Certainty Blog

How COVID-19 changed how to conduct a Job Hazard Analysis

A Job Hazard Analysis (JHA) is a structured process for identifying the hazards associated with each task within a job. It also goes by the name Job Safety Analysis (JSA). Specifically, it involves 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. This is a systematic evaluation of the severity and likelihood of each identified hazard. It draws on the safety official’s experience, applicable OSHA standards, and any governing regulatory guidelines. As organizations continue to refine their safety management systems from lessons learned during the COVID-19 pandemic, several key principles have emerged. In particular, these principles strengthen how teams conduct JHAs for any significant health or biological hazard. They also address infectious disease risks that remain relevant in many workplace settings today. Here are the core considerations every EHS manager should apply:

Job Hazard Analysis | Certainty

Assess the Physical Aspects of the Job

The first step in any Job Hazard Analysis involving infectious disease or biological hazard exposure risk starts with a critical review of the physical aspects of the job. Which tasks actually require in-person physical presence? Which tasks could workers complete remotely without compromising output or quality? The hierarchy of controls provides the foundational framework endorsed by both OSHA and NIOSH. Most importantly, it places elimination and substitution at the top. In other words, if you can remove the physical presence of workers from a potentially exposed environment entirely, that always delivers the most effective control.

Furthermore, the COVID-19 pandemic revealed something significant. Many organizations discovered for the first time that administrative tasks they assumed required physical co-location could actually happen remotely. This eliminated exposure risk entirely. As a result, EHS managers should now permanently embed this lesson into how they structure JHAs. It applies to any task with biological or infectious disease dimensions.

Minimize Outside Exposure

Teams naturally focus their Job Hazard Analysis 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. For example, a maintenance contractor, a visiting auditor, a cleaning crew, or delivery personnel can introduce risks. These interactions fall entirely outside your core operational risk profile.

Therefore, a rigorous JHA must explicitly address non-routine jobs and the outside parties brought in to perform them. This includes contractors, repair technicians, inspectors, and any other visitors who interact with your workforce or facility. Moreover, OSHA’s guidance on multi-employer worksites and General Duty Clause obligations reinforces this need. Controlling employers must manage exposure risks for all personnel on site, not only direct employees. Consequently, mapping every pathway of potential outside exposure becomes 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. However, when a novel or unprecedented hazard emerges, that historical data may not apply. COVID-19 demonstrated this clearly. The data may be absent, unreliable, or simply not applicable to the new threat. For this reason, EHS teams must prepare to set aside precedent-based assumptions. They should approach the Risk Assessment with fresh eyes.

Specifically, this means consulting the most current guidance from authoritative sources like OSHA, CDC, WHO, and relevant industry bodies. It also involves engaging with workers who have direct exposure to the hazard. Additionally, teams should apply the precautionary principle where data remains incomplete. In fact, re-evaluating your assessment processes does not signal weakness in your safety management system. It reflects exactly what a mature, adaptive system does. Furthermore, ISO 45001 Clause 6.1 explicitly requires organizations to determine risks and opportunities on an ongoing basis. This should not happen as a one-time exercise.

Notably, 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. These controls go beyond those applied to the general workforce. Ultimately, identifying and protecting your highest-risk employees remains both an ethical and legal obligation.

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Create Open Communication Channels

The behavioral and psychological dimensions of hazard exposure often receive too little attention in a Job Hazard Analysis. However, they directly affect its effectiveness. Workers who feel anxious, uncertain, or unheard about a workplace health risk make poorer safety decisions. They may underreport symptoms, avoid raising concerns, or disengage from the safety program altogether. For this reason, open, transparent communication with workers is not a “soft” HR concern. It functions as a direct safety control.

Therefore, EHS managers should establish clear, accessible channels for workers to ask questions and raise concerns. Workers need timely, accurate information about the hazards they face and the controls in place to protect them. Moreover, non-punitive reporting cultures consistently link to better hazard identification and lower incident rates. Workers who feel safe surfacing safety concerns without fear of consequences contribute more actively. Additionally, OSHA’s Section 11(c) anti-retaliation provisions and ISO 45001 Clause 5.4 both reflect this principle. These regulations and standards recognize that open communication drives better safety outcomes.

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.

For more information, see OSHA job hazard analysis guidance.

For more information, see NIOSH hierarchy of controls.

Frequently Asked Questions (FAQs)

What is a Job Hazard Analysis (JHA) and when should one be conducted?

A Job Hazard Analysis (JHA) is a systematic process for breaking a job into its component tasks. It also goes by the name Job Safety Analysis (JSA). The process identifies hazards associated with each task and defines the controls required to eliminate or minimize those hazards. OSHA recommends conducting JHAs for jobs where injuries or near misses have occurred. Additionally, they suggest JHAs for jobs with the potential to cause severe or disabling injuries. New or changed jobs also warrant analysis. Similarly, jobs complex enough to require written instructions need JHAs. In particular, jobs performed infrequently deserve attention because workers may be less familiar with the hazards involved. Teams should review and update JHAs 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 provides the framework for selecting the most effective hazard controls identified through a JHA. It includes elimination, substitution, engineering controls, administrative controls, and PPE. Both OSHA and NIOSH endorse this hierarchy, as does ISO 45001 Clause 8.1.2. When completing a Job Hazard Analysis, teams should evaluate each identified hazard against this hierarchy in order. Specifically, can the hazard be eliminated entirely? Can a less hazardous alternative substitute for it? Can engineering controls reduce exposure? Only when higher-order controls prove unfeasible should teams rely on administrative controls and PPE as primary protections. Notably, a common JHA error involves 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 Job Hazard Analysis process in several important ways. They provide standardized digital templates that ensure consistent hazard identification across teams and sites. Moreover, they enable real-time submission and review of completed JHAs. The platforms also link identified hazards directly to corrective action workflows. Additionally, they maintain a searchable, auditable record of all completed analyses. As a result, organizations eliminate the version-control problems and visibility gaps associated with paper-based JHA systems. Most importantly, the critical safety intelligence generated during JHAs stays captured, acted upon, and accessible to EHS managers and auditors when needed.