Management System Documentation

EHS-207
CORPORATE HAZARD IDENTIFICATION AND RISK
ASSESSMENT PROCEDURE
Version H
November 14, 2019

11/14/2019
Brett Larsen Executive VP of Administration CFO & Date
Treasurer
11/14/2019
David Knaggs EVP of Quality and Information Systems Date

11/14/2019
Jim Riley Owner Date

Version Version Date Change Description

Incorporated the new ISO 45001 requirements, simplified the
H 11/14/2019
risk assessment process, updated format
Added definition for Safety/Environmental Deprtment and
G 6/21/2017 added Section 5.7 on approvals for after the assessment is
completed.
F 3/21/2017 Correct electronic file name.
F 3/14/2017 Update Table of Contents
Changed document number from KTC-HR-0007 to EHS-207
F 3/14/2017 and added references to compliance obligations and
environment.
New owner, approver, site, and Doc Type (from Stand Alone to
E 2/23/2017
Management System)
Change to KTC-HR-0007 - CORPORATE HAZARD
E 8/24/2016
IDENTIFICATION AND RISK ASSESSMENT PROCEDURE
CREATE KTC-HR-0007, REV D( USE H&S 201 REV
HISTORY), CHG PROCEDURE TO MATCH JZ AND KTS.
CREATE FORM KTC-HR-F0005A, HAZARD IDENTIFICATION
D 11/19/2015
& RISK ASSESSMENT, CREATE KTC-HR-F0005B, RISK
REDUCTION PROGRAM, CREATE KTC-HR-F0005C,
OPERATIONAL CONTROL DATA SHEET.
 0003823 CORPORATE HAZARD IDENTIFICATION
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AND RISK ASSESSMENT PROCEDURE Version H Version Date 11/14/2019
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EHS-207
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CORPORATE HAZARD IDENTIFICATION

AND RISK ASSESSMENT PROCEDURE
Document # EHS-207

1.0 PURPOSE, SCOPE AND APPLICABILITY ............................................................2

2.0 PROCESS OWNER AND RESPONSIBILITIES ......................................................2
3.0 REFERENCES AND DEFINITIONS ........................................................................3
4.0 HAZARD IDENTIFICATION AND RISK ASSESSMENT PROCEDURE ................4

(Dist: KTC)

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1.0 PURPOSE, SCOPE AND APPLICABILITY

1.1. Purpose
The purpose of this procedure is to define the methodology used by Key Tronic
for the ongoing proactive identification of hazards, the evaluation and
assessment of risks and the establishment of controls to mitigate those risks.
1.2. Scope
1.2.1. The hazard identification and risk assessment (HIRA) process is
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ongoing and proactive, begins at the development stage of any new

product or process, and continues through its life cycle.
1.2.2. The HIRA process helps recognize and understand the hazards in the
workplace and to employees, in order to assess, prioritize and
eliminate hazards or reduce risks.
1.2.3. HIRAs are:
1.2.3.1. Conducted by persons with competence in relevant hazard
identification methodologies and techniques and appropriate
knowledge of the work activity.
1.2.3.2. Conducted prior to starting new processes, implementing
changes to current processes and in response to EH&S
related incidents.
1.2.3.3. Are documented and kept up-to-date.
1.3. Applicability
This procedure applies to all Key Tronic sites that are certified to ISO
14001:2015 and/or ISO 45001:2018.

2.0 PROCESS OWNER AND RESPONSIBILITIES

2.1. Process Owner
2.1.1. The Executive Vice President and CFO is the executive owner of the
EHSMS.
2.2. The Corporate EH&S Manager
2.2.1. The Corporate EH&S Manager is appointed the Corporate
“Management Representative” responsible to assure the
implementation of the policies and procedures as delineated within this
document.
2.3. Site Human Resources Manager
2.3.1. The Site Human Resources Managers are appointed the Site
“Management Representative” responsible to implement the policies
and procedures as outlined within this document throughout their sites.
2.3.2. The Site Human Resources Managers may appoint a Manager or
Supervisor of Environmental, Health and Safety to serve as the “Local

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Management Representative”. This appointment does not remove the

Site Human Resource Managers of the responsibility for the process.
2.3.3. The Site Human Resources Managers are responsible for maintaining
records of periodic evaluations of compliance with applicable EH&S
compliance obligations in accordance with Key Tronic Corporation
Records Retention Program (DRC-204).
2.4. Site EH&S Managers
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2.4.1. The site EH&S Managers or their appointed representative are

responsible for ensuring that hazards are identified, risks are assessed
and controls are implemented to mitigate the risks.
2.5. Safety/Environmental Department (if applicable)
2.5.1. The Safety/Environmental Department is responsible for conducting
hazard identifications, risk assessments and implementing controls to
mitigate risks.
2.6. Process Owners
Process owners are responsible for the defining, implementing and reviewing
prevention programs when risk levels are not at an acceptable level. Process
owners are also responsible for conducting hazard identification and risk
assessment if sites do not have a Safety/Environmental Department.

3.0 REFERENCES AND DEFINITIONS

3.1. References:
DRC-204 Key Tronic Corporation Record Retention Policy
EHS-101 Corporate EH&S Management System Manual
EHS-203 Corporate Hazard Communication Program
EHS-204 Corporate Accident Prevention ProgramEHS-207
Corporate Hazard Identification and Risk Assessment
Procedure
EHS-207SW1 Juarez Hazard Identification and Risk Assessment
Procedure
EHS-209 Corporate Identification of Environmental Aspects
Procedure
EHS-210 Corporate Portable and Fixed Ladder Procedure
HR-201 Corporate Education Training Policy
MS-204 EH&S Policies
EHS-F207a Hazard Identification and Risk Assessment Worksheet
EHS-F207b Risk Reduction Worksheet
EHS-F207c Operational Control Data Sheet
EHS-F207d PPE Training Certification Form
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ISO 45001 OHS Management Systems Standard

3.2. Definitions:
Acceptable Risk Risk that has been reduced to a level that can be
tolerated by the organization having regard to its
compliance obligations and its’ EH&S policy.
EH&S Environmental, Health and Safety
Hazard Source, situation or act with a potential for harm in terms
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of human injury, ill health, environment or a combination

of all of these.
Hazard Identification Process of recognizing that a hazard exists and defining
its characteristics.
HIRA Hazard Identification and Risk Analysis
HIRA Worksheet The hazard identification and risk analysis worksheet
used to determine process and equipment hazards, risks,
controls, and risk ratings.
Probability The likelihood that a given risk event will occur.
Risk Combination of the likelihood and consequence(s) of a
specified hazardous event.
Risk Assessment Process of evaluating the risk(s) arising from hazard(s),
taking into account the adequacy of any existing controls,
and deciding whether or not the risk(s) are acceptable.
Safety/Enviro Dept. Dedicated group of employees assigned to focus on
safety and environmental issues for the facility. This
group is responsible for the completion of risk
assessments, risk reductions and operational controls.
Facilities that do not have a dedicated group must rely on
the process owner to complete these tasks.
Severity The extent of the damage to the organization, its people,
and its goals and objectives resulting from a risk event
occurring.

4.0 HAZARD IDENTIFICATION AND RISK ASSESSMENT PROCEDURE

4.1. General
4.1.1. Products, processes and equipment, with a potential for workplace or
employee hazards, are required to have a Hazard Identification and
Risk Assessment (HIRA) to ensure the EH&S and other risks are at an
acceptable level.
4.1.2. Employee consultation and participation is an important part of the
HIRA process. Whenever possible cross-functional teams should be
utilized so that employees can provide input to the hazard
identification, risk analysis and identification of controls.

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4.2. HIRA Worksheet

4.2.1. The HIRA worksheet (EHS-F207a) is to be used to document process
or equipment hazard identification and risk assessments.
4.2.1.1. A variation of this form may be used as long as it is
controlled and contains the same parameters, criteria and
has three approval signatures.
4.2.1.2. HIRA forms developed specifically for meeting local, state or
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federal compliance obligations are also acceptable.

4.2.2. Activities
4.2.2.1. Under the “Activities” column of the form, list the routine
activities, non-routine activities and emergency situations
associated with the product, process or equipment.
4.2.3. Hazards
4.2.3.1. Under the “Hazards” column of the form, list the potential
hazards associated with each activity. Potential hazards
include:
 Physical (slips, trips, falls, noise)
 Chemical (gases, dusts, fumes, liquids)
 Biological (microorganism, virus, toxins)
 Mechanical (tools and equipment)
 Electrical (shock, fire, explosion)
 Environmental (air, water, soil pollution)
4.2.3.2. The hazard identification process shall take into account, but
not be limited to:
 How work is organized, social factors, leadership and
the culture in the organization.
 Past relevant incident, internal or external to the
organization, including emergencies and their causes.
 People, including those with access to the workplace
and their activities, including employees, contractors,
visitors and other persons.
 Those in the vicinity of the workplace who can be
affected by the activities of the organization
 Workers at a location not under the direct control of
the organization.
 Other issues including the design of the work area,
processes, installations, machinery/equipment, and
operating procedures.
4.2.4. Risks
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4.2.4.1. Under the “Risks” column of the form, list the risks
associated with the potential hazards previously identified.
 Health and safety risks have the possibility that harm
(i.e. death, an injury or an illness) might occur when
exposed to a hazard.
 Environmental Risks are actual or potential threats of
adverse effects on living organisms and the
environment by discharge, emissions, wastes,
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resource depletion, etc., arising out of an

organization's activities.
4.2.4.2. Common risks include but are not limited to:

Health & Safety Environmental

 Abrasion  Air pollution
 Contusion (bruise)  Carbon emissions
 Cuts and lacerations  Deforestation
 Death  Loss of natural resources
 Electrical shock  Soil contamination
 Eye irritation  Water pollution
 Hearing loss
 Inhalation
 Muscle strain
 Skin irritation
 Sprains

4.2.5. Existing Controls

4.2.5.1. Under the “Existing Controls” column of the form, list the
effective engineering controls currently in place to isolate
people from hazards and personal protective equipment
(PPE).
4.2.5.2. Common controls include but are limited to:

Engineering Controls PPE

 Adjustable chair  Ear plugs
 Automatic shutoff  Chemical gloves
 Equipment guard  Cut resistant gloves
 Lockout / Tagout  Respirator
 Self-closing dispenser  Safety glasses
 Shield  Safety harness
 Ventilation hood  Steel toed shoes
4.2.6. Severity Rating
4.2.6.1. Under the “Severity” column of the form, using the severity
rating scale below, rate each risk taking into account the
effectiveness of existing controls.
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 Insignificant 1
 Minor 2
 Moderate 3
 Major 4
 Catastrophic 5
4.2.7. Probability Rating
4.2.7.1. Under the “Probability” column of the form, using the
probability rating scale below, rate each risk taking into
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account the effectiveness of existing controls.

 Expected 5
 Likely 4
 Possible 3
 Unlikely 2
 Very Unlikely 1
4.2.8. Total Rating
4.2.8.1. Under the “Total” column of the form, for each risk, enter the
results of the severity rating multiplied by the probability
rating.
4.2.9. Risk Level
4.2.9.1. Under the “Risk Level” column of the form, enter the rating
level that correlates with the total rating number from the
table below:
Severity

Insignificant Minor Moderate Major Catastrophic

(1) (2) (3) (4) (5)

Very
Expected Medium High High Very High
High
(5) (5) (10) (15) (25)
(20)

Likely Low Medium High High Very High

Probability

(4) (4) (8) (12) (16) (20)

Possible Low Medium Medium High High

(3) (3) (6) (9) (12) (15)

Unlikely Low Low Medium Medium High

(2) (2) (4) (6) (8) (10)

Very Low Low Low Low Medium

unlikely(1) (1) (2) (3) (4) (5)

4.2.10. Approvals
4.2.10.1. After completing the HIRA, the evaluation person(s),
Department Manager and the EH&S person needs to sign
the HIRA to indicate it is complete and accurate.
4.3. Risk Reduction
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4.3.1. Knowing the level of risk enables us to determine if action needs to be

taken to eliminate hazards, substitute hazards, improve existing
controls, add new controls or add worker PPE to reduce risks to an
acceptable risk level.
4.3.1.1. Below is the hierarchy of controls with hazard elimination
being the preferred method and PPE being the least
preferred but acceptable method.
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4.3.2. When eliminating or reducing risk, priority should always be given to

those activities with the highest risk rating; the table below indicates at
what risk level action needs to be taken.
Risk Risk
Required Action
Level Rating

Low 1-4 No action required.

Existing controls are adequate, monitor to ensure controls are

Medium 5-9
maintained.
Implement, with deadlines, measures to reduce risk. Take
High 10 - 16
into account the cost effectiveness of such measures.
Very Stop work until the risk is reduced; allocate sufficient
20 - 25
High resources to significantly reduce the risk.

4.3.3. If action is required a Risk Reduction Worksheet (EHS-F207b) or other

corrective action type form must be completed to document what
actions were taken to mitigate the risk.
4.3.3.1. Using a cross functional team to brainstorm the process or
equipment is recommended.
4.3.3.2. When all of the identified actions have been completed the
HIRA should be reassessed to ensure the risks have been
eliminated or reduced to an acceptable level.
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4.4. Operational Controls

4.4.1. Controls need to be communicated to workers through either Work
Instructions or Operational Control Data Sheets.
4.4.1.1. Work Instructions or Operational Control Data Sheets should
be posted in the vicinity of the process or equipment referred
to on the Work Instruction or Operational Control Data
Sheet.
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4.4.1.2. Workers need to be trained to their operational controls and

training records must be retained.

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