Two PHA provisions deal with consequences, and they are often confused. 29 CFR 1910.119(e)(3)(iv) requires the PHA to address the consequences of failure of engineering and administrative controls. 29 CFR 1910.119(e)(3)(vii) requires a qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. OSHA's most detailed explanation of how they fit together came in a 2005 letter that included a worked example and a sample risk matrix.

What OSHA Has Said

Feb 1, 2005
(e)(3)(iv) vs. (e)(3)(vii): two different consequence requirements
A consultant asked what documentation satisfies the PHA requirement for "a qualitative evaluation of a range of the possible safety and health effects of failure of controls." OSHA explained that (e)(3)(iv) requires the team to identify hazardous situations where engineering and administrative controls fail and the consequences of those failures, while (e)(3)(vii) requires the team to use that information for a qualitative evaluation that helps prioritize prevention and mitigation. Documentation can follow the format of the PHA methodology used, and OSHA attached a sample consequence/likelihood risk matrix as one way to comply. OSHA said it has no fixed criteria and judges compliance case by case, but a PHA that identifies controls and their failures without evaluating and documenting the range of effects does not comply.
Read OSHA Letter ↗

⚡ Key Compliance Takeaway

Make sure your PHA worksheets show both steps: what happens when each safeguard fails (the consequence), and a documented qualitative ranking of severity and likelihood used to prioritize recommendations. A risk matrix is the common way to do it, but OSHA accepts any method that genuinely evaluates and documents the range of effects. A PHA that lists consequences but never ranks them is the gap inspectors find.