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Who has to complete a hazard assessment?

- February 23, 2015 by Guest Bloggers (View all posts by Guest)

As a prior OSHA enforcement officer I have conducted many inspections of jobsites and shops for various industries to view their operations.  Prior to commencing, I would usually ask two Personal Protective Equipment (PPE) related questions:

  • What PPE must I wear to conduct this walkthrough?
  • How did your company ascertain that the PPE is required?

I have received various correct answers to the first question, but the second question is actually far more important.  Documenting how and why certain PPE was selected shows that the exposures have been identified and assessed. Usually this question confuses the company representative because most thought the selection of PPE was common sense.  A typical response was something like, “we are a cutting operation, so flying particles are the hazard, and eye protection must be worn.”  My next request was always to see documentation of the hazard assessment.

There is a specific standard, 29 CFR 1910.132(d)(2), that applies to general industry that requires employers to certify that a hazard assessment was performed and the certification must include the date the evaluation was performed and the name of the person who completed it.  When filling out a hazard assessment, Safety Data Sheets (SDS) are a great resource in determining whether PPE is required or recommended when dealing with chemicals.

While OSHA regulations only specify a certified hazard assessment be completed for general industry, it is typical in the construction industry for subcontractors to be required to provide a hazard assessment, sometimes referred to as a Jobsite Safety Analysis (JSA), prior to any jobsite operations.  This practice promotes the recognition of safety hazards and encourages workers to identify procedures to address these hazards.  The general duty clause requires employers to provide a workplace free of recognized hazards.  The first step in making sure that, as an employer, you meet this requirement is to complete a hazard assessment.