Most of us are familiar with the traditional hierarchy of controls, an internationally recognized approach for identifying solutions to workplace hazards. Wagish Yajaman, WSPS' Manager, Specialty Services, proposes a version that could generate more effective solutions and make it more understandable, accessible and actionable for all workplace parties.
The most common version is an inverted pyramid, with what is considered the most effective solution at the top and least effective at the bottom:
- Elimination - removing the hazard
- Substitution - replacing the hazard with a safer alternative
- Engineering controls - isolating the hazard away from people
- Administrative controls - changing or reorganizing the way people work
- PPE - limiting exposure by providing personal protective equipment
The idea is to start at the top and work your way down the inverted pyramid as needed. Makes sense, but it's not foolproof.
"One of the limitations," says Wagish, "is that it encourages sequential rather than holistic thinking. The alternative, searching for multiple, complementary solutions, may be more productive than working your way down a list one control at a time."
Wagish offers this example: COVID-19 vaccinations are a method of personal protection. While they have significantly reduced the risk of infection and severe illness, they haven't eliminated it. That's why implementing multiple workplace controls, such as the following, has been essential:
- teleworking (elimination)
- screening (administrative)
- physical distancing (administrative)
- barriers (engineering)
- hand hygiene (engineering)
- masks (PPE)
In the inverted pyramid, masks would be considered the least effective control, but in a COVID world masks quickly became essential. In the past two years, who went anywhere without one?
Taking a layered approach to solutions
Wagish has reimagined the inverted pyramid of solutions as concentric circles. "It's no longer a hierarchy. One type of solution doesn't take precedence over another. Instead, it's more of a cumulative layering of solutions."
This offers at least three advantages:
- it helps all workplace parties understand that controlling hazards may involve multiple types of controls.
- It helps prevent gaps in our control strategies. People may think, "We have engineering controls, so we're good," or “We have administrative controls, so we're good." However, neither of these types of controls is foolproof on its own. An engineering control such as a fully automatic paint booth separates workers from potential chemical, fire or explosion hazards, but anyone entering the booth to perform maintenance still requires some type of PPE, such as a paint suit, respirator, and/or gloves.
- Looking at layers of control encourages all workplace parties to engage in identifying solutions based on their experience and expertise. Under the traditional hierarchy, identifying and implementing solutions under the uppermost controls - elimination and engineering - often requires rethinking existing processes, involves specialized expertise, and entails some expense. This could discourage proactive input from many workers and supervisors.
"Regardless of which control model you apply," says Wagish, "identifying solutions starts with understanding the hazards. Make sure your hazard assessments are thorough and up to date."
How WSPS can help
- Hazards (overview of responsibilities re: reporting, recognizing, assessing and controlling hazards, plus related resources)
- Hazard Identification, Assessment and Control (3-hour eCourse)
- Small Business Hazard Assessment Tool (form created for small businesses but useful for workplaces of any size)
- Visibility Hazards Checklist
- Hazard Reporting Form (20-49 workers)
- Hazard Reporting Form (1-19 workers)
- Make robust hazard assessments your new compliance tool (article)
- Conducting a COVID-19 risk assessment before bringing employees back (article)