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    September 1, 2022

    "How Do You Do That?" Blog Series - Question 8: Hazard Analysis

    There are two main reasons why it’s important to conduct a hazard analysis. 1) Identifying hazards so they can be analyzed and remediated is a regulatory requirement and 2) Without conducting a hazard analysis, risks would be very difficult to properly assess because hazard analysis is the first step in the risk assessment process. Before we get too far into this discussion though, let’s cover the basics by defining “hazard’ and “risk”.

    Hazard vs Risk

    The first step to understanding hazards and risks is to understand that they aren’t the same things and shouldn’t be used interchangeably. Hazards are the actual sources of potential harm to humans, property, the environment and/or a combination of these things. Risks on the other hand, are the chances or the likelihood of that hazard causing harm to humans, property and/or the environment.

    Here’s an example that better explains things:

    For cleaning purposes, you buy a bottle of bleach and store it on a shelf in the storage room until it’s needed. Regardless of whether the container of bleach is just sitting there unused or not, it is always going to be a hazard because of its potential to cause harm. The risk part comes in when you evaluate the chances or likelihood of that hazard causing harm because of an exposure (or when it’s used). To do that, you have to assess the risks as they pertain to jobs or tasks that involve using bleach, environmental conditions where the bleach is stored, how the bleach would interact with emergency conditions like fires or explosions, etc. Once the likelihood has been established, then it’s time to figure out ways to mitigate or eliminate the potential for harm. (OSHA has a required process for how employers are to eliminate or reduce risks called the Hierarchy of Controls which you can read about here.)

    Regulatory Requirements

    As we mentioned earlier, one of the two most important reasons to conduct a hazard analysis is that it’s part of a series of regulatory requirements (at least in the US it is). It’s through the General Duty Clause that OSHA first puts employers on notice about their requirements as it pertains to hazards in the workplace. To be more specific, the General Duty Clause requires employers to “furnish to each of his 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 his employees”. And the way the employer does this is by complying with occupational safety and health standards promulgated under the Act (which is actually Section 5(a)(2)) of the OSH Act of 1970.

    The way OSHA worded the General Duty Clause frequently gives employers pause for two reasons. The first is the use of the phrase “recognized hazards” which for certain employers seems to indicate a “loophole” to mean if they don’t recognize the hazards they don’t have to worry about it. However, OSHA combats this potential problem by strategically requiring employers to perform hazard analysis and risk assessment as part of several regulatory requirements found within General Industry, Construction, Maritime and Agriculture standards as well as including it in their “recommended practices” section for small and medium sized businesses.

    The second is the stipulation that only those hazards which could cause death or serious physical harm are included. OSHA worded things this way because they know that what constitutes a hazard is fairly subjective and it would be impossible for employers to eliminate every single hazard from the workplace. Additionally it’s really important to remember that the federal safety regulations are just the minimum compliance requirements employers have to meet. Meaning, if a company is compliant they’re really just meeting the minimum requirements. All that said, the key takeaway here is that if you’re a US employer, identifying, analyzing and eliminating hazards is your primary responsibility.

    Another aspect of the General Duty Clause that we want to mention is that OSHA will also use the General Duty Clause when a hazard materializes that isn’t covered by any of the current regulatory standards. There’s no way OSHA could write regulatory requirements for every hazard that might be present in the workplace so the General Duty Clause provides a bit of a “catch all” in that situation.

    Risk Assessment Process

    The other most important reason to conduct a hazard analysis is that hazard analysis is the first and probably most important step in the risk assessment process. If you’re not familiar with the risk assessment process, it’s essentially a process where companies scrutinize their workplaces to include policies, processes, situations, equipment, etc., looking for actual and potential hazards which are then analyzed and evaluated to establish the level of harm that could be caused. The employer will then develop control measures to either eliminate or reduce the risks down to an acceptable level.

    The very first part of this process is identifying and analyzing those hazards or conducting a hazard analysis. Without this part of the process, nothing else within the risk assessment process can be completed—so the importance of hazard analysis is substantial as it’s related to the risk assessment process. There are also specific types of hazard analysis that are required and/or utilized based on the industry such as:

    • Job Hazard Analysis or JHA
    • Hazard Analysis Critical Control Point or HACCP
    • Process Hazard Analysis or PHA
    • Failure Mode and Effects Analysis or FMEA
    • Design Failure Mode and Effects Analysis or DFMEA
    • Fault Tree Analysis or FTA

    You might be familiar with some of these, especially the Job Hazard Analysis or JHA which is the most common of the different types and is used in virtually every industry. The JHA is an extremely powerful tool for employers of all sizes because it provides a way for employers to reduce or eliminate identified hazards by showing employees the safest way of performing tasks through the use of step-by-step instructions. Another reason the JHA is such a popular hazard analysis method is that it’s a great opportunity to get and then use the buy-in and feedback from the workforce, something we recommend employers do as often as they can.

    Final Thoughts

    No matter how it’s used, hazard analysis has a significant place of importance within a company’s safety program and because of its flexibility can be used by virtually any company no matter the size or type.

    If you’ve never considered using EHS software to manage your risk assessment process, why not check out EHS Insight’s Hazard Identification Risk Assessment module? This module provides the perfect place to manage this process and it won’t cost an arm and a leg.  Give us a call today, we’d love to talk to you about it.