It always surprises me when clients and colleagues ignore the Hierarchy of Controls when deciding what control measures to introduce. Recently Oregon’s OSHA released a podcast about the Hierarchy of Controls which shares some of my concerns.
It was concerning that the podcast stated that some hierarchies place Administrative Controls on the same level as Engineering Controls and that some consider fall protection devices as Engineering Controls due the engineering of the anchor point (a dubious engineering control as this blog has discussed previously).
Below are several quotes from the 4 minute podcast Michael Wood of Oregon OSHA.
“A control that fully eliminates the hazard is always preferred to one that does not.”
“The hierarchy improves the control’s reliability.”
“The hierarchy of control recognises that perfection in human performance can not be attained.”
This short podcast is a good quick reminder to occupational health and safety professionals but could also be discussion catalyst on basic hazard management.
The use of HOC requires more than a vegetable level intellect to realise any thing like its potential in intervening in maintaining or improving wellbeing. Unfortunately there is a sort of ‘antichrist’ “Safety” cult about which recommends people not follow the general advice for people and employers working mutually in keeping workers out of harm, promenading them as completely competent to make their own decisions as to compliance or not.. irrespective of the legal obligations of the PCBU….and that ‘exposure to harm’ at the workplace is a sort of maturing process as it might be with children….The negligence of the proponents of this cult is relentless.
Some children and some workers never mature but are crippled or killed when allowed to their own devices. The concept of each person being competent to make his own/correct/maturing decision also ignores the reality of human development. Every aspect of HOC including ‘elimination’ carries latent and other ‘lurking’ risks…or risks which come afresh or slip past barriers. Every worker is not competent to make personal decisions and stay free from harm and the closer they are to adolescence, the greater the risk….there are however other factors I am not going to deal with here….
There’s always room for some improvement or a spreading of improvement when one seems to have peaked in one or more areas. Intelligent application of the “HOC” and every factor related to it…as it is only a logical set of guidelines put in its simplest order…..is a far bigger picture than the words which make up the HOC ‘in its simplest form’.
Thanks Kevin – that podcast has received a bit of hype – I must have a listen. I am not a big fan of the hierarchy in its simplest form – even the BoK acknowledges its limitations. Elimination and Engineering Controls are not always the best choice without an appreciation of risk transfer, by-products and risk homeostasis.