JSA/JHA & T8CCR 3203 (IIPP)

1. Dick Monod de Froideville Industrial Hygienist/Safety Engineer Cell Phone: 310-464-7237 E-mail: dmonod.pasma@gmail.com JSA/JHA& T8CCR 3203 (IIPP)

2. ENFORCEMENT MANTRA – ed.note IF IT LOOKS A SHADE OF PLUM IT PROBABLY IS, So let’s dig!

3. SOME WORDS in STATUTES Partial list of Vague or ambiguous words Some Vague and/or Ambiguous phrases "To the extent practicable." A decision in the eyes of the READER OR EVALUATOR."Where applicable." There are no criteria for judgment/OR IS THERE?."Shall be considered." The READER OR EVALUATOR will think about… And the latest AB 2774 addition: “reasonably anticipated” ??????????

4. Title 8 California Code of Regulation Section 3203 (T8CCR3203) Injury and Illness Prevention Program • Importance of this Order • Applies to ALL Employers doing business in California at any time • Establishes the who, what, when, where, why and how of Health and Safety in the workplace • Cal/OSHA’s General Duty Clause • Composed of 7 Sections • Still the most often cited Safety Order! WHY!? House and Record keeping is inadequate

5. T8CCR3203 IIPP Critical Sub-Sections • (a)(2) Include a system for ensuring that employees comply with safe work practices. Include: recognition… training and retraining programs, disciplinary actions, or any other such means that ensures employee compliance • (a)(3)Include a system of communication with employees ….Substantial compliance includes: meetings, training programs, posting written communications…or labor/management safety committee.

6. (a)(4) Include proceduresfor identifying and evaluating work place hazards including scheduled periodic inspections…Inspections shall be… (a)(4)(B) When new processes, substances, procedures, or equipment are introduced. (a)(4)(C) Whenever…made aware of new hazard or previously unrecognized hazard. Note: if supervisor knows – EMPLOYER knows. (a)(5) Include a procedurefor investigating occupational injuries or illnesses.

7. (a)(6) Include methods and/or procedures for correcting unsafe work practices, conditions and work procedures in a timely manner: (a)(6)(A)When discovered or observed; and (a)(6)(B)When an imminent hazard exists and cannot be immediately abated without endangering employee(s) and/or property.

8. (a)(7)Provide training and instruction: (a)(7)(B)For all new employees. (a)(7)(C)To all employees given new jobs for which training has not previously been received. (a)(7)(D)When newsubstances, processes, procedures or equipment are introduced. (a)(7)(E)When employer is made aware of a new or previously unrecognized hazard. (a)(7)(F)For supervisors to familiarize themselves with the safety and health hazards which their employees are being exposed.

9. Other Codes Specifically Requiring JSA/JHA T8CCR§3380. Personal Protective Devices. (f)(1) Hazard assessment and equipment selection. The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE)… T8CCR§5097. Hearing Conservation Program (Monitoring) (b)(1) When information indicates that any employee's exposure may equal or exceed an 8-hour time-weighted average of 85 decibels, the employer shall obtain measurements for employees who may be exposed at or above that level. Such determinations shall be made by December 1, 1982. T8CCR§5144. Respiratory Protection. (d) Selection of respirators. This subsection requires the employer to evaluate respiratory hazard(s) in the workplace, identify relevant workplace and user factors, and base respirator selection on these factors. The subsection also specifies appropriately protective respirators for use in IDLH atmospheres, and limits the selection and use of air-purifying respirators.

10. Other Codes Specifically Requiring JSA/JHA – Cont’d T8CCR§5155. Airborne Contaminants. (e) Workplace Monitoring. (1) Whenever it is reasonable to suspect that employees may be exposed to concentrations of airborne contaminants in excess of levels permitted in section 5155(c), the employer shall monitor (or cause to have monitored) the work environment so that exposures to employees can be measured or calculated. T8CCR§5157. Permit-Required Confined Spaces. (c) General requirements. (1) The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces. T8CCR§5189. Process Safety Management of Acutely Hazardous Materials. (d) Process Safety Information. The employer shall develop and maintain a compilation of written safety information to enable the employer and the employees operating the process to identify and understand the hazards posed by processes involving acutely hazardous, flammable and explosive material before conducting any process hazard analysis required by this regulation. The employer shall provide for employee participation in this process. Copies of this safety information shall be made accessible and communicated to employees involved in the processes, and include….

11. Other Codes Specifically Requiring JSA/JHA Construction T8CCR§1510. Safety Instructions for Employees. (c) Where employees are subject to known job site hazards, such as, flammable liquids and gases, poisons, caustics, harmful plants and animals, toxic materials, confined spaces, etc., they shall be instructed in the recognition of the hazard, in the procedures for protecting themselves from injury, and in the first aid procedure in the event of injury. T8CCR§1511. General Safety Precautions. (b) Prior to the presence of its employees, the employer shall make a thorough survey of the conditions of the site to determine, so far as practicable, the predictable hazards to employees and the kind and extent of safeguards necessary to prosecute the work in a safe manner in accordance with the relevant parts of Plate A-2-a and b of the Appendix. Others Safety Orders such as… HazWoper, Asbestos, Carcinogens, Lead and anyplace where the text of the Safety Order requires “initial determinations”

12. HAZARD IDENTIFICATION, EVALUATION, AND CONTROL LANGUAGE IN CODE SPEAK SUCH AS: “system, procedure, means, methods, etc”., means: SHOW the DECISION LOGIC A.K.A Job Safety/Hazard Analysis

13. It is a method for systematically identifying and evaluating hazards associated with a particular job or task. It is also called “job safety analysis (JSA)”….IT IS NOT An INSPECTION CHECKLIST What is Job Hazard Analysis (JHA)?

14. How Do I Conduct A JHA? • Identify the job or task to be analyzed. • Break the job or task into key components. • Identify the hazards found in each key component. • Identify ways to eliminate or control these hazards. • Eliminate the hazard or install controls. • Keep a record of the hazards identified and steps taken to eliminate or control them. • Periodically assess controls to ensure they are working correctly.

15. Identifying The Job For Analysis Any job or task that meets any of the following conditions should have a JHA conducted for it: • Jobs or tasks with a history of injuries or near misses. • Jobs with catastrophic potential – fire, explosion, large chemical releases, massive equipment failure. • Tasks in which one simple human error could lead to serious injury.

16. Identifying The Job For Analysis Any job or task that meets any of the following conditions should also have a JHA conducted for it: • New people doing the task, • Tasks that have changed, • Rarely performed jobs, • Any job done under a “safety permit” - confined space permit, hot work permit, etc.

17. Ranking Hazardous Tasks Once you have identified jobs or tasks that have the potential to or are in fact injuring workers, you will need to rank these tasks and start addressing the most serious first. One method for ranking tasks considers the probability that the hazard will cause an injury and an estimate of the severity of that injury. These are not precise predictions of when or how severe an injury may be, they are only estimates. The method can help you decide which is more important – an infrequent job that has the potential to kill a worker, or frequent job that causes less severe injuries.

18. A method to prioritize hazardous tasks Severity Table Consider the severity of the injury of something may go wrong while doing the task in the severity table. Next, think about how often the worker is exposed to the hazard in the probability table. Multiply the severity rank by the probability rank. Address the highest scored tasks first. Probability Table

19. Non Serious 2 Imminent Danger 4 Slight 1 Serious 3 Probability = of Mishap 1.Unlikely but possible 2. Occurs once in 3years 3. Occurs at least once per year 4. Occurs several times per year 5. Occurs any time Hazard Slight - No Injury or Equipment damage Non-Serious - Controllable by operator or procedure Serious - Causes injury or equipment damage Imminent - Death; severe injury or major damage Wrk Ord Period for Correction Immediate (ASAP) Correction W/In 9 Months Correction W/In 2 Years Correction as resources become available PASMA Hazard Correction Matrix Hazard Probability Possible But Remote 1 Reasonable But Unlikely 2 Occasional 3 Probable 4 Frequent 5

20. Eliminating and/or controlling hazards

21. Break Job Down Into Key Components • Once a job is identified, you will need to break it into key components or sub-tasks and list all the hazards associated with each sub-task. • Too much detail makes the JHA cumbersome • Too little detail may omit hazards. • The correct amount of detail breaks the job into components that make sense in terms of the overall job. • Generally, limit the number of components to 10 or less.

22. Key Components - Example Changing a light bulb

23. Small Business Job Hazard Analysis (General Example) Date of analysis: ________________________ People who participated: _________________________________ __________________________________

24. References & Resources

28. Employees Are Prone To Use Their "Own" Procedures When Not Being Supervised Involving employees will help minimize oversights, ensure a quality analysis, and get workers to "buy in" to the solutions they've helped to develop in their procedures. Ergo, they own the protocols and the responsibilities. Thank You QUESTIONS?