Activity Hazard Assessment (AHA) is a step-by-step review of a task that examines hazards that exist at each step and identifies controls that will eliminate or reduce the potential exposure to that hazard. These AHAs must be sited and should focus on COVID-19 associated risk but should not be limited to COVID-19 hazards exclusively. For example, when assessing a hands-on training for a research fellow, consideration should be given to potential SARS-CoV-2 exposures, but should also consider other hazards such as chemicals, sharps, or lasers.
When identifying the potential for SARS-CoV-2 exposure, supervisors should collaborate with the staff performing the task to determine when potential exposure points exist. Focus on scenarios in which physical distancing is not possible, or close contact is required for greater than 15 minutes. Additionally, the AHA should consider space ventilation and whether multiple personnel may occupy the space for an extended period. Physical distancing alone may not be an adequate control in a space where there is low ventilation and personnel occupy the space for hours. Also consider where equipment is likely to be shared.
The AHA should also include controls for exposure. The hierarchy of controls (i.e., the order of most reliable to least) is:
- Elimination: If the task or step is unnecessary, consider not doing it. This removes the potential for exposures. An example for COVID-19 might include eliminating a process or meeting that is unnecessary.
- Substitution: Identify an alternate means of accomplishing the goal that involves lower risk of exposure. For example, consider revising training to have self-guided or remote training where appropriate and supplement with specific, short duration, in-person training where self-guided training or remote training is inadequate.
- Engineering Controls: This involves the use of mechanical equipment to control exposure to hazards. Examples might include maximizing air exchanges in rooms where personnel must work closely together, using a down-draft table when demonstrating surgical techniques, or conducting work at a chemical fume hood or biological safety cabinet to reduce potential exposures.
- Administrative Controls. The use of procedures and practices to reduce risk of exposure. Physical distancing, working in shifts, room occupancy limits, floor markings, and signage reminding personnel of expected behaviors are examples of administrative controls.
- Personal Protective Equipment (PPE). This should be considered the last line of defense and should be in place in case other controls fail. For reducing SARS-CoV-2 exposure, this would include procedure/surgical masks, gloves, and where appropriate, respirators. Additional PPE controls beyond the standard requirements of the site should be considered for any work that requires personnel to work in close proximity for greater than 15 minutes.
After the AHA has been conducted and controls have been identified, personnel must then be trained on the controls identified in the AHA to ensure they are properly implemented. Training on the AHA should be sited by the supervisor.
Lastly, an AHA should be considered a “living document.” The AHA should undergo routine reevaluation to determine the effectiveness of the controls, the training of the personnel using the controls, and the potential for improving to more effective mitigations on the hierarchy of controls. DOHS recommends that these controls be reevaluated after the first implementation, revised to capture lessons learned, and then reevaluated at least once per year. The AHAs should also be reviewed and revised after any incident where employees were exposed to a hazard. The DOHS is available to assist with developing your AHAs.