OccuSafe Industrial Hygiene Consulting

For most OSHA standards, employers are required to reduce employee exposures to below the Permissible Exposure Limit for the particular chemical or contaminant. It requires that they use feasible engineering or administrative control to accomplish this goal. Administrative controls are ranked lower than elimination, substitution, and engineering controls because this method does not necessarily remove or reduce the hazard from the workplace. For example, administrative controls limit workers’ exposures by scheduling shorter work times in contaminant areas or by implementing other “rules.” These control measures have many limitations because the hazard itself is not actually removed or reduced. Administrative controls should be used in combination with other control measures where possible.

The Hierarchy of Controls includes the following:

Elimination
Substitution
Engineering Controls
Administrative Controls
Personal Protective Equipment

Work practices can be changed to lessen the hazard. Some fundamental and easily implemented work practice controls include (1) changing existing work practices to follow proper procedures that minimize exposures while operating production and control equipment; (2) inspecting and maintaining process and control equipment on a regular basis; (3) implementing good housekeeping procedures; (4) providing good supervision; and (5) minimizing entry and restricting activities in regulated areas. 

At a facility where I consult, employees test fire explosive charges in a steel enclosure. Once fired, the employee must enter the enclosure and remove the spent charge. The employee may be exposed to lead from the smoke. To lessen exposure, the employees are required to wait 3 minutes before making entry. Unfortunately, the operator does not always wait to have the smoke clear and their exposure to lead then increases.

Other administrative controls may include job rotation, preventative maintenance, restricted access to problem areas, warning signs, training, good housekeeping, personal hygiene, available clean bathrooms, and planning for emergencies.

Elimination, substitution, and engineering controls are always the best ways to control a hazard. However, when they are not feasible administrative controls can be implemented. In such a case,, it is important that employees and management understand their limitations and ensure that they are followed as directed.