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December 2013

Administrator's Message

Revisiting the hierarchy of controls

By Michael Wood

In recent weeks, I have had several conversations that ended up hinging on the hierarchy of controls – in most cases, the issue was that the hierarchy was being overlooked in the discussion and controls (such as personal protective equipment) that relied upon a high level of worker "compliance" were being incorrectly treated as controls that largely eliminated the hazards in question.

I have written before that I believe the essence of the hierarchy of controls is less focused on a discussion of "engineering controls" versus "administrative controls" versus "work practice controls" and more focused on a simple set of principles:

As we design our workplace activities, these principles – especially if designed into the basic work processes – can reduce the need for enforcement and progressive discipline, as well as the need to focus excessive attention on shifting worker behavior. They can make our workplaces more intrinsically safe – and that's where we are likely to see the greatest benefits in the long run.

Michael Wood
Oregon OSHA Administrator

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