After visiting a handful of facilities, you develop a routine: Empty your pockets. Put on your steel-toed shoes. Pull back loose hair. Remove jewelry. Grab the hard hat, photo ID and a couple of business cards from your bag in the back seat of the car. Stop at the front desk and review the company’s safety video. Don whatever site-specific personal protective equipment (PPE) is required and/or provided by your host.
Because PPE is so prevalent in workplaces, it’s easy to see why many people view it as the primary line of defense against workplace safety hazards. The boxes and bins of ear plugs, safety glasses, booties and gloves mounted on walls near entrances are likely to be the first thing you see when you enter a production area. These items are mainstays in safety vending machines. You see everyone in the facility wearing PPE, so it must be important, right?
Yes, PPE is important. When the correct types are chosen, worn and used, PPE absolutely helps save lives and reduce the risk of injury or illness. But when you apply risk assessment hierarchy of controls principles, PPE is actually the last line of defense against workplace safety risks. Four other forms of protection need to take precedence before you choose and use PPE as a solution. Here’s a look at how to prioritize:
When processes and procedures are being analyzed for risks, it is important to look for ways to eliminate the risk entirely. If you can, you don’t need to create a process or procedure to avoid it. Of all control methods, eliminating a hazard is the most desirable and effective. However, it is often the most difficult to implement, especially for processes that already exist at a facility,
Substitution means replacing the process or item that causes a hazard with one that does not. For example, replacing a solvent-based degreaser with a citrus-based degreaser is a substitution that reduces air emissions and is typically less harmful to employees and the environment. When considering substitution methods and products, it is important to review them thoroughly to ensure that they do not create new hazards.
3. Engineering Controls
Several workplace safety regulations, such as the ones listed below, require engineering controls as a line of defense against hazards. Often, these controls can be worked into the design of the equipment or process. They can also take the form of barriers, guards or enclosures.
Engineering controls are usually permanently installed devices that remove the need for an employee to remember to do or wear something to work safely. That is why they are considered the best option for managing unavoidable safety hazards or risks.
4. Administrative Controls
Administrative controls document processes that a company will follow to eliminate hazards and/or minimize employee exposure. Forms of administrative controls include standard operating procedures, established safe work routines, employee training and emergency response drills. They can also include what some might consider “creature comforts,” such as taking frequent breaks when working in extreme heat or cold and rotation of job functions. Although they may seem superfluous, these activities do serve a safety function. Scheduling downtime to perform preventive maintenance and routine inspections can also be directly tied to safety controls, because they minimize the chance for malfunctions that could put employees at risk for injury or death.
When engineering and administrative controls aren’t enough to keep employees safe, the balance of the safety load falls on PPE. Although PPE is a form of protection, it presents its own challenges, including the following:
- It has to fit correctly to be effective. A good example of this is respiratory protection. If you can’t get a good seal, it’s not going to work well.
- It has to be worn. Yes, you can get a pair of safety glasses for a couple bucks. But if they’re not comfortable, or if they fog up in hot weather s no one wants to wear them, you’re probably wasting your money. They either won’t be worn, or only if someone vigilantly polices each work area to make sure of it. Spending a bit more for glasses that feel better and don’t fog up is a good use of safety funds, even on a tight budget. The same goes for earplugs, safety shoes and everything else that employees need to wear every day.
- It has to be removed from service when it has passed its prime. Nothing lasts forever, especially PPE. A frayed fall harness, safety shoes with smooth soles, glasses with severely scratched lenses and gloves with holes—these are all examples of PPE that needs to be replaced immediately.
- It has to be understood. Employees need to know about hazards in their workplace and how engineering and administrative controls, in combination with PPE, help them work safely. They also need to be taught how to wear, use and take care of any PPE that they’ve been issued so that it is truly effective and provides that last line of defense against a safety risk.
Eliminating hazards and substituting less hazardous products are not always possible. Retrofitting machines with engineering controls can be expensive. Administrative controls take time from production schedules. Getting everyone to wear their PPE can be a pain. But bringing together all of these elements is the only hope for eliminating the chance of an employee’s duties causing injury, illness or death.