The Hierarchy of Controls as an Approach to Visualize the impact of occupational safety and health coordination

This explored the work of HSE coordinators via the hierarchy of control. A field based observational study with 12 HSE coordinators over 107 days was undertaken.

In conjunction to categorising the types of improvements identified by HSE coordinators, the study also looked at controls that were recommended by coordinators but were denied.

First the authors provide background on this topic. They highlight how HSE practitioners often fail to gain traction, status and organisational support in improving HSE.

Even though HSE practitioners may focus on compliance to safety rules, this factor “may not even be the most central issue to promote OSH” and rather, “focus on compliance may actually be misguided” (p2). A focus on compliance, education, information, PPE and other practices may rather be targeting the more readily observable practices instead of the more complicated and expensive, measures.

Further, drawing on the work of Drew Rae and David Provan it’s highlighted that “OSH professionals have become too concerned with legitimizing and socializing practices, which serve to show both internally and externally that organizations care about OSH with negligible impact on physical, material, or structural risk factors” (p2).

Results

Over the 107 observation days, the 12 coordinators implemented 280 safety measures. The average for all coordinators was 23.3 measures, media 25.5. The highest was 38 measures and the lowest 8.

71 instances of coordinators being denied implementing a safety measure were observed (5.9 times on average per coordinator).

For the hierarchy, most measures were administrative (53.9%) or engineering (35%).

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The majority of administrative measures included safety walks, holding a safety meeting, or examined design material. Quoting the paper, “the coordinators would contact relevant parties (e.g., engineer, supervisor, site manager, project manager, worker, etc.) and discuss the particular measure” (p6).

Only two instances of elimination was observed. One example cited as elimination was how exposure to hazardous chemicals to the client workforce was outsourced to a contractor [which is an interesting social judgement of elimination…elimination for the client, risk shifting for the contractor].

Information was then provided on substitution, engineering and admin. Curiously, the authors listed “procedures for crane work” under engineering controls.

As noted earlier, admin controls largely included meetings, introductions, work activities, and safety walks. Administrative measures “were primarily concerned with talking about safety” [which in reality is critical for, really, any level of the hierarchy or just good performance.]

Denied measures

The distribution of denied measures are shown below (table adapted from a figure in the paper).

The majority of administrative measures included safety walks, holding a safety meeting, or examined design material. Quoting the paper, “the coordinators would contact relevant parties (e.g., engineer, supervisor, site manager, project manager, worker, etc.) and discuss the particular measure” (p6).

Only two instances of elimination was observed. One example cited as elimination was how exposure to hazardous chemicals to the client workforce was outsourced to a contractor [an interesting social judgement of elimination…elimination for the client but risk shifting to the contractor].

Information was then provided on substitution, engineering and admin. Curiously, the authors listed “procedures for crane work” under engineering controls.

As noted earlier, admin controls largely included meetings, introductions, work activities, and safety walks. Administrative measures “were primarily concerned with talking about safety” [which in reality is critical for really any level of the hierarchy or just good performance.]

Denied measures

The distribution of denied measures are shown below (table adapted from a figure in the paper).

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Quoting the paper, “the denied measures are often based on situations where the OSH coordinators had performed a safety walk, meeting, or examination of the design material (p8). In most instances, the coordinator would address the safety issue and, in some cases, receive a verbal rejection from another stakeholder about their suggested measure or in other instances, the stakeholder would agree to the measure but then do nothing about it.

The paper then breaks down the types of denied measures using the HoC; which I’ve mostly skipped. One observation is that denied measures under admin level mostly involved things like required stakeholders not participating in safety meetings or not allowing the coordinator to implement particular measures.

The findings are then discussed. It’s said “we find it thought-provoking that the overwhelming bulk of implemented measures are categorized within the lower levels of effectiveness in the HOC” (p10).

It’s said that while this suggests that coordinators often pay a lot of attention to communication practices for safety measures, it also hints, based on the logics of HoC, that ?“the implemented measures are not sufficient to improve OSH in general” (p10).

Interestingly, they highlight research that “communicational practices and strategies may even have adverse effects on safety” (p10).

For a reason why implemented measures are tipped towards admin or engineering could be that “compliance is harder to obtain than engagement, and may actually divert attention from harder and more complex preventive measures” (p10).

Also, in general coordinators are not denied the implementation of measures compared to the number of successfully implemented measures. Here it’s suggested that most coordinators have a good sense of relevant initiatives to implement, which are then accepted by stakeholders.

No coordinator was denied the implementation of technological devices, which based on this limited sample, might be a promising avenue for practitioners elsewhere (that is, technological devices in this sample were never rejected compared to other measures).

The design material area (plans, procedures, software platforms and other facets) was the only area where coordinators were successful in implementing measures less often than being denied.

The findings are suggested to support the view that practitioners may be too far drawn into safety work (versus the safety of work), where they are “too concerned with legitimization and socializing practices, and not enough with material or structural prevention of risks” (p11).

Focus on communication practices at the lower HoC level may also be a method employed by practitioners to be visible with safety and thus “improve their bargaining power” (p11).

However, the focus on lower HoC actions may limit the effectiveness of improvements. Furthermore there appears to be inadequate critical assessment of the validity of management systems and practices; quoting the paper, ?“As Manuele [30] notes, “a good number of safety professionals do not have in place, systems to determine whether the actions taken in accord with their recommendations achieve the risk reduction intended” (p11).

A number of limitations were present. One is broader than just the study but HoC sub-themes aren’t particularly well standardised, meaning a lot of subjectivity in how measures are classified not just in this organisation but across industries.

Link in comments.

Authors: Ajslev, M?ller , Andersen 2, Pirzadeh and Helen Lingard. 2022, Int. J. Environ. Res. Public Health

Chris Brookes-Mann

HM Principal Specialist Inspector | Chemicals, Explosives and Microbiological Hazards Division

2 年

I feel a certain amount of sympathy with the practitioners here, because without knowing the nature of the work it’s difficult to know how reasonable it would be for someone who may not necessarily have an engineering background to come up with higher-order controls by themselves. In some ways, it perhaps relates to the difference between being “an engineer” and being someone who works “in engineering”. I’ve done a couple of courses relating to process safety for instance, but they told me very little about process engineering. While the hierarchy of controls was discussed in the course materials at a conceptual level, the content seem very much geared towards managing the risks associated with the process as designed and built, not taking that step back and asking the deeper questions my background as a lapsed chemical engineer made me aware of. Those kinds of decisions shouldn’t be made in isolation in fairness, although I suppose if you don’t know enough about the system of work to be able to question it, then you’re not necessarily going to know to instigate change control procedures.

Jeff Dalto, MS

Human Performance Improvement (HPI)/Workplace Learning and Performance Improvement Professional

2 年
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CHERYL KUMPULAINEN

WORKPLACE HEALTH AND SAFETY

2 年

Thanks for posting Ben,very inciteful info.

Robert O'Neill

Director at Work Safety Hub | Championing Human-Centric Safety Solutions | Advocate for Safety Differently and HOP

2 年

Would be interesting to understand if the focus on admin measures could be correlated with increased cost associated with the higher order controls.

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