About a month ago, the Chemical Safety Board (CSB) in the United States completed an investigation and report related to an incident at Texas Tech University in which a graduate student was injured as a result of an explosion that occurred while conducting research. More information associated with the investigation and the event can be found at the CSB’s website.
During the webinar where the results of the investigation were presented, I was struck by an interesting thought about safety control measures. One of the CSB’s findings related to the nature of a chemical lab standard and how it was regulated by OSHA in a public organization such as a university, which got me thinking about a concept that many of us in the safety profession are very familiar with—the hierarchy of controls.
As you know, the hierarchy goes like this: when determining appropriate control measures for a hazard, we consider (in this order):
1. Elimination/substitution of the hazard source;
2. Implementation of engineering controls;
3. Creation of administrative controls; and
4. Finally, use of PPE.
We’ve probably all experienced situations where it takes a combination of these controls to effectively reduce the risk associated with a hazard. I thought, ”Where does a recommendation to change a piece of legislation fit in the hierarchy of controls?”
This thought rumbled about in my subconscious for a while until I had time to ponder this question in greater detail. What if the hierarchy isn’t the be all and end all of hazard control? What if there was more? Do we in the safety profession actually have the ability to go beyond the hierarchy, and even beyond our own workplaces, to influence the control of safety hazards in a larger context? If not just a hierarchy, is there a cycle of control?
After much cogitation and nine pages of notes on my iPad, I came up with this model to express the “Cycle of Control.”
This model incorporates the hierarchy of controls and also allows for additional controls outside of the context of the workplace. It provides for the environment under which hazard controls are required, that is, the “Social Context for Control,” and then acknowledges that additional mitigation strategies, such as emergency response and first aid measures, play a role. Finally, the very act of investigation and corrective action implementation can allow for additional risk reduction.
Enforcement efforts, prosecutions and coroner’s inquests all can lead to recommendations for the implementation of new controls contained in the hierarchy and, in some cases, may lead to changes in the way we work as safety practitioners or the development of new standards or laws. In fact, we have a tremendous opportunity to change the very Social Context of Control by enhancing our communications about tragic workplace events and influencing needed change in society as a whole.
Someone once told me that it’s important to think big about the work we do and the passion we have for it. Often in this profession, we look to the trees and sometimes don’t see the forest. We have a lot of influence as safety practitioners. We can move mountains, save lives and make work better for those within our workplace and outside of it as well. The hierarchy of control is a great tool…the Cycle of Control is even more powerful.
Have you ventured forth from your workplace to influence the Social Context of Control? Any experiences or successes you’d like to share? (Post them in the comments section below.)
Andrew Cooper is an experienced health and safety practitioner based in Edmonton, Alberta. He’s a member of the OHS Insider Editorial Advisory Board and is an active member of the Canadian health and safety community. Andrew shares his thoughts about safety on the Canadian Safety Blog.