chapter 3

the hierarchy of controls.

 

The hierarchy of controls is a common framework for better understanding and communicating risk at the highest level of reliability and control. It has applications across multiple industries — healthcare, energy, aviation, manufacturing and more — for strategically approaching risk.

Evaluating risk through this lens creates a more collaborative environment for stakeholders to assess controls and mitigate risks. It’s directly applicable in the context of staffing, too. Notably, staffing firms and companies can use the hierarchy of controls to identify the most effective controls, then consider the feasibility of applying them before moving down to the next level.

What we need to guard against is not having a process in place to challenge the norms surrounding existing risk controls, especially when it comes to new or emerging risks. Without well-known, effective risk methodologies in place, businesses can default to operating from the bottom of the pyramid — for example, relying on personal protective equipment (PPE), lowest, least reliable method — under the false belief that they are managing safety well.

In that light, it’s important to note that higher-order controls like elimination, substitution and engineering yield much higher levels of reliability and effectiveness as risk controls. By the same token, they may require more resources, and potential greater costs, to achieve. It also takes time to agree on the right approach or solution — and to evaluate potential ROI. That’s one of several reasons that lower-order controls like administrative tools and PPE are often selected as the best methods. In many cases, after all, those practices have been in place for years.

Understanding and practicing the hierarchy of controls is especially valuable when two or more employers are collaborating in a shared work environment. Doing so can unleash tremendous value, lead to greater awareness around risk and controls and help keep workforces safe.

In the context of the COVID-19 pandemic, how can the hierarchy of controls be leveraged for better performance in risk and safety?

Let’s start with the diagram below, which shows a simple overview of the hierarchy of controls. Here, we see levels of reliability along with examples of common controls as part of a COVID-19 response. (This should also make clear how important it is for employers to stay connected throughout the process.) Most often, the host employer (or “client”) has day-to-day and site-specific responsibility as the controlling employer. Meanwhile, the primary employer (or “staffing agency”) serves a key role in helping to advance the dialogue and promote risk-based thinking, which benefits the workforce as a whole.

Consider a few common situations employers are facing right now:

  • returning to work
  • restarting operations following a shut-down, reconfiguring production lines and workcells
  • introducing new sanitation and hygiene protocols

In these and other scenarios, the primary employer is in a position to add tremendous value, leveraging expertise in workforce management across multiple industries to identify better risk controls, find solutions and solve complex problems.

2020 safety heirarchy

It’s important to understand that risk controls related to COVID-19 (as well as other health and safety risks) at the bottom two levels of the pyramid are highly dependent on consistent behavior from the workforce. Otherwise, they aren’t effective. Given that fact, redundant controls might be considered, even at the administrative level, such as supervisor audits of sanitation practices, followed by leadership review and feedback. Ultimately, both employers must embrace their shared commitment to ensuring the reliability of controls at these levels, while also striving to elevate some functions to engineering levels or higher.

Another approach is to “decompress” the work environment through workstation design, the use of guards or barriers, limiting seating areas or even adjusting the speed of production to maximize distance. All of these options are worth considering at an engineering level. Of course, not all of them may be feasible for every work environment, but it is this pursuit of higher-level controls that delivers greater levels of reliability.

Risk always fluctuates during times of change. In fact, how we manage change directly correlates to the level of risk experienced by the workforce. Changing a production line to produce masks instead of curtains, for example, requires wide-ranging reconfiguration — everything from orientation and onboarding to training requirements and more.

For companies undergoing transformation, therefore, a few questions should be top of mind:

  1. What’s changing in our processes?
  2. How are changes and disruptions impacting the workforce?
  3. Are there any potential gaps, delays, new risks and processes in our approach to our supply chain or vendor management?
  4. What are the limitations and challenges with our current safety equipment, such as the fit and function of PPE? (Check out this article for more on fit and function risks.)
  5. Are front-line managers, as well as the workforce in general, fully informed on any changes? Do they know how to deal with new situations or risks?
  6. Can HR and staffing partners contribute in ways that will make my workplace safer?

Managing change in joint-employer environments is a terrific opportunity to drive safety improvements and better control for new and emerging risks. What’s more, it allows both parties to work collaboratively, which means identifying risk and solving problems can become yet another “new normal.” That should enable a stronger culture — and promote better safety outcomes, to boot. For additional insights, be sure to check out this article.

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