Reconsidering the “hierarchy of control”– Part 2

In a recent post I discussed the basis of the hierarchy of control and how it should be applied in practice. It’s something we cover when we deliver the BOHS module M103 “Controlling hazardous substances” and is also relevant to the control of physical hazards such as noise and vibration.

During the M103 course I’ll normally include an exercise where I ask the participants to list the different types of controls they’d include in the main categories (i.e. source, path and worker). They will usually include “training” in the list of worker based controls. Now, I’m not one for being controversial(!) but I usually use this as an opportunity to start a discussion as I don’t think training fits here. “Training” is something of a vague term. Of itself it won’t control exposure.

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When we talk about training as a control what we are usually thinking about is the underlying measure – good working practices or safe working procedures. Different ways of carrying out a job can lead to different levels of exposure. To minimise the health risks we need to establish which working practices will minimise exposure and make sure workers are aware of them. Training will help with this, but only if we’ve identified the best methods. Training workers in poor methods will actually be counterproductive and increase exposure.

In fact training (along with information and instruction) is always needed whatever controls are introduced. Workers need to be aware of the hazards they’re working with and the associated risks. They also need to know why they shouldn’t reintroduce a substance that has been eliminated or substituted, how to use any engineering controls provided properly and, where appropriate how to maintain and test them, what good working methods and safe working practices need to be followed and how to obtain, fit, use and maintain personal protective equipment. In fact quite a lot of training is needed in most cases. So, although I don’t “training” fits into the traditional list of measures in the hierarchy, it’s an essential component of an effective control regime.

To me, training fits into a group of measures that are usually needed to ensure that the controls that have been introduced continue to work effectively. I call these the management measures  and they sit alongside the traditional hierarchy of control.

There are many examples in industry where expensive control measures are installed only for them to remain unused, used infrequently or used incorrectly thereby rendering them ineffective. To overcome these problems, effective management measures need to be put into place. They include

  • information, instruction and training to ensure workers know why the controls are needed, how to use them correctly, procedures for reporting faults etc.
  • supervision to ensure that the controls are used properly
  • maintenance and testing to ensure that engineering controls and personal protective equipment continue to operate effectively
  • auditing to ensure that the procedures and safe working methods are followed
  • exposure monitoring and health surveillance as additional checks that the controls are effective
  • welfare facilities (i.e. washing facilities, changing rooms, segregated rest rooms, separate storage for clean and contaminated clothing) may need to be provided.
  • good housekeeping and cleaning of the workplace.

Anyone familiar with the British Control of Substances Hazardous to Health Regulations (COSHH) will recognise them, as they form the basis of regulations 8 to 13

We can modify the “hierarchy of control” model to incorporate them as illustrated in the following diagram. The management measures form a separate list running in parallel with the traditional list of controls.

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Once appropriate prevention strategies, engineering measures, work practices and PPE have been identified, employers need to decide which of the management measures should be introduced as part of a control regime to ensure that the controls continue to work effectively at reducing the risk to an acceptable level.

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