Once a hazard has been identified, the next step is to develop a strategy for addressing it. For years, safety professionals have relied on a methodology known as the Hierarchy of Controls. Let’s explore the Hierarchy of Controls and the benefits it can provide your hazard identification program.
The hierarchy consists of five control methods:
- Engineering controls
- Administrative controls
- Personal protective equipment (PPE)
The idea behind the hierarchy is that the controls at the top of the list are more effective at reducing employee exposure to workplace hazards than those at the bottom. Let’s look at each control method in more detail starting at the top of the list.
Elimination is the preferred method to address workplace hazards. I recently had a discussion with a client regarding the cleaning of residual grain in the facility’s concrete bins. I was pleasantly surprised that the employees had been working to eliminate completely the need for entry by purchasing specialized reclaim equipment.By eliminating the need for entry, they have eliminated the potential for employees to be exposed to numerous hazards. While an expensive alternative, this allows for the higher level of safety. Elimination may not be feasible for all types of hazards, but should be evaluated regardless. In addition to improved safety, the investment often can be justified by increased productivity and efficiency.
Substitution is a control measure that utilizes less hazardous materials, processes, or equipment. An example would be substituting a hazardous chemical used in the workplace with one that is less hazardous.Another example would be using a self-retracting lifeline (SRL) rather than a lanyard for fall protection. By substituting the SRL for the lanyard, the free fall distance and the potential for severe injury is reduced. Substitution requires leaders to be vigilant in looking for new products, processes, and equipment that allow for a greater level of safety.
Engineering controls are used to remove a hazard or place a barrier between the worker and the hazard. While engineering controls can be expensive to implement, they often provide a greater level of protection than administrative controls and personal protective equipment.Examples of engineering controls include machine guards, interlocks, and ventilation. For example, dust collection systems often are used at the head and boot sections of elevator legs, to reduce suspended dust in the leg to levels below the minimum explosive concentration.
Administrative controls are procedures or policies used to manage exposure to hazards. Let’s return to our example of entering grain bins to reclaim the residual grain. We have identified that the best option would be to eliminate the need to enter the bin through the use of specialized equipment or other means. This may not be feasible in every situation for various reasons (bin characteristics, cost, etc.). n example of an administrative control would be developing a procedure for safe entry into the bin. It would require the use of a confined space entry permit, atmospheric monitoring, lockout of internal moving parts, etc. Employees need to be trained on the procedure, and management must ensure that procedures are followed.
Personal Protective Equipment
PPE is the last resort when addressing exposure to hazards. Let’s use our example of entering the grain bin once more. Entry into bins for cleaning may expose employees to respirable dust. It’s very difficult to eliminate dust inside of a grain bin; therefore, PPE may be an effective alternative. In this case, the proper form of respiratory protection would need to be determined, employees would need to be trained on its use, limitations, etc., and management would need to ensure that respiratory protection is used as required.
The Hierarchy of Controls provides a methodology for addressing exposure to workplace hazards. We have looked at five separate control methods within the hierarchy. I encourage you to share this information with your team. The next time a hazard is identified, start at the top, and work your way through the five control methods identifying which are most feasible both short and longer term. Using this method will take your hazard identification program to the next level.
Written by: Joe Mlynek CSP, OHST – Progressive Safety Services LLC