Understanding the Hierarchy of Controls Through a Pandemic

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Understanding the Hierarchy of Controls Through a Pandemic CHECKPOINTS Understanding the Hierarchy of Controls THROUGH A PANDEMIC By Cathy Spigarelli Like many safety professionals, I tend to view the world through the lens of OSH concepts. I am proud of my keen and constant eye, but my kids have a different opinion of this skill. According to my children, the day I informed the golf course of a deep, uncovered hole on the putting green, they were terribly embarrassed. Even worse was the day I surprised a can we eliminate this deadly virus? effect, making a more lethal virus into store owner with information that an It is possible to eradicate viruses. By a less lethal one. This is possible but employee was improperly using a ladder denying access to host cells, the virus research (competent people, time and on the grounds. And, apparently, I was will be unable to replicate. Denying money allowing) is needed to identify “exhausting” during a recent trip abroad, access comes in the form of effective the correct drug. Substitution work to pointing out every safety concern vaccinations and transmission pre- mitigate the potency of this virus is observed. “Stop, Mom!” they pleaded, to vention. Eventually, extinction of the underway. which I said, “I can’t help it.” virus will occur. Virus eradication That is what led me to consider the is complicated and not a short-term Engineering Controls NIOSH hierarchy of controls (Fig- solution. According to Russell (2011), Next is implementation of engineer- ure 1) in relation to the crisis with this has only been accomplished with ing controls. Essentially, this involves COVID-19. The hierarchy of controls two viruses to date: smallpox (1979) isolating people from the hazard or is a foundational concept for method- and rinderpest virus (2011). Although placing a barrier between them. A phys- ically solving OSH challenges. This hazard elimination is the first choice, ical barrier, such as a glass transaction methodology consists of five ways of it may not be possible, may not be a window with a speak-thru device as is mitigating or eliminating a hazard timely solution or may be cost pro- used at a bank drive-up window, pro- that are ranked in order of effective- hibitive. Currently, in the case of vides protection from viral exposure ness and, therefore, preference. COVID-19, elimination (i.e., develop- and is a form of engineering control. Let’s review the components of the ment of a vaccination) is underway. For those doing research on this virus, hierarchy of controls and consider how work in a ventilation hood is an example they apply to a pandemic, progressing Substitution of protection through use of an engi- through each control from most to Second on the hierarchy of controls neering control. Engineering controls least effective since this is the order of is substitution: replacing a given haz- generally take time to invent, create, consideration. ard with something less hazardous. fabricate, produce and implement. For So, for example, a more lethal virus this reason, we need the next two con- Elimination would be replaced with a less lethal trols. There also may be situations in The first and most effective control virus. Administering a drug that in- which administrative controls and PPE is elimination. Think of elimination as terferes with the virus’s ability to rep- are an appropriate supplement to the physically removing the hazard. How licate once a person is infected is, in higher-level controls. FIGURE 1 Administrative Controls NIOSH PTD HIERARCHY OF CONTROLS MODEL Administrative controls, or changing the way people work or act, is next on the hierarchy of controls. Changes in Most policy or procedures aimed at reducing effective Elimination Physically remove the hazard or minimizing hazard exposure define an administrative control. Personal hygiene practices such as frequent Substitution Replace the hazard handwashing with the appropriate soap and for the necessary amount of time, isolation of people, limiting the size of Engineering Isolate people controls gatherings, and keeping a 6-ft separa- from the hazard tion between people when in groups are all examples of administrative controls. Administrative Change the way controls However, administrative controls have a people work distinct downside. Compliance is need- ed for this type of control to be effective PPE Protect the and human beings are rarely perfect at Least worker with PPE compliance. effective Administrative controls have their Note. Adapted from “Hierarchy of Controls,” by NIOSH, 2015, www.cdc.gov/niosh/topics/hierarchy. place and are needed in the hierarchy of controls. The more effective con- 20 PSJ PROFESSIONAL SAFETY MAY 2020 assp.org Methodically working through each ele- ment of the hierarchy of controls (elimi- nation; substitution; engineering controls; administrative controls; PPE) and creatively applying these controls to the problem can achieve successful elimination of hazards. trols may not be easily implemented needed may also be an issue. For all of a pandemic. Methodically working or put in place in a timely manner. these reasons, PPE is the least effective through each element of the hi- Administrative controls can be a control method, yet it has been a major erarchy of controls (elimination; temporary solution, bridging the gap focus during the pandemic. PPE can be substitution; engineering controls; until more effective controls can be implemented quickly (if equipment is administrative controls; PPE) and employed. available) and is a solution for buying creatively applying these controls to down risk while waiting for more effec- the problem can achieve successful PPE tive controls to come to fruition. elimination of hazards. PSJ Last on the hierarchy of controls, and considered least effective is PPE. Conclusion References This includes items such as gloves, The hierarchy of controls is an Russell, C.D. (2011). Eradicating in- masks and protective clothing that effective model for working toward fectious disease: Can we and should we? provide a barrier between the person mitigation and elimination of haz- Frontiers in Immunology, 2, 53. doi:10.3389/ and the hazard. Effectiveness of this ards, including those faced during fimmu.2011.00053 control requires that the right equip- Cathy Spigarelli, M.S., CHMM, is a corporate environmental health and safety manager for En- ment is used, it must not be damaged capsys LLC, a microencapsulation company located in Appleton, WI. She is responsible for corporate and workers must remember to wear OSH, product stewardship and regulatory affairs. With an M.S. in Pharmacology and Toxicology, and it. Training on the proper use and lim- EHS/Environmental Management, as well as a B.S. in Metallurgical Engineering/Materials Science, she itations of the PPE is also needed. Lack has spent more than 12 years applying this knowledge in the OSH area. Spigarelli is a member of ASSP’s NUTHAWUT SOMSUK/ISTOCK/GETTYof IMAGES PLUS available PPE where and when it is Wisconsin Chapter. EXPERIENCE THE DIFFERENCE OSHA Training Institute (OTI) Education Centers are a national network of non-profit organizations that provide OSHA-authorized safety and health training to improve the safety culture and performance in the workplace. OUTREACH PROGRAM OTI Education Centers are a catalyst in the rapid growth of OSHA’s Outreach Program, with over 6 1/2 million students trained through the Outreach Training Programs. WANT TO BE AN AUTHORIZED OSHA OUTREACH TRAINER? Take one of our Trainer Courses: • OSHA #500 Trainer Course in Occupational Safety and Health Standards for the Construction Industry • OSHA #501 Trainer Course in Occupational Safety and Health Standards for General Industry • OSHA #5400 Trainer Course in Occupational Safety and Health Standards for the Maritime Industry • OSHA #5600 Disaster Site Worker Trainer Course NEED TO KNOW WHAT OSHA REQUIRES? Enroll in one or more of our 50 OSHA courses at your nearest OTIEC: • OSHA #510 Occupational Safety and Health Standards for the Construction Industry • OSHA #511 Occupational Safety and Health Standards for General Industry • OSHA #2225 Respiratory Protection • OSHA #2264 Permit-Required Confined Space Entry • OSHA #3015 Excavation, Trenching, and Soil Mechanics bit.ly/OTIEC_ASSP20 • and many more! assp.org MAY 2020 PROFESSIONAL SAFETY PSJ 21.
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