1.3 Site-Specific Health and Safety Plan (HASP/SSHP) Requirements
Key Takeaways
- The HASP is a mandated, site-specific document required by 1910.120(b)(4) that addresses hazards unique to a specific job site.
- 1910.120(b)(4)(ii) requires exactly ten HASP elements (A)-(J): task hazard analysis, training assignments, PPE, medical surveillance, monitoring and calibration, site control, decontamination, an emergency response plan under (l), confined space entry procedures, and a spill containment program under (j).
- The Job Hazard Analysis (JHA) is a critical methodology used to break down tasks into steps, identify hazards, and implement controls.
- Pre-entry briefings are required by 1910.120(b)(4)(iii) prior to initiating any site activity; daily tailgate meetings are widespread industry practice rather than a separately numbered HAZWOPER requirement.
Site-Specific Health and Safety Plan (HASP/SSHP) Requirements
The Mandate: 1910.120(b)(4)
While the employer's general Safety and Health Program is a high-level corporate document, the Site-Specific Health and Safety Plan (HASP) (sometimes referred to as the SSHP) is the tactical, operational document designed for a distinct project location. Under OSHA 29 CFR 1910.120(b)(4), a HASP must be developed, implemented, and strictly enforced before any site operations commence. It must be kept on-site and made readily available to all personnel.
Mandated Elements of the HASP
Paragraph (b)(4)(ii) lists exactly ten mandatory elements, lettered (A) through (J). Learn them by letter — exam items are often written straight off this list:
| Cite | Element | What the plan must actually say |
|---|---|---|
| (A) | Safety and health risk or hazard analysis for each site task and operation found in the workplan | A task-by-task analysis of chemical, physical, and biological hazards — not a generic site-wide paragraph. |
| (B) | Employee training assignments to assure compliance with paragraph (e) | Who holds 40-hour vs 24-hour status, who has supervisor training, and refresher due dates. |
| (C) | Personal protective equipment to be used for each task, per the PPE program in (g)(5) | The precise ensemble level (A, B, C, or D) tied to each task. |
| (D) | Medical surveillance requirements in accordance with paragraph (f) | Which workers are enrolled and confirmation of respirator clearance. |
| (E) | Frequency and types of air monitoring, personnel monitoring, and environmental sampling techniques and instrumentation, including maintenance and calibration methods | Note the often-missed second half: calibration and maintenance procedures are part of element (E). |
| (F) | Site control measures per the site control program at paragraph (d) | Work zones, site map, buddy system, communication, and access control. |
| (G) | Decontamination procedures per paragraph (k) | The station-by-station decon line for personnel and equipment. |
| (H) | An emergency response plan meeting the requirements of paragraph (l) | On-site emergencies during cleanup, including the necessary PPE and other equipment. |
| (I) | Confined space entry procedures | Permit-required confined space protocols where applicable. |
| (J) | A spill containment program meeting the requirements of paragraph (j) | Drum and container handling and containment of transfer operations. |
Exam trap: the organizational structure and named key personnel are required — but by the general program at (b)(1)(ii)(A), not by the ten-element HASP list. In practice virtually every HASP restates them, which is why they are so often mis-attributed.
Comparing the General Program vs. The HASP
| Feature | General Safety & Health Program | Site-Specific HASP |
|---|---|---|
| Scope | Corporate-wide, applies to all operations | Specific to a single geographic site and project |
| Detail Level | Broad policies and standard operating procedures | Highly detailed, tactical, and task-specific |
| Updates | Annually or when major corporate changes occur | Constantly updated as site conditions or tasks change |
| Location | Corporate headquarters and field offices | Maintained actively on the job site |
Job Hazard Analysis (JHA)
The foundation of the HASP's hazard analysis section is the Job Hazard Analysis (JHA), also known as a Job Safety Analysis (JSA). A JHA is a systematic methodology used to identify potential hazards associated with specific work tasks and to develop controls to mitigate those risks.
JHA Methodology
The JHA process follows a strict matrix approach:
- Select the Job: Choose a specific task to be analyzed (e.g., "Decontaminating a backhoe").
- Break Down the Job into Steps: Divide the task into a logical sequence of individual steps. Avoid making the steps too detailed or too broad.
- Identify Hazards per Step: For each step, identify what could go wrong. Look for physical hazards (pinch points, slips, falls), chemical exposures, biological threats, and ergonomic issues.
- Determine Controls: For each identified hazard, establish a control measure utilizing the hierarchy of controls (Elimination, Substitution, Engineering, Administrative, and PPE).
Example JHA Matrix: Drum Handling
| Step | Description | Potential Hazards | Control Measures |
|---|---|---|---|
| 1 | Inspect drum condition | Drum rupture, chemical splash | Wear Level B PPE; use non-sparking tools; visual inspection only from a distance initially. |
| 2 | Move drum with forklift | Crushing hazard, tip-over, spill | Ensure operator is certified; secure drum with drum-grabber attachment; clear travel path. |
| 3 | Open drum bung | Pressurized release, inhalation | Relieve pressure slowly using a remote bung wrench; ensure continuous air monitoring. |
Roles and Communication Protocols
The Site Safety and Health Officer (SSHO)
The SSHO is a crucial figure on a HAZWOPER site. They are responsible for implementing the HASP, conducting site inspections, performing air monitoring, and verifying PPE compliance. Crucially, the SSHO must have the explicitly granted authority to halt any operations (Stop Work Authority) if they identify an imminent hazard or a deviation from the HASP.
Pre-Entry Briefings and Tailgate Meetings
A HASP is useless if the workforce is unaware of its contents. OSHA requires rigorous communication:
- Pre-Entry Briefings — required by 1910.120(b)(4)(iii): the HASP "shall provide for pre-entry briefings to be held prior to initiating any site activity, and at such other times as necessary to ensure that employees are apprised of the site safety and health plan and that this plan is being followed." The briefing covers site hazards, PPE requirements, zones, and emergency protocols. Note the regulation's trigger: prior to initiating any site activity, and as necessary thereafter — it does not name a fixed daily interval.
- Effectiveness Inspections — required by 1910.120(b)(4)(iv): the site safety and health supervisor (or another knowledgeable person acting for the employer) must inspect as necessary to determine whether the HASP is working, and the employer must correct any deficiencies found.
- Daily Tailgate Meetings — industry practice, not a HAZWOPER-numbered mandate: most contractors satisfy the "at such other times as necessary" language with a 10-15 minute start-of-shift tailgate that reviews the day's tasks and JHAs, discusses changed conditions (weather, new subcontractors, new waste streams), and collects a signed attendance roster. Client contracts and state-plan rules frequently make this contractual, so treat it as expected on any real site — just do not cite it as a numbered paragraph of 1910.120.
Which document is specifically designed to address the tactical, unique hazards of a single project location?
What is the primary purpose of a Job Hazard Analysis (JHA)?
Under 29 CFR 1910.120(b)(4)(iii), when must pre-entry briefings on the site-specific safety and health plan be held?