A Job Hazard Analysis (JHA) — also referred to as a Job Safety Analysis (JSA) — is a structured process for identifying the hazards associated with each task within a job, assessing the risk those hazards present, and defining the preventative controls required to minimize or eliminate that risk. A complete JHA typically incorporates a Risk Assessment: a systematic evaluation of the severity and likelihood of each identified hazard, drawing on the safety official’s experience, applicable OSHA standards, and any governing regulatory guidelines. As organizations continue to refine their safety management systems in response to lessons learned from the COVID-19 pandemic, several key principles have emerged that strengthen how JHAs are conducted for any significant health or biological hazard — including infectious disease risks that remain relevant in many workplace settings today. Here are the core considerations every EHS manager should apply:
Assess the Physical Aspects of the Job
The first step in any JHA involving infectious disease or biological hazard exposure risk is a critical review of the physical aspects of the job. Which tasks actually require in-person physical presence? Which could be completed remotely without compromising output or quality? The hierarchy of controls — the foundational framework endorsed by both OSHA and NIOSH — places elimination and substitution at the top: if the physical presence of workers in a potentially exposed environment can be removed entirely, that is always the most effective control. During the COVID-19 pandemic, many organizations discovered for the first time that administrative tasks they had assumed required physical co-location could in fact be conducted remotely, eliminating exposure risk entirely. This lesson should now be permanently embedded in how JHAs are structured for any task with biological or infectious disease dimensions.
Minimize Outside Exposure
It is natural to focus JHA efforts on the most frequently performed, highest-visibility tasks. However, infectious and biological hazards do not discriminate between routine and non-routine work. Exposure can occur in a single instance — from a maintenance contractor, a visiting auditor, a cleaning crew, or a delivery personnel interaction that falls entirely outside your core operational risk profile. A rigorous JHA must explicitly address non-routine jobs and the outside parties brought in to perform them: contractors, repair technicians, inspectors, and any other visitors who interact with your workforce or facility. OSHA’s guidance on multi-employer worksites and General Duty Clause obligations reinforces that controlling employers must manage exposure risks for all personnel on site, not only direct employees. Mapping every pathway of potential outside exposure is essential to a complete risk picture.
Re-evaluate your Risk Assessment
Traditional Risk Assessments rely heavily on historical incident data and established precedent to calibrate risk probability. When a novel or unprecedented hazard emerges — as COVID-19 demonstrated — that historical data may be absent, unreliable, or simply not applicable to the new threat. EHS teams must be prepared to set aside precedent-based assumptions and approach the Risk Assessment with fresh eyes. This means consulting the most current guidance from authoritative sources (OSHA, CDC, WHO, and relevant industry bodies), engaging with workers who have direct exposure to the hazard, and applying the precautionary principle where data is incomplete. Re-evaluating your assessment processes is not a sign of weakness in your safety management system — it is exactly what a mature, adaptive system is designed to do. ISO 45001 Clause 6.1 explicitly requires organizations to determine risks and opportunities and plan actions to address them on an ongoing basis, not as a one-time exercise.
Importantly, re-evaluation must also consider which specific worker populations face elevated risk. In the context of infectious disease, older workers, those with underlying health conditions, and immunocompromised individuals may require additional protective controls beyond those applied to the general workforce. Identifying and protecting your highest-risk employees is both an ethical and legal obligation.
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Create Open Communication Channels
The behavioral and psychological dimensions of hazard exposure are an often-underestimated component of a JHA’s effectiveness. Workers who are anxious, uncertain, or feeling unheard about a workplace health risk are more likely to make poor safety decisions, underreport symptoms, avoid raising concerns, or disengage from the safety program altogether. Open, transparent communication with workers — particularly during periods of elevated uncertainty — is not a “soft” HR concern; it is a direct safety control. EHS managers should establish clear, accessible channels for workers to ask questions, raise concerns, and receive timely, accurate information about the hazards they face and the controls in place to protect them. Non-punitive reporting cultures, where workers feel safe surfacing safety concerns without fear of consequences, have been consistently linked to better hazard identification and lower incident rates. OSHA’s Section 11(c) anti-retaliation provisions and ISO 45001 Clause 5.4 both reflect the regulatory and standards-based recognition of this principle.
For more on how to assess your preparedness for COVID-19 and future pandemics, check out our COVID-19 Crisis/Pandemic Preparedness Checklist for Business here.
For more on how to manage your business during the COVID-19 (and other) pandemic(s), check out our COVID-19 Crisis/Pandemic Outbreak Management and Response Checklist here.
Frequently Asked Questions (FAQs)
What is a Job Hazard Analysis (JHA) and when should one be conducted?
A Job Hazard Analysis (JHA) — also called a Job Safety Analysis (JSA) — is a systematic process for breaking a job into its component tasks, identifying the hazards associated with each task, and defining the controls required to eliminate or minimize those hazards. OSHA recommends conducting JHAs for jobs where injuries or near misses have occurred, jobs with the potential to cause severe or disabling injuries, new or changed jobs, jobs complex enough to require written instructions, and jobs performed infrequently where workers may be less familiar with the hazards involved. JHAs should be reviewed and updated whenever job conditions change, incidents occur, or new hazard information becomes available.
How does the hierarchy of controls apply to a Job Hazard Analysis?
The hierarchy of controls — elimination, substitution, engineering controls, administrative controls, and PPE — provides the framework for selecting the most effective hazard controls identified through a JHA. OSHA and NIOSH both endorse this hierarchy, as does ISO 45001 Clause 8.1.2. When completing a JHA, each identified hazard should be evaluated against this hierarchy in order: can the hazard be eliminated entirely? Can it be substituted with a less hazardous alternative? Can engineering controls reduce exposure? Only when higher-order controls are not feasible should administrative controls and PPE be relied upon as primary protections. A common JHA error is defaulting directly to PPE without adequately exploring engineering and administrative controls.
How can safety management software improve the JHA process?
Digital safety management platforms like Certainty Software streamline the JHA process by providing standardized digital templates that ensure consistent hazard identification across teams and sites, enabling real-time submission and review of completed JHAs, linking identified hazards directly to corrective action workflows, and maintaining a searchable, auditable record of all completed analyses. This eliminates the version-control problems and visibility gaps associated with paper-based JHA systems, and ensures that the critical safety intelligence generated during JHAs is captured, acted upon, and accessible to EHS managers and auditors when needed.
