Identifying and Controlling Hazards

MODULE 5: CONTROLLING HAZARDS

1. Engineering Controls
2. Management Controls
3. Interim Measures

   Engineering Controls These controls focus on eliminating or reducing the actual source of the hazard, unlike other control strategies that generally focus on employee exposure to the hazard. The basic concept behind engineering controls is that, to the extent feasible, the work environment and the job itself should be designed to eliminate hazards or reduce exposure to hazards. While this approach is called engineering controls, it does not necessarily mean that an engineer is required to design the control.

   
   
   Why engineering controls?
   
   The underlying intent of OR-OSHA law requires employers to first attempt to remove hazards through the use of feasible engineering controls because they have the potential to totally eliminate hazards in the workplace. If an engineering control eliminates the hazard, it may also remove the need to control employee behaviors through the use of management controls. Remember:
   
   

   No hazard...no exposure...no accident.

   
   
   Engineering controls do not necessarily have to be expense or complicated. They can be quite simple in some cases. Engineering controls are based on the following broad strategies:
   
   
   1. If feasible, design or redesign the tools, equipment, machinery, materials and/or facility.
   
   
   
   2. If design/redesign is not possible, remove the hazard and/or substitute something that is not hazardous or is less hazardous;
   
   
   
   3. If removal is not feasible, enclose the hazard to prevent exposure in normal operations; and
   
   
   
   4. If complete enclosure is not feasible, establish barriers or local ventilation to reduce exposure to the hazard in normal operations.
   
   
   Elimination of hazards through design or substitution. Some examples of this strategy include:

   • Redesigning, changing, or substituting equipment to remove the source of excessive temperatures, noise, or pressure;
   • Substituting a toxic chemical with a less toxic or non-toxic chemical;
   • Redesigning a process to use less toxic chemicals;
   • Redesigning a work station to relieve physical stress and remove ergonomic hazards; or
   • Designing general ventilation with sufficient fresh outdoor air to improve indoor air quality and generally to provide a safe, healthful atmosphere.

   
   
   Enclosure of Hazards
   
   When you cannot remove a hazard and cannot replace it with a less hazardous alternative, the next best control is enclosure. Enclosing a hazard usually means that there is no hazard exposure to workers during normal operations. There still will be potential exposure to workers during maintenance operations or if the enclosure system breaks down. For those situations, additional controls such as safe work practices or personal protective equipment (PPE) may be necessary to control exposure.
   
   Some examples of enclosure designs are:

   • Complete enclosure of moving parts of machinery;
   • Complete containment of toxic liquids or gases from the beginning to end of a process;
   • Glove box operations to enclose work with dangerous microorganisms, radioisotopes, or toxic substances; and
   • Complete containment of noise, heat, or pressure producing processes with materials especially designed for those purposes.

   
   
   Barriers or Local Ventilation
   
   When the potential hazard cannot be removed, replaced, or enclosed, the next best approach is a barrier to exposure or, in the case of air contaminants, local exhaust ventilation to remove the contaminant from the workplace. This engineered control involves potential exposure to the worker even in normal operations. Consequently, it should be used only in conjunction with other types of controls, such as safe work practices designed specifically for the site condition and/or PPE. Examples include:

   • Ventilation hoods in laboratory work
   • Machine guarding, including electronic barriers
   • Isolation of a process in an area away from workers
   • Baffles used as noise-absorbing barriers
   • Nuclear radiation or heat shields.

   Management Controls
   
   

   Management controls are aimed at reducing employee exposure to hazards that engineering controls fail to eliminate. Management controls work by designing safe work practices into job procedures and adjusting work schedules. Ultimately, effective management controls will successfully eliminate the human behaviors and conditions that result in 98% of all workplace accidents!

   
   
   Management controls are only as effective as the safety management system that supports them. It's always better to eliminate the hazard so that you don't have to rely on management controls that tend to work only as long as employees behave. Here's an important principle that reflects this idea:
   
   

   Any system that relies on human behavior is inherently unreliable.

   
   
   To make sure management controls are effective in the long term, they must be designed from a base of solid hazard analysis and sustained by a supportive safety culture. They then must be accompanied by adequate resources, training, supervision, and appropriate consequences. Remember, management controls should be used in conjunction with, and not as a substitute for, more effective or reliable engineering controls. Now let's look at some examples of some management controls.
   
   Safe work practices
   
   Safe work practices may be quite specific or general in their applicability. They may be a very important part of a single job procedure or applicable to many jobs in the workplace. Safe work practices include:

   • Removing tripping, blocking, and slipping hazards
   • Removing accumulated toxic dust on surfaces
   • Wetting down surfaces to keep toxic dust out of the air
   • Using safe lifting techniques
   • Maintaining equipment and tools in good repair
   • Using personal protective equipment

   Other safe work practices apply to specific jobs in the workplace and involve specific procedures for accomplishing a job. To develop safe procedures, you conduct a job hazard analysis (JHA). If, during the JHA, you determine that a procedure presents hazards to the worker, you would decide that a training program is needed. We recommend using the JHA as a tool for training your workers in the new procedures. A training program may be essential if your employees are working with highly toxic substances or in dangerous situations.
   
   

   Personal Protective Equipment (PPE) Using personal protective equipment is a very important safe work practice. It's important to remember that, like other management controls, the use of PPE does not control the hazard itself, but rather it merely controls exposure to the hazard by setting up a barrier between the employee and the hazard. Use of PPE may also be appropriate for controlling hazards while engineering controls being installed or work practices developed.

   
   
   PPE Drawbacks
   
   The limitations and drawbacks of safe work practices also apply to PPE. Employees need training in why the PPE is necessary and how to use and maintain it. It also is important to understand that PPE is designed for specific functions and are not suitable in all situations. For example, no one type of glove or apron will protect against all solvents. To pick the appropriate glove or apron, you should refer to recommendations on the material safety data sheets of the chemicals you are using.
   
   Your employees need positive reinforcement and fair, consistent enforcement of the rules governing PPE use. Some employees may resist wearing PPE according to the rules, because some PPE is uncomfortable and puts additional stress on employees, making it unpleasant or difficult for them to work safely. This is a significant drawback, particularly where heat stress is already a factor in the work environment. An ill-fitting or improperly selected respirator is particularly hazardous, since respirators are used only where other feasible controls have failed to eliminate a hazard.
   
   

   Scheduling strategies Scheduling is a way to reduce the duration and frequency of exposure to a hazard. Strategies include: lengthened rest breaks, exercise breaks to vary body motions, job rotation, limit work shifts.

   Interim Measures
   
   When a hazard is recognized, the preferred correction or control cannot always be accomplished immediately. However, in virtually all situations, interim measures can be taken to eliminate or reduce worker risk. These can range from taping down wires that pose a tripping hazard to actually shutting down an operation temporarily. The importance of taking these interim protective actions cannot be overemphasized. There is no way to predict when a hazard will cause serious harm, and no justification to continue exposing workers unnecessarily to risk.
   
   What are "feasible" controls?
   
   Abatement measures required to correct a hazard must be technologically and economically feasible for the employer. Oregon OSHA uses the following criteria to determine feasibility of engineering and management controls:
   • Technical Feasibility. Technical feasibility is the existence of technical know-how as to materials and methods available or adaptable to specific circumstances which can be applied to cited violations with a reasonable possibility that employee exposure to occupational health hazards will be reduced.
   
   
   
   • Economic Feasibility. Economic feasibility means that the employer is financially able to undertake the measures necessary to abate identified hazards. Economic feasibility is a major issue to be considered when imposing hazard controls. According to OSHA's Instruction CPL 2.45, Oregon OSHA may allow the use of PPE to abate a hazard, at least until such time as engineering controls become a less significant economic burden for the company when the following conditions are met:
     
     
     1. If significant reconstruction of a single establishment involving a capital expenditure which would seriously jeopardize the financial condition of the company is the only method whereby the employer could achieve effective engineering controls;
     
     
     
     2. If there are no feasible management (administrative or work practice)controls; and
     
     
     
     3. If adequate personal protective equipment or devices are available.
   In those limited situations where there are no feasible engineering or management controls, full abatement can be allowed through the use of personal protective equipment.
   
   Maintenance Strategies to Control Hazards
   
   What two general types of maintenance processes are needed?
   
   
   • Preventive maintenance to make sure equipment and machinery operates safely and smoothly.
   • Corrective maintenance to make sure equipment and machinery gets back into safe operation quickly.
   
   
   Hazard Tracking Procedures
   
   An essential part of any day-to-day safety and health effort is the correction of hazards that occur in spite of your overall prevention and control program. Documenting these corrections is equally important, particularly for larger sites.
   
   Documentation is important because: 
   • It keeps management and safety staff aware of the status of long-term correction items;
   • It provides a record of what occurred, should the hazard reappear at a later date; and
   • It provides timely and accurate information that can be supplied to an employee who reported the hazard.
   Final thoughts
   
   The hierarchy of controls is the standard system of strategies to effectively eliminate workplace hazards. Remember, the first question to ask when considering ways to eliminate a hazard is, "can we apply engineering controls?" You may need to use a combination of strategies to effectively eliminate the hazard. Whatever it takes, do it. You're not just saving a life....you're saving a father, a mother, a son, or a daughter....you're saving a family. It's worth the effort

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   Module Quiz
   
   36. To combat hazardous conditions and unsafe work practices, three basic control strategies, called the "Hierarchy of Controls" have been developed. Which of the below is not one of the strategies discussed in the text?

   a. Engineering controls
   b. Permanent measures
   c. Management controls
   d. Interim measures

   37. Why do Oregon OSHA standards require the employer to first consider engineering controls to correct workplace hazards?

   a. Because safety is all about conditions, not behavior
   b. They may completely eliminate the hazard
   c. They may completely eliminate exposure
   d. They cost more in the long run than enforcing safe work practices

   38. According the text, engineering controls should not rely on which of the following strategies:

   a. design or redesign
   b. removal or substitute
   c. barriers or ventilation
   d. personal protective equipment

   39. Which of the engineering controls listed below is most likely to eliminate a toxic chemical hazard?

   a. placing a barrier between the employee and chemical
   b. placing the chemical in a container
   c. replacing a toxic with a less/non toxic chemical
   d. wearing appropriate personal protective equipment

   40. According to the text, management controls are only as effective as the:

   a. the policies that implement them
   b. the people that use them
   c. as the engineering controls they control
   d. safety management system that supports them

   41. Ultimately, effective management controls will successfully eliminate the human behaviors that result in _______ of all workplace accidents:

   a. 98%
   b. 80%
   c. 65%
   d. 5%

   42. Management controls should be used ____________ engineering controls:

   a. before
   b. along with
   c. instead of
   d. in the absence of

   43. To pick the appropriate glove or apron, you should refer to recommendations on the _______________ of the chemicals you are using.

   a. material safety data sheet
   b. manufacturer's information
   c. supplier invoice
   d. inner lining of the glove or apron

   44. According to the text, ____________________ is a strategy to make sure equipment and machinery operates safely and smoothly.

   a. corrective maintenance
   b. emergency maintenance
   c. programmed maintenance
   d. preventive maintenance

   45. Tracking hazards is described in the text as being important for all of the following reasons, except:

   a. It keeps staff aware of the status
   b. It provides timely and accurate information
   c. It provides evidence for discipline
   d. It provides a record of what occurred

   Controlling hazards the workplace is one more key to an effective safety management system. Study the next module to learn about effective problem solving tools to help eliminate or reduce hazards in the workplace. If you have any questions or comments, just drop me an email at email.
   
   

   Have a great safe day!