A hazardous substance splashes onto a chemical plant operator taking a sample. The worker is not seriously injured, and the ensuing investigation focuses on training, personal protective equipment and the particulars of the sampling station.
But did anyone ever ask whether the worker needed to take the sample at all?
Identifying and mitigating exposures to occupational hazards before work begins is the objective of all safety and health professionals. NIOSH offers a basic outline through its interpretation of the Hierarchy of Controls.
The hierarchy starts with the controls perceived to be most effective and moves down to those considered least effective. As defined by NIOSH, it flows as follows:
- Elimination – Physically remove the hazard
- Substitution – Replace the hazard
- Engineering controls – Isolate people from the hazard
- Administrative controls – Change the way people work
- Personal protective equipment– Protect the worker with PPE
“You can’t eliminate every hazard, but the closer you can get to the top, the closer you can reach that ideal and make people healthier and safer,” said Jonathan Bach, director of NIOSH’s Prevention through Design Initiative.
Collaborate to eliminate
Dennis Hendershot, staff consultant at the Center for Chemical Process Safety in New York, encourages collaborative thinking. Bring together as many people involved in the job process as possible, including supervisors, engineers, operators and workers. Ideally, Hendershot said, this consultation of “inherently safer thinking” will take place during developmental stages.
“What you want to get is everybody involved in the whole life cycle to be involved in the first question, which is, ‘Can I eliminate this?’” Hendershot said. “There’s no guarantee that you will be able to eliminate it, but there is a guarantee that you won’t know unless you try.”
Referring to the chemical splash example, Hendershot said it may be possible to take the sample elsewhere in the plant, where the material can be found at a lower concentration. Changing thought patterns may pave the way to less hazardous processes.
“They just assume you’ve got to do what you’ve been doing, and then [ask], ‘What kind of safety procedures do I have?’” Hendershot said. “Well, the safest way is don’t do it.”
NIOSH states that elimination and substitution is often more difficult to enact after work has begun. The goal of substitution is to replace a hazardous product or process with a safer one. Examples include using non-toxic or less toxic chemicals and upgrading aging machinery with newer equipment.
‘Make the work easier’
NIOSH identifies numerous hazards for which engineering controls can be effective. They include noise, falls, silica, aerosols, asphalt fumes, formaldehyde, hazardous drugs, lead, asbestos, carbon monoxide and nitrous oxide.
One example the agency cites involves establishing local exhaust ventilation to isolate and remove airborne emissions. Another is using machine guarding to protect operators.
However, establishing engineering controls can come with its own risks. Machine guarding ranked eighth on the list of OSHA’s Top 10 most frequently cited violations for fiscal year 2017. “Well-designed engineering controls can be highly effective in protecting workers and will typically be independent of worker interactions,” NIOSH states. “They typically do not interfere with worker productivity or personal comfort, and make the work easier to perform rather than more difficult.”
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