency-response plan.
8. Waste and environmental controls: collection points, hazardous-waste determinations, accumulation labels/dates, emissions/discharges, decontamination, and documentation.
9. Records and revision: required log entries and retention source, deviation and incident review, management-of-change interface, periodic review, and triggers for retraining.

Validate an SOP by walking it down at the job with operators: every valve, control, instrument, quantity, and sequence must match the field. Then train affected workers and verify competency before independent work.

3. The Site Safety and Health Plan (HASP)

HAZWOPER, 29 CFR § 1910.120, requires an employer engaged in uncontrolled hazardous waste site operations to develop a written safety and health program. Under § 1910.120(b)(1)(ii) that program comprises: an organizational structure; a comprehensive workplan; a site-specific safety and health plan; a safety and health training program; a medical surveillance program; the employer's standard operating procedures for safety and health; and any necessary interface between the general program and site-specific activities.

The site-specific safety and health plan (HASP) is the component the exam tests. Under § 1910.120(b)(4)(ii) it must address, at a minimum, these ten elements:

Two companion requirements in § 1910.120(b)(4)(iii) are frequently tested alongside the list:

• Pre-entry briefing. The HASP must provide for a pre-entry briefing to be held prior to initiating any site activity, and at such other times as necessary, so that employees are informed of the plan and are able to implement it.
• Effectiveness inspections. Inspections must be conducted by the site safety and health supervisor or, in the absence of that individual, another individual who is knowledgeable in occupational safety and health, acting on behalf of the employer, to determine the effectiveness of the plan. Any deficiencies must be corrected by the employer.

The HASP must be kept on site and made available to employees, their representatives, and OSHA. It is a living document: a new contaminant, a new task, or a change in engineering controls requires an amendment and a fresh briefing.

Exam trap. Candidates confuse the written safety and health program in (b)(1)(ii) with the site-specific HASP in (b)(4)(ii). The HASP is one element inside the program, not a synonym for it. A second trap: the HASP element list is a minimum, so a plan that addresses all ten but omits, say, heat stress controls that the site clearly needs is still deficient.

4. Operations That Require a Written Program

The blueprint asks candidates to identify, given a scenario, which operations require a program. Learn the inventory as a checklist.

Give a candidate a scenario — "a facility stores 15,000 gallons of diesel in ASTs, operates a 12,000 lb anhydrous ammonia refrigeration system, requires half-face respirators in its paint booth, and ships 3,000 kg of F-listed solvent per month" — and the correct answer is the full set: SPCC Plan, PSM program and RMP (ammonia appears on both the § 1910.119 Appendix A list and the Part 68 toxic list at a 10,000 lb threshold), respiratory protection program, HazCom program, and an LQG contingency plan with quick reference guide plus documented hazardous waste personnel training. Whether a DOT security plan is also required is a separate, shipment-level determination under 49 CFR § 172.800(b) — it turns on the placarding status, packaging type, and per-shipment quantity, not on the monthly generation rate, so the scenario as written does not by itself establish it.