A Deeper Dive: Hierarchy of Controls Steps
By: Rich Gojdics
While we defined each step simply in our initial blog on the hierarchy, there is much more to discuss about what each step means. Today, we’d like to offer a deeper dive into each step of the controls process, discussing examples and providing more understanding.
Part of a larger program to protect workers, use of the hierarchy is based on a risk assessment, a process used to identify a hazard, estimate the likelihood of an incident and severity, and determine what protective measures are needed.
While there are six controls in the NFPA version of the hierarchy, one could break it into four tiers:
- Elimination and Substitution: Highly effective but nearly impossible to implement
- Engineering Controls: Favorable and effective but hard to rely on
- Administrative Controls and Awareness: Damage mitigation, reliant on human performance
- Personal Protective Equipment: Individual protection
Six Controls in NFPA 70E
As mentioned earlier, the best possible and most feasible control should always be selected. Added to this, controls can be combined (e.g. supplementing engineering controls with the use of PPE, implementing administrative controls after substitution).
Elimination: Physically Remove the Hazard
Considered the gold standard of controls, elimination represents the most effective and error-proof process for protecting workers from an identified hazard. This is the most straightforward of the controls—completely removing the potential for human error. If there is no hazard, there is no risk of injury. This removes the potential for human error when interacting with the equipment.
However, this is easier said than done, as it’s rarely an option for installed equipment.
Substitution: Replacing a More Hazardous Environment with a Less Hazardous One
Though not as completely free from human error as elimination, substitution is another one of the ways to reduce risk. Again, a control that is harder to implement for existing equipment, substitution at the design phase is often plausible.
As discussed in his article on the topic in the NFPA Xchange, Christopher Coache highlights substitution methods such as installing a remote racking system during the installation, utilizing a faster acting overcurrent device or opting for components that limit the available fault current.
Like elimination substitution is rarely plausible after the equipment has been installed, but should always be considered as a reasonable control.
Engineering Controls: Controlling Exposure at the Source
Often the first option when looking at ‘plausible’ controls, engineering controls often take the form of guards and barriers to reduce the probability of an injury. These controls are favored over administrative and personal protective equipment (PPE) for controlling existing worker exposures in the workplace because they are designed to remove the hazard at the source, before it comes in contact with the worker.
Well-designed engineering controls can be highly effective in protecting workers and will typically be independent of worker interactions to provide this high level of protection.
Awareness: Acknowledging and Avoiding Hazards
NFPA 70E takes a different look at the hierarchy than most other entities, incorporating a control known as awareness. A control that exists between engineering controls and administrative controls, this is an important distinction.
Why? A large portion of fatalities and significant injuries from exposure to electricity affect workers who shouldn’t be working on, much less anywhere near the source. Statistics show that sixty-four percent of all on the job electrical fatalities occur in occupations that traditionally receive little to no electrical training.
According to Christopher Coache, awareness methods often have no impact on the severity of injury and have no impact on the hazard. Each system can require unique awareness devices in order to have the desired impact on risk. This risk control is often the most obvious to employees through the use of warning labels and signs.
While administrative controls explore how to approach a hazard (training, permitting, job briefing, etc.), awareness shows workers how to acknowledge and avoid hazards. This makes awareness a critical element of NFPA 70E’s Hierarchy of Controls. One way to address this is to create an unqualified worker skill program as part of a larger electrical safety program. In this, workers will understand signage, know which tasks can only be performed by qualified workers, and more.
Administrative Controls: Procedures, Training, and Briefings
Moving down the list, administrative controls are among the most commonly used, albeit one of the most heavily reliant on humans. Procedures including procedures, employee training, risk assessment, job briefing, auditing, and the use of an energized electrical work permit are all part of the administrative controls process according to Coache’s article on the NFPA Xchange. Among the administrative controls that exist:
- Task Planning: Safe work takes place before you set out to complete it. Before completing any job, workers are required to create a formal, documented job safety plan, which includes a mandatory risk assessment for both arc flash and shock before starting any job that involves electrical work or equipment.
- Documented Processes and Procedures: The process for repairing or maintaining equipment varies greatly by the piece of equipment (also the reason the term ‘qualified’ means different things to different sites). The ability to follow instructions, read and understand drawings, and complete work correctly all should be documented.
- Permitting: While always ideal to deenergize equipment before doing work, there are some situations in which the process for deenergizing may cause increased danger or otherwise be implausible. The process for applying for a hot work permit should take into consideration the entire scenario and act as a precursor to the briefing.
- Training and Qualification: OSHA §1910.399 Subpart S and NFPA 70E define a qualified person as “One who has received training in and has demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved.” Determining the process and training required for qualification is unique and ensures that workers know how to attach a task.
Like awareness, these controls are in place to avoid injury, but all the training in the world can’t change the amount of energy released in an arc flash.
ESWC: ‘Elimination’ through Administrative Control
As mentioned above, controls are often combined or rely on each other. A unique example of this is establishing an electrically safe work condition (ESWC). Establishing an ESWC does not rely on the risk control of elimination; it achieves elimination through the use of administrative controls.
So why is this considered an administrative control? Since establishing an ESWC is a procedure that has to be completed in a specific order, and the process of disconnecting, verifying, testing, and discharging is one that presents its own risks, it still is subject to human error.
Personal Protective Equipment: Supplementing Other Controls or Your Last Line of Defense
Personal Protective Equipment is frequently used with existing processes where hazards are not particularly well controlled. PPE should be the last line of defense, often used in combination with other controls to mitigate the potential damage that may occur as a result of human error.
According to OSHA, PPE is an acceptable control method in the following situations:
- When engineering controls are not feasible or do not completely eliminate the hazard
- While engineering controls are being developed
- When administrative controls and safe work practices do not provide sufficient protection, and
- During emergencies when engineering controls may not be available or feasible for use.
As part of Administrative Controls, Training should include instruction on how to properly select, inspect, and wear appropriate PPE for the job at hand, choosing the correct levels based on hazard and incident energy analyses.
Focusing on Safety No Matter What: Enespro PPE
In many processes or practices, the idea of elimination or substitution are plausible options. However, especially in the case of working on electrical equipment, a complete shutdown is not always a feasible proposition. Personal Protective Equipment is the last line of defense in protecting workers from hazards, and is not only recommended, but required, with Section 130.7 noting the conditions in which employees must be provided PPE.
Today’s organizations need to take every logical step to protect employees, and this starts at the top. At Enespro PPE, we’re proud to deliver the best products possible when you need them. Learn more about our complete range of innovative electrical safety products, download our guide to establishing an electrical safety culture, and sign up for our email list to be the first to get our upcoming Electrical Safety Program 101 guides.
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