Last week we talked about Process Safety Management, which is the overall approach to following accepted standards and managing hazards. On the Hierarchy of Controls, this would be a part of the “engineering controls” level – isolating people from the hazard. Another level of the hierarchy is “administrative controls”, which includes changing the way people work and behave.
Administrative controls include policies, procedures, and practices put in place to reduce the chances of a hazardous event happening by changing the behavior of people. This could encompass written policies, documentation of accepted procedures, and the use of checklists, as well as signage, labelling, and other preventative methods. While some may view these things as cumbersome burdens, in reality they make the job easier by ensuring that everyone is on the same page and following the same procedures.
What makes administrative controls effective?
Administrative controls must be selected and implemented based on what types of hazards are present, and who may be potentially exposed. This may be accomplished by reviewing sources such as OSHA standards, National Institute for Occupational Health and Safety (NIOSH) publications, engineering reports, and equipment manufacturer literature. Complex hazards may require the utilization of an independent or third-party consultant.
Employees must be trained on how to comply with the processes and procedures that make up a plant’s administrative controls. By understanding the consequences of not following or bypassing a safety procedure, employees are better equipped to understand why the policy or procedure is in effect in the first place. Human error can render administrative controls ineffective or less effective, and proper training can help to reduce errors.
The administrative control must be auditable. In order for this to happen, the procedure, practice, or policy must be thoroughly documented and accessible. It must also be reviewed regularly, and employees need to receive refresher training. Periodic review will provide insight on processes or procedures which may be changed due to technology or environment, and which may have the potential to be more productive, more reliable, or less costly.
Measurement of effectiveness is also important. Tracking progress by verifying that controls have been implemented, employees have been trained in them, and that they are being followed are important. This, along with regular audits, and can help to identify the need for changes in the program.
Along with engineering controls and administrative controls, the Hierarchy of Control also includes elimination of hazards, replacement or substitution of the hazard, and use of Personal Protective Equipment (PPE). Utilized in conjunction with each other, all of these levels combine to provide the best possible change of avoiding exposure to a hazardous situation.
Encorus can help you ensure that your company’s plan is compliant and current, including administrative and engineering controls. Call Keith Taylor at 716.592.3980, ext. 143 or email him at ktaylor@encorus.com for more information.
