What Comes First in 2026: LOTO, JHA, PPE Assessment, or NFPA 70E?
Use this 2026 order: safety program, JHA, PPE assessment, then LOTO and NFPA 70E controls for safer, defensible industrial work.
Published: August 15, 2026 · By Steven Brooks
Category: Industrial Safety
Frequently Asked Questions
Does a JHA replace a lockout/tagout procedure?
No. A JHA identifies the task steps, hazards, and needed controls, while the LOTO procedure gives the exact method for isolating and verifying hazardous energy on the equipment.
Do you do the PPE assessment before or after the JHA?
Usually after the JHA identifies the hazards and after engineering and administrative controls are considered. OSHA's PPE requirement is tied to hazard assessment, so the assessment should reflect the real task exposure.
Where does NFPA 70E fit if OSHA already has electrical rules?
OSHA provides the enforceable baseline in 29 CFR 1910.333 and related rules. NFPA 70E is the recognized framework many employers use to structure the electrical safety work program, risk assessment, and PPE decisions.
What should come first at a company level?
The overall safety program comes first because it sets roles, rules, training, and governance. Then the employer can build task-level JHAs, PPE assessments, and LOTO procedures that match the actual work.
Why do these documents often conflict in the field?
They are often created separately, in the wrong order, or from generic templates. Building them from a task-by-task hazard analysis helps keep controls, PPE, and LOTO instructions aligned.