How to Leverage the Hierarchy of Controls to Keep Workers Safe
By Tim Piemonte, Contributor
Fatalities are everyone’s worst nightmare. Naturally, companies say they will do anything to prevent them. However, despite code compliance and even the best of intentions, serious injuries and fatalities continue to occur each year.
Because human error is inevitable, personal protective equipment (PPE) and safety training are not effective when relied upon alone. This article will teach you a methodical approach to ensure people are safe by using the hierarchy of controls.
The Hierarchy of Controls
Safety by design is the best way to protect workers from serious injuries and death. The NFPA 70E, Standard for Electrical Safety in the Workplace, which is the long-time OSHA recognized standard for electrical safety, is geared to people who regularly work with energized equipment as part of their job task. The standard is not intended to offer guidance on protected nonqualified workers. Additionally, the standard is only available in English, which is problematic for non-English speaking U.S. workers. An examination of 897 OSHA Fatality and Catastrophe Investigation Summaries of fatal electrical injuries that occurred between Jan. 1, 2011 and Dec. 31, 2018 found that 64% of all workplace electrical fatalities occurred in occupations outside of the electrical field[i].
Therefore, it is a company’s responsibility to protect all its workers from electrical hazards, and not just those who are qualified to work around the hazard.
The hierarchy of controls starts at the top with the most effective and moves down to the least effective safety measure (see Figure 1). You cannot eliminate all hazards, but the idea is that the closer you get to the top, the safer workers will be.
[i] B. 11 and D. Majano “Expanding workplace electrical safety to non-electrical occupations” Proc. IEEE IAS Elect. Saf. Workshop pp. 1−5 Mar. 2020.
The hierarchy of control’s methods are:
- Elimination: Physically remove the hazard
- Substitution: Replace the hazard
- Engineering controls: Isolate people from the hazard
- Awareness: Inform people of possible hazards
- Administrative controls: Change the way people work
- PPE: Protect the worker with PPE
The NFPA 70E follows the model of the hierarchy of controls. The standard establishes the de-energization of energy sources as the preferred approach to working on or around electrical hazards and emphasizes that PPE should solely be relied upon as a last resort (or an extra layer of protection). PPE is not the first line of defense; it is the last.
The hierarchy of controls is incredibly important for this reason. Nonqualified workers often encounter electrical hazards, but the nature of their job usually does not call upon a need for safety training or PPE. When we consider how most electrical fatalities occur to workers who do not work directly with electricity, then it is essential to position upper-level hierarchy of controls as the focus of your safety strategy.
Human-based safety measures (such as PPE and safety training) are important components of occupational safety, but these methods are prone to error and are unreliable on their own, which is why the NFPA 70E, Standard for Electrical Safety in the Workplace, stresses that they should never be used as the sole safety method unless there is no other choice (see Figure 1).
Ground-fault circuit interrupters (GFCIs), special-purpose GFCIs, and arc-flash relays are all examples of higher-level hierarchy of controls methods. When a company uses these methods, its management team can sleep at night knowing its workers are safe from serious electrical incidents. If they were to solely rely on lower-level methods, then the workers’ safety will not be guaranteed.
The hierarchy of controls is the pinnacle to all facets of workplace safety—especially for anything that involves electrical hazards because it helps companies prioritize which methods are best to ensure protection. Facility operations tend to speed up processes to meet work demands and yet, the safety mechanisms and equipment for preventing incidents often fail to keep pace.
Electrical shock incidents are often due to a lack of awareness. This unawareness may be of the hazard itself, the proper PPE to wear, or even how much time has passed since the worker last familiarized themselves with safety standards (such as the NFPA 70E).
The false sense of safety and awareness goes beyond mere complacency.
The Fire Protection Research Foundation (FPRP) identified a “normalization of deviance” among electrical workplace incidents[i]. Normalization of deviance is a process that initiates from a safety standard and then gradually deviates to what becomes an accepted practice. This effectively begins to operate as the new normal. This is significant because:
- Normalization of deviance underscores how difficult it is for a facility to prevent human error within a framework. Because this deviation is gradual, it is difficult to detect when it happens. Incidents are inevitable in facilities that do not utilize engineering controls at a minimum.
- The gradual and easily undetected degradation that occurs in normalization of deviance is similar to how people often believe they are knowledgeable—even masters— of their subject. In reality, however, their knowledge is often incomplete or out of date.
”A substantial amount of work is inappropriately taking place on or around electrical sources that are energized, that stringent guidelines for personal protective equipment are frequently flouted, and that administrative controls, such as training and pre-job planning, are implemented or practiced haphazardly,” the FPRF said.2
Facilities should implement designs focused on the reduction of human error by implementing substitution or engineering controls (assuming the hazard cannot be eliminated). Substitution methods include items such as resistor monitors, current-limiting fuses, indicating fuses, and electromechanical relays. When substitution methods are not possible, use engineering controls such as GFCIs, special-purpose GFCIs, and arc-flash relays
Tim Piemonte is a vertical market manager at Littelfuse (www.littelfuse.com) with over 10 years of experience in the electrical industry, including six years of field service and power system analysis at GE where he focused primarily on commercial and industrial power distribution. Tim is a member of IEEE, IAEI, NFPA, and received his B.S. in electrical engineering from Rensselaer Polytechnic Institute in 2010.
 B. 11 and D. Majano “Expanding workplace electrical safety to non-electrical occupations” Proc. IEEE IAS Elect. Saf. Workshop pp. 1−5 Mar. 2020.
 R.B. Campbell and D.A. Dini, “Occupational Injuries From Electrical Shock and Arc Flash Events,” Fire Protection Research Found. Quincy, MA, USA, Mar. 2015.
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