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ESH Manual Page: 6000: Job Hazards and Work Action Planning
1.0 POLICY

It is the policy of the Sanford Underground Research Facility (hereafter referred to as SURF) to subject all work to work planning and hazard analysis (HA).  Depending on the hazards and associated risks involved, the HA process may be a verbal discussion, a documented pre-job briefing (5-Point Safety Card or Tool Box Talk), or it may be formal with a written Job Hazard Analysis (JHA) and pre-job briefing.  Based on risk, employees and supervisors are to use their professional judgment in determining the need for a documented HA or a formal JHA (Job Hazard Analysis form).  The Formal JHA Guideline can be referenced to assist in making that determination.

Careful planning of work assures that the work is performed efficiently and safely.  Hazard Analysis (HA) is a critical part of work planning. Work planning ensures the scope of work is understood, appropriate materials are available, all hazards have been identified and mitigative efforts established and all affected employees understand what is expected of them.

2.0 SCOPE

This policy applies to all SURF personnel, including experimenters and project sponsors, temporary employees and contract/subcontractor/term employees. Specific procedures for service and construction contractors may be found in the SURF Construction EHS Manual.

3.0 RESPONSIBILITIES

3.1. Lab Director ? The Lab Director is ultimately responsible for the implementation of this policy and procedure and must provide sufficient resources to ensure its success at the Sanford Underground Research Facility. 

3.2. Department Directors ? It is the responsibility of the department directors for ensuring that this policy is implemented within their respective departments.   

3.3. Supervisors - The supervisors are responsible for: 

  • Ensuring that employees are trained to work in the area of the job and trained in the tools/equipment to be used in the completion of the job. 
  • Planning their work and identifying those activities that require an informal HA, documented HA, or a formal JHA (Job Hazard Analysis Form).  The Formal JHA Guideline can provide direction in determining when a formal JHA is required. 
  • If allowed by the work environment, conducting a job walk-down in those instances where documented HAs and formal JHAs are required.
  • Ensuring that employees are trained in the process of developing documented HAs and formal JHAs.
  • Approving and obtaining approval from EHS on formal JHAs completed by employees in their group.
  • Conducting a pre-job briefing with employees before work begins where formal JHAs apply.
  • Ensuring documented HAs and formal JHAs are signed by the affected employees.
  • Ensuring that the work is performed in accordance with the documented HAs and formal JHAs. 
  • Ensuring that documented HAs and formal JHAs are developed and reviewed by the employee before work begins. 
  • Retaining copies of documented HAs (5-Point Safety Cards, Shift Reports, Tool Box Talks) for at least one year.
  • After appropriate application of the contents of this policy, remaining questions concerning the type of HA to use for a particular project or activity should be referred to EHS.
  • Seeking advice from the EHS Department, as appropriate.

3.4. Employees - The employees are responsible for: 

  • Planning their work and identifying those activities that require an informal HA, documented HA, or a formal JHA (Job Hazard Analysis Form).  The Formal JHA Guideline can provide direction in determining when a formal JHA is required.
  • Participating in developing formal JHAs.
  • Ensuring documented HAs and formal JHAs are signed by the affected employees. 
  • Participating in a pre-job briefing with employees who share in the work performance before work begins.
  • Ensuring that the work is performed in accordance with the documented HAs and formal JHAs. 
  • Not performing work for which adequate training was not received.
  • After appropriate application of the contents of this policy, remaining questions concerning the type of HA to use for a particular project or activity should be referred to your supervisor. 
  • Seeking advice from the EHS Department, as appropriate.

3.5. Project Managers 

  • Assure contractors comply with their responsibilities regarding JHAs.
  • Assure no project work commences before pertaining JHAs are completed.
  • Retain copies of project JHA?s in project files.

3.6. Contractors 

  • Submit a Job Hazard Analysis (JHA) for their work. The JHA shall be approved by the SURF Project Manager before work commences. 
  • Submit a JHA and work procedures to the SURF Project Manager for review prior to the start of work.
  • Develop, implement, and/or adhere to Job Hazard Analysis (JHA) and other pre-job planning documents required by the Construction EHS Manual. 
  • Maintain two copies of the SURF approved JHA. The first copy to be maintained with the project files; the second copy shall be posted on the jobsite/project in a conspicuous location.

3.7. Environment, Health and Safety (EHS) Department  

  • Review and provide approval on formal JHAs. 
  • Provide training support for recognizing and analyzing hazards, preparing Work Action plans, and formal JHAs. 
  • Provide assistance in preparing and reviewing documented HAs and formal JHAs upon request.
  • Archive SURF formal JHAs and make them available for reference. 

It is the intent of this policy that the development, review, and use of the hazard assessment process (HAs, JHAs) rests primarily with the Project Manager or Supervisor. The EHS Department shares, to a lesser extent, some of the same responsibilities. During the development of HAs and JHAs, the Project Manager or Supervisor will take the lead role. Affected employees are expected to contribute to this process. EHS approval and the implied responsibility of such in no way diminishes or reduces the responsibilities described above.   

4.0 DEFINITIONS 

Hazard - Condition, event, or circumstance that could lead to or contribute to an unplanned or undesirable event.  A hazard is the potential for harm. In practical terms, a hazard often is associated with a condition or activity that, if left uncontrolled, can result in an injury or illness.

Hazard Analysis ? A hazard analysis is the first step in a process used to assess risk. The result of a hazard analysis is the identification of different type of hazards and the mitigations to minimize the hazards.  A hazard analysis then becomes a tool to aid in planning work.

High Risk Determination -    Risk is the possibility that something bad or unpleasant (such as an injury or a loss) will happen.  An acceptable risk is a risk that is understood and tolerated usually because the cost or difficulty of implementing an effective countermeasure for the associated vulnerability exceeds the expectation of loss.  A risk assessment is the determination of value of risk related to a concrete situation and a recognized hazard and generally considers the 1) probability or likelihood and 2) the consequence or severity of an unwanted event caused by the hazard.  If the probability, or the consequence, or the combination of probability/consequence is high, it is considered a high risk.  Refer to the Formal JHA Guideline.

Informal, Documented, and Formal - Verbal HAs are informal. A 5-Point Safety Card, a Tool Box Talk Form, a shift report, or other can be used to document an HA.  A formal HA is written on a JHA Form and is termed a Job Hazard Analysis (JHA).

Job Hazard Analysis (JHA) - A job hazard analysis is a technique that focuses on job tasks or steps as a way to identify hazards before they occur. It focuses on the relationship between the worker, the task, the tools, and the work environment. Ideally, after uncontrolled hazards are identified, steps will be taken to eliminate or reduce them to an acceptable risk level.  At SURF, the formal JHA is a form designed to consider the hazards common to many jobs (sections with checklists), and with a table to list 1) work steps (and sub-steps), 2) hazards, and 3) mitigations (Precautions / Procedures / Controls), together with pages to provide authorization sign-off and crew member acknowledgement of pre-job briefing.

Job Site Walk Down ? A visit to the job site for the purpose of identifying work control and EH&S issues that must be addressed prior to beginning work.

Pre-job Briefing ? Dialogue between supervisor and those involved in the work to ensure that all understand the scope of what is to be accomplished, procedural steps, roles and responsibilities, and hazards and controls.  For a formal JHA, this dialog may result in modifications that may then be incorporated.

Post-job Review ? A review of the work that has been performed to identify any improvements or experiences that should be recorded for future job planning efforts.
Work Planning ? Systematic process for determining methods for completing the assigned task safely and efficiently. The process includes defining the work to be performed and the methods for performing the work, identifying the hazards and their controls, hazard analysis (possibly a written one) and a pre-job briefing.

5.0 REQUIREMENTS FOR DOCUMENTED HAs

The level of risk and/or job complexity determines the level of documentation.  Verbal HAs are not documented.  5-Point Safety Cards provide documentation for consideration of hazards at the time of or just prior to work performance.  Shift reports can be used to record the recognition and analysis of hazards encountered to be passed on to benefit the next shift.  Tool Box Talks are used to document the more involved work planning and HA considered by a crew prior to work performance.  As risk and job complexity rise to a higher level, supervisors and employees will identify those activities that require a formal JHA.


Work Action Plan Process
The work action plan process consists of six elements:  1) job site walk down, 2) hazard analysis, 3) pre-job briefing, 4) performance of the work, 5) post-job review, and 6)  record retention. 
These elements are considered in detail below.  Sections 5.1 thru 5.5 are written to pertain to the formal JHA though those elements apply by degrees to the documented HAs. 

Work Action Plan Process

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5.1. Job Site Walk Down 

In those instances where the job site can be safely accessed, an inspection of the job site shall be conducted. Ideally this inspection should be conducted prior to developing the hazard analysis in order to assure all job site hazards and work control issues are identified and addressed. 
Otherwise, the job site walk down shall be conducted by the workers performing the work prior to beginning work, as part of the pre-job briefing.

5.2. Formal Job Hazard Analysis

A. The supervisor and employees develop the hazard analysis. The results of the job site walk down shall be incorporated into the hazard analysis.

B. The supervisor and employee(s) will determine if a formal JHA is required.  The Formal JHA Guideline can be referenced to assist in making that determination.  If it is determined a  formal JHA is required, EHS provides guidance in completing the JHA, then reviews and approves the completed JHA.  

C. If a formal JHA already exists, it must be reviewed and revised as appropriate for actual job site conditions and to incorporate previous work experiences and lessons learned.

D. The preparation of the formal JHA will include or involve the following aspects.

  • Detailed scope of work, including how the person/team intends to complete the work;
  • Walk down or inspection of the work area and equipment while planning the work;
  • Identification of materials to be used;
  • Identification of hazards associated with each sequential step in the work process;
  • Identification of work requirements, controls, procedures, instructions and personal protective equipment necessary to perform the work safely (including permits); and
  • Involvement of the workers and EHS in the preparation of the work plan.

 The documents Common Site Hazards and Common Underground Hazards list the  causes/effects and the common controls for a variety of hazards.  These documents may  be referenced to provide useful information to aid in writing a formal JHA.  

E. The level of detail in the HA should be relative to the complexity of the work and the hazards involved with the activity. For instance, cleaning and weighing self rescuers on an open worktable in the administration building would require less detail than the same activity in the underground mine while standing on a ladder. The JHA Form shall be used to document the formal JHA.

F. The supervisor will review the formal JHA for completeness and thoroughness and determine whether the hazards for the work activity have been adequately identified and controlled. Permits, Material Safety Data Sheets, etc., shall be attached to the formal JHA (to the extent possible) to consolidate the work package. The supervisor will then approve the formal JHA and forward it to EHS for review and approval.

G. Exceptions - A formal JHA is not required if the work activity is performed under a  Standard Operating Procedure (SOP) as SOPs incorporate detailed hazard analyses; or if the work activity involves the use of a permit where all the hazards and their mitigation requirements are identified and addressed, a formal JHA is not required.  Examples of this could include lockout/tagout procedures, radiation work permits, confined space

permits, excavation permits, and electrical hazard analysis/work permits.  In cases of work performed subject to an SOP or Permit, job planning and some form of pre-job briefing are required and may be documented on a 5-Point Safety Card, Tool Box Talk Form, shift report, etc.  

H. A procedure performed to try out a revision to an SOP will have a documented HA or formal JHA done and a pre-job briefing with the supervisor held before it is performed.

I. ?Generic? formal JHAs may be used. Generic formal JHAs are those that would be routinely used for a specific activity (e.g., asbestos removal). They shall be reviewed by employees and updated as necessary prior to each specific activity to ensure that all hazards of the work and the job site are addressed. In all cases, some form of pre-job briefing at the job site is required.

J. Emergency repair activities may be required during off-shift hours. If an SOP or formal JHA for the work to be performed exists, it shall be reviewed and updated to incorporate field conditions.  If a formal JHA needs to be written, this can be done in the field. Verbal approval from the supervisor is to be sought in lieu of a signature.  In all cases, a pre-job briefing is required. Under no circumstances shall an emergency serve as reason for ignoring established safe work practices.

K. Urgent situations requiring immediate deviations from or not covered by an SOP or JHA still require a hazard analysis before work is performed, though that analysis may be verbal; the principle is to keep all participants aware of the situation and to provide a reasoned collaborative approach. When the situation is no longer urgent or has stabilized, the hazard analysis and the actions taken to stabilize the situation shall be documented.


5.3. Pre-Job Briefing

A. The supervisor and employees performing the job shall discuss the work action plan to ensure everyone is aware of how the job will proceed. For low-risk tasks the briefing may be a quick exchange between the supervisor and employee(s). For more complex and higher-risk tasks, a more detailed and formal pre-job briefing is required. The supervisor and employee(s) shall assure the briefing is adequate for the circumstances and hazards.  The Tool Box Talk Form or JHA Form can be used to conduct this briefing. The pre-job briefing shall consist of the following:

  • Summarizing the critical steps and materials:  This would include steps where the success depends solely on the individual work, and that serious injury or significant loss of property could result from not following the prescribed safe work procedures.
  • Anticipating what can go wrong or where errors can occur:  This would include distractions, confusing procedures, inexperience and assumptions. Examining what errors have occurred with the activity in the past may be helpful. 
  • Foreseeing consequences:  What is the worst that could happen? Work plans should incorporate defenses to prevent the incident.
  • Review operating experience:  How has the task gone in the past? Work plans should incorporate defenses to prevent a repeat incident. EHS is a good informational source in this area.
  • Review of Equipment:  Review of PPE, equipment necessary for the job, engineering controls, and equipment controls.

B. All who review a formal JHA will document the review by signing the form.  Only then will the supervisor allow the work to begin.  Personnel who have not reviewed the formal JHA and signed the form will not be allowed to participate in the work activity.


5.4. Performance of Work

A. The formal JHA shall be posted in the work area or shall be readily available to those performing the work. 

B. The work activity must be completed in accordance with the formal JHA.  If there is a change in the work scope, if work conditions change or if new hazards are identified, or the controls prove inadequate or ineffective, the work activity shall cease immediately. The formal JHA shall be reviewed by the employees and supervisor, revised as necessary, and approval obtained before the work is continued.

5.5. Post Job Review

After the activity has been completed, the formal JHA should be updated to include improvements that were identified while performing the work. This will help assure better planning and a safer work experience the next time the job has to be performed.

5.6. HA Record Retention

The supervisor will keep copies of the 5-Point Safety Cards, Tool Box Talks, and shift reports. Project Managers will keep a copy of contractor JHAs with project files.  EHS will SURF formal JHAs and make them available for reference. These will be made available to anyone who requests them, for the purposes of providing oversight, trending, and/or lessons learned.

In general, a written action work plan/hazard analysis should be kept on file for at least one year. 

6.0 REFERENCE AND RELATED DOCUMENTS

6.1. References

  • Formal JHA Guideline
  • Construction EHS Manual
  • JHA Form
  • Common Site Hazards
  • Common Underground Hazards
  • 5-Point Safety Card
  • Tool Box Talk Form