UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                  REGION I
                      JOHN F. KENNEDY FEDERAL BUILDING
                      BOSTON, MASSACHUSETTS 02203-0001
                                       EPA REGION 1 LIBRARY
               .      _  .                JFK FEDERAL BLDG.
    Explanation of the —         BOSTON MA 02203-2211
                    U.S. EPA-NEW ENGLAND REGION


               JOB SAFETY ANALYSIS (JSA) PROGRAM


                                      by

                             N. A Beddows, CSP, CIH
Introduction
The JSA program, described here, is a major, new, regional initiative for  1998.  It is a
regional occupational safety program required by the 1997 EPA-New England Safety and
Health Directive #1440.

Performing JSA's in most federal agencies is a requirement of an OSHA standard titled:
Federal Employees Occupational Safety and Health Program (at 29CFR. 1960). There is no
current, similar standard for General Industry. However, the  OSHA leadership, in  1997,
stated that "[having a General Industry] Safety and Health Program standard,  which covers
management commitment to employee  participation, hazard analysis, hazard prevention
and control, training and evaluation, is  [its] number one priority" [underlining emphasis
added]. The wording in this statement, as to what JSA comprises, is instructive.

In addition to meeting a regulatory (and  regional) requirement, having a consistently high
quality JSA program in place, regionally, will provide enhanced employee safety and boost
employee morale, through the expressed regard of the supervisor for the employees' safety,
and the employees' involvement in managing their own occupational safety. Moreover, it
would demonstrate compliance with the aforementioned OSHA standard. Additionally, it
will provide evidence of  appropriate  employee  instruction in any  future  Workers
Compensation Claim, or a third party suit.

Costs are minor for a JSA program for the EPA-New England's, approximately 250, field
and laboratory workers. Mostly, a one-time-only analysis, for homogeneous groups of
workers, would be necessary, and  1-2 hour group meetings, between the supervisors and
these groups of workers, to specifically discuss job safety, conducted once or a few times
a year, generally, would only be entailed.
                                                                 Recycled/Recyclable
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                                                                 contains at least 75% recycled fiber

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THE JSA PROGRAM

To show what JSA is, we will resort to giving commonly-asked questions and the answers to them.
Additionally, how the JSA might be documented, for one homogeneous group of field workers, will be
shown using an model letter and report form.

   What is JSA?

   JSA,  simply put,  means  identifying the safety  and health hazards of a specific job (field or
   laboratory work assignment); establishing, and implementing, the appropriate safeguards; and,
   having the supervisor and the field or laboratory employee, or a homogeneous group of these
   employees, discuss the recognized hazards and the corresponding safeguards. JSA involves  a
   systematic "Look Far-Look At" study of job steps (including travel), respective hazards, possible
   causes, safeguards, and effective communication. Each specific JSA needs to be developed by
   the supervisor and his/her field or laboratory employees. The industrial hygienist or safety specialist
   should participate  in the development and discussions when the hazard  analysis, the selection of
   appropriate safeguards or personal protective equipment,  or understanding of a safety standard
   are likely to be complex or contentious. The JSA development and discussions need to be in place
   as close as practicable to the work assignment. For completion, the JSA needs to be documented
   and maintained  on file by  the supervisor.

   JSA complements the basic 40-hour safety and health training which these employees are given
   by the agency. And, it is, itself, complemented by  the annual, 8-hour, refresher  job safety training
   for field and  laboratory workers.

   While a JSA  may constitute  required, specific job  safety instruction, it may not, by itself, meet all
   the appropriate safety  training  requirements in  applicable (and numerous)  Codes of  Federal
   Regulations, OSHA standards, and the agency's own safety directives.

   What are the Management's Objectives in the JSA program?

   There are five main objectives in the program:
   1. Enable employees to effectively avoid unsafe  work and working conditions.
   2. Stress that job safety  is  an important part of everyone's job.
   3. Promote supervisor, and field/laboratory worker participation  and partnership.
   4. Enable supervisors and employees to recognize and control job hazards.
   5. Demonstrate commitment to employee welfare and regulatory compliance.


   How Extensive is the JSA process?

   The coverage and detail of the JSA's for the regional field and laboratory workers will depend on
   the actual jobs.  Most JSA's will  be similar in scope, will involve known  hazards and safeguards,
   will entail four or five pages of written text and tabulated information,  and will, in many cases,
   involve only one JSA for a homogeneous group of workers.

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How Complex will doing a JSA be?

Generally, it will not be complicated at all.  If it were to be, it would only be in the  Hazard
Identification part. Even this part, however, generally will be quite simple because the job hazards,
as will be the safeguards, will be well known to either the supervisor or the affected employees.
In some situations, the hazards may not be immediately known, and hazard identification may
have to be achieved by "brainstorming" involving the supervisor and the employees, and, possibly,
the industrial hygienist or safety professional.

What does Hazard Identification by Brainstorming mean?

As used here, it means using a "What If" approach to hazard identification. You systematically,
and collectively, identify the "What If" scenarios. Next, you look for, and list, the potential hazards
in each scenario. For each hazard, you ask, and decide on, "What to Do," Who Does it," and
"When is it Done."  Use a five-column chart with the preceding headings, and with an appropriate
number of rows, one row per "What If scenario, to document the findings and plan.

Might Hazard Identification call for more than just Brainstorming?

When the hazards in a situation are not immediately known, simple brainstorming, to identify the
hazards, will be effective, generally. And, information on hazards in facilities being inspected can
be obtained by pre-inspection discovery involving the facility managers, operators and maintenance
personnel.  The  OSHA log, which  the employer must maintain, also provides a way to identify
hazards.

In some JSA situations, more highly-structured hazard identification (or risk assessment) methods
than "What If," such as Hazard and Operability (Hazop) analysis. Failure Mode and Effect Analysis
(FMEA), and Fault Tree Analysis, may be required. These methods require expertise. Mostly,
however, they are used only for chemical process hazard analysis and risk assessment in complex
processes.

How often is a JSA to be revisited?

Some minimal hazard jobs, such as EPA personnel office visits to businesses, will only require an
initial job hazard analysis and EPA supervisor-employee discussion. Only the discussions will need
repeating  periodically, perhaps annually or several times a year.

Jobs which could involve serious hazards might require, in addition to an in-depth hazard analysis,
regular, joint discussions, of hazards and safeguards, between the supervisors and the employees.

Which JSA's need to be documented?

All of them, without regard to the perceived levels of risk. Each JSA and supervisor-employee
safety meeting should be written  up completely. The JSA should be maintained permanently on
file by the  supervisor.

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The term 'Risk' has been used. What does it mean?

Risk can be thought of as the product of the consequence of an hazardous exposure and the
frequency of that exposure.  If you look at  the  extremes of the possible combinations of
consequence and frequency of exposure you will see that when both consequence and frequency
are low, the risk is de minimus. And. at the other extreme, when both consequence and frequency
are high, the risk might reasonably be  described as very severe or potentially catastrophic.
Between these limits, of course, other combinations of consequence and exposure frequency arise.
These can, admittedly, arbitrarily, but sensibly, be described, variously, as low, moderate, serious,
or as some other, appropriate, risk-classification term.  As an example, in a case where the
consequence of a mishap, were it to occur, would be an injury requiring medical treatment, and
the frequency of the exposure would be, say, a few times or less, a year, the risk could reasonably
be classed Serious. You will see. also, that when a field or laboratory worker faces the same kind
of hazards on a daily or weekly basis—that is, the frequency of facing some potentially adverse
consequencefsj is relatively constant, the severity of the possible adverse consequence of a
mishap (the recognized hazard) dictates the class of the risk. The above scheme is the basis for
some computer risk analysis and project prioritization models.

You've used the term 'Recognized Hazard.' What does it mean?

First, this term has regulatory significance. The General Duty Clause (§5 (a)1) of the OSH-Act of
1970 prescribes an employer duty to provide work and work places free of recognized (serious)
hazards. A  supervisor, manager, or safety professional  can, in most cases, recognize (and is
expected to know about) job-related matters which, either by themselves or in concert with other
events, could lead to a serious accident or incident.

In context with the application of OSHA regulations and standards, and this term, the employer
(i.e., its supervisors, managers and  safety professionals, as the representative of the employer),
even if it did not  immediately know about  a hazard, generally would be regarded as being
imputably knowledgeable. That is, it should have known for one or more reasons (such as existing
industrial practice, or industrial standard).  Ignorance of an occupational serious hazard is generally
no defense against a charge of violating an applicable OSHA regulation or standard.

Not all hazards, however, are recognizable within the meaning of the OSH-Act. For example, an
isolated action  by an employee which created a serious  hazard or led to a serious accident,
arguably, is not a  recognized hazard, as OSHA applies the  term.

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What are the key Steps in Regional JSA program?

There are six, qualitative steps in our JSA program.

   1.     Select the Job to be Analyzed.

           When there are many  jobs to be processed, JSA should be done on  a
          priority basis, based on perceived risks. [The more risky jobs are processed
          first. Some jobs are similar enough to require only one JSA].

   2.     The Supervisor and the Employees Discuss the Job.

          Discussion entails focusing on the job-activities, the hazards, and  the
          safeguards to use; the applicable  regulations and  standards; and,  any
          additionally-needed information, instruction or employee safety training.

   3.     Define the Job.

          Break the job down into the key activities. List the activities.

   4.     Identify Hazards and List Them.

          Look at each key activity in the job for potential hazards: physical hazards,
          such as stack-climbing; physical agent hazards, such as high  noise level;
          chemical hazards, such as toluene vapor exposure); and, biological hazards,
          such as the lyme disease tick, and poison ivy.

          Use short-hand,  hazard identification terminology in this step  (4). Classify
          hazards as (but not limited to):

             »   Striking Against
             »   Struck By
             »   Slips and Falls
             -   Strain (Lift/Push/Pull)
             »   Hazardous Environment Exposure via Any Route
                 •   Physical Agent.
                 •   Chemical Substance.
                 •   Biological Agent.

   5.  Identify/Select Safeguards and List Them.

       Look at.  and list, ways to  avoid  injury or illness. This might include extricating
       oneself from a risky situation.

   6.  Document the JSA.

       Write down the findings from steps 1 through 5. Write down (and follow up on) any
       planned additional investigations, inquiries, or discussions.

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Are there any basic, common themes to use in a JSA Supervisor-Employee Discussion?

Yes. Depending on  the  circumstances,  one  might  include  in  the  discussions   points  on
administrative matters, and common physical, chemical or biological hazards and safeguards. In
this regard, consider:

   Administrative Matters:

      •  Work rules exist to protect both the employee and the employer, all employees must work
         safely; unsafe acts and violations of the rules will not be condoned.

      •  When any vehicle is used for agency business, seat belts must be used by the driver and
         any passenger. Driving safety rules must be followed.

      •  Car phones when available should only be used when the vehicle is stationary.

      •  Any government vehicle defect or involvement in any accident must be reported to the
         issuer. Every vehicular accident must be reported to the supervisor.

      •  When visiting a site, you must follow every reasonable site safety rule. You are expected
         to be appropriately dressed, and  to use appropriate personal protective clothing  and
         equipment.

      •  In assessing potential hazards to yourself (or co-worker) at an unfamiliar work site or work
         place, ask the site management or  plant personnel about them.  Obtain information about
         : the processes; the work activities; the work site layout (i.e., the designated and prohibited
         walkways);  the physical  hazards; the chemical hazards; personal or  area chemical
         exposures; and the history of accidents and OSHA inspections and citations.

      •  Familiarize yourself with the applicable OSHA standards and regulations. Also, when you
         need exposure and risk information, look at the relevant material safety data sheets, the
         NIOSH Criteria Documents, and the U.S. HHS-ATSDR Toxicological Profiles before you go
         into the field.

      •  Terminate an inspection if  irritation to the eyes, skin, or pulmonary system becomes a
         problem,  or if hazardous physical  conditions  present themselves  at any  stage of your
         inspection.

      •  Get to know beforehand the location of emergency services.

      •  Consult the supervisor, industrial hygienist or safety specialist if in doubt about any safety
         or health requirement  or procedure to be followed.

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Common Physical Hazards:

   •   Falling on sloping or slippery surfaces, falling off unguarded scaffolds or platforms, slipping
       on steep banks, falling in climbing a ladder in inclement weather or climbing an unguarded,
       fixed ladder which is over 20 feet in length.

   •   Straying off the proper walkways. This could result in being struck by railroad  rolling stock
       in some industrial sites.

   •   Getting  close  to unguarded,  live  electrical equipment, rotating  equipment,  hydraulic
       equipment,  crane swing-arcs, and unshielded welding operations.

   •   Standing/walking under moving or suspended loads.

   •   Wearing loose  clothing—ties and sleeves—around rotating equipment.

   •   Stepping  on piles  of wood with protruding  nails  or climbing  unsecured  ladders  and
       scaffolds.

   •   Being close to  inadequately secured or improperly stacked material and  containers.

   •   Entering confined spaces, high traffic areas, or high  noise areas.

   •   Taking a short-cut across a property, or climbing over a property fence.

   Notes.

       1.  Significant physical hazards are more likely to exist m older industrial sites. For many
           physical hazards, the primary safeguard is distance.

       3.  Employees may not enter any confined space unless and until they have had
           appropriate training on Confined Space Entry, consistent with the OSHA Permit
           Required Confined Space Entry standard (29 CFR 1910.146).

       3.  Any industrial steady state noise level which is uncomfortable is potentially
           injurious. However, provided the employee limits the duration of his/her time in
           a high noise area, an impermissible exposure to steady state noise is not likely.
           For a 1 /4 hour exposure, the level of noise which would be legally impermissible
           is 115 decibels (dBA-Slow). This level would be generally evidently excessive.
           The level of impact (discontinuous) noise which is legally impermissible for any
           duration (140dB) would be immediately, generally evident. Most industrial high
           noise areas will be  posted. The EPA employee d) should not enter high  noise
           areas without hearing protection, (n) should minimize  exposure time in every
           case, and (in)  is not at risk of noise-induced hearing loss when he/she uses the
           appropriate precautions in high noise areas and around  high  noise equipment.

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Biological Hazards:

   These hazards are more likely to be encountered at wetlands, landfills, waste water
   treatment plants and Superfund sites. The more general biological hazards in field work
   include:

      •  Poison ivy, spiders, and snakes (mostly at some wetlands and waste sites).

      •  Tetanus or Septicaemia from a puncture-wound.

      •  Lyme Disease-carrying ticks. [These ticks are  present throughout the  New England
         states. The risk of exposure to an infected tick may when left untreated. Complete
         covering of the ankles, legs, arms and neck;  the  use of tick-repellent; careful self
         examination after each site visit; and, knowing the signs and symptoms of infection
         are critical to your safety].

      •  Pathogenic bacteria and viruses at raw/waste water treatment operations [Blood-borne
         pathogens are  not likely to encountered by field workers, but Emergency Response
         program workers need to  watchful for possible blood or drug needle contact].

Chemical Hazards:

   Organize discussions around -

   •  Organic Vapors (in industrial settings, but generally at concentrations which are within the
      relevant permissible exposure level—PEL).

   •  Gases (for example, chlorine at water treatment plants).

   •  Metal Fumes (from welding/gas/arc-burning).

   •  Acid or Alkaline Mists (metal  cleaning operations).

   •  Chromium ( + 6) (hard chrome-plating baths).

   •  Hazardous Surface Contaminants (lead waste in bridge work)

   •  Non-Ionizing (noise and/or U.V. light) and Ionizing  Radiation (industrial X-rays; radiation
      from the improper use of an XRF monitor).

   •  Dusts  (fibrogenic  dusts:  asbestos-containing material  (ACM) and crystalline  silica-
      containing  material.  Exposures to these materials  are  of particular concern.  These
      materials may be encountered in some older industrial operations and metal foundries).

   •  Hazardous Containers (containers of hazardous waste which are evidently in poor condition
      or under pressure, and improper containers used to transport hazardous materials are of
      particular concern. Watch for bulging containers).

   •  Compressed Gas Cylinders (cylinders must be appropriately approved, maintained, properly
      handled, and used).

   •  Sample Containers (only use appropriately approved containers).

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Notes:

1.   In virtually every industrial site, the use of ionizing radiation sources are stringently controlled and are
    subject to federal or state regulation and periodic inspection. An impermissible exposure to ionizing radiation
    at the site is not viewed as being likely. Misuse of a XRF meter or a small radiation source by the EPA
    employee is seen as a possible cause of ionizing radiation exposure.

2.   The presence of asbestos fibers in heat insulation on pipes and boilers, and in dust associated with such
    insulation can not be detected by unaided visual examination. The EPA employee should ask the site owner
    if any asbestos is present in any work area to be inspected, and should assume unless reliably informed
    otherwise that insulation and associated dust in boiler rooms and the like in older facilities could contain
    asbestos, and should not subject him/her self to possible exposure.

3.  High pressure compressed gas cylinder valves and gauges when mounted on the cylinder must be protected
    by the cylinder construction.


What Responsibilities exist relating to  our JSA program?

Managers,  supervisors,  field and laboratory workers, and  other  employees  have  ceratin
responsibilities under the program.  Managers and supervisors are generally responsible for
arranging for the JSA, selecting the appropriate format for the documentation, developing and
discussing JSA's with the employees, and documenting and filing the JSA.

Field and laboratory workers are responsible for conducting common-sense evaluations of
recognizable risks  in their own jobs.  The are expected to ascertain,  to the best practical
extent, the potential physical, chemical, physical-agent, and biological-agent hazards at the
sites they are to  visit/inspect.  They  need to  bring  this kind  of information  to the joint
employee-supervisor, JSA  developmental meeting  and  discussion.  They should actively
participate in the development  and discussion of the JSA. And, they need to be diligent in
applying the JSA information in their daily work.

Industrial hygienists and  other occupational  safety and health specialists are generally
responsible for providing technical assistance to managers,  supervisors and employees, and
participating in joint supervisor-employee JSA meetings when requested by supervisors or non-
supervisory employees. Additionally, they should assist, when requested, in identifying serious
hazards; in  establishing appropriate safeguards; and, in  reviewing completed  JSA's for
program quality  assurance.
    Note:
       An employee or a supervisor can require the participation of a safety and health specialist in a JSA
       development  or discussion meeting if  hazard identification,  selection of safeguards,  or
       interpretation of a safety regulation or standard are in question.

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Is there a standard form to use to document a JSA and a Supervisor-Employee Discussion?
There is no standard form. Supervisors may document the JSA and discussion as they choose.
However, documenting the JSA findings and  other matters (as  previously mentioned)  in
tabular form (a tabular form for documenting a  JSA is offered in the attachment), and using
a cover letter, could be time-saving. The letter  might comprise:
   •  An introduction.
   •  A statement of the scope and limitations of the JSA.
   •  A description of type of field work and activities involved.
   •  A list of the recognized hazards.
   •  A list of the appropriate safeguards.
   •  Specific directives given to the employee(s).
   •  Examples of situations to be generally found, and what to do to safeguard oneself.
   •  A statement of relevant controls and safety procedures.
   •  Employee safety training requirements and plans for further training.
   •  A statement on occupational medical program participation.
   •  Specific recommendations coming out of the supervisor-employee discussion.
   Note.
      A pre-inspection inquiry, when practicable, concerning the facility layout, the processes, the
      history of injuries and  illnesses, particular hazards, and plant safety rules and requirements, and
      any other relevant matter that comes to mind, can be useful for hazard identification.
                                           Norman A. Beddows
                                           Regional SHEMP Manager.
                                           June 12, 1998.
                                          10

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                                       ATTACHMENT


MEMORANDUM

Date:

From:  [Manager]
       [Occasional Field Visit-Employee]
       [Health and Safety Specialist]

To:    File/Distribution:

Subject:   Job Safety Analysis. A Scripted Message


Today [date] we met to identify and discuss the job hazards and safeguards relating to the EPA field
[laboratory] work assignment(s) of the individual(s) listed below.

The general points which were made,  and the  job-specific hazards and safeguards which were
discussed, included:

1. Type of Field Work Required by the Job

From  time to time the job may require  visiting facilities such as manufacturing plants, recycling
facilities, laboratories, or waste treatment, storage or disposal facilities for brief plant tours and
inspection of plant operations, but not for enforcement program inspections and audits. Facilities will
range from those which are staffed with safety specialists and  have well-run safety  and health
programs to those which have only minimal expertise in, and/or commitment to, occupational safety.

It is anticipated that in these visits, the  EPA employee will be escorted by a representative of the
facility, no sampling or environmental testing will be undertaken, and there will be less  then about
ten visits in the course of a typical year.

2. Potential Hazards & Safeguards

Potential hazards in this kind of field work arise in driving to and from the sites, and in participating
in conducted  site tours. Potential hazards in these controlled, limited frequency and duration visits
1) are essentially physical, and 2)  are not expected to constitute a serious risk when the  safeguards
are known and applied. No chemical and/or biological exposures are likely to arise.  No significant
health risks or potential violations of applicable legal permissible exposures limits as far  as the EPA
employee  is directly affected are  recognized as being likely. Appropriate safeguards to employ in
such visits include advance knowledge of what one will be looking at and doing, an initial  discussion
of the facility's health and safety plan,  avoidance of prolonged durations of process inspections,
avoidance of exposure to dusty dirty environments, removing oneself from environs and environments
which are suspect, and good personal hygiene.

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Safe Driving. Let's briefly review driving safety going to and coming away from the site, before we
discuss potential hazards and safeguards to employ at the site.

Drive defensively! Always use seat belts, passengers included. Don't exceed the legal speed limit,
and drive at a reduced speed in poor driving conditions. The best chance of getting out of a skid or
a spin on a wet or icy road is to keep your speed down beforehand. Anticipate the other drivers'
actions - the driver of the car in front of you, and the driver in front of that one. Keep enough space
between you and the car in front so that: 1) you can stop without a collision if it suddenly stops; and,
2) you can move forward safely if you see the driver behind you having difficulty in braking when the
traffic in front forces a quick stop. Watch how you change lanes or turn. Look and look again, and
signal.

Industrial Situations - Hazards and Safeguards. While risk of serious injury in these visits and settings
is judged to be remote, one needs to be aware  of potential physical hazards1 which may exist at one
time or another at the site being visited:  Slips and falls, being struck by equipment or material, or
striking against equipment  or structures  at the site  and  intermittent elevated levels of airborne
hazardous gas, vapor or  paniculate,  as might arise in  batch-process operations.

The most likely root cause of injury involving such hazards at these kinds of sites, would be one or
more of the following: Not knowing about the  work areas,  the processes, and the equipment at the
site, walking on surfaces not normally intended for pedestrian traffic, or being too close to unguarded
platforms or elevated sloping surfaces, and a concomitant lapse in attentiveness or caution. If in
doubt, ask the facilities manager.

Some Genera/ Industrial Situations. The following are some points to be aware of to avoid putting
oneself in an unsafe situation.

•  Moving Equipment. There should be no need to be close to or touch moving process equipment
   in the facility.  If its moving, stay away. Make sure you keep to the proper walkways and roads
   in the facility.

•  Be careful crossing rail road tracks or crane tracks which cross walk ways. Do not cross multiple
   sets of railroad/crane tracks which run parallel to road/walk ways. Keep to the proper walk ways
   or roads.

•  Loose Clothing or Articles.  Do not enter the facility with loose straps on equipment or clothing
   that might be caught in equipment. [Loose  clothing and long hair are well known hazards around
   rotating equipment!]

•  Wet Floors.  Avoid wet areas to prevent slips and  falls.

•  Unsecured Handrails or Ladders.  Do not rely on handrails or railings without first ensuring their
   stability. Do not climb a ladder which is not in good condition or properly placed and supported.
   Watch for broken or severely corroded ladder rungs, for too-steep ladder angles, insufficient ladder
   lengths, and unsecured footing and tie-down.

•  Keep clear of unguarded open water, such as lagoons and aeration tanks.

•  Overhead Fixtures and Objects. Always be aware of head clearance and moving overhead objects
   to avoid head injury. Consistently wear a hard hat to avoid injury from head-bumps. Move out of
   the way of any traveling over-head loads. Do not stand/work under suspended loads.

•  Moving Vehicles. Look  out for forklifts, trucks or other vehicles.

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•  Unstable Ground. Do not venture in outside filled waste disposal areas where ground or slope can
   be unstable.

•  Scaffolding, Elevated Platforms, and Roofs. Do not climb on temporary scaffolding or makeshift
   stairs or ladders, or walk on slanted elevated surfaces. If you have to work at elevation keep
   away from unguarded platform edges and make sure that a proper guardrail is in place and secure
   whenever you have to walk or work on an elevated walkway. Watch out for some older roofs
   having painted-over re-enforced glass  skylights which may seem to be a  contiguous part of the
   roof.

•  Flaking  or Exposed  Friable Asbestos Material. In  some older (pre-1988) buildings, ceiling
   insulation, and insulation on steam pipes and water boilers in some boiler rooms or vaults may be
   asbestos-containing material. Over time, the insulation may have become friable. Subsequently,
   airborne or settled asbestos-containing dust may be present in the work area.  If you see any
   questionable insulation or dust,  ask  the plant personnel what the material is. Assume the
   questionable material or dust does contain asbesti-form material until you are  reliably assured
   otherwise. Immediately remove yourself from any space in which you see flaking material or dust
   which may contain asbestos.

•  Dusty atmospheres, or areas with flying particles or liquid sprays or splashes from processes. [Use
   safety glasses with side shields at a minimum in any visit to such places.  Check with the facility
   management on what to use in particular areas].

3. Controls and Safety Procedures

Before entering an operational (non-administrative) area of the facility, ask about the facility layout
and processes, and the safety rules and procedures, and the protective equipment applicable to the
areas being entered. Follow the facility's safety rules,  including any requirements to use a hard hat,
hearing protection, safety glasses, safety  shoes or boots or disposable foot covering, or a respirator.
Require an  escort from the facility personnel, and be guided accordingly.

One would like to think that each visit to every  facility will be  controlled and safe. However, on
occasion one may find that the facility or some part of it is substandard regarding safety conditions,
practices,  or providing  for the safety of visitors.  If  one thinks that the  prevailing conditions are
unsafe, or experiences discomfort with a particular condition in a work place, immediately leave the
area.

Hard hats, safety glasses, hearing protection, insect repellent, and disposable coveralls are available
to EPA employees who need them. Safety footwear will be provided on an as-needed basis for EPA
employees.  Equipment must be requested in a timely manner  prior to the  trip. To obtain safety
equipment, contact the safety specialist,  or (         ), the designated person.

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4. Limitations on Field Responsibilities

The job does not require entering uncontrolled hazardous waste disposal areas, or confined spaces.
The job does not require entering or working in areas which require wearing personal protection
beyond a hard hat, hearing protection, safety glasses,  safety shoes/boots, and/or a disposable
coverall to basically protect against nuisance dust  or dirtying ones street clothes.

It is believed that respiratory protection will not be required to be used by the EPA employee in these
kinds of site visits. If the EPA employee has reason to believe the use of a respirator will be necessary
and intends to use one, he/she must be properly trained and fit-tested on the use and applicability of
respirators. Consult the supervisor for further direction.

The EPA employee should not enter areas or spaces were hazards are present for which the employee
has not appropriate background or training to assure his or her safety.

If the limitations described herein interfere with performing some other job duty, or if one believes
that this job safety review and discussion  needs to be augmented in any way by further discussion,
or that additional  or  special safety instruction or training  is needed, the supervisor should  be
consulted.

5. Safety and  Health Training Courses

In addition to this job safety review and discussion, 8-hour health and safety courses (i.e., the annual
refresher  training which is given to those employees who engage  in  routine, regular field and
laboratory work), 40-hour safety  and health training for  those  employees who  engage in routine,
regular field and laboratory work are available. Also, other new program-dedicated courses  will  be
available if and when needed. The employee is encouraged to register for the appropriate training.

Note. If further health and safety training, such as the referenced 40-hour health and safety training,
is desired due to off-site conditions encountered on the job,  the supervisor should be consulted.

6. Specific Recommendations Arising Out of this Meeting.

       fTo be completed at the conclusion of the joint manager-employee discussion by the manager,  based on
       the outcome of the meeting].

   A.
    B.
    C.
    D.
    E.

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                                                    ATTACHMENT
Employee Name:
JOB SAFETY ANALYSIS



         Title
                                                                                                            1 of 2 pages
Prepared by Immediate Supervisor:
	  Group



 Date: 	/
INCUMBENT'S TITLE/POSITION: REF.#:
KEY WORD DESCRIPTION of DUTIES/TASKS/ASSIGNMENT:
Job Steps

Physical Hazards

Env. Conditions / Hazards

Bio-Hazards

Comments / Safeguards / Instructions
""SUPERVISOR-Uook at hazard! and potential
accidents in terms such as "Sinking Against." "Struck
By." 'Slip* and Falls.' "Stain.' and Hazardous
Environment Exposure "
JSA by Date: / / Reviewed by Date: / /
ADDITIONAL INFORMATION. SUPERVISOR'S or SAFETY MANAGER'S COMMENTS:

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REFERENCE

GENERAL INSTRUCTIONS PROVIDED [Do's
& Don'ts]

SPECIFIC INSTRUCTION(S) provided to Employee
«• To Supervisor: Use a supplementary sheet to record additional information.
[/] THE DRIVER AND ALL PASSENGERS MUST WEAR SEAT BELTS IN EVERY CAR
USED FOR BUSINESS.
ADMINISTRATIVE RECORD: JSA discussed with by [Supervisor]. Date / /
To Supervisor SEND THE EMPLOYEE-SIGNED JSA To the HUMAN RESOURCES OFFICE for Filina.
2 of _ pages I Form 031097NABI

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