A couple of us are on our way back from the National Safety
Council’s 2013 Congress and Expo in Chicago. We like to go to these because it
helps us to get a flavor for what’s going on in the world of safety. If you’ve
never been to one of these conferences, it’s quite an experience. There are big
events with famous keynote speakers (former-astronaut Mark Kelly was the big
speaker at this conference), as well as numerous smaller presentations that
tend to be more focused on specific areas within safety (leadership seemed to
be a big theme this time).
One of the big draws of the show is the exposition, which
features hundreds of vendors who come to show off their products. The National
Safety Council Congress and Expo being the biggest safety conference in the US,
it naturally has the biggest of these expos. However, the cross-section of
vendors seemed very similar to other conferences we’ve been to. This year the
themes at the Expo were similar to the themes we noticed at the American
Society of Safety Engineers’ Professional Development Conference, Safety 2013 –
fall protection, fire-retardant clothing, gloves and boots, and compliance
assistance with the upcoming Globally Harmonized System. But what there was a
lot of was less interesting than what there wasn’t that much of – safety
products designed to implement controls at the top of the hierarchy of
controls.
A little background is probably important to make sure we’re
all on the same page. When safety professionals have a hazard they want to
mitigate or a risk they want to reduce we turn to (or at least we’re supposed
to turn to) our old trusty hierarchy of controls to help us choose the most
effective controls. There are different types of hierarchies out there but the
one we prefer is:
- Elimination (e.g. removal of noisy equipment, performing work at ground level instead of on a roof)
- Substitution (e.g. using less-toxic chemicals, purchasing equipment that have less vibration hazards)
- Engineering Controls (e.g. ventilation systems, machine guarding)
- Warnings (e.g. back-up alarms, signage)
- Administrative Controls (e.g. training, procedures)
- Personal Protective Equipment (e.g. respirators, gloves)
The idea is that the lower you go on the hierarchy the more
risk you have, primarily because the controls become more reliant on people
doing the right thing every time the lower you get. When a risk is eliminated
the workers don’t have to do anything to protect themselves from it. When using
personal protective equipment the workers have to do the right thing every
single time they put on the equipment, creating many opportunities for error.
One of the primary reasons most people do not use the higher
order controls (controls 1, 2, and 3 from the list above) is because it seems
too difficult and too expensive. It’s so much easier to just put on a
respirator than to take the time to find, purchase, and deploy a less harmful
chemical. Plus the costs on these on the front end are way higher. Consider the
cost of buy a fall arrest harness and lanyard (a few hundred dollars) compared
to redesigning a structure to avoid going on the roof (many thousands of
dollars).
Consider the Expo we talked about above for a minute. The
great thing about capitalism is that businesses tend to go where the money is.
So if you want to know where other businesses are spending a lot of money, look
at the vendor industry that surrounds that business. My point is – if the
higher order controls were so much more expensive, wouldn’t there be lots of
businesses at that expo selling products to assist organizations in
implementing those controls? But there wasn’t. There were a handful of
companies that sold some engineering controls, but everything else was lower
order controls. If so many vendors have realized that there’s a lot of money to
be made by selling lower order controls, doesn’t that seem to fly in the face
of the argument against using higher order controls?
Think about it and let me know your thoughts in the comments
below.
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