Management system guidance
8.1 Operational Planning and Control
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8.1.2 Eliminating hazards and reducing OH&S risks
Is the hierarchy of controls correctly applied? Your organization must establish, implement and maintain a process (or processes) for eliminating hazards and reducing OH&S risks, and that process must work through the controls in a set order of preference:
- Elimination: remove the hazard altogether;
- Substitution: replace hazardous processes, operations, materials or equipment with less hazardous ones;
- Engineering controls and reorganization of work: isolate people from the hazard or change how the work is organized;
- Administrative controls, including training: procedures, instructions, signage, supervision and competence;
- Personal protective equipment (PPE): provide adequate PPE as the last line of defense.
Each level is regarded as less effective than the one above it, because the lower controls depend more heavily on people behaving correctly every time. In practice, several controls are normally combined to bring the risk down to a level that is as low as reasonably practicable. ISO 45001 also notes that in many countries legal requirements oblige employers to provide PPE to workers free of charge.
Examples at each level
- Elimination – stop using a hazardous chemical; design out work at height by assembling at ground level; remove fork-lift trucks from pedestrian areas; build ergonomics into the planning of new workplaces; eliminate monotonous work or work that causes harmful stress.
- Substitution – switch from solvent-based to water-based paint; replace slippery floor surfaces; use lower-voltage tools; buy materials in pellet rather than powder form.
- Engineering controls and reorganization of work – machine guarding and interlocks; local exhaust ventilation; noise enclosures; guard rails and edge protection; mechanical lifting aids; physical segregation of vehicles and pedestrians; reorganizing work to avoid lone working, excessive hours or unmanageable workload, and to prevent victimization.
- Administrative controls including training – safe systems of work, permits and lock-out/tag-out; induction and task training; periodic inspection of safety equipment; fork-lift operator authorization; coordination with contractors; health surveillance for workers exposed to noise, vibration, respiratory or skin hazards; training to prevent bullying and harassment; clear instructions on how to report incidents and concerns without fear of reprisal; changes to shift patterns.
- PPE – safety footwear, eye protection, hearing protection, gloves suited to the hazard, respiratory protection, high-visibility clothing – together with instruction on correct use, fit testing, storage, maintenance and replacement.
Making the hierarchy work
The most common weakness auditors find is a jump straight to administrative controls or PPE without any record that higher-level options were considered. To avoid this:
- Build the hierarchy into your risk assessment form so that the assessor must record which options at each level were considered and why any were rejected as not practicable;
- Consider the hierarchy at the design and procurement stage, when elimination and substitution are cheapest (see 8.1.3 and 8.1.4);
- Check that new controls do not introduce new hazards, and re-assess residual risk after controls are in place;
- Verify that controls remain effective through inspection, monitoring and audit (see 9.1.1);
- Use incident investigations (see 10.2) to test whether a higher-level control could have prevented the event.
Worker participation
Clause 5.4 requires the participation of non-managerial workers in determining the mechanisms for controlling hazards and risks. Workers should be involved in selecting controls, trialing PPE for comfort and fit, and identifying where administrative controls are difficult to follow in practice. Remove barriers to participation, such as language or literacy, and ensure workers can raise concerns without fear of reprisal.
You should seek and record evidence that a process for eliminating hazards and reducing OH&S risks has been established and maintained; that risk assessments show the hierarchy of controls was worked through in order, with reasons recorded where higher-level controls were not practicable; that PPE is adequate, maintained and provided in line with legal requirements; that workers participated in selecting controls; and that the effectiveness of controls is monitored and reviewed.
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