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Controlling Hazards

The Hierarchy of Controls (HOC)

Hierarchy of Controls
Click to enlarge.

As you learned earlier, there are many different types of hazards in the workplace.

  • Hazardous conditions include: unsafe materials, equipment, environment and employees.
  • Unsafe work practices include: allowing untrained workers to perform hazardous tasks, taking unsafe shortcuts, horseplay, or long work schedules.

To combat hazardous conditions and unsafe work practices, various "Hierarchy of Controls" (HOC) models have been developed. We have adopted a HOC that includes two prioritized hazard control strategies and four prioritized control methods. See the HOC strategies and controls listed below:

Control Strategies

  1. Elimination. The most important strategy.
  2. Mitigation

Control Methods

  1. Engineering controls. The most important control method.
  2. Warnings.
  3. Administrative controls
  4. Personal protective equipment

The highest priority control method is the use of engineering controls because it is considered most effective. As you can see, no matter which control method is selected, the most important strategy is to totally eliminate the hazard or exposure. If elimination is not possible, mitigation, or the reduction of the severity of the hazard or exposure, is the strategy selected.

1. Which of the following is listed as one of the two fundamental control strategies?

a. Warnings
b. Engineering Controls
c. Mitigation
d. Administrative Controls

"Feasible" Controls

guardrail
Hazard correction must be feasible.

Hazard control methods required to correct a hazard must be technologically and economically feasible for the employer. OSHA uses the following criteria to determine feasibility of engineering and administrative controls:

  • Technical Feasibility: Technical feasibility is the existence of technical know-how as to materials and methods available or adaptable to specific circumstances which can be applied to cited violations with a reasonable possibility that employee exposure to occupational health hazards will be reduced.
  • Economic Feasibility: Economic feasibility means that the employer is financially able to undertake the measures necessary to abate identified hazards. Economic feasibility is a major issue to be considered when imposing hazard controls.

OSHA may allow the use of PPE to abate a hazard, at least until such time as engineering controls become a less significant economic burden for the company when the following conditions are met:

  1. If significant reconstruction of a single establishment involving a capital expenditure which would seriously jeopardize the financial condition of the company is the only method whereby the employer could achieve effective engineering controls;
  2. If there are no feasible administrative or work practice controls; and
  3. If adequate personal protective equipment or devices are available.

2. Hazard control measures required by OSHA to correct a hazard must be technologically and economically _____.

a. feasible
b. applied
c. defined
d. demonstrated

Elimination and Mitigation

As mentioned earlier, the two most fundamental strategies in achieving the goal of a safe and healthful workplace is to either eliminate or mitigate hazards and exposure.

  1. Elimination. The first and most important strategy is to use hazard control methods to totally eliminate a hazard and exposure. The highest priority is to remove the hazard, but if that's not possible, try to eliminate exposure to the hazard.
  2. Mitigation. If elimination of a hazard or exposure is not possible, try to reduce the severity of the hazard. If you can't reduce the severity of a hazard to an acceptable level, try to reduce exposure to the hazards.

As you can see, elimination is the first priority, and if that's not possible, mitigation should be attempted. Some examples of these two strategies include:

  • Elimination. Install a conveyor belt to remove the need to carry objects.
  • Elimination. Use an extension pole to change ceiling lights to remove the need for a ladder.
  • Mitigation. Substitute a toxic chemical with a less toxic chemical.
  • Mitigation. Redesign equipment to reduce the noise it produces.
  • Mitigation. Replace heavy boxes with smaller, lighter boxes to store products.

3. Which hazard control strategy would be considered first to completely remove the source of excessive temperatures, noise, or pressure?

a. Mitigation
b. Administration
c. Elimination
d. Training
engineering controls
Design the hazard out of the equipment.

Engineering Controls

These controls focus on eliminating or reducing the actual source of the hazard, unlike other control strategies that generally focus on employee exposure to the hazard. The basic concept behind engineering controls is that, to the extent feasible, the work environment and the job itself should be designed to eliminate hazards or reduce exposure to hazards. While this approach is called engineering controls, it does not necessarily mean that an engineer is required to design the control. Redesigning or replacing equipment or machinery may be expensive, but remember, according to the National Safety Council, the cost per medically consulted injury in 2013 was $42,000, and the cost per death was $1,450,000.

Remember: No hazard + No exposure = No accident.

Engineering controls do not necessarily have to be expensive or complicated. They can be quite simple in some cases. Engineering controls are based on the following broad strategies:

  1. If feasible, design or redesign the tools, equipment, machinery, materials and/or facility.
  2. Enclose the hazard to prevent exposure in normal operations; and
  3. If complete enclosure is not feasible, establish barriers or local ventilation to reduce exposure to the hazard in normal operations.

Some examples of this strategy include:

  • Redesigning a process to reduce exposure to a hazardous moving part;
  • Redesigning a work station to relieve physical stress and remove ergonomic hazards; or
  • Designing general ventilation with sufficient fresh outdoor air to improve indoor air quality and generally to provide a safe, healthful atmosphere.

4. Why are engineering controls preferred over administrative and work practice controls to correct workplace hazards?

a. Because safety is all about conditions, not behavior
b. They are designed to eliminate or isolate the hazard
c. They focus on employee exposure
d. They cost less in the long run
engineering controls
Enclosure of a rotating shaft hazard.

Engineering Controls (Continued)

Enclosure of Hazards

When you cannot remove a hazard and cannot replace it with a less hazardous alternative, the next best control is enclosure. Enclosing a hazard usually means that there is no hazard exposure to workers during normal operations. There still will be potential exposure to workers during maintenance operations or if the enclosure system breaks down. For those situations, additional controls such as safe work practices or personal protective equipment (PPE) may be necessary to control exposure.

Some examples of enclosure designs are:

  • Complete enclosure of moving parts of machinery;
  • Complete containment of toxic liquids or gases from the beginning to end of a process;
  • Glove box operations to enclose work with dangerous microorganisms, radioisotopes, or toxic substances; and
  • Complete containment of noise, heat, or pressure producing processes with materials especially designed for those purposes.

Barriers or Local Ventilation

When the potential hazard cannot be removed, replaced, or enclosed, the next best approach is a barrier to the exposure or, in the case of air contaminants, local exhaust ventilation to remove the contaminant from the workplace. This engineered control involves potential exposure to the worker even in normal operations. Consequently, it should be used only in conjunction with other types of controls, such as safe work practices designed specifically for the site condition and/or PPE. Examples include:

  • Ventilation hoods in laboratory work
  • Machine guarding, including electronic barriers
  • Isolation of a process in an area away from workers
  • Baffles used as noise-absorbing barriers
  • Nuclear radiation or heat shields

5. Because these control methods involve potential exposure to the worker during normal operations, they should only be used in conjunction with other types of controls.

a. Enclosure of hazards
b. Engineering controls
c. Barriers or local ventilation
d. Elimination and Substitution

Warnings

With the release of ANSI Z10-2012, "warnings" have been promoted to their own hierarchy level. Previously they were considered part of administrative controls. Warnings do not prevent exposure to a hazard, but they do provide a visual or audible indicator to warn people of potential danger.

Image of Feasibility
Signs can be used to warn people of potential hazards.

Warnings can be either visual, audible, or both. They may also be tactile. Some examples of warnings are:

  • Visual. Signs, labels, tags, and flashing/strobe lights.
  • Audible. Alarms, bells, beepers, sirens, announcement system and horns.
  • Tactile. Vibration devices or air fans.

For instance, a door could have both a sign warning of a hazard as well as an alarm if opened. Warnings can be effective deterrents, but are not as effective as elimination, substitution, or engineering controls.

OSHA Signs

OSHA's 1910.145, Specifications for accident prevention signs and tags details the following types of signs:

  • Danger Signs - Signs that alert people to specific and immediate dangers (including radiation hazards).
  • Warning Signs - Signs that warn people of potential hazards that can lead to death.
  • Caution Signs - Signs used to alert people to potential hazards. This class can also be used to caution people against certain unsafe practices. This class is for hazards that can result in minor (non-life threatening) accident or injury.
  • Safety Instruction Signs - These signs offer instructions for how someone should act or perform to avoid possible hazards.

One potential problem when using warnings is the misinterpretation of the warning itself. Does the symbol or text clearly explain what the hazard is to the public? For example, if a sign only contains a written warning, someone might read the sign but not know what the warning actually means. Or, if an alarm sounds, what does the alarm mean? These are challenges when using warnings and why they are not as effective as higher-level controls.

6. Warnings may take any one or combination of the following forms EXCEPT _____.

a. visual
b. audible
c. tactile
d. hydraulic

Administrative Controls

trench
How do you control unsafe behaviors?

Administrative controls work by developing safety policies, programs, procedures, and designing safe work practices into job procedures. Ultimately, administrative controls can potentially influence workplace behaviors causing most of the workplace accidents.

Administrative controls are only as effective as the safety management system that supports them. It's always better to eliminate the hazard so that you don't have to rely on management controls that tend to work only as long as employees behave. Here's an important principle that reflects this idea:

Any system that relies on human behavior is inherently unreliable.

To make sure management controls are effective in the long term, they must be designed from a base of solid hazard analysis and sustained by a supportive safety culture. They then must be accompanied by adequate resources, training, supervision, and appropriate consequences. Remember, administrative controls should be used in conjunction with, and not as a substitute for, more effective or reliable engineering controls. Now let's look at some examples of some administrative controls.

7. Any system that relies on human behavior is inherently _____.

a. inefficient
b. unreliable
c. effective
d. unacceptable

Safe Work Practices

unsafe behavior
Can you see the missing PPE?

Administrative controls also take the form of safe work practices. They may be quite specific or general in their applicability. They may be a very important part of a single job procedure or applicable to many jobs in the workplace. General safe work practices include:

  • Removing tripping, blocking, and slipping hazards
  • Removing accumulated toxic dust on surfaces
  • Wetting down surfaces to keep toxic dust out of the air
  • Using safe lifting techniques
  • Maintaining equipment and tools in good repair
  • Using personal protective equipment (PPE)

Other safe work practices apply to specific jobs in the workplace and involve specific procedures for accomplishing a job. To develop safe procedures, you conduct a job hazard analysis (JHA). If, during the JHA, you determine that a procedure presents hazards to the worker, you would decide that a training program is needed. We recommend using the JHA as a tool for training your workers in the new procedures. A training program may be essential if your employees are working with highly toxic substances or in dangerous situations.

8. Which of the following would be considered a specific safe work practice?

a. Maintaining tools in good repair
b. Testing the atmosphere during confined space entry
c. Using safe lifting techniques
d. Using personal protective equipment
ppe
Wearing PPE is always a best practice.

Personal Protective Equipment (PPE)

Using personal protective equipment is a very important safe work practice. It's important to remember that, like other administrative controls, the use of PPE does not control the hazard itself, but rather it merely controls exposure to the hazard by setting up a barrier between the employee and the hazard. Use of PPE may also be appropriate for controlling hazards while engineering controls are being installed or work practices developed.

PPE Drawbacks

The limitations and drawbacks of safe work practices also apply to PPE. Employees need training in why the PPE is necessary and how to use and maintain it. It's also important to understand that PPE is designed for specific functions and is not suitable in all situations. For example, no one type of glove or apron will protect against all solvents. To pick the appropriate glove or apron, you should refer to recommendations on the material safety data sheets of the chemicals you are using.

Your employees need positive reinforcement and fair, consistent enforcement of the rules governing PPE use. Some employees may resist wearing PPE according to the rules, because some PPE is uncomfortable and puts additional stress on employees, making it unpleasant or difficult for them to work safely. This is a significant drawback, particularly where heat stress is already a factor in the work environment. An ill-fitting or improperly selected respirator is particularly hazardous, since respirators are used only where other feasible controls have failed to eliminate a hazard.

9. What is the best source of information to help you select the most appropriate personal protective equipment while working with potentially hazardous material?

a. Secondary label
b. Supplier invoice
c. Safety Data Sheet
d. The inner lining of a glove or apron
workers
There's always a possible interim measure.

Interim Measures

When a hazard is recognized, the preferred correction or control cannot always be accomplished immediately. However, in virtually all situations, interim measures can be taken to eliminate or reduce worker risk. These can range from taping down wires that pose a tripping hazard to actually shutting down an operation temporarily.

The importance of taking these interim protective actions cannot be overemphasized. There is no way to predict when a hazard will cause serious harm, and no justification to continue exposing workers unnecessarily to risk. By the way, OSHA believes there is always some kind of interim measure that can be used to temporarily abate a hazard.

10. What is OSHA's belief about the use of interim measures to control hazards?

a. They should not be used
b. They are always available
c. Employers must always use them
d. Some interim measures are not useful

Maintenance Strategies to Control Hazards

workers
Preventive maintenance is proactive!

There are two general types of maintenance processes needed to control hazards:

  • Preventive maintenance to make sure equipment and machinery operates safely and smoothly.
  • Corrective maintenance to make sure equipment and machinery gets back into safe operation quickly.

Hazard Tracking Procedures

An essential part of any day-to-day safety and health effort is the correction of hazards that occur in spite of your overall prevention and control program. Documenting these corrections is equally important, particularly for larger sites.

Documentation is important because:

  • It keeps management and safety staff aware of the status of long-term correction items;
  • It provides a record of what occurred, should the hazard reappear at a later date; and
  • It provides timely and accurate information that can be supplied to an employee who reported the hazard.

Final Words

The hierarchy of controls is the standard system of strategies to effectively eliminate workplace hazards. Remember, the first question to ask when considering ways to eliminate a hazard is, "can we apply engineering controls?" You may need to use a combination of strategies to effectively eliminate the hazard. Whatever it takes, do it. You are not just saving a life....you are saving a father, a mother, a son, or a daughter....you are saving a family. It's worth the effort!

11. What strategy can be used to make sure equipment and machinery operate safely and smoothly?

a. Emergency maintenance
b. Preventive maintenance
c. Corrective maintenance
d. Programmed maintenance

Check your Work

Read the material in each section to find the correct answer to each quiz question. After answering all the questions, click on the "Check Quiz Answers" button to grade your quiz and see your score. You will receive a message if you forgot to answer one of the questions. After clicking the button, the questions you missed will be listed below. You can correct any missed questions and check your answers again.

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