Phil La Duke
This morning I used the restroom at my local greasy spoon, as I stood at the urinal fighting the urge to retch at the sewer smell I noticed one of those yellow “wet floor” signs. The floor was dry (at least before I got there, after all, “wet floor” is a command, not a warning.) and I thought to myself, this is why the Hierarchy of Controls is such a joke: here we have a situation where the most effective solution (elimination of the hazard) is relatively cheap and easy to implement (don’t TELL me the floor is wet, dry the damned floor). The administrative controls in our lives are absurd, from the signs in Michigan warning that the bridge might be icy in 100° weather in mid-August, to beware of dog signs on the gates of homeowners whose dog has long ago shuffled this mortal coil, to the small packet of desiccant placed in a box of electronics with “do not eat” written on it. At the risk of getting off on a tangent, who in their right mind opens up the latest gadget finds the packet and says, “I’m gonna eat this”? I have used this example many times in training sessions and every once in a while someone will point out that a pet or a child could eat this material and become gravely ill. Fair point. How many of your pets and toddlers can read? My dog is very smart, but even she moves her lips when she reads so I doubt that she fully comprehends the message and is just as likely to eat it. My other dog only reads for entertainment and would gulp down the desiccant scoof without so much as a hazy concept that might develop into an action.
The point is that in these cases and others more too numerous to mention, we are taught that many warnings are stupid, inaccurate, or just plain lies. In the workplace as in life, we are forced to determine whether the danger is real, probable, and severe enough to worry about.
If after this split second analysis we judge the warning or rule to be unnecessary we will violate it. Take for example a “Don’t Walk” signal. Many good people, including more than a couple of safety practitioners, have looked around and seeing nary a vehicle for miles in either direction, have made the bold decision to cross against the light.
My point, albeit a circumlocution, is that PPE and Administrative controls aren’t just the least effective way of controlling a hazard they are also in many cases the product of lazy safety engineering. In fact, I will go so far as to say that there are a lot of instances where using administrative controls are downright criminal. Administrative controls is safety done on the cheap. Heck, why don’t we just make a rule against getting hurt. Oh, wait, in many companies we’ve done just that. We fire or discipline people for getting hurt when in fact WE failed to control the hazard. In fact, there are some countries where people who have been injured are immediately fired so that the injury doesn’t show up in their records. I know of several workers pronounced dead in an ambulance even though their corpses were so badly mangled it took two trips to put them IN the ambulance.
If employers believe that eliminating a hazard is too cumbersome (read expensive) they will just outlaw getting hurt. And since violating a safety rule is a bulletproof way of firing someone without repercussions administrative controls is a great way of protecting the company despite putting workers at extreme risk. It’s a nice system for companies, but less so for workers who end up as the guest of honor at a closed casket funeral.
What’s worse is we can do better. We know that administrative controls (excluding training) don’t work very well and unlike an engineering control, when an administrative control fails we default to blaming the “stupid, lazy worker”. It’s a fair conclusion; a stupid, lazy worker is to blame, but the stupid, lazy worker is the person who put that control into place and thought that it would work. This kind of lazy incompetence is rife in the safety function and people get maimed and blamed because of it. I find it odd that nobody ever asks why the organization depended on such an ineffectual control to keep workers safe, and furthermore never held the person or persons responsible for their ineptitude.
The Hierarchy of Controls is one of those sacred cows of safety, and when used correctly, can be a powerful tool in creating safer work processes. But many of us don’t use them properly, we accept the excuse that eliminating the hazard is impossible, that substitution would be too expensive, and we accept that PPE and administrative tools will be enough to protect workers when all we are protecting is our own ample asses. A perfect illustration of this is a contact of mine who dismissed awareness programs by saying, “I was aware of breast cancer but I got it anyway”. Too bad getting breast cancer wasn’t against the rules, it might have saved her a lot of grief.