Environmental

Help with Board Question no word count, Unit Assessment, and Article Review. APA Format Throughout.

Board Question.

Provide an example of a hazard where you imagine starting at the bottom of the hierarchy would be the easiest path for management to take. Which path do you believe is the best choice to take?

Unit Article Review

Select an article that deals with considering return on investment when deciding upon the implementation of hazard controls.

Write a review of the article that includes the following items:

a brief introduction to the article,
a summary and analysis of the key points in the article,
a discussion related to the concept of return on investment considerations for advocating the implementation of appropriate controls, and
a summary of the article’s conclusions and your own opinions.

The assignment must be in APA format and at least two pages in length, not including title and reference pages.

Unit Assessment

QUESTION 1

In the not-too-distant past, it was common for Occupational Safety and Health professionals to consider the hierarchy of controls according to the following priority order:
1) Engineering controls,
2) Administrative controls
3) Personal Protective Equipment
However, eliminating the hazard and substitution have usurped engineering control’s position at the top of the hierarchy although they have always been obvious best options, just not always included in discussions of the hierarchy of controls. Identify two examples where elimination of the hazard or substitution was, or might be, applied as a means of hazard control. Discuss some of the pros and cons of this option as compared to the other options in the hierarchy. You may also select examples from places you have worked or for which you have some familiarity.
Your response must be at least 200 words in length.

QUESTION 2
In Unit III, you sent a document in which you informed management at Gemstone Fabricators, Inc. that it would need to enhance its accountability specifications in its performance evaluations for managers. You also pointed out the need to make sure that employees who have been asked to be involved in the safety endeavors at Gemstone understand and are trained in the roles they are expected to play. Cindy is the plant manager from Gemstone, and she has asked you to perform a sound level survey and noise dosimetry in the fabrication shop, which can get pretty noisy when all three mechanical power presses and the 12-foot shear are running at the same time for several hours a day. She also asked that you identify noise level exposures in the adjacent welding department. Your results indicate that the noise levels in the area are just above the Occupational Safety and Health Administration (OSHA) permissible exposure level for an average day in the fabrication department.
The welding department is adjacent to the fabrication department, and there is no separating wall. The welding operations are not quite as noisy, although the crackle of a well-adjusted MIG welder can be rather loud when welding mild steel. Noise monitoring and dosimetry of the welders indicated an exposure of just over OSHA’s Action Level of 85 Dba. In addition, you remember taking the survey readings and watching the noise level jump in the welding shop every time the power presses or shear cycled in the fabrication area.
After consulting with fellow industrial hygienists, it was determined that setting up a 12′ X 30′ noise barrier wall between the fabrication area and the welding area and adding noise absorption panels to both sides of the barrier wall and to the white-painted concrete walls in the fabrication department would decrease the sound levels in the welding area to several decibels below OSHA’s Action Level.
Of course, these engineering controls will cost $33,000 dollars. This is compared to a continuing hearing conservation program to include annual audiograms, or hearing tests, annual training, and providing noise protection for the welding department which is estimated to cost $9,000 per year. This amount would be saved each year if the engineering controls are installed.
If the company takes out a loan for $33,000 at 5% interest, what will the payback period be for the loan? Please consult your unit lesson for the necessary formulas. What would be your recommendation to the employer with respect to the options available? Please show your work. Make sure you justify your reasoning and that you consider the hierarchy of controls in your discussion.
Your response must be at least 200 words in length in addition to your financial analysis.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reconsidering the cost and benefits of a formal safety progr
Professional Safety; Dec 1995; 40, 12; ABI/INFORM Collection
pg. 28

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

ctfAPTER 14

HIERARCHY OF CONTROLS:
SECTION 5.1.2 OF 210

Section 5.1.2 of ANSI/AIHA Zl0-20~2, the ~cc~pational Health and Safety
Management Systems standard, deals with the hierarchy of controls. T~e opening

ntence in that section states: “The organizat~on shall establish and implement
seprocess for achieving feasible risk reduction based on the following order of a .
controls.” A prescribed hierarchy of controls immediately follows that provision.

The hierarchy in· ZlO is the base for decision making when action is taken to
resolve occupational health and safety issues. Those issues are “defined as hazards,
risks, management system deficiencies, and opportunities for improvement,” . as in
the Planning Secti.on_(4.0): .. , .. , . , . ‘:

Application of a hierarcqy of controls 1s of such importance that a separate chapte

r

is devoted to it. Thus, in this chapter we:

• Comment on th~·~volution of hierarchies of control
• Discuss the hierarchy ~f controls in ZlO
• Provide guidelines: on the application of a hierarchy of controls
• Establish the logic of taking steps in the hierarchy of controls in the order given
• Place the hierarchy of controls within’ a good problem-solving techniques, as in

The Safety Decision Hierarchy

;:;:–_
Advanced S .
Second Ed’~ ety Management: Focusing on ZJO and Serious Injury Prevention,
© 2014 1/lion .. Fred A. Manuele. · · hn Wiley & Sons, Inc. Published 2014 by John Wiley & Sons, Inc.

26

7

268 HIERARCHY OF CONTROLS: SECTION 5.1.2 OF 210

EVOLUTION OF THE HIERARCHY OF CONTROLS

210, hi hy of controls has six elements. Hierarchies in other PUbl ‘ s erarc . 1 t Zl0’ hi Ishect dards and guidelines have three to nme e emen s. s. erarchy of controJ _stan.
f th k Of a large number of safety professionals over ma s is the outcome o . e wor . . . ny Ye

f .b t cannot be recognized here. A hmited review of the ars, l\li o the contn u ors evolutio
the hierarchy of controls follows. n of

AT THE NATIONAL SAFETY COUNCIL

Th third edition of the National Safety Council’s Accident Prevention Man
pu:lished in 1955. Section-~’ “Removi~g tqe_ H~ from the Job,” provides a th~’- Was ,. ‘ . ,, Thi . tak th A . Ll!lt(! step “order of effectiveness ano preference, . .s· is en uom e ccident Pr,,. ,e .

” Y ntion Manual.

The engineer should include in his planning and follow-through such measures
as will attain one of the accident prevention goals listed as follows (in the order
of effectiveness and preference):

• Elimination of the hazard from the machine, method, matetjal, or plant
I structure. ·

• Guarding· or otherwise minimizing the hazard at its source if the hazard
cannot be eliminated. ·

• Guarding the person of ,~he operator through the use of personal protective
equipment if the hazard cannot be eliminated or guarded at its source.
(p. 4-1) . . . .

Company policies should be such that safety can be designed and built into the
job rather than added after the.job has been put into operation.

Establishing the concept that risk reduction actions should be taken in an order of
effectiveness and preference was an important step in the evolution of the pra~tice of
safety. It implies that some steps in the process are ·preferable since they achieve
greater risk reduction than others. Declaring ·that safety policies should require that
safety be designed and built into the job rather than be dealt with as an add-on is also
a premise that influenced late,r versions pf hierarchies .of control.

THE COUNCIL OF THE EUROPEAN COMMUNITIES

Although the excerpts taken from the Directive issued in 1989 on workplace ~afety
by the Council of the European Communities are not labeled a hierarchy of co~tr~Is, that’s what they are: a nine-element list of “principles of p· revention.” It is intn~~1.ng
b ‘t b · · · b1bt1es ecause 1 egms with nsk avoidance, stresses adopting_ the work to the capa

ANSI/PMMI B155.1-2011 269

ives prominence to the design of the workplace and the choice of
f incfivi~uals, f and advises employers “to talce account of changing circumstances o ipmen’ . . ” rk equ . ove existing s1tuattons.

a,i.rJ1 to::: of the bulletin is “Council J?irective 89/39!/EEC of 12 June 1989 on
‘[he full . of measures to encourage improvements m the safety and health of

tbe introducu:; … It is available at http://eur-lex.~uropa.eu/LexUriServ/LexUriServ.
workers at wEX:31989L0391:en:HTML.
do?uri::::CEL . g general obligations on employers is from Article 6. ‘[he folloWtn

. the context of his responsibilities, the employer shall take the mea-
l . Within ecessary for th~ ~afety and health protection of workers, including

sores n I • al . ks and . . f . C • . tion of occupatton ns , prov1s1on o m1ormation and training
pre;eri provision ot tne necessary organizatioh and means. The employe;
:a1tbe alert to the n~ed to_ adjust thes~ ~eas~es !o take account of changing
. mstances and rum to llllprove extsting situations. crrcu

The employer shall implement the measures referred to in the first subpara-
2· , p. h of paragi:aph 1 on the basis of the following general principles of gra , . .

preveptio~: . .
a. avoiding n ~fs;
b. evaluating the ,t;isks which cannot be avoided:
c. combating the risks at source;
d. adapting· the· work to the individual, especially as regards the design of

work places, the ·choice · of work equipment .and the choice of working
and production methods, with a view, in particular, to alleviating monot-
onous work and work at a predetermined work-rate and to reducing their
effect on health. ·

e. adapting to technical progress; . ·

f. replacing the dangerous by the non-dangerous or the less dangerous;
g. developing a coherent overall ,prevention policy which covers technology,

organization of work, working conditions, social relationships and the
influence of factors related to the working environment;

h. giving collective protective me~s~res priority over indi_vidual protective
measures;

i. giving appropriate instructions to the workers.

ANSVPMMI B155.1-2011

The Packa . M . , . . . .
Safety R gi?g achinery Manufacturers Institute is the secretanat for the standard
Machine equirem~n:s for Packaging Machinery and Packaging-R~lated Convert~ng
issued , ry . A revision ofBI55 .1 was approved by ANSI in 2011. ltreplaced a version
In part

1
tnhi~~6· In effect, this is an eight-element process within three classifications.

‘ S 1S th ‘d ‘ h ” e gui ance given in section 6.5.1, “Use the Hazard Control Hierarc Y·

7

270 HIERARCHY OF CONTROLS: SECTION 5.1.2 OF 210

In selecting the most appropriate risk reduction measures, apply the follo .
principles in the order in which they appear. Wing

Classification-Design Out
Elimination or substitution

Classification-Engineering Controls
Guards and safeguarding devices

Classification-Administrative Controls
Awareness devices
Training and procedures
Personal protective equipment

,I

. ‘ ‘
This hierarchy of controls repeats the ele~ents in the hierarchies in other sta d

They are close to the provisions i_? MIL-STp-882E, comments for which follo:.ards.

MIL-STD-882E-2012

The Department of Defense Starz4ard Practice For Syst~m Safety, MIL-STD-882 i . . , . . F . . , ssuec1
in 1969, was a sennnal document at that time. our rev1s1ons of 882 have been is eel
over a span of 43 ye~. ~s ~tandard has ~d c~nsiderable influence on the develop;~nt
of risk assessment, elimination, and amelioration concepts and methods. Much of th
wording on risk assessments and hierarchies of control in safety standards and guide~
lines issued throughout the world is comparable to that in the several versions of 882.

The fifth edition, issued in May 2012, is designated MIL-SID-882E. It is available
on the Internet at http://www.systemsafetyskeptic.com/yahoo_site_admin/assets/
docs/MIL-SID-882E_final.135l52939 . It can be downloaded at no cost. Scroll
down and click on .the 882E indicator,on the right-hand side.

A “system safety design order of precedence” is outlined in 882E. Precedence
means priority in order, rank, or importance. In 8820, the 9-esign order of preference
had four elements. ~is lates~ “.Crsion has( fi,v~. (p. 13)

The system safety desi’gn order of precedence identifies alternative mitigation
approaches and.lists them in order ,of decreasing effectiveness.

a. Eliminate hazards through design selection.
b. Reduce risk ‘through design alteration.·
c. Incorporate engineered features or devices.
d. Provide detection and warning devices.
e. Incorporate signage, procedures, training, and PPB.

Instruction is given in 882E to assure that:

• Mitigation measures, if necessary, are selected and implemented to achieve an
ac~eptable risk level’. ·

• Im 1 · · · hieved the P ementation . measures• are evaluated to verify that they have ac
risk reduction exp~cted. . ,

. · · · · supPort • Documentation comments on the validation steps taken and the logic m
of risk acceptance.

HIERARCHIES OF CONTROL: PREMISES AND GOALS 271

RCHIES OF CONTROL: PREMISES AND GOALS tUERA
hy is a system of persons or things ranked one above the other Th hi h ·erarc . ‘d . • e er-A ‘ of controls in ZlO 1s to ~rov1 ea systematic way of thinking, considering

archY. ranked and sequential order, to choose the most effective f in a . means o
steP~ . g or reducing hazards and the nsks that derive from them. Ac know I d .
l·ounaun d . h e gmg e 1 ·se that risk re uct1on measures s ould be considered and taken • h t prem1 , . . m a

t 8 ‘bed order, represents an important step m the evolution of the practice
prescn
f safety. . f l . . 0 odel of hierarchies o contro may give examples of the types of actions to be
A~ reach of its elements, as does Appendix Gin ZlO. But little is written about

taken • o be hi ed . l . hi
urpose and the goals to ac ev m app ymg a erarchy of controls. An attempt theP ·

to do so follows. . . . .
A major premise to be considered m applymg a hierarchy of controls is that the

,me of the actions taken is to be an acceptable risk level, defined as follows outco,…_. ·

Acceptable risk is that risk for which the probability of a hazard-related incident
or exposure occurring and the severity of harm or damage that could result are
as low as reasonably practicable in the situation being considered.

That definition requires taking into consideration each of the two distinct aspects
of risk as risk reduction actions are decided· upon:

• Avoiding, eliminating, or reducing the probability of a hazard-related incident
or exposure occurring

• Reducing the severity of harm or damage that may result if an incident or
exposure occurs

The definition of acceptable risk also requires reflection on the feasibility and
effectiveness of the risk reduction measures to be taken and their costs in relation to
the amount of risk reduction to be achieved. The following appears in the “shall”
column as a part of section 5.1.2 of ZlO.

Feasible applications of this hierarchy of controls shall take into account:

• The nature and extent of the risks being controlled
• The degree of risk reduction desired
• The requirements of applicable local, federal and state statutes, standards,

and regulations
• Recognized best practices in industry
: tailable technology

0st effectiveness
• lnternati 1 • . ona orgamzat10n standards

Decision ak · 1 f tion shown · m ers should understand that with respect to the six leve s O ac
in the hi erarchy of controls in ZlO:

272 HIERARCHY OF CONTROLS: Sl:CTION 5.1.2 OF 210

Toe ameliorating actions described in the first, second, and third a .
are more effective because they Ction levels

• Are preventive actions that eliminate ?r reduce risk by desi
gn, subsr and engineering measures , 1tuti 00

• Rely the least on personnel peef ormance ‘
• Are less defeatable by supervisors or other employee~

Actions described in the fourth, fifth, and’ sixth levels are cont· ingent . and rely greatly on the performance of per~?nnel. actto08
\ •• • j

What Kepner and Tregoe wrote in. The: New Rational Manager b
preventive and ,contingent actions in the . problem-solving process fia out laking

1. · Its Pre ‘ with the risk elimination and ame 1oration concepts set forth here. c1se1y

1\vo kinds of actions are available to anyone conducting a Potential Pr
Analysis: preventive actions and contingent actions. The effect of pr obI~m

. all th l’k 1 eventtve actions is to ~move, partially _or tot Y,_ e_ e y cause of a potential prob!e
The effectiveness of a contingent actio~ 1s to reduce the impact of a p bi rn.

.. . . ‘fth ro em that cannot be prevented. Preventive actions, 1 ey can be taken, are obvious!
more efficient than contingent actions. (p. 147) Y

As decisions are made in applying each step in the hierarchy of control th
following should be considered as goals: · ,1 s• e

• Avoiding y.,ork methods that are overly stressful, taking into consideration worker
capabilities and limitations

• Keeping the probability of human error as low as reasonably practicable by
designing workplaces and work methods that are not error-provocative, meaning
that they do not (as in Chapanis, p. 119):
• Violate operator-expectation~
• Require performance beyond what an operator can deliver
• Induce fatigue
• Provide adequate facilities or information for ·the operator
• Present unnecessarily difficult or unpleasant requirements
• Include unnecessarily dangerous methods

• Designing systems so that human interaction with equipment and processes
is as low as reasonably practicable , ‘.
D · · · • · t is as low as • es1gmng systems so that use of personal protective eqmpmen
reasonably practicable

THE HIERARCHY OF CONTROLS IN Z10
d and not

We said in Chapter 1 that although ZlO is a management system standarl are the
a specification standard, the provisions pertaining to a hierarchy of contro 501co111es . – . I . to the o exception. Rather than present a performance statement re atmg

THE LOGIC OF TAKING ACTION IN THE DE SCENDING ORDER GIVEN 273

weved through a risk reduction process a s .
co t,e ale is outlined in section 5.1.2. , pec1fically defined hieran:by of
contro s

ro-anization shall establish a process for achie • £ • fhe
O

,:, &
11

• c vmg 1eas1ble risk d
based upOn the ,o owing pre,erred order of controls: re uction

A, Elimination

B
. substitution of less hazardous materials, processes, operations, or
equipment

C. Engineering controls
D, warnings
E. Administrative controls
F. personal protective equipment

rf’l..is hierarchy of controls contains six elements. The first step Eli • . . J.lJJ b • •
1

. , mmatton, 1s

Par
ated from the Su sututton e ement. In reahty undertaking separat . se . . ‘. e processes 1s

required to accomp_hsh what 1s needed. Those subjects were combined in some hier-
archies issued prev10usly.

THE LOGIC OF TAKING ACTION IN THE DESCENDING
ORDER GIVEN
comments follo~ on e3:qh of the action elements listed in ZlO’s hierarchy of controls
including the riitionale for the listing in .the order liiven. Talcing actions as feasible and
practicable ill; the. p~~scribed ordq is the most effective means to achieve risk

reduption.

A. Ellmlnatlon .
Use of the teflll elimination as the first step in applying a hi~rarchy of controls is
a bit simplistic. My experience’ requires that it be replaced with such as: ”Eliminate
or reduce ~azards and risl,cs through system design ~d redesign.” (In Chapter 16,
“Prevention through Design”, Avoidance .precedes Elimination.) ,

The theory is stated plainly. If the hazards are eliminated in the design and
redesign processes, risks that derive from those hazards are also eliminated. But
th’ complete elimination of hazards by modifying the .design may not al_ways be
practi7able. Then the goal is to modify the design, within practicable hm!ls, so as
to hmit the: ‘ · ‘

: (mbability of personnel making human errors because of design inadequ'”:ies
Abdity of personnel to defeat the work system and the work me

th
ods prescnbed

‘ . .. ‘

Examples include designing to eliminate or reduce the risk from:

274 HIERARCHY OF CONTROLS: SECTION 5.1.2 OF 210

• Fall hazards
• Ergonomic hazards
• Confined-space hazards
• Noise hazards
• Chemical hazards.

Obviously, hazard elimination or reduction is the most effective
reduce risk. If a hazard is eliminated or reduced, the need to rely O way to rernove or
to avoid risk is diminished. n worker behavior

B. Substitution of Less Hazardous Materials, Processes
Operations, or Equipment ‘
Methods that illustrate substituting less hazardous methods, materials
for that which is more hazardous include: ‘ or processes

• Using automated material-handling equipment rather than manual .
handling · , matena)

• Providing an automatic feed ·system tb reduce machine hazards
• Using a less hazardous cleaning material
• Reducing speed, force, amperage
• Reduce pressure, temperature
• Replacing an ancient steam-heating system and its boiler explosion hazards

with a hot-air system
Substitution’ of a less hazardous method or material may or may not result in

equivalent risk reduction in rel~tion to what might be the case if the hazards and risks
were reduced to an acceptable level through system design or redesign.

Consider this example. Considerable manual material handling is often necessary in
a mixing process for chemicals. A reaction takes place and an employee sustains serious
chemical burns. There are identical operations at two of the company’s locations. At
one location, a decision is made to redesign the operation so that it is completely
enclosed,, fed automatically, and operated by computer from a control panel, thus
gt~atly r~UCing Ope~ator exposure. ·., . ·.· : . . , . . I , . the

At the other locat10n, funds for domg the same were not available. To reduce
risk, a substitution took place ‘in this manner:

r

• It was arranged for the supplier to.premix the chemicals before shipment.
• Some mechanical·feed equipment for the -chemicals was also inStalled.
, . . ‘ . ‘ . : . . . . , ‘ . th t attained by
The risk reduction achieved by substitution was not eqmvalent to a

redesigning the operation.

C. E,nglneering Control~ . ols, , , . . . eenng contr
When safety devices are incorporated in a system in the fonn of en~tn are to prevent
substantial risk reduction can be achieved. Engineered safety devices

.J

THE LOGIC OF TAKING ACTION IN THE DESCENDING ORDER GIVEN 275

azard by workers .. They are to sep~ate ha zardous energy from the worker
cceSS to ah ker error. They tnclude such devices as:

a d ter wor
afld e

• Machine guards
lock systems • inter

• Circuit breakers
• s tart0P a1arms .

Ce sensing devices • presen –
• safety nets

,,. u·iation systems
• ven
• sound enclosures
• fall-prevention systems
• Lift tables, conveyors, and balancers

o. warnings [Warning Systems]
. system effectiveness, and the effectiveness of instructions, signs, and warning

WaJ1llllgly considerably on administrative controls, such as training, drills, the quality of
labels, re · ab’li · p, …. 1. alth . ance and human reaction cap 1 Ues. w u1er, ough vital in many situations,
JJ1at0ten . . th th al . systems may reactionary m at ey ert persons only after a hazard’s
;::~ is in the process of being realized (e.g., a smoke alarm). Examples are:

• smoke detectors
• Alarm systems
• Backup alarms
• Chemical detection systems

• Signs
• Alerts in operating procedures or manuals
A comment is necessary on my preferred use of the term warning systems rather

than warnings or warning signs. The latter terms appear in some published hierar-
chies of control, as in ZlO. The entirety of the needs of a warning system must be
considered, for which warning signs or warning devices alone may be inadequate.

For example, the NFPA Life Safety Code 101 may require, among other things,
detectors fdr smoke and products of combustion; automatic and manual audible and
visible alarms; lighted exit sigJ s; designated, alternate, properly lit exit paths; adequate
spacing for personnel at the end of the exit path; proper hardware for doors; and
emergency power systems. Obviously, much more than merely “Warnings” is needed.

E. Administrative Controls
Administr ti , · · 1 : t th a ve controls rely on the methods chosen being appropnate m re anon o

q
eali~eedS, the capabilities of people responsible for their delivery and application, the
u ty ofsu · · -1-: .. : u· co tr pefVls1on, and the expected performance of the workers. Someauuuu,stra ve
n ols are:

276 HIERARCHY OF CONTROLS: SECTION 5.1.2 OF Z10

• Personnel selection ‘
• Developing appropriate work methods and procedures
• Training
• Supervision
• Motivation, behavior modification
• Work scheduling
• Job rotation
• Scheduled rest periods
• Maintenance
• Managementofchange
• Investigations
• Inspections

Achieving a superior level of effectiveness in.all of these administrative method
. d s is difficult, and not often attame . . . .

f,.Personal Protective Equipment .

The proper tise of personal protective equ~pment relies on an extensive series of super-
visory and personnel actions, such as the identification of the type of equipment neede~
its selection, fitting, training, inspection, maintenance, and so on. Examples include:

• Safety glasses
• Face shields
• Respirators
• Welding screens
• Safety shoes
• Gloves

. • Heari~g prot~cti9n. ,
1

Althoµgh the ,pse of p~r~~na,1 protective eq~ipment is common and necessary in
~any occupat~~nal situations, it_ i~ the. J~ast effeptive ~ethod to deal with ~azards and
i:isks. Syste~s put in,pJace f~r,their,use c~n ~asily be defeated. In the de~ign proce:
one of th~ g~als sh9u,ld pe ~P reduce reliance on personal protective equipment to
low a level as prac_ticable. , ! , , ..

APPLICATION OFTHE HIERARCHY

F . k . . . thods shown or many ns situations, a combination · of the risk management me the
in the hierarchy of controls is necessary to achieve · acceptable risk levels. Bu~ng
expectation is that consideration will be given to each of the steps in a descen

ATTACHING THE HIERARCHY OF CONTROLS TO PROBLEM-SOLVING TECHNIQUES 277

.. nd that reasonable attempts will be made to eliminate or d h rder, “” . . . . re uce azards
0 d their associated nsks through steps higher m the hierarchy before low t an · th hi h f er s eps are

‘dered A lower step m e erarc y o controls is not to be chosen unt’I . al
0

ns1 · . 1 pract1c
c

1
. u· ons of the preceding level or levels are exhausted.

app1ca

rTACHING THE HIERARCHY OF CONTROLS
~O pROBLEM-SOLVING TECHNIQUES .

The following observations.are a reflection_ of _my experience: encompassing the design
and engineering, the operational, the post-mc1dent, and the post-operational aspects of
the practice of safety:

• safety practitioners often recommend solutions to resolve hazard/risk situations
before they define the problem: that is, before they identify the specifics of the
hazards and assess the associated risks

• Rarely are safety management systems in place to detennine whether the
preventive actions taken achieve the risk reduction i~tended

Those observations led to res,e.~ch into tqe feasibility of encqmpassi~g the hierarchy
of controls within a sound problem-solving technique which:

‘ ‘ ‘
• Begins with problem identification and analysis
• Requires measu(ement of results of the actions t$en to determine . their

effectiveness
• Necessitates taking further · preventive measures if the residual risk is not

acceptable
The initial step in this research was to review what is proposed in several texts

regarding the basics of problem solving. The problem-solving m~thods the authors pro-
pose J»ve, great similarity. A, compo.site of those techniques is, presente9 in Table 14.1.

In every problem-solving method, reviewed, the first steps are to identify and
analyze the problem. Also, they end with a provision requiring that evaluations be
made of t,h~ effepts of the ~ctions taken. Figure 14.1, the Safety Decision Hierarchy,
presents a logical sequenc~ 9f actions that. safety professionals should co,nsider in
resolving safety issues; identify and analyze the problem; consider the possible
solutions; decide on and implement an action plan; and determine whether the
actions taken achieved the intended risk reduction results.

TABLE 14.1 Problem-Solving Methodology

1. Idenyfy the problem.
2. , An~yze the problem.
3. Explore alternative solutions.
4. Select a plan and take action.
5. Examine the effects of the actions taken.

278 HIERARCHY OF CONTROLS: SECTION 5.1.2 OF 210

The Safety Decision merarchy
I

A. Problem identiftcation and analysis:

l. Identify and analyze hazards.

2. Assess the risks.

B. Consider these actions in their order of effectiveness:

Most
effective

I . A void, eliminate, or reduce risks in the design p. roee sses.
2. Reduce risks by substituting less hazardous methods

OrmateriaJs
3. Incorporate safety devices. .

Least ·
effective

4. Provide warning systems.

5. Apply administrative controls (work methods, training, etc.).

6. Provide personal protective equipment.

C. Select risk-reduction measures and implement them.

D. Measure for effecti~eness.

E. Accept the residual risk, or start over if it is unacceptable.

FIGURE 14.1 The Safety Decision Hierarchy

The safety decision-hierarchy 1depicts a way of thinking about hazards and risks
and establishes an effective order for risk avoidance, elimination, or amelioration.
Why propose that-safety professionals adopt a safety decision hierarchy? This quote
from The New Rational Manager, reflecting the real-world observations of Kepner
and Tregoe in dealing with many clients, makes the case:

The most effective managers, from the announcement of a problem until its
resolution, appeared to follow a clear formula in both the orderly sequence and
the quality of their questions and actions. (p. vii)

‘ .
It makes sense to apply a safety decision hierarchy encompassing methods in an

orderly sequence of effectiveness to resolve safety issues. ·

ON PROBLEM IDENTIFICATION AND ANALYSIS
. dentification

In utilizing the safet:x decisi~~ ):tl~{archy, the goal in the .problem :ss the risks,
and analysis phase is to identify and analyze the hazards and . ass hazards are
Hazard and risk situations cannot be dealt with intelligently until the exposures

· ‘dents or analyzed and assessments are made of the probability of 10c1
occurring and the severity of their consequences are estimated. . resource for

t” 1s a Chapter 11, “A Primer on Hazard Analysis and Risk Assessmen ‘
this problem identification and analysis phase.

ing
‘etc.).

azards and risks
Dr amelioration.
chy? This quote
tions of Kepner

]em until its
equence and

, methods in an
I

A1CEPT THE RESIDUAL RISK
• OR START

, OVER IF IT
A~TERNATIVE SOLUTIONS IS UNACCEPTABLE

279

s s_hown in The Safety O . . • Th . . ec1s1on H’ •~ . eir . Order ‘of Efti . Ierarchy u d
1.11,. ‘ • •A-… ectivene ” n erthe . erw..-..,,~”~”‘oa. .avo1ua.uce, elimin t’ ss provid caption “C . u . h F in a mn, or red . e a base f ons1der i . . the preferred order uction measures or considerin
conti:ol~. •m 210. The log1·c . of controls outlined: They are similarg

listed: . . . . . m support in sect’ -, : were given· earlier in th h of those steps tn 5. l.2, the
, ” •. . e c apter. an the order in

~AKING AC:”l”ION
\,~.

s~~ty decision hierarchy ap I
c {~tiity, ·prqcess, system pi!; o;hen_ considering the hazards a d
~ ·broadly applicable in ~ll four ofritpm~nt, or tool in its simpl;st
(.h :),,._.. , . , . ·. ,. . e ffia,Jor aspects of the practice

, ‘\i .•:,·.(. • , , I• •

‘gn Ptoces$es; •pre-operational: wher~ th . .
s ~ ,lb’We~.fornazard avoidance el· . e ~pportumttes are greatest

ratiotial . . . , ‘ ., . , . . • munation, or control
-,n•:r ,, ~~e. wb~re, 1rttegrated withi · .
, – . ,..: ,.· •_·u ·· ,· •. :-.._r ,.d, . n a continual improve · s m:e e mmi:1:te •or controlled be~ th . . ment

-related 1ncidents qr, expbsures o~cur ore e1r potentials are realized
t· thfd~· -‘h ‘ih I., .. ; ;”: , ,’ ,. , , : ”
• , , · ·i~ ;1 +: ;ve~J;t~~ti,Q~ of ~~z.ard-related incidents and exposures
an4 ,,, ‘i;f\i ~r~r Of R?~~ol their causaj_ factors

onal: i~;t•en demolition, decommissioning, or i:eusing/rebuilding
~\lD •~~en, .. 1.:,,, .,,f , ,· .

J,i;>.;, .’J,; ‘ . . · \ :, ‘ ‘

,,:o~~~-t~Ct,veNE:SS ; ,,
;bl”t\,1 ‘ 1 — ‘, · ‘l,, ‘, , ,.i\f{ ffl~.~t,,:1./1. v, ‘.: ,,, , -. ,:i~Uv , ”, ;), ( ‘

ProxJsions e ~ah?i~µietit &~yiew Proces~ – Section 7.1 .. of ZlO, require that
sys~ms ,place :f~ ·:·m~as~~~;1eff~~veness otthe risk ·r~duction measures
take~~.Th~ p.q,visidnsJt~~IatlN’e’:to the measuring for effectiveness and re-analyzing
step’ ~ !-The ew Ped!~J~n· ·tµer~hy. . .

Assuring the ,actjijtjp,~· ~~J:.ICcomplish what w~ inten~ed 1s an mtegral part
of theJ~DC ess~ .f,ql,to\v~up.,~tivity would detemune that.

• ~as’~~§~l~ed;)o~;~nly partially resolved, or not resolved.
‘ ‘1hr ac taken ~!-~1 Wa _not cteate new hazards.

t,’\” 11’fnt~i’ · : , , -· .. \
‘ . J’. ,. >’I,, _: . ,
s1ou44 Rl,Sl(,.,OR START

N4~P.EPTABLE–
. _.r.,,,~ , · 1′ th ught
::i r::H’> . . . . . . ot acceptable, the . o .

·vity fiidi’9ates that the residual nsk is n lied again, begmnmg , .. ,.; •. . . w· chy would be app the safetf:-dec1s1on erar
‘t, l • • •

ation and:ana1ys1s.

280 HIERARCHY OF CONTROLS: SECTION 5.1.2 OF Z10

CONCLUSION

The hierarchx of col)trols in Zl O derives from \:York that has evolved
As ~anagement “implement(s) and mai~tain(s) a.process f~r ~hie~:er ;a~y Years.
~~dijption,” the hierarchy presents the act10ns to be coi;isjdered in a lo _g tasibJe risk
, , Encompassing a hierarchy o,f controls wjthin a soqnd problem~so~~~: ~

rd
er ..

furtpei:s th~ ability o( management .and safety ,professionals to achieve ffig ~hnique
‘dan limi’ · ed · d th · e ective n· k av01 ce, e nation, or r uction,. an to m~t e requirements of . s

sions in ZlO. Adopting established problem-solving techniques t~ ~dre~e:n provj.
risk situations is a fundamentally sound approach. That is th~ purpose 0; and
Decision Hierarchy. • ·

1
, e afety

REFERENCES

Accident Prevention Manual, 3rd ed. Itasca, IL: National Safety Council, 1955.
ANSI/AIHA 210-2012-. Occupational Health -and Safety·Management Systems, Fairfax, VA:

American Industrial Hygiene Association ,: 2005. ASS:a i& now the secretariat. ,Available at
https://www.as~e.org/cartpage.php ?link==z 10_2005. . ( ‘ . ‘ ” . , .

ANSJ/PMMI B 155.1-2011. Safety Requiref11!!,:Zt$for ]?acka,ging Machiftl!ry and Packaging-Related
Converting Machinery. Arlington:vA: Packaging Machinery Maµufacturers Institute, 2011.

-‘· 1 ‘ ‘
Chapanis, Alphonse. ~’The , Error7J>rovocative Situation.” ,In The ~easurement of Safety

. Performance, Willikm E. Tarrants, Ed. N~w York:·Garland Publishing, 1980.
Kepper, ~harles H. and BenJkl~ B. Trego~. Th~< New Rational Manager. Princeton, NJ: . Princeton ,Research 'Press, 1981. · . . . . Manuele, Fred A. On the Practice of Safety, 4th ed. Hoboken, NJ: Wiley, 2013. · Manuele, Fred A. "Risk Assessment and Hierarchies of Control." Professional Safety, May

2005
·

. . · t of Defense,
MIL-STD-882E. Starukzrd Practice for System Safety. ,Washington, DC: ~epartmen sTD-SS2E

2012. Available at http://www.system-safety.org/. Scroll down and click on MIL-
in the right-hand column for a free copy. · . · ·

. . . . • . A •ation 2012.
NFPA.101. Life Safety Code. Qumcy, MA: National Ftre Protection ssoci ‘

I I

‘ ” iJ

I ‘• I

1

Course Learning Outcomes for Unit V

Upon completion of this unit, students should be able to:

4. Examine the components of an effective hazard prevention and control system.
4.1 Explain a decision hierarchy when evaluating workplace hazard control measures.
4.2 Explore current trends in hazard prevention and control.

6. Relate continuous improvement principles to safety management concepts.
6.1 Identify advantages for improving workplace safety through advocacy of appropriate hazard

controls.

7. Examine management tools necessary to implement effective safety management systems.
7.1 Apply financial tools to safety-related decision making.

Reading Assignment

Chapter 14:
Hierarchy of Controls: Section 5.1.2 of Z10

Unit Lesson

Following the hazard analyses and risk assessments we discussed in Unit IV, the next step is to select the
controls that will reduce the risk to our defined acceptable level. As we noted in previous units, zero risk is not
possible or practical. For most organizations, cost is another significant limiting factor when selecting risk
controls. Unfortunately, many organizations simply select the least costly option rather than evaluating all
available options.

Where do we start? It would be helpful to have a list of control strategies, ordered from most effective to least
effective. Fortunately, there are many of these lists available to the safety practitioner. The most common,
and a good place to start, is the three-strategy list found in many safety management publications:

1. Eliminate the hazard.
2. Use engineering controls.
3. Use administrative practices.

By itself, this list does not provide quite enough information and guidance, so it is helpful to break it down
further. Eliminating the hazard can be done by not creating the hazard in the first place or removing an
existing hazard (Jensen, 2012). For example, when designing a warehouse operation, we can avoid
introducing a carbon monoxide hazard through the use of electric forklifts rather than gasoline-powered ones.
Similarly, we can remove the hazard in an existing warehouse by replacing gasoline lifts with electric lifts.

UNIT V STUDY GUIDE

Controlling Hazards and Risks

2

UNIT x STUDY GUIDE

Title
Engineering controls can be divided into at least five strategies (Jensen, 2012). The table below shows how
these strategies could be applied to various hazards:

STRATEGY TACTIC EXAMPLE

1. Moderate the hazard. Use a less hazardous material.

2. Avoid releasing the hazard. Lock out a potential source of energy release.

3. Modify release of the hazard. Use a ventilation system to remove welding
fumes.

4. Separate the hazard from that needing
protection.

Place a barrier between the hazard and the
workers.

5. Improve resistance of that needing
protection.

Vaccinate healthcare workers against
hepatitis.

Similarly, administrative practices can be divided into strategies (Jensen 2012):

STRATEGY TACTIC EXAMPLE

1. Help people perform safely. Provide visual and auditory warnings, training
in safe work practices.

2. Use PPE. Require the use of hearing protection.

3. Expedite recovery. Provide effective on-scene medical care.

For many hazards and risks, requiring the use of personal protective equipment (PPE) is among the least
costly and easiest to implement. All that is needed is to buy a bunch of earplugs, hard hats, and safety
glasses and hand them out. It does not take a seasoned safety professional to recognize that this may not be
the most effective option. For PPE to be an effective control, continuous education, enforcement, and
enticement on the part of management are required. In other words, it takes a lot of effort on the part of
management and the safety staff.

Decision hierarchies provide us with a means to evaluate controls based on effectiveness. These hierarchies
are not new but have evolved significantly in recent years. The hierarchy of controls recommended by ANSI
Z10 and endorsed by Manuele (2014) has six levels: elimination, substitution, engineering controls, warnings,
administrative controls, and personal protective equipment. The hierarchy can be applied to the severity of a
hazard or the probability of the risk. While the top level, elimination of the hazard, is always the preferred
choice, selecting from the other levels may be necessary due to practical or monetary constraints. The safety
management system should ensure that there is a process in place. This process should use the hierarchy to
inform risk control decisions.

Hierarchy of controls
(Manuele, 2014)

3

UNIT x STUDY GUIDE

Title

The Language of Business:

One important aspect of managing any safety and health endeavor is being able to speak the language of
business. Speaking the language is important in order to be able to communicate with organizational decision
makers who frequently tend to view a given investment in terms of how it will add to the bottom line. This
concern for the bottom line is particularly important when it comes to a significant investment that a
corporation might have make to properly address an occupational safety and health issue.

Consider, for example, a situation where an employer needs to guard several new mechanical power presses
in order to comply with OSHA standards and has to make a decision with respect to which machine guarding
approach to use: two hand controls, a cage guard, pull backs, hold backs, or a light curtain.

There are pros and cons to all of these approaches, but you and the supervisor believe that the light curtain
approach will provide the best balance with respect to productivity and safety. Unfortunately, the light curtain
approach is the most expensive and requires a loan from the bank. How do you convince management that it
is worth the investment?

In the business world, there are a number of tools that are frequently used by finance-savvy managers to help
make decisions like this. One of these tools that you have likely heard from time to time is known as return on
investment, or ROI. Basically, this tool simply allows one to determine what the return will be, typically in
dollars in the U.S., for an investment that has been made.

Payback period is often calculated with the following formula:

P=F(1 + i)-n

Where

P = principal, the present value of the money

F = the F comes from future worth or value of money, but the best way to think about this is savings.
That is, how much will this save you per year?

i = the annual interest rate in decimal format. For instance, 12% interest would be represented as
0.12.

n = interest compounding period, typically equal to the number of years being considered.

Looking at our light curtain scenario, let’s say that the purchase and installation of three light curtains will cost
$30,000 but will save $10,000 in labor every year due to the ease of use of the light curtain compared to the
second place alternative.

Looking at this, it seems one would simply conclude that if there is a $10,000 savings every year, it would
take three years for payback. However, this does not take into account that there is a bank loan and an
annual, compounded interest.

To make this calculation one must do so for each period, 1 year, and the principle sums are totaled.

Year 1
P= $10,000(1+0.12)-1(year)

P= $10,000(1.12)-1(year)

P= $8928.57

Year 2
P= $10,000(1+0.12)-2(year)
P= $10,000(1.12)-2(year)
P= $7971.94

Running Total:
Year 1
$8928.57

Year 2
$16,900.51

Year 3
$24,018.31

4

UNIT x STUDY GUIDE

Title
Year 3
P= $10,000(1+0.12)-3(year)
P= $10,000(1.12)-3(year)
P= $7117.80

Year 4
P= $10,000(1+0.12)-4(year)
P= $10,000(1.12)-4(year)
P= $6255.18

Year 4
$30,273.49

Based on this series of calculations, it appears that the light curtains will essentially pay for themselves over a
period of four years as a result of the efficiency inherent in using the light curtains versus other more
cumbersome guarding options.

Given the scenario above, it is clear that financial tools can be very useful in helping to make decisions
related to safety and health. Indeed, such tools are commonly used to determine the present and future cost
of capital items or investments. Here is another example of how the formula can be algebraically rearranged
to determine the future value of a given amount of money over a number of years considering compounded
interest:

F=P(1 + i)n

Consider a case, for instance, in a situation where one wants to know how much $100,000 today will be worth
in 10 years with annual compounded interest rate of 8%.

F = $100,000 x 1.08^10 = $215,900

Thus, if you were to invest $100,000 in the bank today and earn 8%, you will end up with $215,900 in 10
years. Why would a safety professional need to know this? Knowing the future value of money is important for
comparison purposes. Investing $100,000 in a safety related capital project, for instance, may have its own
return on investment over a period of 10 years, and this number may be compared against the future value of
money to help in making a given business decision.

There are other applications of the general formulas indicated above that are commonly used, and you may
end up facing some questions like this on future professional certification exams. Again, it is important to be
able to utilize financial tools in order to compare the costs of various acceptable options. Understanding
concepts like pay-back period and the future value of money can be useful for making a case for safety in
presenting to organizational decision makers. As a safety manager, it is important to know how to use the
language of business, which frequently includes consideration of the bottom line.

Course Project

As in previous units, the non-graded learning activity in this unit is an exercise designed to help you with
sections of the course project that will be due in Unit VIII. By completing this activity and similar ones in other
units, you will have data and analysis to aid you in putting together a high-quality report to management on
the state of the safety management program.

References

Jensen, R. C. (2012). Risk-reduction methods for occupational safety and health. Hoboken, NJ: Wiley.

Manuele, F. A. (2014). Advanced safety management: Focusing on Z10 and serious injury prevention (2nd
ed.). Hoboken, NJ: Wiley.

5

UNIT x STUDY GUIDE

Title
Suggested Reading

In order to access the following resources, click the links below.

The suggested readings below provide additional content on developing preventive and risk reduction
strategies for occupational health and safety:

Alli, B. O. (2008). Preventive and protective measures. In Fundamental principles of occupational health and
safety (2nd ed.) [ebrary version]. Retrieved from
https://libraryresources.waldorf.edu/login?auth=CAS&url=http://site.ebrary.com.libraryresources.wald
orf.edu/lib/waldorf/detail.action?docID=10512156&p00=preventive+protective+measures

Jensen, R. C. (2012). Risk-reduction strategies. In Risk-reduction methods for occupational safety and health
[ebrary version]. Retrieved from
https://libraryresources.waldorf.edu/login?auth=CAS&URL=http://site.ebrary.com.libraryresources.wal
dorf.edu/lib/waldorf/detail.action?docID=10542524&p00=risk-reduction+strategies

Learning Activities (Non-Graded)

Non-graded Learning Activities are provided to aid students in their course of study. You do not have to
submit them. If you have questions, contact your instructor for further guidance and information.

Evaluating Hazard Identification and Control

Note: This activity can be used as one of the building blocks of the Unit VIII
Project.

Using the readings in this unit as guides, evaluate how the hierarchy of controls is used at your current
organization or an organization with which you are familiar. For objective evidence to support your evaluation,
look for organizational documents such as safety manuals and instructions, safe operating procedures, job
hazard analyses, OSHA citations, and inspection reports. Interview management personnel, supervisors, and
employees, and walk through some workplaces to observe conditions for yourself.

Prepare a report to management that summarizes the positive and negative results of the evaluation and
provides recommendations for improvement.

https://libraryresources.waldorf.edu/login?auth=CAS&url=http://site.ebrary.com.libraryresources.waldorf.edu/lib/waldorf/detail.action?docID=10512156&p00=preventive+protective+measures

https://libraryresources.waldorf.edu/login?auth=CAS&url=http://site.ebrary.com.libraryresources.waldorf.edu/lib/waldorf/detail.action?docID=10512156&p00=preventive+protective+measures

https://libraryresources.waldorf.edu/login?auth=CAS&URL=http://site.ebrary.com.libraryresources.waldorf.edu/lib/waldorf/detail.action?docID=10542524&p00=risk-reduction+strategies

https://libraryresources.waldorf.edu/login?auth=CAS&URL=http://site.ebrary.com.libraryresources.waldorf.edu/lib/waldorf/detail.action?docID=10542524&p00=risk-reduction+strategies