Non-routine tasks present a variety of risks and can result in serious injuries if a facility’s Job Hazard Analysis (JHA) and preventive measures aren’t adequate. Reviewing a project and worksite to identify and address risks are the first steps to making non-routine tasks safer, but you can make your efforts even more effective by increasing visual cues for 5S organization, chemical safety, and reminders for hazard controls, such as machine guards and personal protective equipment. Read on to learn the importance of operating procedures for non-routine tasks and how to get started with pre- and post-task protocols.
What Are Non-Routine Tasks?
A non-routine task is an activity or set of activities that are not generally performed on a regular or even semi-regular basis. Examples of non-routine tasks include:
- Operating a new machine
- Cleaning up a chemical spill or residue
- Troubleshooting and servicing activities
- Adding electrical sources or making panel upgrades
- Unplanned equipment startups and shutdowns
- Annual housekeeping and maintenance
As you can see, these do not have to be huge projects. In fact, the non-routine activities risk assessment for changing a lightbulb in a hard-to-reach location is as important to address as upgrading an electrical circuit.
The Importance of a Job Hazard Analysis
What employees don’t know, can kill them! Failing to identify a task that’s out of the ordinary or dismissing the need for a Job Hazard Analysis (JHA) and training are the largest contributors to task-related accidents. Experienced safety professionals will tell you that some of the most common testimonies from employees at investigations involving fatalities and/or catastrophic loss are:
- We’ve never done a job like this before the accident
- We weren’t trained
- We don’t have a written plan
- Usually, we only do this type of job once in a while
It is tragic to hear these statements after a serious accident that could have been avoided if the workplace was following OSHA’s recommended practices for hazard identification and assessment¹. Risk to workers rises when they’re performing job tasks they have either never done or only do occasionally—but JHA methods exist to prevent these dangerous or fatal situations.
An OSHA Compliance Officer will ask an employer two typical questions at the opening of an investigation involving a suspected non-routine task accident: “Do your employees routinely perform this kind of work?” and “Are there methods used to outline and inform employees of the hazards of the tasks they do and were they trained on how to protect themselves from hazards?” Answers to these questions should come from your documentation files for the Written Plan for Hazard Communication (as required by OSHA 1910.1200)² and your Job Hazard Analysis written plan.
What Is the Difference Between a Pre-Task Plan and a Job Hazard Analysis?
A pre-task plan and Job Hazard Analysis are two names used for the same safety procedure. Some workplaces might call this a Job Safety Analysis or another similar term. Pre-task plans or JHAs define non-routine tasks, identify any related hazards that may cause injury, and state how hazards will be eliminated or controlled to prevent harm.
Steps of Planning Non-Routine Tasks
A Job Hazard Analysis gives non-routine tasks extra attention so they may be approached with particular caution. Reviewing the work site, speaking with employees, and gathering information will give you a well-rounded understanding of the hazards and how to control them. While JHAs vary based on the workplace, environment, and the task at hand, most have four basic steps.
1. Define the Non-Routine Task
Break the project down to make sure there aren’t smaller steps within it that require the same level of analysis as the “main” job. This might seem tedious but it can prevent any part of the process from slipping through the cracks. Interview employees and supervisors to get a wide perspective.
2. Analyze the Jobsite and Collect Information
Do a walk-through of the job site. Take notes of any and every hazard present. Document the area with pictures and measurements if needed. Inventory chemicals and verify relevant SDS documentation is available, and check for protective equipment, devices, and other task-related supplies. Bring all of this information to the pre-task meeting where you will start drafting the operating instructions and divvying responsibilities, keeping worker safety at the forefront.
3. Hold a Pre-Task Safety Team Meeting
Assemble a team of diverse stakeholders, such as managers and supervisors, an HR representative, safety staff, a minute taker, and experienced employees. Together, complete a non-routine activities risk assessment for every aspect of the job. Name all phases of the project, the hazards for each, and the safety controls that will be most effective for the specific non-routine task.
Use the Hierarchy of Controls as a guide. Start with the goal of Elimination and continue down to PPE, identifying what methods are the most effective at reducing hazards on a task-by-task basis. The goal is to identify the most feasible, practical controls for every situation within your plan. PPE is often considered the least effective hazard control, so keep this in mind as you plan and seek alternate methods to reduce harm. Document your decisions for which safeguards are preferred so this information may be added to your written plan.
3. Develop a Written Hazard Control Plan
This formal written procedure should be developed and approved by the team and should spell out the controls that were chosen during the non-routine activities risk assessment. The hazard control plan must also provide a roadmap regarding who is responsible for purchasing, installing, or implementing the controls, a timeline for each step, and how the effectiveness of the controls will be measured and monitored.
4. Implement Hazard Controls
Put into place the most feasible, practical, and effective controls the team selected. For example, if dealing with a dangerous chemical, hazard controls could include eliminating the hazard altogether, finding a substitute, or reducing exposure by increasing ventilation. Test the controls once they are in place, and if implementation will take some time, identify interim controls and repeat the evaluations. Then, install floor marking tape and signs to better support hazard control methods.
5. Complete Employee Training and Testing
Employees should be instructed on job procedures, potential hazards, which controls are implemented in the work area, and how to use them for protection. Ensure proper understanding of guardrails, lift systems, warning signals, or other safety measures and test employees to assure that the training is understood. Consider both written and practical exams, which OSHA recommends.
Employee training and oversight must be arranged as part of your plan. Document training and strictly enforce safety measures with a written disciplinary program, and inform employees of the set consequences for any safety violations. If an accident happens and trained employees weren’t following a written non-routine task plan, the fault will fall on your business—and OSHA will likely issue citations.
Updating your procedures now for non-routine tasks can save you from penalties later, and adding visual cues makes your facility safer during everyday and occasional tasks. Our inventory of floor signs and tape are lasting solutions for safety messages, hazard control reminders, and other protocols. Find out more ways to use these tools to prevent injuries and accidents during any kind of task in our Resource Center.
¹ https://www.osha.gov/safety-management/hazard-Identification
² https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
