Job Safety Analysis - Meeting New Requirements for Training
The right way to do a Job Safety Analysis or JSA is a hot topic in the oil patch right now. The Bureau of Safety and Environmental Enforcement (BSEE), which already requires them as a part of SEMS, is proposing to require that all offshore workers be trained on SEMS annually. The updated SEMS rules are also expected to require that Stop Work Authority be a part of the JSA process. That proposal is going through its final review by the White House right now, meaning whether it is out in 30 days or 3 months, it is on its way. JSAs are a big subject on land as well because oil and gas companies require them for most well site jobs and they are telling us they are not happy with the quality of JSAs they are seeing.
At PEC, we developed a new JSA class to help industry meet the new BSEE training requirements, as well as the concerns of landside operators. Our goal was to create a JSA class that would be taught by one of our 1,700 PEC instructors authorized to teach SafeGulf of SafeLandUSA nationwide. In researching JSAs, we learned a couple of interesting things. First, the reason companies do JSAs has changed over the years. Second, the problem may not be that workers are untrained on how to do a JSA; it may be that they don't know why they should do a JSA.
For anyone who is not already familiar with JSAs, they are an organized way of analyzing a specific job, determining any hazard that job may present and deciding how to control those hazards. Typically a crew breaks the job down into steps, figures out what could go wrong to hurt someone and then agrees on safety measures to protect everyone on the job. In the PEC training course, we call that the JSA Triangle.
In the oil patch, we use JSAs as a way to give crews ownership of their own safety. Workers who have had to focus on how they do the job and how to protect themselves from incidents are more likely to go home unhurt at the end of the hitch. For that reason, a lot of oil and gas companies require that crews write out their JSAs by hand to make sure they have taken a direct role in addressing the hazards of that particular job.
What we found in our research is that the JSA process didn't start out like that. The concept of breaking tasks down into steps dates back to the assembly lines of the 1920's and then it was a way to figure out how many workers to hire per shift. In the 1930s, engineers started looking at the task step process as a way to improve safety, but it was still a tool that management used to design the assembly line to make it safer. It would be many, many years before industry really paid much attention to what workers thought about their own safety. The big leap forward in job task analysis came in World War II when it was used to help Rosie the Riveter and the other hundreds of thousands of inexperienced factory workers learn their jobs quickly. All of those are valuable uses, but none of them quite fits with today's efforts to empower individual workers to manage their own safety, which is one of the fundamental goals of JSAs in our industry.
What Workers Think
We also found was that if the goal is to involve crews in making sure they go home unhurt, a lot of workers aren't getting the message. On online forums, oilfield workers are open in considering JSAs as unnecessary paper work, done to satisfy management back at the home office, not to keep them safe.
Two comments posted online were particularly telling:
- "During the safety meeting, we sign about 30 JSAs and (do) not go over…one of them"
- "Do a verbal (JSA), open the book to the correct JSA for the job and leave it there (so) if anyone shows up and asks, I tell them 'it's right there.'"
Interviews with operators and contractors confirm that many workers simply do not see the connection between their safety and doing JSAs properly.
They should. Accident investigations show a direct connection between the way a crew prepares and follows JSAs and incidents. Here are three examples from our research:
- July 18, 2006 – Guidepost under pressure breaks, killing floorman; Procedure never discussed in JSA meeting. – MMS investigation of fatal accident V-door guide post failure Chandeleur Block 31, Well No. 1
- January 19, 2008 – Worker repairing emergency shutdown device swept by wave and drowned; no JSA done because job considered "routine." – MMS investigation of fatal accident North Padre Island Block 969, Platform JA
- April 13, 2012- Offshore roustabout falls through well-access opening on deck during decommissioning project; No written JSA and not everyone attended JSA meeting. - Bureau of Safety and Environmental Enforcement Gulf of Mexico OCS Region Safety Alert No. 301
At PEC, we think the lesson here is that training on JSAs is necessary and the requirements coming from the government and individual operators will help our industry improve on its safety record. However, that training has to go beyond rote learning courses that just ask workers to memorize the three elements of a JSA. It needs to focus on why we do JSAs, how to identify hazards correctly and when to stop the job if the JSA is not being followed. Above all, at PEC we try to teach students that, if done correctly, a JSA is the way to make sure everyone understands his or her job and everyone will finish the job safe and sound.
Ken Wells is Director of Special Projects for PEC and can be reached at Ken@pecsafety.com.
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