WHY MUST JSA AND JHA BE PART OF THE METHOD STATEMENT?

I was delivering a short course on ISO 9000 when several participants posed some very challenging questions. I genuinely appreciated the engagement they were not just asking for the sake of it, but trying to connect the requirements to real construction practices and avoid ambiguity. (Though, to be fair, a few were clearly testing the “old man” as well.)

Q: Why must Job Safety Analysis (JSA) and Job Hazard Analysis (JHA) be addressed in a Method Statement?

A: JSA and JHA are not separate from the Method Statement, they are embedded within it.

The Method Statement forms part of the formal document submission, alongside drawings, material submissions, PQP, POSH Plan, PEMS Plan (or an integrated plan). These are typically stipulated either explicitly or by standard practice in the contract.

From an ISO 9000 perspective, this aligns with fulfilling client and statutory requirements. Failure to incorporate JSA/JHA can result in rejected submissions, delays, additional costs etc.

Q: But what if the contract does not clearly state the need for submission?

A : One must look beyond literal wording and understand the intent and linkage of requirements.

For example, when a Quality Manual defines Job Descriptions, Responsibilities, and Authorities, it is indirectly tied to compliance with the Employment Act 1955.

Similarly, JSA and JHA can fall under Responsibilities and Authorities, especially in managing operational risks.

More importantly, virtually all construction contracts include provisions on Safety and Health practices. Whether expressed or implied, these provisions require compliance with the Occupational Safety and Health Act 1994 (Amendment 2022) which mandates structured risk assessments such as HIRARC for all work activities. JSA and JHA are practical tools to demonstrate that these requirements are being fulfilled.

Additionally, most contracts contain a standard legal clause stating that the agreement shall be governed by the laws of Malaysia. This automatically incorporates all applicable statutory obligations even if not spelled out line by line.

From a practical construction standpoint, integrating JSA/JHA into the Method Statement also:

• Improves clarity for site execution teams
• Aligns safety controls with actual work sequences
• Reduces rework, incidents, and disruptions
• Provides defensible documentation during audits, inspections, or incident investigations

Even if not explicitly stated, the requirement for JSA and JHA is driven by a combination of contractual obligations, statutory compliance, and good engineering practice. In construction, what is “not written clearly” is often still required by law, implied by contract, and expected by industry standards.