Of all of the controls in the Hierarchy of Controls, Personal Protective Equipment (PPE) is the one most people are familiar with. Why? Well, PPE is quick, easy, often less expensive than other options, and readily available. What you might not realize, though, is that PPE is what OSHA considers to be a “last resort”. When it comes to the Hierarchy, PPE is supposed to be used either a) while other controls are being implemented, b) in conjunction with other controls or c) when all other options have been exhausted. In other words, a full body harness should not be your go-to fall protection solution. Yet, so many companies turn to PPE first.
Personal Protective Equipment really is exactly what the name implies: protection you use personally. So, while a personal fall arrest system is considered PPE, a guardrail is not. While a respirator is considered PPE, ventilation is not. PPE includes most things required to be worn on the job, such as earplugs or other forms of hearing protection, hardhats, safety glasses or goggles, face shields, gloves, coveralls, steel or reinforced-toe boots, reflective vests, and so much more. PPE is so prevalent among the workforce that you’d think injuries would be virtually non-existent, but they’re not. Why?
Insufficient / Wrong PPE
PPE sometimes gets thrown at a hazard without really evaluating the situation. Hearing protection is great, but does it do the necessary job? Ear plugs are rated for noise reduction, so how do you know that grabbing that pack of earplugs out of the jar in the office will reduce the noise below acceptable levels? Has a noise survey been performed? If so, was the equipment selected based on that survey? Or in terms of respiratory protection, has anybody determined what the dust in the air is composed of before deciding to buy a cheap box of dust masks? Even if you know what the dust is made of, has anybody sampled to determine the levels to which your employees are being exposed? PPE is not a game of guesswork, though it might seem that way if you were to wander into various workplaces throughout the United States. Careful consideration needs to be taken to determine what PPE is appropriate to protect your employees from workplace hazards
PPE is Not Properly Cared For / Used
PPE is only as good as the user. Safety glasses offer no eye protection if they are constantly left on top of the user’s hardhat. A reflective vest offers no visibility if the user throws a coat over it when he or she is cold. A respirator may do more harm than good if hazardous dust is allowed to accumulate on the inside of it and it is not properly cleaned. A full body harness, rather than save your life, could cause serious internal damage and other bodily harm if it’s not worn properly. Using PPE as a hazard control includes using it properly, maintaining it properly, and caring for it properly. Harnesses are supposed to be kept hung in a cool, dry place, yet how many do you see lying around a jobsite or in the back of a truck exposed to sunlight (UV decay), rain, freezing temperatures, and more? When that harness fails, is it because it was the wrong equipment? No. It wasn’t properly cared for. Respirators should have change out schedules depending on the filters you are using and exposures your employees have. Does your plan have one? If not, how do your employees know when to get new cartridges. Do they know to get new cartridges? And can a user even use equipment properly if they don’t know if it should even be used in the first place? Are your employees inspecting their PPE or are they just pulling it out of the toolbox and going to work? How will they know if something has gone wrong if you do not have them doing inspections? You can’t throw PPE at a problem and expect it’s going to help without the proper preparations.
Which brings us to our next point: training. How do you expect your employees to know how to properly inspect, use and care for their equipment? If you don’t train them, there’s a good chance they may barely be able to figure out how to put a harness on, let alone how to put it on properly. If you don’t train them, they could be using a respirator with cartridges that have broken through, but they have no idea because the hazard is not one they can smell or taste. They may be using ear plugs that should do the trick, but have been inserted improperly. You can’t assume people will just know what to do. Not only is training a good idea, but it’s required by OSHA. Take the time necessary to ensure your employees are able to keep themselves safe. You don’t need to do an eight-hour training to show employees how to wear earplugs, but you do need to do some training.
The Hierarchy of Controls is a phrase used often in the safety and industrial hygiene world. If you weren’t familiar with it before this series, hopefully now you’re better informed. Of course, now that you know what it is, there’s still a lot of work to do: you still need to investigate your hazards, you still need to determine what the best possible control is, you still need to design and implement that control, and you still need to train your employees. A breakdown at any step could cause failure. And, when human lives are at stake, failure is unacceptable.
In the first two articles on the Hierarchy of Controls, we discussed controls that were intended to mitigate hazards at their source either through elimination, substitution, or an engineering solution that made it so the employee was no longer exposed. With administrative controls, we take a little bit of a turn from that approach. At this point in the hierarchy, the reality is that the hazard is one that must be – or can be – lived with, so long as certain precautions are taken or certain levels of exposure are not exceeded. Administrative controls, which may be used in conjunction with engineering controls and/or PPE, would also be required if work was to continue while engineering controls are being developed. Ultimately, though, administrative controls are not the optimal solution and cannot be the selected method of abatement if a hazard, or employee exposure to that hazard, can be eliminated.
Examples of administrative controls are fairly simple: warning alarms, for example, are just that – alarms that let you know when something isn’t right. An alarm might notify you of something as common as a guard being left open on a machine in a manufacturing process or it might be on the rotating structure of a crane working near power lines that could not be de-energized, to let you know you cannot swing any further. Obviously, neither of these by themselves would eliminate a hazard, but they would provide an employee with a warning. A more effective approach for the guard would be an engineering control: to have an interlock that prevented the machine from running when the guard was open. Without it, an employee could ignore the alarm and reach into the machine. For the crane, the alarm would not prevent the crane from swinging closer to the power lines. Instead, you are relying on the operator to heed the warning.
Labeling systems would also be considered administrative controls. We see safety labels everywhere, but clearly they are not sufficient to protect workers. Labels are often used along with other controls to keep employees safe. Warning of high voltage, a certain chemical in use, or that an area is a high-noise area, among many other things, labels act as a good reminder for workers not to enter areas in which they do not belong, to follow certain procedures, or to wear certain PPE. They, alone, will not protect a soul if they are not heeded by the employees.
This brings us to another form of administrative control: training. You can put as many engineering controls in place as you want, you can require PPE, you can warn of hazards in an area, but if you don’t train your employees how to comply with the safety requirements, controls can still be bypassed. Somebody who is not trained on the dangers of entering a high noise area may think it’s really not that big of a deal, for instance. Perhaps you’ve substituted a non-silica product for sand in your sandblasting operations, but you still need sand in your facility for other applications. If you don’t train your employees on the hazards of silica as well as what your new procedure is, how will they know to use the safer product (or why will they bother if they can’t find any, but sand is readily available)? You may not have realized that training was an administrative control, but hopefully you’ve been using it all along.
One final method that needs to be discussed is a little more on the complicated side, compared to other administrative controls. Reducing the amount of time somebody is exposed to a hazard can be an effective control, but it’s not as simple as placing a sign or adding a warning alarm. For instance, hazards like noise and chemical exposure are often given permissible exposure limits (PELs) by OSHA that are measured in time-weighted averages (TWAs). So for instance, Carbon Monoxide (CO) has a PEL of 50 parts per million (ppm). This does not mean that the moment somebody is exposed to Carbon Monoxide in an amount greater than 50 ppm they are going to die, it just means that when you average out the amount an employee is exposed to over the course of an eight-hour day, it needs to be below 50 ppm. There are also Short-Term Exposure Limits (STELs) and Action Levels (ALs) to be concerned with, and though we can see that determining an allowed exposure time might be a bit involved, we’d need more room/time than this article allows to go into detail on it. Suffice it to say, as long as employee rotation through a job can keep the employee under all applicable limits, then it is an acceptable solution. While CO has a limit, in many cases, employers would find the source of emission and eliminate it because CO is much too dangerous. A more common application of controlling exposure time might be in a high noise area or a hot work area. By rotating other workers into these areas throughout the day or by simply putting a cap on the amount of time spent in them, workers can be kept below the allowable exposures for noise or heat.
Administrative controls can be simple, but remember, they are often not the best or sole solution. Using administrative controls should almost always be looked at in the context of other controls that are being put in place to determine how they can be paired to provide employees with the best actual protection possible. Now, with elimination, substitution, engineering controls, and administrative controls covered, we are left with one final level of the hierarchy in the next article: PPE. Yet, if it’s the final level of the hierarchy, why is it that it is so often the first solution employers turn to? The final article in our series will explain just that.
In the last article, we discussed the first level of control when it comes to protecting employees from recognized hazards: elimination or substitution. The concept, while possibly difficult to implement, was simple to understand. Unfortunately, this second step, engineering controls, is often more difficult in both concept and implementation. (Note: there seem to be two schools of thought on this hierarchy or controls. One is that substitution and elimination fall under engineering controls and the other is that they are separate. For the purpose of this article series, we’ve chosen to separate them into different categories.)
Engineering controls, to put it as succinctly as possible, are methods designed to get as close to eliminating the hazard as possible, without actually eliminating it. This is done by designing something into the facility, the piece of equipment, or the procedures themselves to reduce the hazard or the employee’s exposure to it. As long as they are designed properly (and used by employees properly) they tend to be very reliable.
An example of an engineering control is isolating a hazardous portion of the process. In manufacturing, for instance, a part of the process may be spray painting parts. This task poses both health and ignition concerns. In order to isolate the hazard, many manufacturers would utilize a spray booth. The booth prevents the worker from inhaling the paint fumes and paint residue while also reducing the risk of explosions and fires. A glove box for handling hazardous materials and chemicals is another example of isolation as the box allows the employee to do the work while not being exposed to the material/chemical.
A process change is also considered an engineering control. This control is common (though maybe not common enough) when dealing with silica. Using water to suppress concrete dust or a HEPA-filtered vacuum attachment to remove the dust from the air are not only good controls, they are – in ways – integrated right into the new silica standard. Automating the hazardous work so that no employee has to be exposed is another example of a change in process.
Another option is ventilation, the most effective of which is local exhaust. Local exhaust removes the hazard (in this case, a fume, gas, vapor, or dust) at its source, while general ventilation allows the hazard into the work area as it’s diluted to an acceptable level or as it’s pulled or pushed (depending on whether it’s a positive or negative pressure system) into an exhaust duct, door or window. Dilution methods are really only able to be used in very low toxicity situations where employees are able to maintain a safe distance from the source. General ventilation can be costly as large amounts of air need to be moved in larger spaces and that air often needs to be temperature controlled to keep the workplace comfortable.
Often, an engineering control doesn’t exist in a vacuum. Some need to be used in conjunction with other controls, such as personal protective equipment, to ensure they are used and working properly. Training is always required because no system is human-proof. In fact, engineering controls are definitely not a one-size-fits-all solution. Before one is selected, it’s necessary to look at a number of factors. How easy is it to use? Your employees are going to be expected to use it properly. An over-complicated system could greatly increase the possibility of human error or, worse yet, the possibility that your employees choose to attempt to bypass the system. How reliable is it? Engineering controls need to have a practically perfect rate of success. If they don’t, not only are your employees not protected, but they may be operating under a false sense of security. How much does it cost? Yes, as safety professionals we like to think it’s “protect the employees, no matter the cost!” but in the end, employers do still exist to make a profit. That’s not to say that a company will not implement necessary controls, but they’re not going to be happy if they spend a fortune on one solution only to discover that there is a cheaper and equally effective solution available. Do your homework before selecting any one option.
Engineering controls are your best option when the hazard cannot be eliminated. Ensure the safety of your employees by selecting/designing the proper solution and then train your people so that the control works as intended. If the possibility of substitution, elimination, or engineering controls all fail – or if you simply as desire additional protection – administrative controls will be the next step.
If you’re a safety professional, it’s been ingrained in you since you were in diapers sitting through your first OSHA 30 hr. How many times have you caught yourself in a conference room shouting, “But don’t you understand?? PPE is a last resort!”? Countless, I’d imagine, but the problem is that PPE is what people know. PPE is easy and readily available. Ask somebody what engineering or administrative controls they could have used to abate a hazard and they’ll look at you like you’re still wearing diapers (that is, assuming you’re not).
For those unfamiliar with the hierarchy of controls, a tiered approach to solving problems might seem alien. Even for the initiated, some aspects of the hierarchy can be confusing. So, rather than just tell you what the hierarchy is at face value, let’s take a more in-depth look at each level, starting with two of the easier concepts: elimination and substitution.
The concept of elimination is easy, because it’s as simple as it sounds. Take the hazard that your employees face and eliminate it. Done, piece of cake.
Maybe not. The problem with elimination is that if the implementation of it was as simple as it sounds, everybody would be doing it, wouldn’t they? What company would not choose to completely eliminate the chance of their employees getting hurt if doing so was simple? Not many, I’d venture. In fact, according to the hierarchy of controls, if Elimination is available to an employer, it is the option they must choose. Remember, the employer has a duty to provide a workplace free of hazards to their employees. If the employer is able to do that, but chooses not to, they could be looking at a Willful violation, should an OSHA inspection occur (not to mention employee injuries and fatalities that might occur due to your failure to remove the hazard).
If we are talking about elimination in terms of equipment or materials, such as removing some flammable gas containers from an area where hot work is being performed or eliminating an unnecessary blade on a machine, the solution should be 100% effective, as long as there isn’t a communication breakdown that allows somebody else to reintroduce the hazard back into the workplace or process.
Again, this is pretty much what it sounds like. With substitution, we are identifying a hazardous substance or piece of equipment and substituting a substance or piece of equipment that is not hazardous. For instance, instead of a solvent-based paint, use a water-based paint. Instead of sand-blasting, use a non-silica containing abrasive material. If an alternative product exists on the market, substitution can be a very effective solution.
Except, there’s a reason why the hazardous versions still exist. If the substitutions were perfect, they’d force the hazardous substances off the market. So why don’t they? Well, the downfalls of substitutions tend to usually be quality and cost. Let’s take the paint example. Paint used to be almost exclusively solvent based, but solvent based paints are high in VOCs (volatile organic compounds). Over time, as VOCs were required to be reduced in solvent-based paints, other paints came on the market, such as water-based. Early on, the quality of water-based paints was inferior to solvent based, so some companies probably continued to stick with the solvent-based to ensure a better job. Unfortunately, something like that leaves a stigma and many people probably still believe to this day that solvent-based paints are superior despite the fact that with current technology, many water-based paints are not only equal to solvent-based but superior to.
Regardless of quality, though, cost can still be prohibitive. Oftentimes, the production of a synthetic material costs more than the acquisition of a natural one, demand for the less hazardous version drives up its cost, or any other number of reasons that make the alternatives more expensive. It’s this industry’s equivalent of why a grilled chicken salad costs $9.99 and a burger costs $5. Cheaper usually does not mean better for you.
The other downfall to substitution is just because a material does not pose the same hazard as the one you’re replacing, does not mean it doesn’t pose a hazard at all. An employer needs to do the necessary research to ensure that they are not replacing one hazard with another.
Elimination and substitution are not only great ways to abate hazards, but need to be your preferred way. In other words, engineering controls, administrative controls, and PPE should not even come into the discussion until elimination and substitution have been ruled out (except in the case where PPE use is required at all times, like a 100% safety glasses policy). Take the time to look at some of the solutions your company has come up with for the hazards in your workplace. Are there situations where elimination or substitution could have been used? You may be surprised how often your answer is “Yes.”
After you’ve done that, keep your eyes open and come back for our next article which will discuss what is meant by “engineering controls”.