The Administrative Hierarchy of Controls
A structured approach to administrative controls can improve workplace safety by organizing and prioritizing these controls, much like how engineering controls are categorized in the hierarchy of controls.
- By Tim Carrico
- Oct 21, 2024
An earlier hierarchy of controls had engineering controls as the top-level control. Of course, now most hierarchy of controls, including the one used by OSHA, include elimination and substitution as better controls. The ANSI Z590.3, which is the Prevention Through Design Standard, actually has a control above elimination: avoidance. It would be far better to avoid the hazard in the first place, by preventing it with a safety design review, than to eliminate the hazard after it has already been introduced into the workplace. Obviously, views on safety have changed over the decades (and continue to change), and our understanding of hazard controls has improved.
However, it could be argued that eliminating a hazard, as well as substitution and even prevention, all require engineering. In a sense, they are all engineering controls. Even so, not all engineering controls are created equal, and it must be recognized that it takes a very different thought process to look at how to eliminate a hazard versus engineering a safeguard around a hazard. Thus, it is an important contribution to safety to delineate the hierarchy of controls in this way to look at the best engineering controls (i.e., prevention, elimination and substitution) first, before merely engineering other types of protections around the hazard.
Of course, not every hazard can be prevented or eliminated. Nor can every hazard be controlled solely by an engineered solution. Thus, lower levels on the hierarchy of controls — namely administrative controls and PPE — exist. While not as effective as the higher tiers, these controls are still an important part of an overall strategy for controlling hazards in the workplace.
After discussing these concepts at a safety conference, one of the attendees said they were having trouble finding good controls for a constantly changing construction environment. Because every day was different, traditional engineering controls, in many cases, were difficult to implement.
Having worked in construction in the past, it's not that one doesn't use the higher tier controls in construction, but these controls are often limited due to the nature of the work being done and the environment the work is being done in. Unlike a manufacturing environment where the equipment and operating floor may change very little day to day, it may not be practical or even feasible to put in permanent engineered solutions at a work site that may be drastically different and present entirely new hazards tomorrow.
So the attendee was hoping to get further guidance on using administrative controls effectively on the job site. The challenge was they couldn't find much documentation focused on administrative controls. This isn’t much of a surprise, since administrative controls are really a lower-level control. Most safety professionals are — and should be — focusing on the more effective controls at the top of the hierarchy. However, after all engineering options are exhausted, administrative controls are the next on the list to consider. And just like engineering controls, not all administrative controls are created equal. If delineating engineering controls into additional tiers on the hierarchy of controls has assisted safety professionals in making better decisions, could the same be done for administrative controls? How should one go about choosing the most effective administrative controls?
OSHA, in their document “Identifying Hazard Control Options: The Hierarchy of Controls", breaks administrative controls into three broad categories: warnings, procedures and training. All three are critically important in the field of safety. Which should be the first consideration when it comes to controlling hazards? A clue can be found in the ANSI Z10 standard on Occupational Safety and Health Management Systems. The Hierarchy of Controls in this standard already has a separate control category set between engineering and administrative controls: Warnings. Similarly, even though the OSHA document cited earlier categorizes warnings within the administrative controls bracket, the attached worksheet lists “Administrative Controls: Warnings" as its own consideration above “Administrative Controls: Procedures and Training".
What makes warnings a better control? And how can that help us delineate other administrative controls? First, consider what makes engineering controls so much more effective than administrative controls. Engineering controls make physical changes to the environment that typically do not rely much on worker behavior to protect them from the hazard. The National Institute of Occupational Safety and Health (NIOSH) points out that administrative controls, on the other hand, are less effective because they “require significant and ongoing effort by workers and their supervisors.”
Warnings fall somewhat between these two spectrums. A warning is both something physical in the environment (e.g., a siren, light or sign) that also requires effort from the worker to heed the warning. Even warnings can be further categorized as to their effectiveness. Active warnings — such as audible alarms, lights or even computer messages — activate and notify a worker when a hazard is present. The active nature of the warning captures the worker’s attention and instigates them to take needed action. Passive warnings — such as signs, labels, and even posted instructions — are always present. They may help notify or remind a worker of a potential hazard and motivate an appropriate response. However, as passive warnings are always present, the danger is that workers will eventually become complacent and ignore, intentionally or unintentionally, the message. Even active warnings, if overused, can create a stimulus fatigue where workers will eventually ignore or confuse differing warnings.
Using these same principles, how would other administrative controls be ranked by effectiveness? The least effective controls would be those that do not substantially change the work environment and would require the most effort from workers and supervisors.
When looking at the various types of administrative controls, training would seem to fit this description. This is a difficult admission for any trainer who knows the importance of training as well as its limitations. Additionally, with all of the controls discussed, it is important to recognize that there are varying degrees of quality and methodology that can also drastically change the effectiveness of the control. For example, how well was the training designed? What are the qualifications of the trainers? How is the training provided? Also, the training category itself could be further delineated between online training, classroom training, on-the-job training, and coaching and mentoring.
All these aspects determine the effectiveness of the control. It is also important to note that merely placing training at the bottom tier of administrative controls does not mean that it is not a critical component of the hierarchy, just as administrative controls being listed lower than engineering controls doesn’t mean that administrative controls aren’t an important consideration in any safety and health management system. They all have their place, more often in combination with other controls rather than as a standalone hazard mitigation.
Next on the list, going up the hierarchy, would be standard operating procedures and pre-filled task hazard analyses. Like training, these documents give workers guidance on how to safely do their jobs, but still require the active participation of the workers to follow the guidance as well as supervisors to enforce compliance. Unlike training, standard operating procedures are typically more available in the work environment, either posted next to the task or able to be printed or viewed from a computer. Standard operating procedures also have a slight advantage in that, if followed regularly, they quickly become habit.
Going further up the hierarchy brings us to work practices. While work practices must be enforced by supervisors and followed by employees, they do create changes in the working environment, particularly in how the work is done. Work practices include rotating workers to different tasks, mandating rest breaks, determining production speed and limiting access to qualified personnel.
Just below warnings would be forms and checklists. Like warnings, these are physical items in the workplace that can help workers stay safe by ensuring compliance (e.g., by completing a checklist before proceeding) or determining a safe work plan (e.g., by completing a form). Unlike warnings, which are present based on conditions, forms and checklists require effort on the part of workers to retrieve and use them to be effective.
A great example of this type of form and how they can be utilized to protect workers is the SPEAK/CLEAR form, developed at the Comanche Peak Nuclear Power Plant by their operational excellence team in conjunction with Lucas Engineering and Management Services. This form includes a pre-job briefing (SPEAK) to help plan the work. This includes reviewing the steps of the task, determining where problems may arise and listing how to prevent any potential problems from resulting in negative consequences. It also provides criteria for stopping the job before a major event occurs. This part of the form facilitates discussion to provide a safe work plan that sets up defenses and guides workers to know what to look for and when to stop the job. But the form also includes a post-job review (CLEAR) that allows the workers to determine how to do the job better next time so that safety continuously improves with every task.
As can be seen, there are several types of administrative controls, and just like engineering controls, not all administrative controls are created equal. Thus, when considering administrative controls, a hierarchy should be used as a guide to help employers select the best controls to mitigate hazards in an ever-changing dynamic work environment. Just as in a standard hierarchy of controls, no one control should be solely considered and there is often some amount of overlap of effectiveness in the varying tiers of the hierarchy. For example, a well-designed administrative control often will be a better control than a poorly designed engineering control. Similarly, well-designed training could very well be a better control than a poorly implemented work practice. Thus, the safety and health professional should consider layering hazards with multiple levels of controls, selecting and designing the best control possible from multiple tiers of the hierarchy, and not overlooking any one control just because it may be on a lower level. After all, every tier of the hierarchy of controls is an important and critical part of a comprehensive safety and health management system.