JERROLD J. SCHARNINGHAUSEN, Ph.D.
Directorate of Assessments and Prevention
Workplace Safety Division
U.S. Army Combat Readiness Center
Fort Rucker, Alabama
Author’s note: The processes described in this article will help leaders prevent and control hazards identified in my previous article, “Hazard Identification and Assessment,” which can be found at https://safety.army.mil/MEDIA/Risk-Management-Magazine/ArtMID/7428/ArticleID/6721/Hazard-Identification-and-Assessment.
Effective controls of workplace hazards protect workers; help avoid injuries, illnesses and incidents; minimize or eliminate safety and health risks; and help leaders provide safe and healthful working conditions. To effectively control and prevent hazards, units need to follow these six simple steps:
1. Identify control options
A wide variety of information exists to help leaders investigate options for controlling identified hazards. Before selecting any control options, it is essential to solicit input from the workers on the feasibility, effectiveness and acceptability of the control. Collect, organize, review and document information to determine what types of hazards may be present and which workers may be exposed or potentially exposed. The information available in the workplace may include:
- Review sources such as OSHA standards and guidance, industry consensus standards, National Institute for Occupational Safety and Health publications, manufacturers' literature and engineering reports identifying potential control measures. Keep current on relevant information from trade or professional associations. Historical data may also be available through the U.S. Army Combat Readiness Center Help Desk, which can be reached at usarmy.rucker.hqda-secarmy.mbx.safe-helpdesk@mail.mil or (334) 255-1390 / DSN 558-1390.
- Investigate control measures used in other workplaces and determine whether they would be effective at your workplace.
- Get input from workers who may be able to suggest and evaluate solutions based on their knowledge of the facility, equipment and work processes.
- For complex hazards, consult with safety and health experts.
2. Select controls
Leaders should select the controls that are the most feasible, effective and permanent. This is a process for achieving an acceptable level of risk reduction based on the preferred order of controls.
- Eliminate or control all serious hazards (hazards that are causing or likely to cause death or serious physical harm) immediately.
- Use interim controls while you develop and implement longer-term solutions.
- Select controls according to a hierarchy that emphasizes engineering solutions (including elimination or substitution) first, followed by safe work practices, administrative controls and, finally, personal protective equipment (considered the last resort or least desired in the hierarchy). See the chart below.
- Avoid selecting controls that may directly or indirectly introduce new hazards. Examples include exhausting contaminated air into occupied workspaces or using hearing protection that makes it difficult to hear emergency alarms.
- Review and discuss control options with workers to ensure controls are feasible and effective.
- Use a combination of control options when no single method fully protects workers. The hierarchy of controls below is a systematic way to determine the most effective feasible method to reduce risk associated with a hazard. Generally, the use of a combination of controls is most effective.
3. Develop and maintain a hazard control plan
A hazard control plan describes how the selected controls will be implemented. An effective plan will address serious hazards first. Interim controls may be necessary, but the overall goal is to ensure effective long-term control of the hazards. It is important to track progress toward completing the control plan and periodically (at least annually and when conditions, processes or equipment change) verify that controls remain effective.
- List the hazards needing controls in order of priority.
- Assign responsibility for installing or implementing the controls to a specific person or persons with the power or ability to implement the controls.
- Establish a target completion date.
- Plan how you will track progress toward completion.
- Plan how you will verify the effectiveness of controls after they are installed or implemented.
4. Select controls to protect workers during non-routine operations and emergencies
The hazard control plan should include provisions to protect workers during non-routine operations and foreseeable emergencies. Depending on your workplace, these could include fires and explosions; chemical releases; hazardous material spills; unplanned equipment shutdowns; infrequent maintenance activities; natural disasters; workplace violence; terrorist or criminal attacks; disease outbreaks (e.g., pandemic influenza); or medical emergencies. Non-routine tasks, or tasks workers don't normally perform, should be approached with particular caution. Prior to initiating such work, review job hazard analyses and job safety analyses with any workers involved and notify others about the nature of the work, work schedule and any necessary precautions.
- Develop procedures to control hazards that may arise during non-routine operations (e.g., removing machine guarding during maintenance and repair).
- Develop or modify plans to control hazards that may arise in emergency situations.
- Procure any equipment needed to control emergency-related hazards.
- Assign responsibilities for implementing the emergency plan.
- Conduct emergency drills to ensure procedures and equipment provide adequate protection during emergency situations.
5. Implement selected controls in the workplace
Once hazard prevention and control measures have been identified, they should be implemented according to the hazard control plan.
- Implement hazard control measures according to the priorities established in the hazard control plan.
- With limited resources, implement measures on a worst-first basis, according to the hazard ranking priorities (risk) established during hazard identification and assessment. Regardless of limited resources, leaders have an obligation to protect workers from recognized, serious hazards.
- Promptly implement any measures that are easy and inexpensive — e.g., general housekeeping, removal of obvious tripping hazards such as electrical cords, basic lighting — regardless of the level of hazard they involve.
6. Follow up to confirm that controls are effective
To ensure that control measures emplaced are and remain effective, leaders should track progress in implementing controls; supervise, inspect and evaluate controls once they are installed; and monitor routine preventive maintenance practices.
- Track progress and verify implementation by asking the following questions:
- Have all control measures been implemented according to the hazard control plan?
- Have engineering controls been properly installed and tested?
- Have workers been appropriately trained so that they understand the controls, including how to operate engineering controls, safe work practices and PPE use requirements?
- Are controls being used correctly and consistently?
- Conduct regular inspections (with industrial hygiene sampling, if indicated) to confirm engineering controls are operating as designed.
- Evaluate and monitor the effectiveness of controls to determine the need for modification. Involve workers in the evaluation of the controls. If controls are not effective, identify, select and implement further control measures that will provide adequate protection. Be prepared to adapt to changes in the situation.
- Confirm work practices, administrative controls and PPE use policies are being followed.
- Conduct routine preventive maintenance of equipment, facilities and controls to help prevent incidents due to equipment failure. Establish a feedback system to ensure controls were effective. Collect feedback data that can be shared in the form of lessons learned or reports.