Where the JHA sits in Part 1926
Construction has its own rulebook, 29 CFR Part 1926, and its general provisions in Subpart C set the frame for everything a JHA does. The training duty is the one to pin to the wall:
“The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.”
Read that against a JHA's three columns. The steps and hazards columns are the “recognition of unsafe conditions”. The controls column, with the paragraph that requires each control, is “the regulations applicable to his work environment”. Train the crew from the JHA and you have covered both halves of the duty for that task.
Two more Subpart C duties shape how the JHA is used:
- The employer must initiate and maintain the programs needed to comply with Part 1926, and those programs must provide for frequent and regular inspections of the job site, materials and equipment by competent persons the employer designates. [OSHA]
- Only employees qualified by training or experience may operate equipment and machinery. [OSHA] A JHA for an equipment task should say who is qualified to do each step.
Training duties in Part 1926 are owed to each employee separately: each failure to train an employee in the manner a standard requires may be a separate violation. [OSHA] That is a good reason to keep a signed roster with the JHA.
The Focus Four and the subparts behind them
OSHA's construction outreach training is built around four hazard groups it calls the Focus Four: falls, caught-in or -between, struck-by, and electrocution. [OSHA] A construction JHA that checks each step against those four, and against the subpart that regulates each, catches most of what matters. Here is where each lives:
| Focus Four hazard | Where the rules are | Core duties |
|---|---|---|
| Falls | Subpart M (fall protection), Subpart L (scaffolds), Subpart X (ladders) | Guardrails, safety nets or personal fall arrest at 6 feet or more above a lower level on unprotected sides and edges [OSHA]; fall protection on scaffolds above 10 feet [OSHA]; ladder rails extend 3 feet above the landing [OSHA]; a fall protection training program for each exposed employee [OSHA]. |
| Struck-by | Subpart M 1926.501(c), Subpart P 1926.651(e), Subpart L 1926.451(h) | Hard hats plus toeboards, screens, canopies or barricades where workers are exposed to falling objects [OSHA]; nobody under loads handled by digging or lifting equipment [OSHA]; falling object protection on scaffolds [OSHA]. |
| Caught-in or -between | Subpart P (excavations) 1926.652 | A protective system against cave-ins for every employee in an excavation, with the two exceptions the rule names [OSHA]; nobody in a shield while it is being installed, removed or moved vertically [OSHA]. |
| Electrocution | Subpart K 1926.416 and 1926.417 | Find energized circuits before work begins and warn the crew [OSHA]; no work within reach of a circuit unless it is deenergized and grounded or effectively guarded [OSHA]; deenergized circuits rendered inoperative and tagged at every point they could be energized [OSHA]. |
The 6-foot trigger for falls is the number people remember, so here is the exact rule for unprotected sides and edges:
“Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.”
Watch the scope. The 6-foot figure is Subpart M, for construction. Scaffolds have their own 10-foot trigger in Subpart L. [OSHA] Excavations have a 5-foot depth below which a competent person may find a protective system unnecessary, [OSHA] and trenches 4 feet or deeper need a ladder or other exit within 25 feet of lateral travel. [OSHA] A construction JHA should quote the number that belongs to the step, never a number borrowed from a different rule.
Who writes it
Part 1926 does not say who writes a JHA, but it does define the person who should be at the center of it:
“Competent person means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.”
The subparts that call for a competent person (scaffold erection and inspection, daily excavation inspection, ladder inspection, fall protection training) are the ones where that person should lead the JHA for the task. [OSHA] [OSHA] [OSHA] [OSHA]OSHA 3071 adds the other half of the team: involve the employees who do the job, because they know it and will spot what the office misses, and include them from listing the steps to choosing the controls. [OSHA]
PPE goes in the controls column last, and the employer provides it. In construction, protective equipment must be provided, used and maintained wherever hazards of the process or environment make it necessary, [OSHA] and the employer pays for it with the exceptions the rule lists, such as ordinary work boots and everyday clothing. [OSHA]
A construction worked flow: sheathing a residential roof
Here is how the pieces fit on one real task: a framing crew decking a pitched roof on a house. The steps are a typical sequence; the hazards are the Focus Four as they show up in this job; each control names the paragraph it comes from.
| # | Job step | Hazard | Control (paragraph) |
|---|---|---|---|
| 1 | Set the extension ladder to the eave and climb | Ladder slides out or tips; fall while stepping onto the roof | Set the base so the horizontal distance to the top support is about one quarter of the working length (1926.1053(b)(5)(i)) [OSHA]. Extend the side rails at least 3 feet above the landing, or secure the top and provide a grab device (1926.1053(b)(1)) [OSHA]. Keep at least one hand on the ladder when climbing (1926.1053(b)(21)) [OSHA] and carry nothing that could throw you off balance (1926.1053(b)(22)) [OSHA]. A competent person inspects ladders periodically and after anything that could affect safe use (1926.1053(b)(15)) [OSHA]. |
| 2 | Check the trusses and any existing deck before loading them | Surface will not hold the crew and the material | Determine that the walking and working surface has the strength and structural integrity to support employees safely; let them work on it only when it does (1926.501(a)(2)) [OSHA]. |
| 3 | Hoist and stage sheathing on the roof | Sheets or tools slide off the edge onto people below | Each exposed employee wears a hard hat, and the employer uses one of the listed measures: toeboards, screens or guardrails; a canopy with materials kept back from the edge; or a barricaded zone below that nobody enters (1926.501(c), (c)(1) to (c)(3)) [OSHA]. |
| 4 | Fasten sheathing, working toward the edges | Fall from the roof edge or through an opening | Residential construction 6 feet or more above a lower level: guardrails, safety nets or personal fall arrest, unless another paragraph of 1926.501(b) provides an alternative (1926.501(b)(13)) [OSHA]. A fall protection plan under 1926.502(k) is allowed only when the employer can show those systems are infeasible or create a greater hazard, and the employer carries that burden (1926.501(b)(13), note) [OSHA]. Cover or guard holes, including skylight openings, more than 6 feet above a lower level (1926.501(b)(4)(i)) [OSHA]. |
| 5 | Work near the service drop or other overhead lines | Contact with an energized line by a person, sheet or tool | Before work begins, find out by inquiry, observation or instruments whether any energized circuit is within reach of the work, post warning signs, and tell the crew the location, hazards and protective measures (1926.416(a)(3)) [OSHA]. No one works close enough to contact a circuit unless it is deenergized and grounded or effectively guarded (1926.416(a)(1)) [OSHA]. |
| 6 | Record the training and the inspection | Nothing shows the crew was trained or the site was checked | Keep a written certification of fall protection training with each employee's name, the training dates and the trainer's or employer's signature (1926.503(b)(1)) [OSHA]. Frequent and regular inspections of the job site, materials and equipment by a designated competent person are part of the required program (1926.20(b)(2)) [OSHA]. |
Two things to notice. The fall protection row does not say “use a harness”; it lists the three systems the rule allows and keeps the fall protection plan as the exception it is, with the burden on the employer. [OSHA] And the last row is paperwork, on purpose: the fall protection training record is a separate written certification the rule requires, so the JHA tells the foreman to make it. [OSHA]
Making the JHA part of the day
- Phase changes. A construction job changes every few days. OSHA 3071 lists jobs that are new or have changed processes among the first to analyze. [OSHA] Write a JHA at each new phase, not once per project.
- Morning review. Read the steps and controls with the crew before the task, and get the roster signed. The eTool version of this says everyone doing the job should be present when it is written and the supervisor should sign it before the task starts. [OSHA]
- Inspections. The competent person's frequent and regular inspections are a program requirement [OSHA]; the JHA tells them what to look at on this task.
- After an injury or close call. Review the JHA, change the procedure if needed, and retrain everyone affected. [OSHA]