Hierarchy of Control – Are our Controls working for us?
Are our Controls working for us? A Practical Look at the Hierarchy of Control
When a hazard is identified, the response is often familiar: provide training, introduce a procedure, put up a sign, or issue PPE.
Those measures may all have a place. But before jumping straight to them, it is worth asking a more important question:
Are we controlling the hazard, or relying on people to recognise and avoid it?
The hierarchy of control provides a simple framework for thinking this through. It encourages businesses to consider controls in order of effectiveness, starting with eliminating the hazard altogether and working down towards controls that rely more heavily on individual behaviour.
The hierarchy of control
In broad terms, businesses should consider whether they can:
Eliminate
Remove the hazardous activity, substance, or equipment altogether.
Substitute
Replace it with something safer.
Use engineering controls
Physically separate people from the hazard through measures such as guarding, enclosure, extraction, automation, or mechanical handling.
Use administrative controls
Reduce risk through planning, procedures, supervision, training, signage, or restricted access.
Use PPE
Protect the individual from any remaining risk.
The aim is not to pick one control and stop there. In practice, several measures may need to work together.
The important point is to avoid jumping automatically to the easiest or most familiar option. Controls higher up the hierarchy are generally more reliable because they depend less on someone remembering an instruction, following a process correctly or wearing PPE every single time.
What does this look like in practice?
Imagine a task that creates harmful dust.
Respiratory protection may form part of the solution, but before reaching that point it is worth asking:
- Can the material be supplied pre-cut?
- Can the process be changed to prevent or reduce dust generation?
- Can extraction capture the dust at source?
- Can the task be enclosed or separated from other people?
- What training, maintenance, inspection, and supervision are needed?
- What RPE is required for any remaining exposure?
RPE can also introduce additional requirements and costs, including suitable selection and face-fit testing where required. Sometimes controlling the hazard further up the hierarchy is both more effective and more cost-effective in the long run.
Manual handling is another good example
Manual handling is an area where businesses can easily become stuck at the lower end of the hierarchy.
If employees routinely lift or move heavy materials, the first response may be to provide handling aids, refresher training, or reminders about technique.
Those measures can help, but they still leave people physically involved in the task.
Where investment is possible, it may be worth stepping back and asking whether the process itself could be changed.
- Could the material be supplied differently?
Could the lift be removed altogether?
Could machinery, conveyors or mechanical handling be introduced?
Could materials be stored or transferred differently?
This may involve greater upfront investment, but the return can be broader: fewer injuries and absences, less reliance on individual technique, more consistent working methods, and improved efficiency.
Sometimes the stronger safety control is also simply the better business decision.
When your people are telling you something
Accidents, near misses and cases of ill health can sometimes be the first indication that existing controls are not working as intended.
Recurring back pain in someone routinely lifting heavy materials, for example, should prompt more than another reminder about lifting technique.
Likewise, repeated fatigue, sickness absence or difficulties among shift workers may indicate that working patterns and recovery are not being managed effectively.
The individual may be where the problem becomes visible, but that does not necessarily mean the individual is the problem.
If a work activity presents a foreseeable risk of injury or ill health, the business needs to consider whether that risk has been adequately controlled. Sometimes the right response is to step back and ask whether the activity itself could be better designed, reduced, mechanised, or controlled.
A practical question to take away
Choose one activity in your business where you currently rely heavily on training, PPE, written instructions, or manual effort.
Then ask:
Could we remove, reduce, or physically control more of the hazard before relying on people to manage what remains? And where improvement requires investment, consider the wider return too.
Could it reduce absence?
Could it make the task easier or more efficient?
Could it improve consistency?
Could it remove a recurring operational problem as well as reducing risk?
Is it going to strengthen the business in the long run? (we’d say likely yes, if it means reducing the likelihood of hurting people or action being taken)
Good risk management is not about automatically adding more controls. It is about choosing controls that are practical, proportionate, and genuinely effective.
For further support please do reach out, hello@shedoessafety.co.uk
About the author
Laura Tull CertIOSH MIFSM is Director of SHE Does Safety Ltd, providing practical health, safety, and fire support to businesses across East Anglia.