May 2017

Environment and Safety

Prevent human-created hazards with improved job safety analysis

Safety incidents have occurred since the beginning of time. If a “hunter-gatherer” failed to return at the end of a day, the remaining group members took it in stride.

Sawyer, M., Jayawardena, P., Apex Safety Consultants

Safety incidents have occurred since the beginning of time. If a “hunter-gatherer” failed to return at the end of a day, the remaining group members took it in stride. Early humans were too busy trying to survive to worry about much else. However, as civilization progressed and became industrialized, workers were increasingly needed for factories and plants. These workers were subject to an array of human-created hazards that vastly differed from any natural hazards.

As industrialization advanced, laws and regulations were enacted in an attempt to protect workers. These laws, as well as industry regulations and best practices, have had varying degrees of success, depending on the industry segment targeted. The threat of litigation after an incident is an additional deterrent in allowing workplace hazards to go unabated.

The how and why of safety hazards

The hazards that workers are exposed to today are created by people, with very few exceptions. Only a negligible portion of workplace incidents may be attributed to natural occurrences.

Advances in safety engineering, the enactment of laws and regulations, the potential for penalties being assessed by federal and/or state agencies and the risk of litigation have not completely curtailed workplace injuries and fatalities. Based on the perpetuation of workplace incidents, should it be concluded that worker injuries and fatalities are consequences that must be accepted?

Fig. 1. Successful implementation of prevention techniques leads to zero incidents.
Fig. 1. Successful implementation of prevention techniques leads to zero incidents.

Zero incidents may be a reasonable goal (Fig. 1) that sounds good on safety posters and company websites. However, most efforts by companies to achieve zero incidents fall far short. Typically, investigations of catastrophic incidents reveal a focus of safety resources on low-risk items, and a systematic failure to address the higher-risk factors in the workplace.

The rationale for the misdirection of safety resources varies, but typically the low-risk items are easier to address, and the higher-risk items are not well understood or adequately identified prior to an incident. During several investigations of fatal incidents, one of the authors was instructed to fasten his seat belt and don safety glasses while being transported to an incident site, although the speed limit was less than 10 mph and the risk of a projectile to the eye was negligible. Had that degree of attention been directed toward the real risk, the incident might have been prevented. Yet, many companies remain focused primarily on lesser- and easier-addressed risk issues.

If a zero-incident rate is a reasonable goal, is it really obtainable? H.W. Heinrich, one of the early safety professionals, first published a scientific approach to preventing incidents in 1931.1 In this and subsequent editions, Mr. Heinrich proposed a multi-step philosophy for preventing incidents. Eighty-five years have passed since he introduced his prevention philosophy, with numerous methodologies and strategies proposed during that time, yet none have resulted in a zero-incident rate.

While a zero-incident rate may or may not be achievable, the great majority of all incidents can be easily and cost-effectively prevented. Even in light of prevention being cost-effective, numerous industrial incidents occur each day. It is not surprising that companies have become somewhat insensitive toward incidents.

One factor that seems to have been overlooked by most companies is that workplace hazards are human-created. Therefore, it seems logical that whatever people create in the workplace can be controlled by people. The engineering needed to prevent workplace incidents is sound, practicable and available. Implementation of prevention techniques remains the critical failure path.

The how in preventing incidents is known, and the technology is feasible and readily available. Yet, incidents still occur. If the how is known, then the why must be analyzed. When the implementation of preventive measures is incomplete or inappropriate, an incident is the result.

For example, preventing explosions of flammable hydrocarbons while conducting hot work on a pipeline segment is a common concern. The solution is often as simple as inserting mud plugs and dry ice into the pipeline in preparation for hot work. Prevention techniques can differ from this hypothetical depending on the circumstances, but they are readily available. Regardless of the prevention technique needed, unless properly implemented, any technique may be rendered ineffective in preventing an incident.

Methods for avoiding safety incidents

Various methodologies have been developed, such as leading indicators to identify precursors of incidents.2 The concept is that the prevention of incidents will be aided through the analysis of leading indicators. Again, just as with the how in incident prevention, the use of leading indicators or metrics is sound and feasible, but often not effectively implemented.

The job safety analysis/job hazard analysis (JSA/JHA) approach has the potential to analyze implementation steps and prevent incidents. However, all available hazard information must be included in the analysis. A good example is Hernandez vs. Brinker Intl.3 Brinker Intl. owned and operated a restaurant. In March 2005, Brinker retained a contractor for needed repairs to an air conditioning (AC) unit on the roof. During the repairs, the contractor stepped away from the AC unit and the roof collapsed, injuring the contractor. After the incident, Brinker admitted that it had scheduled the replacement of the roof due to leaks.

When completing his JSA, the contractor would not have had information about the condition of the roof unless provided by the owner-operator, or unless visible signs of deterioration could be observed by the contractor. Only through collaboration between the owner and contractor during the JSA preparation would sufficient hazard information have been available to ensure proper implementation of preventive measures. These preventive measures may have included barricading any deteriorated roof sections or reinforcing those areas with suitable materials to prevent collapse.

The JSA methodology is commonly used throughout industry. Although recommended by the US Occupational Safety and Health Administration (OSHA), it is not required. OSHA does require a formal hazard analysis at facilities covered by its PSM standard.4 These hazard analyses are more detailed than the JSA, and typically concentrate on identifying process hazards rather than task-oriented activities.

Building on the knowledge that workplace hazards are created by people, and that prevention techniques are known and available, the remaining step is implementation. Therefore, implementation becomes a critical factor requiring careful analysis to ensure that proper prevention techniques are fully implemented.

Ensuring safety with solid JSAs

If properly administered, the JSA can serve as a good methodology for analyzing the implementation steps to prevent incidents. However, reviews of numerous JSAs conducted in the field have shown that most are not used appropriately. Many workers viewed the JSA as only a paper shuffle, giving little attention and thought to its contents.

A hazard identification study (HAZID) is another hazard analysis technique that is well suited to analyzing task-oriented activities. The drawback with the HAZID methodology is that field workers actually performing the task are not often involved in the analysis.

Since the JSA concept is known throughout industry, a revamp of it could provide the needed concentration on how to properly implement prevention techniques. Revamping a well-known and widely-used technique, such as the JSA, has the potential to achieve the most risk reduction worth when compared with other available methodologies.

The following is a list of suggested enhancements to the JSA format to aid in achieving higher incident prevention:

  • Adaptation to an electronic JSA (eJSA) format, whereby databases for hazards, preventive techniques and implementation methods are easily updated and kept active. In addition, an electronic analysis format allows real-time participation by multiple parties while at different locations.
  • The use of a trained hazard analysis facilitator can guide workers, contractors and all involved parties through the analysis. Note: All involved parties, including property owners and site operators, must participate before the eJSA can be completed.
  • A member of management or a designated safety engineer must evaluate the eJSA and sign the form to signify approval prior to any work being conducted. The hazard analysis requirement must be more visible within companies. One way of ensuring visibility is to have a member of management responsible for the analysis.
  • The eJSA should provide a database of pre-determined prevention techniques for each task step. An additional column should be listed on the eJSA form to document the basis or justification for each prevention method, particularly if a prevention technique will not be used.
  • An eJSA records retention policy should be developed to evaluate completed analyses and determine areas needing improvement.

Through improvements in the area of implementation, companies should achieve a significant reduction in incidents resulting from human-made hazards. With the technology available today, no worker should be harmed by any hazards created by people. HP

LITERATURE CITED

  1. Heinrich, H. W., Industrial Accident Prevention: A Scientific Approach, 1st Ed., McGraw-Hill Book Co., New York, New York, 1931.
  2. Center for Chemical Process Safety, Guidelines for Process Safety Metrics, CCPS, American Institute of Chemical Engineers, New York, New York, 2010.
  3. Hernandez vs. Brinker Intl. Inc., Houston 14th Judicial District, Case No. 14-07-00341-CV, 2009.
  4. US Occupational Health and Safety Administration, “Standard for hazardous materials—process safety management of highly hazardous chemicals,” 29 CFR 1910.119.

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