A Friday thought on controls.

Why is it that often our first thought is the last thing we should do?

Health and Safety in the workplace has come along way since the Factories Act of 1831.  We now apply science to protecting people from our work processes.  We have models, acronyms and standard processes all to help us minimise risk and maximise the protection of workers and those who can be impacted by our work.

Despite these improvements, we still hear Jeremy Clarkson regularly deride the health and safety professional.  In episodes of Top Gear we see jokes about Hi-Vis vests, risk assessments and men with beards.  Similarly we read articles in the national press about Christmas lights that wont be put up because of the working at height regulations or events that have been cancelled because no-one was suitably qualified to perform a risk assessment.  So prevalent are these misconceptions that the UK Health and Safety Executive has seen the need to dedicate a section of its website to ‘Mythbusters’, spreading truths and dispelling the myths that seem to have formed around health and safety.

So why do some people feel the need to decry ‘health and safety gone mad’?  Why do people not see the massive advances in working practices that have seen accident rates fall so dramatically?  Furthermore, do we need to be concerned about this?

In part the problem is a human one.  We all have a tendency to focus on what is obvious rather than what is important.  This is as true in health and safety management as it is in advertising where experts aim to get their products in the front of our mind rather than what we should be concentrating on.  To this end, people tend to associate health and safety management with hi-vis vests and safety glasses because these objects are obvious and very visible to us.  So when a local authority misinterprets the working at height regulations and cancels their Christmas lights, people see this, it is very apparent and understandable.  However, when the same local authority replaces all their sodium light fittings with LED ones without incident or injury, this tends to go unnoticed.

So why should we be concerned about this in the workplace?  The answer is that we employ humans, and if this is a human trait, then we are bound to see it at work too.  In my experience I have generally found that when I ask a Manager without any direct health and safety responsibilities a question about safety, they tend to immediately refer to PPE.  Likewise, if I talk to a visiting contractor about their commitment to safety, they will generally respond with a comment along the lines of “Yes, I always make sure I wear all the correct PPE.”  Likewise, when I visit a site and ask to join in a safety walk-down, most workplace inspections tend to focus on whether or not the working party is wearing all the correct PPE for the task.  While this is important, should it be our primary focus?  Well decades of health and safety management and learning suggest otherwise.

Eric is our friend.

Anyone who has studied for a NEBOSH exam or IOSH qualification will probably have been introduced to a private detective called Eric.  ERIC PD is a popular mnemonic used to help us remember the hierarchy of safety controls.  Based on years of observation, analysis and investigations the effectiveness of key safety controls has been ranked in order.  The order, starting with the most effective is as follows.

Eliminate – remove the hazard all together.  This removes the risk of the hazard doing harm.

Reduce or substitute- reduce the potency of the hazard or substitute for a less hazardous version that performs the same job to reduce the risk of harm.

Isolate – the hazard remains present, but you isolate the person from the hazard.

Control Measures – the hazard remains but we have control measures in place such as a safe system of work, special handling equipment or forced ventilation.

PPE – wear personal protective equipment to protect from the hazard.

Discipline – when nothing else is available to minimise the risk, the person takes care and follows rules to ensure they come to no harm.

So let’s take a typical work example to illustrate how this might work in practice.  The task is using a degreasing bath to clean some engine parts.  The bath uses a chemical dissolved in water applied via a hose fed brush.  The chemical is corrosive and causes severe irritation on contact with skin.  The hazard is the chemical, the risk is that it comes into contact with the person and irritates the skin or eyes.  So let’s look at the hierarchy of controls.

The most effective control is to eliminate the hazard.  This doesn’t necessarily mean performing the same task but without the chemical.  It could mean not performing the task at all.  Look at why the engine parts are being cleaned.  Could they be replaced instead?  Could they be sent offsite for cleaning using a different process?  Could they be used without cleaning?

If it is decided that the task must be performed, we look at the next control, can the solution be further diluted to reduce the hazard?  Can we use steam, water or a different chemical instead?

Then we consider isolation, can we enclose the engine parts and the chemical in a vessel that is totally sealed, therefore eliminating the need for the worker to contact the chemical at all?  A nice interlock that prevents the chemical from being used until the vessel is locked shut would ensure complete isolation.

If we can’t achieve complete isolation, maybe some control measures can be applied.  These could include a splash guard, long reach tools, flow restriction to minimise splashing, training for the worker, detailed method statement and risk assessment for the task.  Standby antidote or an emergency shower and eye bath would also be considered control measures.

If the worker really has to get their hands in the cleaning bath, then PPE, can be issued such as gloves to protect the hands and goggles to protect the eyes.

Finally we rely on the worker’s discipline, to follow the method statement, apply the controls and take care of themselves and others.

Sometimes we are blinded by the hi-vis!

Hopefully two thing will have struck you whilst reading this.  Firstly, these things are not mutually exclusive, we can apply multiple controls from the different levels of the hierarchy.  Secondly, PPE is well down the ranking of effectiveness.  So the first thing many people think of when they think of safety is one of the least effective controls available to us.  Although this appears obvious, it isn’t always as obvious as you think.  Wearing an insulated coat whilst working in a refrigerated warehouse will be a less effective control than avoiding the need to enter the warehouse in the first place.  Yet I used to work at a place where the guy who wrapped pallets of product wore cold weather clothing in the refrigerated warehouse as he did his work.  No one thought to wrap the pallets before they were transferred to the warehouse.

So this is where the behavioural bit comes in.  Those who have done NEBOSH or a similar safety qualification will be aware of the hierarchy of control.  The first question we should ask ourselves is, do those in my organisation who perform risk assessments have the same level of awareness of controls?  Secondly, even if they do, are they thinking in terms of the hierarchy.  When faced with the task of removing bolts from a hot machine, our first thoughts turn to wearing heat resistant gloves and using insulated tools.  However, according to ERIC PD, our first thought should be, can we leave the bolts in there or wait for the machine to cool down.  If we can’t wait, can we force cool the bolts to reduce the temperature for handling?  Is this what is happening in your organisation?

Our natural tendency is to dash for the obvious.  We go straight to the solution stage without considering if the problem exists in the first place.  Before reaching for some specialist PPE, ask whether the job needs doing, then work down the hierarchy, apply as many controls as are reasonably practicable, then you can be certain that the risk is minimised.

Following the principal of the hierarchy of controls isn’t strictly behavioural safety.  However, recognising that the hierarchy is contrary to the natural human tendency and encouraging its use, is a behavioural measure.  So how do we get our people to apply the hierarchy?  As always, here are a few tips to help:

  1. Simple one this, educate your team.  They can’t apply the hierarchy if they haven’t seen it.
  2. Test comprehension.  Check that everyone understands the principal and how to apply it.  Use worked examples.
  3. Re-test.  Perform periodic exercises and checks.  Do group risk assessments during health and safety meetings.  Not to catch anyone out, but to check everyone is still on the same page.  This way you can refresh understanding and share learning.  If you do periodic workplace inspections, make an ERIC PD test part of that inspection, check the risk assessment being used against the principal.
  4. Empower.  Ensure people realise that control measures are at their disposal.  Controls should be applied in the order of the hierarchy with a test of reasonable practicability.  Ensure everyone knows what this means and what power they have to lengthen a job or increase the cost.
  5. Feedback.  Check back with workers on the usability and success of the controls.  So many risk assessments are performed once and then used for years without any feedback on how good they are.  Ask the people working in accordance with the method statement and risk assessment for their views.  They may well be best placed to suggest more effective controls from higher up the hierarchy.
  6. Recognise and reward.  As future behaviour is driven by consequence, why not recognise best practise with some sort of reward.  This could be a pat on the back, a mention in your newsletter or a token gift.  You know what mechanisms work for your organisation. Let people know when they have correctly applied the principal and let them know that you noticed.

As with all methodologies, simply raising awareness of the ERIC PD hierarchy will help.  Make reference to it in toolbox talks, team meetings and planning meetings.  If the maintenance office is where your risk assessments and work planning takes place, put a poster on the wall.  The graphic in this article will suffice.  If you want a hi-resolution version for printing, just drop us an email and you are welcome to one.

Remember, everyone wants to do a good safe job, but sometimes we just jump to the obvious answer before we have even asked the question.  We just need gentle reminders from time to time.  Hi-vis vests are great for helping you to be seen.  Sadly they are not bulletproof and do not provide any protection from a speeding vehicle.

N.B. PPE is very effective.  It should be used in combination with the other controls to minimise risk.  I didn’t want you to think we were having a downer on PPE!



Leave a Reply

Your email address will not be published. Required fields are marked *