COMPLETE HEALTH , ENVIRONMENTAL & SAFETY SERVICES (C.H.E.S.S.)
The Hierarchy of Controls by Janet L. Keyes, CIH and Carol A. Keyes, CSP
If you could eliminate a hazard,
dark space under cars or they will use
the person using it. And it only protects
would you do it? The expected answer
jacks. Are those safer? I don’t think so.
if it is used correctly. It often is the most
is, “Of course I would!” But the real
We won’t ask you to eliminate all
cumbersome to use. And, the most
answer is, “It depends.” You weigh
hazards. That’s futile. A more practical
the trade-offs. Get rid of all flammable
approach is to use the hierarchy of
paint, and you eliminate the hazard of
controls. Eliminate the hazard if you
people doing noisy tasks are using
paint vapors starting a fire. Eliminate
can. Substitute – use something similar
hearing protection? If you think they
vehicle lifts, and you eliminate the risk
but safer. Use engineering controls
don’t need hearing protection, go
of a car falling off a lift. But you can’t
to separate people from the hazard.
talk to them. Do they need to stop
refinish cars if you can’t paint, and
Change the way work is done – use
what they’re doing to converse? If so,
nonflammable clearcoats are hard to
administrative controls. And if none of
hearing protection was needed. Why
find. Getting rid of vehicle lifts certainly
those will do the job, resort to requiring
aren’t they using it? It’s uncomfortable.
eliminates one potential hazard, but it
personal protective equipment.
It’s too hot. It’s too inconvenient.
replaces it with others. If employees AASP0720_CHESS.qxp_Layout 1 6/18/20 1:13 PM Page 1
Why is personal protective
difficult to enforce. Walk into your shop. How many
It didn’t seem that loud. See the
need to work under vehicles, they
equipment the last choice? It’s the least
problems with relying on personal
either will try to work in that cramped,
effective. It only protects one person,
protective equipment? Administrative controls are
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considered more effective than requiring personal protective equipment. How could you use that to control noise exposure? You could try to limit how long people spend at the noisiest tasks. That’s not very practical. But there are tasks and times when administrative controls are very effective. Frequent breaks or reducing production expectations during hot weather is an administrative control.
An AWAIR program by July 2020*
Annual Right to Know / Hazard Communication Training
A COVID-19 Prevention Plan by July 2020**
Where is your air compressor? Is it in a corner of the main shop? Or does it have its own sound-insulated room? If the latter, you’ve applied a very effective engineering control.
*By July 2020, automotive repair facilities must have A Workplace Accident and Injury Reduction (AWAIR) program **Essential businesses must have a written COVID-19 Prevention Plan
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Contact us today for help with your shop’s safety, health and environmental needs. (651) 481-9787 chess@chess-safety.com www.chess-safety.com 18 | July 2021
AASP-MN News
Choosing quieter tools that have noise control built into them is an engineering control. Dust extraction systems used for sanding and buffing are engineering controls. Spray booths reduce fire hazards and can reduce employee exposure to paints – they count as engineering controls.
