Audit, Compliance and Risk Blog

Applying A Hierarchy of Controls to Increase Workplace Safety

Posted by Jon Elliott on Tue, Jun 28, 2016

Hazards_sign.jpgEvery workplace poses at least some potential hazards to workers, but every set of hazards is unique. To effectively identify and manage those hazards, an organization should apply logical and systematic approaches. A number of related approaches are available. A few months ago I blogged about a proposal by the Occupational Safety and Health Administration (OSHA) to revise the Safety and Health Program Management Guidelines it promulgated back in 1989 (click here) – comments were due in February and OSHA is considering what to do next. OSHA’s proposal focused on overall program design, so included important structural considerations – who’s in charge, how are expectations communicated, etc.

Meanwhile, readers can consider a narrower approach to individual hazards. “Hierarchy of controls” is advocated by many industrial hygienists and safety professionals. One example of this approach appears in information from the National Institute for Occupational Safety and Health (NIOSH).

What Does NIOSH Recommend?

NIOSH provides a multi-step approach, which generally should be considered a sequence of efforts to reduce the inherent hazards in a workplace.

  • First, eliminate hazards that can be eliminated

The only way to completely avoid a hazard is to eliminate it. If your workplace uses carcinogenic solvents, the cancer risk can be removed by substituting safer chemicals. Recognize, however, that this may be easier to say than to do, if the hazardous chemical or component is critical to workplace activities. On the other hand, it may be easier to remove hazards when preparing to expand operations to a new location, or when planning for major modifications of an existing workplace.

  • Second, substitute lower-hazard alternatives

If you can’t eliminate a hazard, you may still be able to reduce it somewhat. For example, many locations have replaced compressed gases with liquids, or liquids with solids. Others have found they can perform their work with less-concentrated chemicals, or chemicals that are less acidic or corrosive. Workplace activities are still inherently hazardous, but less so because spills or releases would have less drastic consequences.

  • Third, install engineering controls to separate workers from hazards

Many of OSHA’s safety standards begin with this step: assuming the workplace needs to continue to employ the hazardous chemical or equipment, employers can still build in barriers between the hazard and the workers. This can include more robust primary (and maybe secondary) containment, walls or other impediments to contact, and point-of-operation barriers such as machine guarding.

  • Next, enforce administrative controls to improve workers’ use of the hazardous elements

Another major focus of OSHA standards is on the design of safer procedures, and on training and workplace oversight to ensure that workers actually follow those procedures in the presence of the hazards. These often involve thorough Standard Operating Procedures (SOPs) intended to ensure that each necessary step is taken and each associated precaution followed. They also include efforts to ensure that employees stay out of tight spaces, watch out for moving parts, and stay alert for sounds, sights and smells that may mean something’s amiss.

  • Finally, use personal protective equipment to personalize barriers between hazards and workers

OSHA requires PPE when necessary … when an acknowledged hazard cannot be mitigated far enough to be “safe” for workers. Remember that employers are generally not allowed to skip to this last step as a way to avoid other changes and controls that may be more expensive or disruptive. So an employer can’t just spend more to buy good headphones rather than attempt noise mitigation, or give everyone a respirator so the workplace’s air can remain hazardous.

How Might It Work In The Real World?

In most situations, the sequence NIOSH conceptualizes actually turns into a five-pronged approach to safety. Employers and their health and safety personnel apply all these efforts simultaneously, seeking to optimize workplace safety with the organization’s missions. OSHA standards and industry-promoted SOPs are designed to facilitate these efforts and prevent dangerous shortcuts.

Self-Evaluation Checklist

Does the organization take steps to identify and assess workplace hazards?

Does the organization implement hazard prevention and control activities?

Do control activities consider all the steps in NIOSH’s hierarchy:

  • Hazard elimination

  • Substitutions to reduce hazards

  • Engineering controls

  • Administrative controls (including associated training)

  • PPE

Where Can I Go For More Information?

Specialty Technical Publishers (STP) provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements. These include:

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About the Author

jon_f_elliott.jpgJon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 25 years. He was involved in developing 12 existing products, including Environmental Compliance: A Simplified National Guide and The Complete Guide to Environmental Law.

Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).

Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).

You may contact Mr. Elliott directly at: tei@ix.netcom.com.

photo credit: physical hazard label via photopin (license)

Tags: Health & Safety, OSHA, EHS, Employer Best Practices, Employee Rights