Hazard identification

What is hazard identification?

Royal Decree 39/1997 structures the risk assessment procedure into three phases: hazard identification, risk assessment using objective criteria, and conclusions regarding the need for measures. Identification is the starting phase and conditions everything else: an unidentified hazard is not assessed, not controlled, and does not appear in the prevention plan. The INSST Basic Guidelines place it as stage 1 and describe it as the identification of working conditions that, due to their characteristics, are likely to cause harm to the worker.

A well-executed hazard identification process is systematic, because it covers all positions, tasks, and people, not just the obvious; descriptive, because it names the hazard, its source, the exposure situation, and the form of harm; participatory, because it consults those who perform the work and their representatives; and prior to assessment, because it doesn’t require measuring or quantifying, but rather recognizing and recording. Accident history is helpful, but it doesn’t replace observation of the actual work.

In Spain, hazard identification is integrated into the risk assessment required by Article 16 of Law 31/1995 and forms part of the company’s preventive documentation. In the European Union, it derives from Directive 89/391/EEC. In Latin America, the same process is often called IPER or IPERC and is documented in matrices with their own specific format; in the United States, OSHA refers to it as hazard identification and assessment in its recommended practices, which are technical guidelines and not regulations applicable in Spain.

Differences between hazard identification, risk assessment and IPER

The three terms are confused because they describe moments of the same process and because the terminology changes depending on the country and the reference standard.

• Hazard identification. Recognition and description of the sources and situations capable of causing harm. It answers what can cause harm, to whom, and how. It does not yet assign a level of risk.
• Risk assessment. A comprehensive process that, based on identified hazards, estimates the magnitude of unavoidable risks and determines what measures are necessary. It answers the question of how much risk exists and the priority with which action should be taken.
• IPER. This is the common term in Peru, Colombia, Chile, and other Latin American countries for the identification of hazards and risk assessment combined into a single matrix; when it incorporates controls, it is called IPERC. It is the same process with a different documentary format.

Practical rule: if the result is a descriptive list of hazards by position or task, it is being identified; if the result includes probability, severity, and priority, it is being assessed.

How is hazard identification performed?

The identification process is organized by units of analysis: job positions, tasks, or processes, and, in highly variable activities, specific phases or operations. For each unit, the actual work is described, not just the written procedure, and the observed conditions are compared with the families of possible hazards: safety, physical, chemical, biological, ergonomic, and psychosocial.

The scope must include normal operations as well as unusual or sporadic situations: maintenance, repairs, cleaning, start-up and shutdown, breakdowns, and foreseeable emergencies. It must consider all potentially affected individuals, including contractors, temporary staff, and visitors, as well as those who are particularly vulnerable due to their personal characteristics or biological condition, as required by Article 4 of Royal Decree 39/1997.

1. Define the scope and units of analysis (centers, positions, tasks, processes), with the people involved and those responsible for each phase.
2. Gather existing information: instruction manuals, safety data sheets, inspection reports, maintenance records, previous assessments, accident and incident data, and health surveillance results.
3. Observe the work in its actual location and conditions, including non-routine tasks, and compare it with what has been documented.
4. Consult with workers and worker safety representatives, who have the right to be consulted about the procedure and to accompany technical staff during the assessments.
5. Describe each hazard accurately: source, exposure situation, people exposed and possible harm, using concrete and verifiable language.
6. Record the result in a traceable format that allows for risk assessment and updating the list when conditions change.

The INSST Basic Guidelines recommend using checklists, interviews, questionnaires, photographs, and videos as auxiliary tools. None of these replace direct observation or the technical judgment of the evaluator.

Most commonly used techniques and sources of information

There is no single technique. The choice depends on the type of activity, the family of hazards, and the information available, and in practice, techniques are combined.

• Document analysis. Equipment manuals, safety data sheets, work instructions, inspection and audit reports, prior assessments and measurements.
• Work inspection and observation. Planned visits to the workplace, task observations and safety walkthroughs, supported by checklists adapted to the activity.
• Consultation and participation. Interviews, questionnaires, and meetings with workers, managers, and safety representatives. In psychosocial hazards, consultation is the primary source of identification.
• Analysis of events. Investigation of reported accidents, incidents, and hazardous situations. Accident and health surveillance data reveal hazards that the inspection did not detect.
• Task and change analysis. Breaking down a task into steps and reviewing a process before introducing equipment, substances, technology, or organizational changes, to identify new hazards before exposure occurs.

For hygiene, ergonomic, or psychosocial hazards, identification usually requires specialized knowledge; for safety hazards, direct observation and checklists cover most cases. Generic lists help to avoid overlooking hazard categories, but they do not demonstrate that actual work has been observed.

How it is documented and kept up to date

Identification is part of the risk assessment which, in Spain, must be documented and kept available for the labor authority. A useful identification record meets, at a minimum, these conditions:

1. Identify the center, position or task and the date of identification.
2. Describe each hazard with its source, the exposure situation, and the possible harm.
3. Indicate the people or groups exposed, including those who are especially sensitive.
4. It includes the control measures already in place at the time of identification.
5. Identify who performed the identification and who was consulted, and link each hazard to its subsequent assessment and the planning of measures.
6. Keep previous versions to maintain traceability of changes.

The hazard list is not static. It must be reviewed when health problems are detected, when periodic checks show that the measures are inadequate or insufficient, when working conditions, equipment, substances, or the organization change, and at intervals agreed upon with workers’ representatives, as per Article 6 of Royal Decree 39/1997. In the event of a hazard with the potential to cause serious and imminent harm, immediate measures are taken and the situation is recorded for later analysis.

Regulatory framework in Spain and the European Union

• Law 31/1995, articles 15, 16 and 18. They require avoiding risks and evaluating those that cannot be avoided, carrying out an initial assessment that takes into account the activity, the positions and the people who occupy them, repeating it when choosing equipment or substances or when conditioning workplaces, and reporting the identified risks.
• Royal Decree 39/1997, articles 3 to 7. They define the evaluation as the process aimed at estimating the magnitude of the risks that could not be avoided, they set its content by job position, they place the identification of hazards as the first phase of the procedure and they regulate its review and documentation.
• Law 31/1995, articles 33 and 36. Consultation of workers on the evaluation procedure and the right of worker safety representatives to accompany technical staff during the evaluations.
• Directive 89/391/EEC, Articles 6 and 9. General obligation of the employer to assess the risks to safety and health and to have a documented assessment; it is the basis of the Spanish framework and the EU-OSHA OiRA tools.

In other areas, the ILO includes hazard identification in the ILO-OSH 2001 guidelines, and the US OSHA incorporates it as a core element of its recommended practices for occupational safety and health programs. Both are technical references, not regulations applicable in Spain.