OSHA’s Hierarchy of Controls is an integral component of their current Recommended Practices for Safety and Health Programs, which updated their 1989 guidelines to more accurately reflect the changing nature of our workplaces.
In typical OSHA fashion, these recommendations address principles that result in the continuous improvement of core business processes, rather than laying out specific actions. This allows enough flexibility that the recommendations can easily be applied in any industry, from construction to retail.
These principles start with the creation of a safety culture through top-down leadership in identifying safety and health as a critical component of successful business operations. They emphasize the key role of workers in identifying hazards and finding the best solutions.
Most importantly, these recommendations call for the creation of a systematic approach to finding and fixing workplace hazards. This is where a health and safety hierarchy comes into play.
Taking a closer look at OSHA, their goal, of course, is to protect workers so that everyone goes home healthy at the end of their shift. These recommended practices represent a proactive approach to safety and health in the workplace, rather than reacting after the fact.
Now that you’ve got a better understanding of the rationale behind OSHA’s recommended practices, let’s look at some specifics.
Hazard Identification
This is where the hierarchy of control of occupational hazards and the process of improving safety and health really starts. If you’re unaware of hazards, it won’t cross your mind to take any preventative action.
How do you identify hazards? Fortunately, when it comes to the hierarchy of controls, OSHA has some guidelines on the hazard identification process, which will be a necessary first step. Failure to identify and assess your workplace hazards forces you to be reactive, waiting until accidents happen.
Here are some hazard identification and assessment actions you should be doing routinely:
- Identify known hazards presented by the tools and equipment used in your workplace.
- Conduct routine workplace inspections to identify any new hazards caused by specific work practices.
- Investigate any injuries, incidents, illnesses, or close call/near miss situations to identify the underlying hazard, dangerous work practice, or failure in your current safety program.
- Look for trends in types of injuries and illnesses to identify underlying hazards.
Fix any hazard possible on the spot. Certain hazards, such as trip/fall hazards are easily handled this way. Other hazards require more systemic corrective approaches.
It’s important to assess the risk associated with each hazard you identify. Think of risk as a combination of a hazard and your workers’ exposure to that hazard. To mitigate the risk, control or eliminate the hazard or reduce your workers’ exposure to that hazard. Looking at risk helps you prioritize which hazards to eliminate or control first.
What Is Hierarchy of Controls?
A simple, workable hierarchy of controls definition is that it’s a framework that identifies the relative effectiveness of various corrective actions that can be taken to mitigate safety hazards. This video will help you understand the concept:
Why would you need a hierarchy of controls? OSHA recognizes the role of human fallibility when it comes to safety. Removing the hazard entirely is going to be a much more effective action than depending on workers to wear their PPE.
Based on human nature, this hierarchy provides an easy-to-follow framework that couples the effectiveness of a preventative action with the likelihood that it will actually work in mitigating the risk of a specific hazard. Take a look at the inverted hierarchy of controls pyramid to understand its relationship to your safety program:
OSHA’s Hierarchy of Controls, at a glance.
Hierarchy of Controls Method and Process
So, how do you put this all together to make it work for you? Remember, first you’ll need to identify your hazard. Start with the one that’s posing the most risk to your workers, maybe one they are exposed to on a daily basis.
Next, get your workers involved. Have them help you identify what’s causing the hazard. Gather their ideas on options for eliminating or controlling the hazard, by starting at the top of the hierarchy:
- Elimination: This is always where you should start. Is it possible to physically eliminate the hazard entirely? Notice that this type of corrective action doesn’t depend on your worker remembering to do something.
- Substitution: Is it possible to replace the hazard, for example changing the equipment or tools used to perform a hazardous task? The effectiveness of this type of preventative action is, like elimination, also not worker-dependent.
- Engineering Controls: Is it possible to create a physical barrier between your workers and the hazard? If your workers are not directly exposed to the hazard, the likelihood of injury is reduced.
- Administrative Controls: Is it possible to change the process or the way that your workers are performing a hazardous job? This type of control is highly dependent on workers following the preventative process.
- Personal Protective Equipment (PPE): If none of the above are realistic, is it possible to provide PPE that will protect your workers from the hazard? Again, you have to rely on your workers remembering to don PPE each time they encounter the hazardous situation.
Select controls that are the most feasible, the most effective in mitigating risk from the hazard, the most cost effective (everybody has a budget!), and the most permanent in eliminating or controlling the hazard.
Hierarchy of Controls Examples
Let’s look at a real-life example of how this process works. If your workers use utility knives, the hazard that they’re exposed to on a daily basis is the risk of laceration injuries. Use the hierarchy to decide on the best control to implement.
- Elimination: Stop having your workers perform tasks with utility knives.
- Substitution: Provide your workers with safer utility knives. Slice® makes a complete line of utility knives that use our finger-friendly® blades that are safe to touch, reducing the likelihood of lacerations from incidental contact with the blade.
- Engineering Controls: It isn’t feasible to place any kind of barrier between the utility knife and the material your workers are cutting.
- Administrative Controls: Can you change work processes so only certain workers are entrusted with using utility knives? This might slow down your operations in some cases.
- PPE: You could issue work gloves that would reduce the likelihood of lacerations. These gloves also reduce manual dexterity, risking that some workers won’t comply with PPE regulations.
Another example: You’ve instituted a safety policy that requires your workers to use auto-retractable knives. You find that workers have taped the sliders open, keeping dangerous traditional blades exposed and risking lacerations. Let’s apply the hierarchy to select an appropriate corrective action.
- Elimination: You outsource or remove the work requiring the use of utility knives, thereby removing the hazard.
- Substitution: You provide your workers with Slice’s 10558 Smart-Retracting Utility Knife which has a mechanism in the handle that instantly retracts its finger-friendly blade when cutting pressure ceases, even if the slider is still engaged. This knife outsmarts your workers!
- Engineering Controls: Again, these wouldn’t work if you still want your workers to perform cutting tasks.
- Administrative Controls: You change your work process to limit the use of utility knives.
PPE: You issue work gloves, and hope that your workers will wear them.
In these cases, substitution of a safer tool is your most feasible, effective, permanent, and least costly hazard control.
As a safety manager in your organization, you have an obligation to keep your workers as safe as possible. By using a hierarchy of controls, you will have a systematic way to protect workers, even when they must engage in inherently dangerous activities.
