Understand the hierarchy of controls

Achieve viable hazard prevention through increased robustness

By Zach Ganster February 3, 2020

Firmly understanding where a safety program falls within the hierarchy of controls can reveal gaps in that safety program and reduce the likelihood of an electrical incident. It’s more than a recommendation from organizations like Occupational Safety and Health Administration (OSHA); it can be a matter of life and death.

According to a Panduit independent safety study, in the past five years, 40% of companies have reported electrical incidents, and sadly, OSHA reports concur that roughly 350 electrical-related deaths occur in the workplace every year. Panduit’s research also reveals that only 75% of the safety and environmental, health and safety (EHS) leaders surveyed describe themselves as very or extremely familiar with the hierarchy of controls, compared to 93% with the proper use of lockout/tagout (LOTO) equipment and 91% with OSHA requirements.

This data suggests that a possible cause of electrical incidents in the workplace isn’t a lack of consideration for safety, but rather a lack of education regarding the more robust levels of the hierarchy of controls and how proper understanding can translate to practical and enhanced workplace safety measures.

A key tool to use when attempting to make electrical safety in the workplace more robust is the hierarchy of controls. The five hierarchy tiers start at the bottom with the controls perceived to be the least innately effective and move up to those considered the most effective methods of hazard prevention (See figure 1).

PPE, administrative controls

While the lower tiers of the hierarchy technically represent the “least effective” methods of hazard prevention, those layers — particularly personal protective equipment (PPE) — are referred to as the foundation on which well-rounded safety programs should be built, but far from where safety considerations should conclude.

Defined by OSHA as equipment worn to minimize exposure to hazards, PPE is essential equipment to improve safety for employees. The most common examples of PPE for electrical hazards include voltage-rated gloves, safety glasses, face shields, hard hats, safety shoes, hearing protection, flame-resistant clothing and arc-rated clothing such as hats, coveralls, vests and full body suits.

The Centers for Disease Control and Prevention reports PPE is used by 20 million workers and according to Global Market Insights, the PPE market will hit $67.6 billion by 2023. As these numbers suggest, PPE can be effective, and it undoubtedly contributes to the prevention of injuries and fatalities.
However, hazards are still present. Although PPE is safer than nothing, it does not mitigate all hazards. It is imperative that PPE is used in tandem with other levels of the hierarchy to maximize effectiveness.

According to OSHA, administrative controls are meant to change the behavior of workers, with examples including training, procedure development, policy enforcement and installation of signs and warning labels to reduce the threat of workplace hazards. Like PPE, these are mainly used alongside existing protocols where hazards are not well controlled, and in any industry where electricity is present.

Inexpensive to implement and establish, administrative controls require effort and adherence from management and staff to be effective.

For many organizations, these are the primary approach to reducing workplace injuries. As a result, the safety of workers in these settings relies on the administrative controls being properly designed, maintained and implemented by the staff.

Panduit recognizes that most businesses have well established PPE practices and some level of administrative controls in place. But there are still many opportunities for businesses to solidify and improve their safety programs with greater emphasis on the theory of prevention through design (PtD).

Engineering controls increase effectiveness

Engineering controls represent the middle tier of the hierarchy, more effective than PPE and administrative controls, but technically less effective than elimination and substitution. However, equipment within and above this level is developed so as to design-out hazards, with engineering controls thereby taking on an increased level of effectiveness.

According to The National Institute for Occupational Safety and Health (NIOSH):
“Prevention through design encompasses all of the efforts to anticipate and design out hazards to workers in facilities, work methods and operations, processes, equipment, tools, products, new technologies and the organization of work. The focus of PtD is on workers who execute the designs or must work with the products of the design. The initiative has been developed to support designing out hazards, the most reliable and effective type of prevention.”

In other words, engineering controls solutions, like data access ports and voltage testers, built with PtD in mind share the core concept that elimination or removal is considered to be the most effective hazard prevention solution.

Evaluating robustness

While elimination or substitution are theoretically the most effective prevention methods, they’re rarely the most practical, and often, not achievable.

For example, inherent risk exists in opening an energized electrical enclosure, but performing service work without power to the equipment prohibits diagnosing or monitoring the equipment.

Working up the hierarchy of controls pyramid, the next option is “substitution,” the second most effective hazard control. Substitution involves replacing something that produces a hazard with something that does not produce a hazard.

An example of this is arc-resistant equipment. Rather than using traditional equipment such as switchgear and motor-control centers (MCCs), arc-resistant versions of this equipment can be specified and installed in place. This substitution incorporates arc-resistant material and reduces exposure to an arc flash hazard by directing the energy away from a worker performing a task, such as operating or racking a circuit breaker in or out with the doors closed.

Since “elimination” is the most effective way method to design out hazards, the easy answer would be to completely remove any energy within the electrical enclosure. Unfortunately, in this case, removing all energy from the enclosure is prohibitive to diagnosing or monitoring the equipment within and therefore, elimination usually is not feasible when it comes to electrical work on a plant floor.

Looking ahead

Electrical incidents can result in damaged equipment, serious injuries or worse. A firm understanding of the hierarchy of controls and the willingness to take a design-first approach to electrical safety improvements can help safety professionals and plant managers protect workers from electrical injuries more effectively than relying solely on administrative controls and PPE.

As these technologies are designed into modern equipment, plant floor and safety professionals will have peace of mind that their extended staff is better protected. The personnel required to service this technology often expands beyond the standard qualified electrician role and into roles occupied by machine operators, IT personnel and others.

Author Bio: Zach Ganster is the product manager for Prevention through Design (PtD) at Panduit. In this role, he supports and expands existing product lines, driving revenue and profitability.