Environmental
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 chapter 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.
267
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.pdf. 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. • ·
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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 '
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