HEIRACHY OF CONTROLS- ISNT IT TIME TO RE-DEFINE PPE - THE LAST LINE OF PROTECTION
TATA VENKATA SURYA PRAKASH, PMP?
A Chemical Engineer with Project Management Professional (PMP?) & 26 Years of experience as Project Manager with expertise in Oil & Gas Major Projects Management from Conceptualization, FEED, EPC.
In 25 years of experience and exposed to projects from Concept development and feasibility assessment, FEED, Detailed Engineering, Construction, Commissioning and Operational assurance acrosss life cycle, always i stuck up at PPE in the "HEIRARCHY OF CONTROLS" which neither misinterpreted to the convenience to execute the job while risk being unmitigated or it is broadly misunderstood.
When a Risk is Not Eliminable or Substitutable, an engineering control is not available as well as and administrative control couldn't reduce the risk the with PPE as control of risks while it being present was allowed to perform the said task.
In-fact, the option of PPE in hierarchy of controls makes most of managements to avoid other hierarchy of controls due to cost involved and prefer PPE only which has enormous accounts of leading cause of incidents.
Hence, the time has come get rid of PPE from hierarchy and replace the work with an CAR (Commitment, Accountability & Responsibility) onus on the TOP MANAGEMNT of an organization.
With What we can replace?
ETWRPS-EXECUTE THE TASK WHILE RISK PRESENT SAFETY
How it shall work?
A Procedure shall be in place whenever such scenario arises and the risk is neither elimanatable, Substitutable or An engineering control can be established or Administrative control is available then the top management shall form a team of SME to develop a SEMS(Safe Execution Method Statement) which can have if not in totality but in parts of Elimination, Substitution, Engineering Control, Administrative Control which will protect the engaged workforce from personnel injury and not asset loss is possible and there is no Environmental repercussions.
As we all know and practice Prevention through Design the pinnacle of the Hierarchy of Controls all of the efforts to anticipate and design out hazards to workers in facilities, work methods and operations, processes, equipment, tools, products, new technologies, and the organization of work becomes key.
Employers shall look to workers who have proper experience with given hazards and work conditions for such tasks with presence of RISK, and after determining possible control items, employers and managers should select the best controls, finalize a plan and implement it.
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As we heard often "Prevention is Better Than Cure" or "An ounce of prevention is worth a pound of cure" negating it before it reaches to the PPE stage is far better apporoach than grabbing all to that level which not only puts the innocent workforce in "Line of Fire".
As per OSHA use of PPE – considered the last line of defense against worker injury and illness – is acceptable when controls higher in the hierarchy don’t eliminate the hazard or are in development. Numerous types of PPE are available, depending on work conditions and the part of the body that might be susceptible to a hazard.
As before that , experts encourage workers to explore the viability of other controls, if possible, before deciding to don PPE.
Every Hazard is not elimanatable but more and more closure you apply all Hierarchy of controls in tandem the lessor the hazard to workers while discharging the task under PPE(ETWRPS).
While Developing ETWRPS- Executing the Task while Risk being Present Safely follow questions shall be asked by everybody involved in the whole life cycle:
Upon reviewing thoroughly the responses and implementing them the ETWRPS risk level shall be established and task shall be carried out.
TATA VENKATA SURYA PRAKASH
AUTHOR AND EXPERIENCED OIL & GAS PROJECT MANAGER, RISK MANAGEMENT CONSULTANT & PROJECT MANAGEMENT EXPERT.