Why OSHA Demands Engineering Controls First, PPE Last.Back to The PIG® Library
Often, we think of personal protective equipment (PPE) as one of the primary methods of protecting employees. Indeed, PPE is an important and practical defense against workplace hazards. But did you know that PPE should be considered your last line of defense against workplace hazards? Engineering or administrative controls – methods that employers can implement to reduce or eliminate a particular workplace hazard — must always be considered first when evaluating and mitigating workplace hazards.
What types of engineering controls should you consider implementing before doling out the PPE? It's impossible to address every conceivable danger, so we've chosen three common hazards to consider.
Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.95, regarding Occupational Noise Exposure, states: "When employees are subjected to sound exceeding those listed in Table G-16, feasible administrative or engineering controls shall be utilized." (Table G-16 lists decibel limits for various noise exposure durations). When evaluating appropriate engineering or administrative controls for noise, here are actions to consider:
- Move employees away from the noise-producing equipment
- Place noisy machinery in an area away from as many workers as possible
- Place machinery on rubber mountings to reduce vibration
- Use sound-absorbing acoustical tiles and blankets on floors, walls and ceilings
- Arrange work schedules to reduce the time each worker spends in a noisy area
Remember, the controls listed above may not provide the necessary level of hearing protection required by OSHA. Your employees may still need to wear some type of hearing protection.
Flying Debris Hazards
Not only are machine guards an effective engineering control, they're required by OSHA. 29 CFR 1910.212 states that "One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are barrier guards, two-hand tripping devices, electronic safety devices, etc." Modern machinery usually comes equipped with the necessary machine guards, but if you have older machinery at your facility, look into adding guards. Other engineering or administrative control steps to consider:
- Use barriers or ropes to keep employees out of unauthorized areas near machinery and moving parts
- Establish inspection schedules and preventive maintenance to ensure that machinery is always in working order
- Encourage employees to maintain proper housekeeping
- Train employees in the proper use of machinery and guards
OSHA regulation 29 CFR 1910.134 states "In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures." When considering implementing engineering or administrative controls to help control respiratory hazards, think about taking these steps:
- Install ventilation systems to help control and/or eliminate air contaminants
- Enclose or confine operations to avoid employee exposure
- Substitute chemicals that are less hazardous to employees
Of course, the implementation of engineering or administrative controls isn't meant to eliminate or replace the use of PPE. You may find that the combination of engineering or administrative controls and the use of PPE provide the best protection for your employees!
For more information on engineering or administrative controls, go to any of the following websites:
Noise and Hearing Conservation:
Eye and Face Protection: