Hierarchy of Controls: Why Are They Necessary?

If you have been in the workforce for awhile, especially the industrial sectors, you should have received training on the identification and mitigation of hazards. Of course, the whole idea is to mitigate a hazard down to ALARP (As Low As Reasonably Practicable). What is the decision process for mitigating the hazard and why?

First things first, what is a hazard and why do we need to control them? A hazard can be described as anything with the potential to cause harm. This brings us to why we need to control the hazards; to prevent occupational injury or illness. It is not only good business practice (both ethically and financially), but companies will typically have a legal obligation to provide a safe workplace (OSHA-US, HSE-UK, etc.). Generally speaking, when discussing hazards and control, we speak in terms of risk (likelihood and severity of the hazard causing harm) and mitigation of risk.

The process of controlling risk is called “Heirarchy of Control.” This is a well-established process or methodology to systematically understand the best way to mitigate hazard and risk. It sounds complicated, but in reality it is very simple.

  1. Elimination
  2. Substitution
  3. Engineering Controls
  4. Work Practices / Administrative Controls – Personal Protective Equipment (PPE)
  5. Discipline

Elimination: It is always the best practice to eliminate a hazard or risk whenever possible. If the hazard is not present, it cannot cause harm. It is that simple. I know in reality, most things we do must be done, whether operations, maintenance, logistics. We cannot say we will not do it. But, you may want to ask yourself, “Can I eliminate a specific part or step in the process to make it safer?”

Substitution: Do you use a chemical which has carcinogenic properties or an incredibly caustic chemical? Why not source another chemical or combination of multiple chemicals which are much less hazardous to your health or the environment? You cannot eliminate the process and hazard. But, you can lessen the hazard by substituting a new less hazardous chemical into the process.

Engineering Controls: If you cannot eliminate or substitute, then what should you do? Engineer a control, machine guarding, automated process, noise blocking walls, or guardrails to direct workflow or segregate people from processes. If you have a press that must be manually activated, you could put a control in place that requires the operator to use both hands to function the press. This eliminates the chance of the operator having his hands smashed during the press operation.

The first three controls of the hierarchy are not interchangeable and, pretty much, set in stone. When you move to the bottom section of the hierarchy, things can get a little confusing. Depending what text you are reading, it can differ slightly; however, the controls will include some of the items mentioned below.

Work Practices / Administrative Controls – Personal Protective Equipment (PPE): I believe these items are synonymous in nature. Most policies or procedures will include the use of PPE and most use of PPE is driven by company policy (either directly or indirectly). For example, if you are working on exposed edge more than 6 feet you will need to have barriers or fall protection. The policy, procedures for completing the task and simple risk assessment will dictate whether you also need to use barriers or fall protection. I could give you multiple examples of how this works, but I am confident you have an understanding.

Discipline: In my opinion, this is the last step in control. If all other efforts have failed, there is a good chance an employee has violated company policy. I am a safety guy not an operations supervisor or HR manager so I am not going to dive into the discipline process. What I will say is this… discipline should always be the last line of defense.

The key is to ensure your employees have been trained in the recognition of hazards and how to mitigate them. Whether you agree 100% with my take on the hierarchy of control or not, does not worry me. What concerns me is you cascade the information to the guys doing the work and you get out there and help them complete the process.

OSHAcademy’s free course 704: Hazard Identification, Analysis and Control discusses the hierarchy of controls in much more depth.  Take a look!