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Choosing The Right Safety Controls For EHS Hazards: The Hierarchy of Controls

Identifying workplace hazards is only the first step in managing risk. The real challenge is determining which controls will most effectively prevent an incident and making sure those controls remain effective long after implementation. 

The Hierarchy of Controls provides a structured framework for workplace controls based on their effectiveness. Let’s explore more. 

What Is The Hierarchy of Controls?

The Hierarchy of Controls (HOC), sometimes called the hierarchy of safety controls or hierarchy of risk management, lists the most effective ways to mitigate a workplace hazard, starting with the most effective means of control: 

  1. Elimination: Physically remove the hazard 
  2. Substitution: Replace the hazard with something less severe 
  3. Engineering controls: Isolate people from the hazard through physical means 
  4. Administrative controls: Change the way people work to reduce their interaction or presence with the hazard 
  5. PPE: The last resort, and the least effective way to prevent harm 

Structured this way, the hierarchy prioritizes eliminating a risk wherever reasonably practicable and minimizing what can’t be eliminated. Industry guidance backs this approach, with the INGAA reporting, “The identification of CAPAs that utilize controls in the top half of the HOC (i.e., engineering, substitution, or elimination) are more effective those in the bottom half (i.e., administrative or PPE) for controlling SIF exposures.”  

Example of Hierarchy of Controls

To better understand how the hierarchy prioritizes controls, let’s look at an example of a fall-from-heights hazard. Using the Hierarchy of Controls, appropriate mitigative controls could look like the following: 

  1. Elimination: Redesign the task to be completed at ground level 
  2. Substitution: Use a scissor lift instead of a ladder for extended work at height 
  3. Engineering controls: Install guardrails, safety nets or anchor points for a fall arrest system 
  4. Administrative controls: Put a documented fall protection plan, permit system and training program in place 
  5. PPE: Equip workers with harnesses, lanyards and hard hats with chin straps 

How To Choose The Right Controls

Workplace risks that have an increased chance of leading to a serious injuryincident or fatality require critical controls to prevent these instances from occurring. Critical controls function as the best line of defense an organization has against harm, and the absence of critical controls leaves workers increasingly vulnerable. By prioritizing the most effective means of hazard prevention, this directly follows the level of prioritization outlined by the hierarchy. 

Many industries have established regulations, standards, codes of practice and technical guidance that identify recognized control measures for common workplace hazards. Consulting the recognized organizations below can help determine what is considered reasonably practicable and demonstrate due diligence during audits, inspections and investigations: 

  • ISO: International Organization for Standardization 
  • NIOSH: National Institute for Occupational Safety and Health 
  • OSHA: Occupational Safety and Health Administration 
  • SWA: Safe Work Australia 
  • HSE: Health and Safety Executive (United Kingdom) 
  • NFPA: National Fire Protection Association 
  • CSA: Canadian Standards Association (now CSA Group) 
  • ANSI: American National Standards Institute 
  • ASSP: American Society of Safety Professionals 

Remember, no single control should carry the full weight of protecting your workforce. Layer multiple controls so that if one fails, another is still in place, especially for risks that are known to cause serious injuries or fatalities. This is what planning for the worst-case scenario looks like in practice: assuming any one safeguard could fail and making sure another is there to catch it. 

Documenting and Following Up on Controls

Implementing a control is only part of the process. Every control should be documented so workers understand what is required for safe work and leaders can verify that safeguards remain effective over time. At a minimum, organizations should document: 

  • The identified hazard and associated consequences 
  • The selected controls  
  • The person responsible for control implementation and verification 
  • Review dates and performance measures 

This information is commonly maintained within risk register. 

After controls have been implemented, their effectiveness should be evaluated regularly. Incident investigations, workplace inspections, audits, maintenance records and worker feedback can all reveal whether a control is functioning as intended. Controls should also be reviewed whenever: 

  • An incident or near miss occurs 
  • New equipment, materials or processes are introduced 
  • Work conditions change 
  • Regulatory requirements are updated 
  • Monitoring data indicates the control is not achieving the desired result 

The goal of risk management is not simply to comply with requirements, but to create multiple layers of protection that reduce the likelihood of workplace injuries, illnesses and serious incidents. 

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About the author

Team Evotix

This article was developed by Evotix’s team of health and safety professionals. With backgrounds across EHS&S, our experts collaborate to share practical insights and proven strategies to help organizations strengthen their EHS&S programs.

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