Hierarchy of Hazard Controls
After you have successfully identified all of the hazards your employees face in the workplace, the next step is to prevent or control the risks. Many employers believe that this simply involves buying personal protective equipment (PPE) for workers, but according to OSHA’s established hierarchy of hazard controls, PPE is a last resort that should only be applied when three other methods of control of failed.
The hierarchy of hazard controls is often represented by a five-tiered pyramid. Controlling and preventing hazards starts at the top of the pyramid because as you work your way down, the methods decrease in effectiveness. Starting from the top, the five methods are Elimination, Substitution, Engineering Controls, Administrative and Work-Practice Controls and PPE.
Elimination and Substitution
The most effective method available for controlling hazards is to simply remove or eliminate them so that employees are no longer exposed to a safety or health risk. Of course, this is not always possible because the equipment or process is intrinsic to your business. For instance, a fabrication shop cannot operate without cutting equipment, and all cutting equipment carries some form of risk.
Many hazards can be successfully eliminated by redesigning your facility or processes. Following are a few examples of eliminating hazards through design:
- Redesigning equipment so that it does not create excessive noise, temperature or pressure
- Redesigning a process so that toxic chemicals are no longer necessary
- Redesigning a workstation to make it ergonomic and reduce physical stress
If the equipment, process or workstation cannot be eliminated, the next-best method is to substitute it for something that does not pose a hazard or that is less dangerous. For example, if you are using a chemical, say for polishing or sealing a slab, you can research whether a different product is available that does not include the ingredients that make it toxic.
Engineering Controls
If a particular hazard cannot be eliminated or prevented through substitution, the next methods that should be tried are in a category called engineering controls. Engineering controls are basically redesigns that prevent or reduce human exposure to specific hazards and include three specific types: enclosure, barriers and local ventilation.
The most effective engineering control you can implement is enclosure because it controls how employees are exposed to health-and-safety risks. Some equipment, such as robotic or programmable saws, can be completely enclosed even during production. Other types of equipment require human operators or a human presence during production, but keeping this equipment enclosed when not in use may prevent or reduce hazards during maintenance or for people simply passing through the area.
Examples of enclosure controls are as follows:
- Moving parts of machinery are enclosed and inaccessible while it is operating.
- Toxic substances, such as liquids and gasses, are contained until they can be detoxified or safely disposed.
- Toxic chemicals and substances are enclosed in glove boxes so workers can conduct their jobs while remaining separated from the hazard.
If a hazard cannot be enclosed, then a barrier should be constructed to prevent exposure. Fences, ropes and chains are all examples of effective barriers, but local ventilation is also considered a type of barrier for hazardous gasses or airborne substances. In addition, baffles can be used as barriers to reduce or eliminate noise hazards.
Administrative Controls
Administrative controls are essentially work practices aimed at reducing employees’ exposure to hazards. Examples of administrative controls include adding relief workers or rotating workers through different jobs to keep exposure under hazardous levels. For instance, silica dust becomes increasingly hazardous the longer a person is exposed to it. If a job can be split up between two or three people, it is often safer than if one person is performing it for a longer period. Another administrative control that can be implemented is to establish a system of targeted breaks or activities.
Personal Protective Equipment
As mentioned above, PPE is the best-known type of hazard prevention and control. However, it is also the least effective. PPE includes protective clothing and gear such as respirators. To ensure that PPE is being used effectively and is not creating additional hazards, training is often required. In addition, workers may need to undergo thorough medical examinations to determine whether the PPE is not adversely affecting their health. This is particularly the case with respirators, which puts increased strain on the lungs and pulmonary system. According to federal and state law, all workers required to wear most types of respirators must first be cleared by a licensed physician. The physician is required to retain all medical records while the employer is required to keep clearance certificates or another form of proof that they have passed the physical exam. For specific information on PPE use and implementation, you can read OSHA Standard 1910 Subpart I. However, you must be aware that many states have implemented standards that are more rigorous than those at the federal level.
For further information about the standards in your state or about compliance in general, please contact your regional OSHA office, which can be found at the end of OSHA’s Q&As for Small Business Employers. All you have to do is ask for the consultation department. Despite popular belief, asking OSHA for information about compliance will not trigger an actual compliance inspection. Such practices by the administration are banned by federal law. The consultation department is required to keep all information confidential are banned from sharing it with the health-compliance or safety-compliance departments.
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