Track the Length of Time Interim Controls Are in Place – Safetip #215

Safety Tip and Best Practice
July 22, 2020

Our latest Safetip is about tracking the length of time for which interim controls have been in place.

Addressing Risks Right Away

When a new hazard that can cause a risk of an incident is identified, you must determine the most effective and feasible measure to either eliminate the hazard, or control the risk and reduce the likelihood of an incident.

The hierarchy of controls shows the types of control measures and their effectiveness:

Hierarchy of Controls

The controls at the top are the most effective. But they are also potentially costly and may require changes to equipment or processes, or even important physical changes to a facility.

The controls at the bottom are more feasible. Some can even be implemented in a few days. But they’re not as effective as the controls at the top.

Many organizations are willing to invest significant time and effort to implement one of the more effective controls (elimination, substitution, engineering controls).

But a risk of injury may still be present while a permanent control is being assessed and implemented, which sometimes can take months.

Interim controls can protect workers while permanent controls are being developed.

A Leading Indicator

Interim controls are used on a temporary basis. For example, if indoor air quality (IAQ) is an issue at a facility, and the solution is to install a better central ventilation system, consider providing PPE to workers and/or using job-rotation schedules (i.e. an administrative control) to limit employee exposure in specific areas of the facility where IAQ is the worst.

Also, a document from OSHA on leading indicators for measuring the implementation of hazard prevention and control practices suggests the “length of time interim controls have been in place” as a leading indicator.

Tracking the length of time can provide insights into potential issues: you may have problems if you’re relying too much on interim controls or if you’re taking too much time to implement more effective controls located at the top of the hierarchy of controls. Here are some examples of problems:

  • Ineffective process for identifying and assessing the most appropriate permanent control.
  • Inefficient sourcing procedures when, for example, having to purchase components that will form an engineering control solution.
  • Too many delays in executing the implementation of a control measure.
  • Relying too much on an interim control and becoming complacent.

Remember that, ultimately, an interim control is meant to be only temporary until a more effective control (elimination, substitution, engineering control) is implemented.


Our Safetips share safety tips or best practices that contribute to safety excellence. Visit our blog regularly for new Safetips!

Verdantix Green Quadrant Operational Risk Management Software 2019

This report provides a detailed comparison of the 17 most prominent ORM software vendors. It is based on the proprietary Verdantix Green Quadrant methodology, including interviews with software users from high-risk industries and a survey of 211 operations decision-makers.

Author

JG

Jean-Grégoire Manoukian

Content Thought Leader - Wolters Kluwer | Enablon