Should the Hierarchy of Hazard Controls Be Turned Upside Down?
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Should the Hierarchy of Hazard Controls be turned upside down? The resurgence of black lung in the Australian coal mining industry is a cause for concern. An increasing number of workers have been diagnosed with the disease, despite the belief that pneumoconiosis had been obliterated from our industrial landscape. But how did this happen? © Drägerwerk AG & Co. KGaA 1 By letting our personal safety standards slip? (PPE) is notoriously placed at the bottom of the list, but why? When the Hierarchy is used as a managerial tool, the order of controls makes sense. It depends on where you The re-emergence of the disease in 2015 and 20161 shows stand in the hierarchy of your business. the importance of remaining ever vigilant against the health risks in underground and even open-cut coal mining2. There Personal Protective Equipment such as dust masks and are a number of ways companies can protect their workers. respirators are all too often treated as the least important Safety professionals will usually refer to the “Hierarchy control at our disposal. This is a critical mistake, as the of Controls” to guide their priorities when developing far presence of one control does not preclude another if we reaching safety policies and practices. wish to ensure the highest standards of safety in a coal mine. According to former Queensland Department of Mines When a hazard like airborne coal dust cannot be eliminated, Inspector Kevin Clough, the re-emergence of black lung can 5 and the activity of coal extraction cannot be substituted, in part be tied to workers attitudes towards PPE . Clough engineering controls have to be implemented. Such controls said that during his time as a mining manager at mines in include: watering the coal face to lower dust levels, or NSW and Queensland, he knew of some workers who ensuring adequate ventilation of fresh air in combination with did not wear appropriate personal protective equipment to a threshold limit value for exposure. protect themselves against inhaling coal dust. “You could tell them to wear the mask, and they’d wear them while you were there but then they’d take it off,” he said. “Through the years, you’d have a downright argument with But is this enough to ensure the safety the boys: ‘You wear the mask’; ‘I don’t want to wear it’. “Ninety of our staff? per cent of them did [wear dust masks], but you’d always get one or two that would say ‘I’m fine, I’m bulletproof’.” Clough stated that it was that type of refusal to wear PPE 4 The “Hierarchy of Controls” is a tool for safety professionals that had contributed to the re-emergence of black lung in and is treated as gospel. It is a dangerous approach when the industry. But, workers were not the only ones to blame. people in administration and management roles ignore some “The workers contributed to it, the companies contributed to levels of environmental and protective control in favour of it and the supervisory staff contributed to it,” he said. meeting operational targets. Personal Protective Equipment © Drägerwerk AG & Co. KGaA 2 So how do we change the overall sees which controls are available to them. For a worker at the coalface, PPE is the first AND last line of defence for attitude toward PPE? protecting one’s lungs. If you do not control the elimination, substitution, engineering or administrative controls, what do you personally control? What can YOU do to keep your What if we were to consider the individual who works at the lungs safe? coalface, and their position in relation to the Hierarchy of Controls. What if we were to turn the hierarchy upside down, The answer is clear. Workers ought to consider PPE as and look at the options available to the individual worker? being just as important, if not more so, than the so-called Most workers at the coalface cannot modify the engineering higher levels of control that are beyond their own personal controls that affect the presence of coal dust. On a personal level of control. This requires a change in culture. With a level, there is only one type of control for which the individual view to controlling the hazards of coal dust inhalation at the is solely responsible for, and that is the use of PPE. While personal level, Dräger is a specialist in the field of respiratory the onus is on the mining company to supply their workers protection technologies. Dräger personal protective options with the correct equipment, the buck stops with the worker offer a range of different levels and types of protection to who has to wear it. mining companies, so that they can protect their workers by world’s best practice standards/guidelines. PPE is only effective if you use it properly. There is a problem with workers who choose not to use the PPE supplied, and From the most basic P2 dust masks and half masks to the one rely instead on other levels of control to function and protect of the most sophisticated Power Purifying Respirators and them. This attitude presents a problem. Mine managers have airline fed supply systems, Dräger has worked with research come out to speak about the issue of black lung, saying organisations around the world to produce the most reliable that there is an issue with workers failing to use PPE. The and effective equipment for protecting workers in the line of reasons for this are hard to nail down, the only evidence duty6. Black lung is not a disease of the past. It is a very real of this is anecdotal, and workers are reluctant to talk about and present danger to all workers in the coal industry, and their reasons for failing to wear PPE. Education and culture while it is very important that companies exercise their power are key to the successful implementation of PPE policy. By to control dust at every level, it is up to individual workers placing such importance on the “Hierarchy of Controls” and their supervisors to ensure that all levels of control are when inducting workers, the order of controls is treated engaged in the highest levels of protection Proper PPE is as an order of importance, hence PPE is seen as the least ensuring this, starting at the workers’ level. important level of control. For more information about how Dräger can improve safety Indeed, it is the last line of defence for a coal miner, but at your mine site, provide on-site training for your staff and a that does not make it the least important. What is needed range of other safety solutions contact us on 1 800 372 437 is a total shift in attitude, a system by which the worker or visit www.draeger.com © Drägerwerk AG & Co. KGaA 3 REFERENCES 1 Interim Findings: Review of Respiratory Component of Coal Mine Workers’ Health Scheme https://www.dnrm.qld.gov.au/__data/ assets/pdf_file/0008/352286/qcwp-interim-findings.pdf 2 Commissioner for Mine Safety & Health:Queensland Mines Inspectorate Annual Performance Report 2014-15 https://www.dnrm.qld. gov.au/__data/assets/pdf_file/0008/311498/qld-mines-inspectorate-annual-performance-report-2014-15.pdf 3 Table of exposure limits for chemical and biological substances https://www2.worksafebc.com/PDFs/regulation/ExposureLimits.pdf 4 https://www.safework.sa.gov.au/uploaded_files/HierarchyofControlMeasures.pdf 5 Former mines inspector speaks out about black lung https://australianmining.com.au/news/former-mines-inspector-speaks-out- about-black-lung/ 6 Efficiency of respirator filter media against diesel particulate matter http://ro.uow.edu.au/cgi/viewcontent.cgi?article=2473&context=s spapers © Drägerwerk AG & Co. KGaA 4.