Job Hazard Analysis & Safe Systems of Work

– Who’s Missing the Statutory Link?

Paper presented by:
Ron Greenwood
CPMSIA Member # 1438
PRINCIPAL CONSULTANT

Read the whole paper HERE (includes some excellent example of a STANDARD OPERATING PROCEDURE (JHA) RECORD FORM) [download id=”70″]

Extract:

In this paper, we explore the connection and how people miss the Statutory link between the establishment of
Standard Operating Procedure (SOP’s), the process of Job Hazard Analysis (JHA) and the establishment of Safe
Systems of Work. The review will hopefully shed light on why methods such as establishing Standard Operating
Procedure (SOP’s) and Job Hazard Analysis (JHA) are currently not working so well in many workplaces. You
will most probably come to the conclusion by the end of the paper, that the risk assessment technique to establish
a Safe System of Work via JHA (or by whatever name you call it) is not well understood within your workplace by
Management, Supervision and even a few Safety Practitioners.
The objective outcome of this paper is, to provide information to assist in facilitating a change in employee
behaviour and Management culture, towards establishing:
• Documented routine standards of work practice that are known and available to employees in a suitable
format
• A JHA (Risk Assessment) process that is a credible management of change tool and that works in
reducing workplace risk and provides for establishing a safe system of work.
• How the JHA (Risk Assessment) process is intrinsic to the Quality Assurance/Control (QA/QC) systems
approach of Risk Management and integral to continuous improvement and that via establishing a Safe
Systems of Work provides for a more viable and profitable business enterprise.
The concept of Job Hazard Analysis (JHA) in many cases appear to be, ‘not well understood’ by Industry as the
essential Risk and Change Management technique required for identifying and confirming the establishment of a
Safe System of Work; consistent with OHS Statutory and Common Law Duty of Care requirements.
The term JHA in itself, is not common to all workplaces. Some workplaces refer to the process as a Job Safety
Analysis (JSA), some include environmental considerations resulting in a JSEA, whilst other workplaces prefer to
call the process, a Task Risk Assessment (TRA). Fact is, we should probably call it a Hazard Analysis of Job
Safety, Quality, Environment and Financial Risks (HAJSQEFR). The reality is, that whatever you are calling the
process, any risk assessment of business activity is better than none!

However, whatever name your organisation chooses to give the risk assessment process, it often fails in
achieving of focus of a safe system of work, in that the employer has not established a standard of operating
practice in the first instance. By the way, the term Standard Operating Procedure (SOP) is also not in itself
common to all workplaces. As an example, some workplaces refer to a collection of job steps as a Work
Instruction (WI’s), Work Method Statement (WMS), or Task Instructions (TI’s). By whatever name, in short, it
has been my experience as an Auditor and Incident Investigator, that if tested; many Employers in work
places across varying industries today are exposed from both a statutory non-compliance and common law
perspectives due to not having standards of operating practice established.
To set the framework for this paper, we need to first take a look at a sample STANDARD OPERATING
PROCEDURE (JHA) RECORD FORM, found in Appendix 1. This could be used within a workplace for the
purpose of undertaking a Risk Assessment on a job. This title is important in that it is implying that whatever
the assigned job (or task) is, that the steps for carrying out the job will be to a standard of practice that each
person involved understands. Further that via a JHA (Risk Assessment), anything that could be different
(i.e. a Change), is managed.
At this point it is important to acknowledge that yes, not all job steps will have been documented in the past
and there will be a requirement to write the job steps from scratch. However, it must be a question that if an
organisation does not have established and documented standards of work practice, then how do its
customers expect a quality of service or supply.
On the sample form (found in Appendix 1), for formality, there are a number of titled boxes found in the first
section. Although the titles are most probably self explanatory, the titles provided are provided consistent with
work planning inclusive Supervisor assignment, requirements for interfacing with Permit to Work system
requirements related to critical safety activities; and work activity scheduling and also time management
considerations.
The second section of the form is designed to capture the names and signatures of those persons
participating in the work activity. By completing this section, the undersigned confirm they have received a
full briefing by the Supervisor on the job step and that subject to the JHA (Risk Assessment), understand the
safe system of work to be followed and will work in accordance with the agreed safe work practice. The
practicality of this signed endorsement by participating employees is extremely important and will be
discussed in more detail later in the paper.
The next sections of the example form are probably more familiar to the majority in that they consist of a
column to document the Standard of Operating Practice (Routine Steps), a column to document the
Hazard/Loss Potential (What’s Different), columns to capture the risk assessment process of consequence,
likelihood & risk classification, and finally a column to document the proposed control measure for the
perceived risk. What you will observe to be different about the form is that the columns for documenting the
Hazard/Loss Potential (What’s Different), Risk Assessment process and the proposed Risk Control are
grouped under the heading of Job Hazard Analysis. This is where we identify the first difference from the
norm in industry today, in that the emphasis is:
STANDARD OPERATING PRACTICE + JOB HAZARD ANALYSIS = SAFE SYSTEM OF WORK
In exploring the Standard of Operating Practice (Routine Steps) column, perhaps one of the key areas where
the establishment of a Safe System of Work fails, I must acknowledge the frustration of many workplace
Supervisors. In the first instance, we quite often naively provide a blank JHA template to employees and
anticipate that those people involved in the job, in particular in the role of a Supervisor, have the necessary
literacy skills to express themselves adequately, let alone to write down the steps of the job. The result of this
assumption, in many circumstance results in a more conservative approach in documenting the job steps. ……………….

……………………….Significantly, there is also another side to the Duty of Care implication as it relates to each individual
employee and their duty to work in a safe manner so as to not harm themselves or a fellow workmate. The
implication is that should as a result of non-compliance by one employee result in another employee
sustaining an injury; then the negligent employee may be exposed to penalties under OSH Statutory, Criminal
Laws and possibly Civil litigation.
In conclusion, the current methods of how Standards of Operating Practice are being documented and
referred to within many workplaces, needs a radical overhaul if employers are really concerned about
embracing the concept of safe systems of work. An important recommendation in support of this, is that
employers consider providing the job steps for SOP’s already in the JHA format to assist Supervisors and
workers in carrying out tasks in accordance with the organisations requirements. Consistent with this is the
need for employers to focus on the importance of the Management of Change link between the JHA process,
a Risk Register, and the continuous improvement of work practice. The hardest aspect of change
management is guiding people to successfully change. Successful change management requires a change
of heart and a change in thinking.

Read the whole paper HERE (includes some excellent example of a STANDARD OPERATING PROCEDURE (JHA) RECORD FORM) [download id=”70″]