Safetip #67: Follow up to Confirm That Controls Are Effective

February 22, 2017
By Jean-Grégoire Manoukian

This week’s Safetip is about inspecting and evaluating control measures after they are implemented, to make sure they remain effective.

OSHA’s Recommended Practices for Safety and Health Programs

To help organizations establish a safety and health program in their workplaces, OSHA published recommended practices that provide a framework for addressing safety and health issues. They can be used in any workplace, and apply to many industries. The practices also include information specifically aimed at temporary worker and multiemployer work situations. There are also separate recommended practices for the construction industry, but there is a lot of identical or similar content between the two documents.

OSHA’s recommended practices highlight the importance of hazard prevention and control. After hazards have been identified, assessed and prioritized, controls must be selected using the hierarchy of controls (see NIOSH’s hierarchy of controls below) and implemented.

NIOSH Hierarchy of Controls

Inspect and Evaluate Controls Regularly

To make sure that control measures are effective and remain that way, OSHA’s recommended practices urge employers to track progress in implementing controls, inspect and evaluate controls once they are installed, and follow routine preventive maintenance practices, by doing the following:

  • Track progress and verify implementation by asking the following questions:
    • Have all control measures been implemented according to the hazard control plan?
    • Have engineering controls been properly installed and tested?
    • Have workers been appropriately trained so they understand the controls, including how to operate engineering controls, safe work practices, and PPE use requirements?
    • Are controls being used correctly and consistently?
  • Conduct regular inspections (and industrial hygiene monitoring, if indicated) to confirm that engineering controls are operating as designed.
  • Evaluate control measures to determine if they are effective or need to be modified. Involve workers in the evaluation of the controls. If controls are not effective, identify, select, and implement further control measures that will provide adequate protection.
  • Confirm that work practices, administrative controls, and PPE use policies are being followed.
  • Conduct routine preventive maintenance of equipment, facilities and controls to help prevent incidents due to equipment failure.

The implementation part is only the beginning. There must be ongoing maintenance of control measures to make sure that changes in hazards due to changes in processes do not lead to ineffective controls.

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