Job hazard analysis software › OSHA job hazard analysis
OSHA and the job hazard analysis: what's required and what's guidance
No federal OSHA rule requires a written job hazard analysis for most work. OSHA's JHA booklet, publication 3071, is guidance. Several standards do require you to assess hazards, inspect, or certify an assessment in writing, and contracts, general contractors, Army Corps of Engineers jobs and state plans such as California's often turn the JHA into a requirement.
What OSHA 3071 is, and what it isn't
Job Hazard Analysis (OSHA 3071, 2002 revised) is a 51-page booklet for "employers, foremen, and supervisors." It defines a JHA as "a technique that focuses on job tasks as a way to identify hazards before they occur," looking at the worker, the task, the tools and the work environment together, and it walks through how to write one. It is not a standard: nothing in it carries a citation or a penalty, and it says its examples "do not necessarily include all the steps, hazards, and protections that apply to your industry."
The legal hook people usually point to is the General Duty Clause, section 5(a)(1) of the OSH Act: each employer must provide a workplace "free from recognized hazards that are causing or are likely to cause death or serious physical harm." A JHA is a common way to show you looked for those hazards, but the Act doesn't name a JHA or any particular form.
Where federal rules do require a hazard assessment
These are the standards most often confused with a JHA requirement. Each asks for an assessment, an inspection or training, and a well-built JHA can carry part of the paperwork, but none of them uses the words "job hazard analysis."
| Rule | What it requires | Who it covers |
|---|---|---|
| 1910.132(d) | Assess the workplace for hazards that need PPE, select the PPE, tell each affected employee, and verify the assessment with a written certification naming the workplace, the person certifying, the date(s), and stating that it is a certification of hazard assessment | General industry: shops, yards, plants. The construction PPE rule, 1926.95, has no certification paragraph |
| 1926.20(b) | Run the accident prevention programs needed to comply with Part 1926, including "frequent and regular inspections of the job sites, materials, and equipment" by competent persons the employer designates | Construction |
| 1926.21(b)(2) | Instruct each employee in recognizing and avoiding unsafe conditions and in the rules that apply to the work | Construction |
| 1926.651(k) | A competent person inspects excavations, adjacent areas and protective systems daily, before work starts, as needed during the shift, and after every rainstorm | Excavation and trenching |
| 1926.1203(a) | Before work begins at a worksite, a competent person identifies every confined space employees may work in and which ones are permit spaces, testing as necessary | Construction confined spaces |
| 1926.1408(a) | Before equipment operations, define the work zone and determine whether the equipment, load line or load could get closer than 20 feet to a power line; if so, follow one of the rule's three options | Cranes and derricks near power lines up to 350 kV |
| 1926.952 | Before each job, the employee in charge briefs the crew on the hazards, work procedures, special precautions, energy-source controls and PPE; at least one briefing before each day or shift | Power line work (Subpart V) |
| 1910.119(e) | A documented process hazard analysis that identifies, evaluates and controls the hazards of the process | Processes with highly hazardous chemicals |
One federal rule outside OSHA does name the JSA: the offshore safety rule 30 CFR 250.1911 (BSEE) requires a JSA for each operation or task in an offshore oil and gas operator's safety program, documented and kept current.
Among the OSHA rules, the one with a written-format requirement is 1910.132(d). If you use a JHA as your PPE certification for yard or shop work, make sure it carries those four items, because a list of PPE by itself doesn't.
Where a JHA becomes required in practice
- State plans. OSHA 3071 notes that 24 states and two territories ran their own approved programs when it was revised, with standards that can differ. California is the clearest case: 8 CCR 3203 requires every employer to keep a written Injury and Illness Prevention Program with procedures for identifying and evaluating workplace hazards, including scheduled periodic inspections, when the program starts, when new substances, processes, procedures or equipment bring a new hazard, and when the employer learns of a new hazard. Inspection records are kept for at least a year. For construction, 8 CCR 1509 adds a written Code of Safe Practices and toolbox or tailgate meetings at least every 10 working days. None of this says "JHA," but a JHA library is a common way to document the hazard evaluation.
- Army Corps of Engineers and NAVFAC jobs. USACE's safety manual, EM 385-1-1, requires an activity hazard analysis (AHA) for the work, in its own format. The current edition is dated 15 March 2024, renamed "Safety and Occupational Health Requirements"; according to Gadzoom's summary, it requires a reference number for each step, hazard and control, and contractors follow the edition in effect when the contract was solicited. The USACE and NAVFAC copies of the manual turned away automated readers on November 13, 2026, so read your contract's edition before relying on any summary, this one included.
- General contractors, owners and insurers. HammerTech's guide says JHAs are "widely required by General Contractors (GCs), owners, and insurers as a baseline for safe work," and that matches what subcontract safety manuals ask for. Many GCs also want a daily pre-task plan built on top of the JHA.
OSHA 3071's method, in order
- Involve your employees. They know the job, and they buy in to controls they helped choose.
- Review your accident history, including near misses, which show where existing controls may be weak.
- Do a preliminary job review. Talk through known hazards, and fix anything that is an immediate danger now, without waiting for the analysis.
- List, rank and set priorities. OSHA puts first the jobs with the highest injury rates, the potential for severe injury even without a history, those where "one simple human error" could cause a severe injury, jobs that are new or changed, and jobs complex enough to need written instructions.
- Outline the steps. Watch the job and list each step as the worker takes it, not so detailed it becomes long and not so broad it skips basics. Photos or video help. Make clear you are evaluating the job, not the worker.
- Identify the hazards with five questions: what can go wrong, what are the consequences, how could it arise, what are other contributing factors, and how likely is it. A good hazard scenario names the environment, the exposure, the trigger, the consequence and other contributing factors.
- Choose controls in order: engineering controls first (elimination, substitution, enclosure, isolation, ventilation), then administrative controls such as procedures, permits and training, then PPE. Review the JHA periodically, and always after an injury or illness on that job; after a close call, discuss it with everyone who does the job and remind them of the procedure; retrain everyone affected when it changes.
OSHA's worked example is a shop job, grinding 15-pound iron castings at 20 to 30 an hour. The booklet's sample form (Appendix 3) has these fields: job title, job location, analyst, date, task number and description, hazard type and description, consequence, hazard controls, and rationale or comment. A blank construction version of that form, and how to fill each column, is on JSA template.
What this means when you pick software
No rule requires software; a paper JHA that the crew actually discussed meets the same standards. Software helps with the parts the rules and contracts check: a date, a named competent person, signatures, and a copy you can produce later. For USACE work, pick a tool that outputs the AHA format, such as Gadzoom or JSABuilder. Dozer writes JHAs that cite the OSHA sections for the task, mostly 29 CFR 1926, and collects the crew's signatures on one phone, free for one site, but it has no AHA format or risk score and covers US federal rules only. Its JHA templates are free to read on its site.
Questions
Does OSHA require a JHA?
Not as such. No federal OSHA standard requires a written job hazard analysis for most work, and OSHA 3071 is guidance. But specific rules require hazard assessments, inspections or a written PPE certification (for example 29 CFR 1910.132(d), 1926.20(b) and 1926.651(k)), and GCs, owners, USACE contracts and state plans often require a JHA or an equivalent.
Is OSHA 3071 a regulation?
No. OSHA 3071, Job Hazard Analysis (2002, revised), is a guidance booklet that explains how to do a JHA. It has no enforceable requirements of its own; the enforceable rules are in 29 CFR 1910 and 1926 and the OSH Act's General Duty Clause.
How often should a JHA be reviewed?
OSHA 3071 says to review it periodically, and especially after an injury or illness on that job, to go over the procedure with the crew after a close call, and to retrain everyone affected whenever it changes. Many crews also check it every morning in a pre-task plan.
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