The Hierarchy of Controls (Administrative Controls)

In the first two articles on the Hierarchy of Controls, we discussed

controls that were intended to mitigate hazards at their source
either through elimination, substitution, or an engineering solution
that made it so the employee was no longer exposed.  With
administrative controls, we take a little bit of a turn from that
approach. At this point in the hierarchy, the reality is that the
hazard is one that must be – or can be – lived with, so long as certain
precautions are taken or certain levels of exposure are not
exceeded.  Administrative controls, which may be used in
conjunction with engineering controls and/or PPE, would also be
required if work was to continue while engineering controls are
being developed.  Ultimately, though, administrative controls are
not the optimal solution and cannot be the selected method of
abatement if a hazard, or employee exposure to that hazard, can be
eliminated.

Examples of administrative controls are fairly simple: warning

alarms, for example, are just that alarms that let you know when
something isn’t right.  An alarm might notify you of something as
common as a guard being left open on a machine in a
manufacturing process or it might be on the rotating structure of a
crane working near power lines that could not be de-energized, to
let you know you cannot swing any further.  Obviously, neither of
these by themselves would eliminate a hazard, but they would
provide an employee with a warning.  A more effective approach for
the guard would be an engineering control: to have an interlock that
prevented the machine from running when the guard was open.
Without it, an employee could ignore the alarm and reach into the
machine.  For the crane, the alarm would not prevent the crane
from swinging closer to the power lines.  Instead, you are relying on
the operator to heed the warning.
Labeling systems would also be considered administrative controls. 
We see safety labels everywhere, but clearly they are not sufficient
to protect workers.  Labels are often used along with other controls
to keep employees safe.  Warning of high voltage, a certain chemical
in use, or that an area is a high-noise area, among many other
things, labels act as a good reminder for workers not to enter areas
in which they do not belong, to follow certain procedures, or to wear
certain PPE.  They, alone, will not protect a soul if they are not
heeded by the employees.

This brings us to another form of administrative control: training. 

You can put as many engineering controls in place as you want, you
can require PPE, you can warn of hazards in an area, but if you
don’t train your employees how to comply with the safety
requirements, controls can still be bypassed.  Somebody who is not
trained on the dangers of entering a high noise area may think it’s
really not that big of a deal, for instance.  Perhaps you’ve
substituted a non-silica product for sand in your sandblasting
operations, but you still need sand in your facility for other
applications.  If you don’t train your employees on the hazards of
silica as well as what your new procedure is, how will they know to
use the safer product (or why will they bother if they can’t find any,
but sand is readily available)?  You may not have realized that
training was an administrative control, but hopefully you’ve been
using it all along.

One final method that needs to be discussed is a little more on the

complicated side, compared to other administrative controls. 
Reducing the amount of time somebody is exposed to a hazard can
be an effective control, but it’s not as simple as placing a sign or
adding a warning alarm.  For instance, hazards like noise and
chemical exposure are often given permissible exposure limits
(PELs) by OSHA that are measured in time-weighted averages
(TWAs).  So for instance, Carbon Monoxide (CO) has a PEL of 50
parts per million (ppm).  This does not mean that the moment
somebody is exposed to Carbon Monoxide in an amount greater
than 50 ppm they are going to die, it just means that when you
average out the amount an employee is exposed to over the course of
an eight-hour day, it needs to be below 50 ppm.  There are also
Short-Term Exposure Limits (STELs) and Action Levels (ALs) to be
concerned with, and though we can see that determining an allowed
exposure time might be a bit involved, we’d need more room/time
than this article allows to go into detail on it.  Suffice it to say, as
long as employee rotation through a job can keep the employee
under all applicable limits, then it is an acceptable solution. While
CO has a limit, in many cases, employers would find the source of
emission and eliminate it because CO is much too dangerous.  A
more common application of controlling exposure time might be in a
high noise area or a hot work area.  By rotating other workers into
these areas throughout the day or by simply putting a cap on the
amount of time spent in them, workers can be kept below the
allowable exposures for noise or heat.

Administrative controls can be simple, but remember, they are often

not the best or sole solution.  Using administrative controls should
almost always be looked at in the context of other controls that are
being put in place to determine how they can be paired to provide
employees with the best actual protection possible.  Now, with
elimination, substitution, engineering controls, and administrative
controls covered, we are left with one final level of the hierarchy in
the next article: PPE.  Yet, if it’s the final level of the hierarchy, why
is it that it is so often the first solution employers turn to?  The final
article in our series will explain just that.