When to use a JSA - is it required by law?

08 Jul JSAs – compliance, safety, or business opportunity?

Posted at 11:06h in Articles by Rachel Bell

In the arena of health and safety in New Zealand, we are swamped with acronyms and abbreviations, that to many are meaningless, and to some, confusing. An example of this are the term JSA, SSSP, SWMS, JSEA and others.

These translate to the following:

a JSA is a Job Safety Analysis;
a SSSP is a Site Specific Safety Plan;
a SWMS is a Safe Work Method Statement;
a JSEA is a Job Safety Environmental Analysis;
an SOP is a Safe Operational Plan (an SOP can also be a Safe/Standard Operating Procedure);
a HSSP is a Health and Safety Site Plan; and
a HIRA is a Risk/Hazard Identification and Risk Assessment.

To enlighten the uninitiated, there really isn’t any major difference in what they are for. They are planning documents that describe in a systematic step-by-step and logical evaluation process how a job, task, process, procedure, or the contracted work is to be carried out safely. They are all tools used to identify any actual or potential hazards and risks with the key focus to:

develop and document a contract safety plan;
to ascertain the level of risk;
to communicate the plan;
to manage the plan with the involvement of those involved in the task;
to use as a tool to prove compliance to the client and others; and
to use as a tool for the post contract review to identify areas for improvement of the business.

In summary, the JSA is to eliminate or reduce the risks or hazards to as low as reasonably practical (ALARP – another acronym!) in order to protect workers from injury or illness, or worse.

This process should not only be about safety factors, but also include items that could impact on machinery/equipment, and environmental factors. This helps identify unplanned requirements for the work which can and do impact on the profit of the business. Have you encountered this situation before, and lost part or all of your contract’s profit margin?

It’s a process that requires consideration and forethought – after all, it’s only a fool that tests the water with both feet.

Is the JSA required in the Health and Safety at Work Act 2015 or 2016 Regulations?

There is no specific reference to the terminology JSA or SSSP or similar in this legislation.

It is now the accepted best practice for contracting companies to provide evidence to a PCBU that they are managing the health and safety responsibilities for the contract or services in a logical and responsible process.

The reason is because the responsibilities of a PCBU have now been clearly defined, and the method or tool now required by many PCBUs is the JSA/SSSP. This is to ensure that the contractors engaged have:

the health and safety systems in place;
considered and documented the contract stages; and
identified and risk rated all the identified safety factors to mitigate the occurrence of accidents, injuries, environmental risks and contract disruptions.

Prequalification and JSAs

Over the past 6 months, we have received numerous calls from contractors enquiring about help with their pre-qualification process, and the use and supply of JSAs to meet the pre-qualification audit process. One of the main comments is about the amount of JSA paperwork that must be completed, regardless of the size of the job.

Why should the JSAs have to be a tome of information (in some cases, up to 24 pages) – when really, who will read them or are they just a butt-covering exercise by principal contractors?

Several of the enquiries said they may complete 1-3 jobs per day, but still had to complete a JSA for all jobs.

So, is there an easier way?

Yes, there is. Why not do as some contractors have done (especially if they are doing the same type of work), and develop a generic JSA that has all the key information and then add in the specific job information and any other specific hazards and other information as required?

JSAs – tokenism or compliance?

But just how effective are JSAs?

Is the JSA completed prior to starting the contract work, or on the first day and on the job?
Are they really used as part of the compliance checks by the main contractors, or just used as a means of tokenism to comply to get the job or contract?
Who checks them for compliance and effectiveness, or are they becoming another tick-and-flick exercise?
Are they reviewed on a regular basis during the process of a contract by the contractor and the principaal contractor for effectiveness?
Are all employees engaged in this review, or part of it?
Is a post contract review undertaken to measure its effectiveness, and to identify areas for future business improvement?

These are all relevant questions to ensure the effectiveness of the JSA process, but can other business opportunities arise from the use of these documents?

JSAs for business improvement and growth

Why not use your JSAs/SSSPs as a proactive management tool for the business to gain an advantage over other tenders?

Why not use them as an added value proposition to your business by applying the following?

Use the JSA as a training process with your employees for when tendering or planning for a contract – after all, they are going to be involved and by doing this will get buy -in from them.
No 1 will also elevate the communication of your health and safety standards to your employees, and this then allows them to take greater ownership of the site health and safety responsibilities.
Develop a generic JSA that has all the key information and then add the job information and any other specific hazards and other information as required. This will save you time on other contracts.
When completing the different steps for the contract, treat the JSA as your process planning document, and consider all the internal and required externally supplied hire equipment and plan for this in your tender.
Complete and include a draft copy of your JSA with your tender document. Don’t forget to watermark and to PDF the JSA for your security. This will show that your business is organised, professional, and have considered the necessary H&S factors for the pending contract.
Always take time to carry out a “post contract review” for continuous improvement of the business. Involve your staff, as they will have been exposed to all the positive and negative aspects of the contract.
Document and learn from any financial loss or contract omissions, and implement the necessary corrective action to close the gaps to increase profit to build your business.

Please contact us if you wish to discuss this further.