What is a JSA?
A JSA is a short written study of one job. You watch the job, write down the steps in order, ask what could hurt someone at each step, and decide what will stop it. OSHA's definition, written for the JHA name, fits a JSA word for word:
“A job hazard analysis is a technique that focuses on job tasks 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.”
The federal offshore rule that uses the JSA name defines it the same way, from the risk side:
“The JSA is a technique used to identify risks to personnel associated with their job activities.”
Whatever you call it, the finished document has three parts for every step of the job. The offshore rule lists them: the steps of the job, the existing or potential hazards of each step, and the actions or procedures that will eliminate or reduce those hazards. [BSEE (eCFR)] OSHA's drilling eTool uses the same three columns (basic job steps, potential hazards, recommended safe job procedures). [OSHA]
What OSHA actually calls it
OSHA's booklet on the subject is titled Job Hazard Analysis (OSHA 3071), and it says “job hazard analysis” throughout. [OSHA] It uses the other name exactly once, in the section on what to know before you start, and treats it as the same thing:
“When conducting your own job safety analysis, be sure to consult the Occupational Safety and Health Administration standards for your industry.”
OSHA's safety and health program guidance says it plainly. In its list of information to collect about workplace hazards, one item reads:
“Results of job hazard analyses, also known as job safety analyses.”
And OSHA's eTool for oil and gas drilling, where the JSA name is the everyday term, opens with:
“Today, many companies within the oil and gas industry use the Job Safety Analysis Process (also referred to as a JSA, Job Hazard Analysis, or JHA).”
So the agency that writes the rules treats JSA and JHA as one technique. Anyone who tells you one is “task level” and the other is “job level”, or that one looks at hazards and the other at consequences, is describing their own company's form, not a distinction OSHA makes.
JSA vs JHA side by side
| JSA | JHA | |
|---|---|---|
| Full name | Job safety analysis | Job hazard analysis |
| Who uses the name | The offshore oil and gas rule, 30 CFR 250.1911, and OSHA's oil and gas drilling eTool. [BSEE (eCFR)] [OSHA] | OSHA's own booklet (OSHA 3071) and OSHA's safety and health program guidance. [OSHA] [OSHA] |
| What goes on the form | Steps, the hazards of each step, and the actions or procedures that eliminate or reduce them. [BSEE (eCFR)] | Job steps, a hazard description and consequence for each, and hazard controls. [OSHA] |
| Who takes part | Offshore: the immediate supervisor conducts and signs, every participant signs, the person in charge approves. [BSEE (eCFR)] Onshore drilling eTool: everyone doing the job is present when it is written; the supervisor reviews, approves and signs. [OSHA] | Involve the employees who do the job; review the steps with them; include them in every phase. [OSHA] No signature rule. |
| Is it required by name? | Yes, offshore on the Outer Continental Shelf, as part of a SEMS program. [BSEE (eCFR)] | No OSHA standard requires a document called a JHA; OSHA 3071 is guidance. [OSHA] |
Where each name is used
JSA: offshore oil and gas, by law
The clearest use of “JSA” in federal law is the offshore safety rule run by the Bureau of Safety and Environmental Enforcement (BSEE). Its Safety and Environmental Management System (SEMS), and the hazards analysis section of that rule says:
“You must ensure that a hazards analysis (facility level) and a JSA (operations/task level) are developed and implemented for all of your facilities and activities identified or discussed in your SEMS.”
That rule is also where the strictest sign-off lives. The crew's immediate supervisor must conduct and sign the JSA and make sure every crew member understands it and signs it, and the person in charge of the facility must approve and sign every JSA before the job starts. [BSEE (eCFR)] For a recurring job whose parameters do not change, the person in charge of the job may decide a new JSA is not needed for each repeat, after considering changes in personnel, procedures, equipment and environmental conditions. [BSEE (eCFR)] Note that this is a Department of the Interior rule for offshore operators, not an OSHA standard.
JSA: onshore drilling and servicing
OSHA's eTool for well drilling and servicing is written around the JSA name. It says the people who will do the job should be present when the JSA is written, that the supervisor should review, approve and sign it before the task starts, and that the JSA must be reviewed and updated whenever a step changes or a new step is added. [OSHA]
JHA: OSHA's guidance for every industry
OSHA 3071 is written for employers, foremen and supervisors in any workplace and uses the JHA name. [OSHA] OSHA's recommended practices for safety and health programs also use “job hazard analyses” first and give “job safety analyses” as the alternative name. [OSHA] If you are in construction, manufacturing, warehousing or any trade outside oil and gas, you will see JHA more often in OSHA material.
Does OSHA require a JSA or JHA?
Not by name. OSHA 3071 is a guidance booklet, and it says so about its own contents:
“The job procedures discussed in this booklet are for illustration only and do not necessarily include all the steps, hazards, and protections that apply to your industry.”
What OSHA does require are the duties a JSA or JHA helps you meet, and those are written for each industry. Two examples:
- Construction (29 CFR 1926). The training rule in Subpart C makes the employer teach every worker how to recognize and avoid the unsafe conditions, and which regulations apply to their work. [OSHA] A step-by-step JHA is a natural record of that instruction.
- General industry (29 CFR 1910). The PPE rule requires the employer to assess the workplace for hazards that call for PPE, select PPE for them, and verify the assessment through a written certification that names the workplace, the certifier and the dates. [OSHA]
Neither rule uses the words JSA or JHA. Both are met more easily when you have one. OSHA 3071 puts it this way:
“Compliance with these standards is mandatory, and by incorporating their requirements in your job hazard analysis, you can be sure that your health and safety program meets federal standards.”
The five steps, as OSHA lays them out
OSHA 3071 answers “Where do I begin?” with five numbered steps: [OSHA]
- Involve your employees. They know the job and will spot hazards you miss.
- Review your accident history, including near misses, as a sign that current controls may not be enough.
- Conduct a preliminary job review with the crew, and fix anything easy or immediately dangerous right away rather than waiting for the analysis.
- List, rank and set priorities for the jobs with the highest risk.
- Outline the steps by watching the job, keeping each step neither too detailed nor too broad.
Then, take each step and ask what could go wrong, what the consequences are, how it could arise, what else contributes, and how likely it is. [OSHA] The answers are your hazard column; the controls column follows, in OSHA's order of engineering controls first, administrative controls second, and PPE last. [OSHA]
What to call yours
- Offshore under SEMS: call it a JSA. That is the word in 30 CFR 250.1911 and the one an inspector will look for. [BSEE (eCFR)]
- Oil and gas onshore: JSA is the common term and the one OSHA's eTool uses. [OSHA]
- A client or general contractor hands you a form: use their name for it. The content is what matters.
- Everything else: either name is correct. If you want to match OSHA's own booklet, use JHA. [OSHA]
A simple way to end the argument on your own forms is to title them “Job Hazard Analysis (JSA)” so both searches, and both habits, land on the same sheet.