2.5: Hazard Prevention and Control

Effective controls protect workers from hazards; help avoid injuries, illnesses, and incidents; minimize or eliminate safety and health risks; and help employers provide workers with safe and healthful working conditions. The processes described in this section will help employers prevent and control hazards identified in the previous section.

Action items:

1. Identify control options: A wealth of information exists to help employers investigate options for controlling identified hazards. Before selecting any control options, it is essential to solicit workers’ input on their feasibility and effectiveness. Review sources such as OSHA standards and guidance, industry consensus standards, NIOSH publications, manufacturers’ literature, and engineering reports to identify potential control measures. Keep current on relevant information from trade or professional associations. Investigate control measures used in other workplaces and determine whether they would be effective at your workplace. Get input from workers who may be able to suggest and evaluate solutions based on their knowledge of the facility, equipment, and work processes. For complex hazards, consult with safety and health experts, including OSHA’s On-site Consultation Program.

2. Select controls: Employers should select the controls that are the most feasible, effective, and permanent. Eliminate or control all serious hazards (hazards that are causing or are likely to cause death or serious physical harm) immediately. Use interim controls while you develop and implement longer-term solutions. Select controls according to a hierarchy that emphasizes engineering solutions (including elimination or substitution) first, followed by safe work practices, administrative controls, and finally PPE. Avoid selecting controls that may directly or indirectly introduce new hazards. Examples include exhausting contaminated air into occupied workspaces or using hearing protection that makes it difficult to hear backup alarms. Review and discuss control options with workers to ensure that controls are feasible and effective. Use a combination of control options when no single method fully protects workers.

3. Develop and update a hazard control plan: A hazard control plan describes how the selected controls will be implemented. An effective plan will address serious hazards first. Interim controls may be necessary, but the overall goal is to ensure effective long-term control of hazards. It is important to track progress toward completing the control plan, and periodically (at least annually and when conditions, processes, or equipment change) verify that controls remain effective. List the hazards needing controls in order of priority. Assign responsibility for installing or implementing the controls to a specific person or persons with the power or ability to implement the controls. Establish a target completion date. Plan how you will track progress toward completion. Plan how you will verify the effectiveness of controls after they are installed or implemented.

4. Select controls to protect workers during nonroutine tasks and emergencies: The hazard control plan should include provisions to protect workers during nonroutine operations and foreseeable emergencies. Depending on the workplace, these could include fires, explosions, chemical releases, hazardous material spills, unplanned equipment shutdowns, infrequent maintenance activities, natural and weather disasters, workplace violence, terrorist or criminal attacks, disease outbreaks (e.g., pandemic influenza), or medical emergencies. Nonroutine tasks, or tasks workers don’t normally do, should be approached with particular caution. Prior to initiating such work, review JSAs/JHAs with any workers involved and notify others about the nature of the work, work schedule, and any necessary precautions. Develop procedures to control hazards that may arise during nonroutine operations (e.g., removing machine guarding during maintenance and repair). Develop or modify plans to control hazards that may arise in emergency situations. Procure any equipment needed to control emergency-related hazards. Assign responsibilities for implementing the emergency plan. Conduct emergency drills to ensure that procedures and equipment provide adequate protection during emergency situations.

5. Implement selected controls on the job site: Once hazard prevention and control measures have been identified, they should be implemented according to the hazard control plan. Implement hazard control measures according to the priorities established in the hazard control plan. When resources are limited, implement measures on a “worst-first” basis, according to the hazard ranking priorities (risk) established during hazard identification and assessment. (Note, however, that regardless of limited resources, employers have an obligation to protect workers from recognized, serious hazards.) Promptly implement any measures that are easy and inexpensive—such as general housekeeping, removal of obvious tripping hazards such as electrical cords, and basic lighting—regardless of the level of hazard they involve.

6. Follow up to confirm that controls are effective: To ensure that control measures are and remain effective, employers should track progress in implementing controls, inspect and evaluate controls once they are installed, and follow routine preventive maintenance practices. Track progress and verify implementation by asking the following questions: Have all control measures been implemented according to the hazard control plan? Have engineering controls been properly installed and tested? Have workers been appropriately trained so that they understand the controls, including how to operate engineering controls, safe work practices, and PPE use requirements? Are controls being used correctly and consistently? Conduct regular inspections (and industrial hygiene monitoring, if indicated) to confirm that engineering controls are operating as designed. Evaluate control measures to determine if they are effective or need to be modified. Involve workers in the evaluation of the controls. If controls are not effective, identify, select, and implement further control measures that will provide adequate protection. Confirm that work practices, administrative controls, and PPE use policies are being followed. Conduct routine preventive maintenance of equipment, facilities, and controls to help prevent incidents due to equipment failure.