A Deeper Look at the Hierarchy of Controls: A Brief History
Moved from informational note to the main text in NFPA 70E (2018), the Hierarchy of Controls has existed in the safety world for years. Like situational awareness, human performance, and safety cultures, the hierarchy of controls goes beyond electrical work, but is absolutely necessary to protect employees of all ages, backgrounds, and experience levels.
Knowing this, adherence is and will always be a vital concept for companies, and following our highly informative and popular blog on how the hierarchy of controls became a key part of NFPA 70E (2018), we would like to take an even deeper look at this systematic process for minimizing risk over the next couple weeks.
Focus on Worker Safety
So why is a company who specializes in electrical PPE talking about five methods deemed more effective than the wares we sell? Not once, but twice?
We’re not building safeguarding tools, providing consulting services, or printing warning signs; we won’t even step on the toes of protective footwear manufacturers or dropping into the fall protection space. We do arc flash PPE and we do it well—at least that’s what our customers say.
Even if we focus on making better, lighter, and more comfortable arc flash PPE, we still treat worker safety as our top priority (check out our guide to creating a safety culture to learn more). We also know that there are many situations when you can’t eliminate or substitute your way out of live work.
We also understand just how important and surprisingly misunderstood the hierarchy is. A recent article in Facility Executive found despite 85% of respondents to a recent study said they were familiar with NFPA 70E, 40% of respondents were unfamiliar with the hierarchy.
How did the Hierarchy of Controls Come into Existence?
Much like a variety of organizations and safety topics, The specifically-defined Hierarchy of Controls process has been around for a lot longer than you may think. While the process for choosing effective measures may have been around for much longer, the official introduction of the hierarchy of controls took place nearly three quarters of a century ago.
The Pre-History of System Safety
Prior to the 1940s, safety consisted of basically trial-and-error. At this time, safety could be compared to a trial and error process called “fly-fix-fly,” a term associated with having an aircraft make a circuit and if it broke they would fix it and fly it again, repeating until the real problem was fixed.
1941: The Need for Best Practices
By 1941, the National Safety Council began to explore in depth the causes of fatal occupational accidents, noting that at the time, 2 out of 3 accidents have both personal and mechanical causes. It was also around this time they were seeking a better way to describe effective controls.
1950: National Safety Council Introduces Hierarchy of Controls
Introduced in 1950, the NSC began describing a safety system known as the “hierarchy of controls.” The philosophy of this was simple, “controlling exposures to occupational hazards is the fundamental method of protecting workers.”
This model was created to show that that design, elimination and engineering controls should be used and/or exhausted first, as they are the most effective when available.
As discussed in an article comparing hierarchy- to behavior-based safety programs, it was noted:
“The highest feasible level of control should be used to control every hazard. When high level controls are not feasible or do not adequately reduce risk, lower level controls such as warnings, training, procedures and personal protective equipment must be implemented.”
In this, the goal is to reduce the risk that human error can cause an incident or the potential damage if such an incident takes place (for example, substituting a hazardous chemical with a less hazardous one will reduce the damage caused by a spill, a deenergized piece of equipment isn’t going to release energy).
How Governing Bodies and Codes Reference the Hierarchy of Controls
Understandably, as a process that has been around for decades and has been proven effective through use, the hierarchy has found its way into common use in governing bodies and documents.
NIOSH Recognizes Hierarchy of Controls in Prevention through Design
Though the hierarchy has been around since 1950 and informally used by government agencies (for example, much of the hierarchy was discussed in a 1986 document on occupational lung diseases and has discussed engineering controls for decades), the real focus on it was introduced in 2007.
The National Institute for Occupational Safety and Health was created as the educational wing of the Occupational Safety and Health Act of 1970. With a stated goal of “Safety and health at work for all people through research and prevention,” their job is to inform while OSHA’s is to enforce.
Prevention through Design
Prevention through Design (PtD) is a national initiative introduced in 2007, aiming to find ways to prevent or reduce occupational injuries, illnesses, and fatalities through the inclusion of prevention considerations in all designs that impact workers. A program that has expanded over the years, PtD looks to discover strategies focused on elimination and substitution.
As it stands, the NIOSH Hierarchy of Controls provides a five-step program, which differs from the NFPA 70E’s six.
Hierarchy of Controls Enters, is Enshrined in NFPA 70E
Another governing body in which the hierarchy has long been informally mentioned but not enshrined until recently was the NFPA.
Introduced as an informative annex to 110.1 and 110.2 in the 2015 edition, the Hierarchy of Controls not only became a core feature of the 2018 edition, it was featured on the cover.
Five or Six? The Introduction of Awareness in NFPA 70E
One of the biggest differences between the NIOSH version and the NFPA one is the introduction of awareness. Defined as “educating workers on the hazards and providing information on making safe decisions,” awareness exists as an extension of administrative controls.
This is an incredibly important consideration in the electrical industry, as it addresses the fact that many of the workers injured in electrical incidents were either untrained, unqualified, or unaware that a hazard exists. In turn this creates an overlap with administrative controls, which rely on employee training, risk assessment, job briefing, auditing, and the use of an energized electrical work permit.
Can OSHA Use the Hierarchy of Controls?
As with anything cited in NFPA or NIOSH, the question of whether OSHA can cite an employer for something not officially enshrined in 29 CFR 1910 (general industry) and 1926 (construction) comes up. Paired with the fact that OSHA lists this in their “Recommended Practices for Safety and Health Programs” (as opposed to practices you shall implement), and you might not think too much of this.
However, as we discussed in a recent blog, NFPA standards can be used as ‘industry consensus’ standards and in limited circumstances, you can be cited under the General Duty Clause.
Enespro PPE: Your Best Last Line of Defense
The addition of the hierarchy of controls in the latest editions of NFPA 70E marked an important shift to systematically addressing safety. We understand that PPE should be your last line of defense—but it also shouldn’t be something that workers dread wearing.
At Enespro PPE, we travelled the country to gain a deeper understanding of the needs of workers in the electrical industry with the goal of transforming the industry with greater comfort, functionality and safety for a wide range of work requirements.
Stay tuned for our upcoming blog digging into each step in the hierarchy of controls, and while you wait, download our free guide to developing a safety culture. Ready to learn more about our innovative line of products? Check them out here.
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