Why the Hierarchy of Controls is Actually Upside Down!
The hierarchy of controls is actually upside down!
That sounds provocative doesn’t it? The hierarchy of controls is actually upside down. PPE should be at the top and Elimination should be at the bottom. Or at least, that’s one point of view anyway.
Now don’t get me wrong, I’m not saying PPE is more effective than Elimination, far from it, I’m not saying that at all. I understand the Hierarchy of Controls, Elimination is at the top because that’s the most effective, and then there’s Substitution, which is a little bit less effective but still pretty good. Followed by Engineering Controls, which is quite good, but not perfect. Then Administrative Controls, which are pretty rubbish. And Finally PPE, which is the least effective.
But when I’m delivering IOSH Managing Safely training, NEBOSH training or anything like that, we talk about the Hierarchy of Controls, but the way it sometimes comes across is that you start at the top and work your way down. Which is true if it’s a new activity. When you’re designing the process, you would, first of all, consider how could we eliminate the hazards we’ve identified? How could we substitute them? How could we engineer them out and so on?
So if it’s a new process, new building, new machine, then yes, makes complete sense. But that’s not the reality for a lot of people, especially when they’re introducing safety or getting better at safety for the very first time, they’ll risk assess an existing activity and an existing task, and they’ll find that there are hazards and risk which are uncontrolled or need further work. And here’s where the hierarchy is upside down, because eliminating a hazard is a process which can take months.
Substituting a hazard is also really hard. It’s like the use of chemicals that are highly flammable, potentially carcinogenic, or cause nausea or dizziness, a project to substitute that for a water-based solvent which is less damaging is going to take a long time.
It’s going to take months, to find a chemical which might be suitable. Getting a supplier to bring in samples for testing and trialing. Finding out what does and don’t work. Getting another chemical in and going through that process again and again. You might end up going through 3 or 4 different chemicals and not get anywhere closer to the problem. In the meantime, you’ve got a risk is not being controlled. You can’t just leave it the way it is.
And this is the thing which we have to hammer home. That the hierarchy of controls is not about starting at the top and working your way down. No, it’s about what’s effective and what’s least effective. If you have an existing task or process and the risk is currently not acceptable, then you need to start at the bottom and you work your way up, because things like PPE and Administrative Procedures can be done today.
And we call these temporary measures. Even engineering controls, like temporary barriers, temporary guardrails could be temporary measures. It’s important that line managers know that they are expected to control risks today.
Just because it’s going to take months to substitute it or engineer it out or eliminate it, that doesn’t give them an excuse to just carry on.
What can I act upon today?
- Ask for PPE
- Issue a briefing
- Ask for some training
- Ask if you can increase your supervision
- Ask if you need a permit to work
- Ask if you can buddy people up together
These are all temporary measures which are not that effective, but if you throw enough mud at the wall, some of it’ll stick, they do reduce the risk to some extent, hopefully enough to allow you to carry on the job.
In the meantime, whilst you’re doing that, you speak to your engineering team, your process engineers or facilities manager, whomever it may be, and you talk about engineering controls. Can you manufacture a guard? Can you design a switch or an interlock or something to engineer this problem out? And then you start to look at the more longer term, harder solutions like, can you just substitute it entirely?
Maybe you can eliminate this process, which is something that you might be able to speak to designers about in many cases.
So there we are, the hierarchy of controls, which in some ways is literally upside down.
Think about it in the terms of temporary controls, which are at the bottom, but which you should implement straight away, and the longer term controls which take longer to implement, should be planned in and trailed.
So start at the bottom and work your way up. And that’s health and safety in real life.
Catch you later.
