Understanding the Hierarchy of Controls: Personal Protective Equipment

The hierarchy of controls is one of the most valuable tools safety professionals have at their disposal for addressing workplace hazards and preventing occupational injuries and illnesses. Over the past year, we’ve written about elimination and substitution, engineering and administrative controls, and we’ve finally reached the last line of defense: personal protective equipment (PPE).

“It’s imperative that employers implement the proper safety controls on every jobsite,” said LHSFNA Management Co-Chairman David Rampone. “Each control in the hierarchy has an important role to play. Properly fitting PPE, in combination with the other controls, can mean the difference between returning home safely or suffering a life-altering injury on the job.”

What Is PPE?

PPE refers to clothing and equipment worn to protect workers from chemical, physical, mechanical or other hazards encountered on the job. When using the hierarchy of controls, it’s always preferable to use solutions that eliminate the hazard completely or isolate a hazard from the worker. If none of these can be used to achieve the desired protection, PPE is the next line of defense. It’s important to note that the hazard is still present in these scenarios, making PPE the least protective control.

Some specific examples of how PPE might be used include:

• Reflective vests to make sure a worker is visible when working in low-light conditions
• Insulated gloves to protect hands from frostbite when working in the cold
• Puncture-resistant work boots to prevent sharp objects like nails or broken glass from penetrating workers’ feet
• Safety helmets to protect workers’ heads from falling debris
• Respirators to keep workers from inhaling dangerous particles like silica dust
• Personal fall protection to protect workers exposed to fall hazards while working at elevations more than six feet

Weaknesses of PPE

As the last control in the hierarchy, PPE is considered the least effective and, if possible, should never be the primary source of protection used on a job. Using PPE comes with some limitations, which include:

• The hazard in the workplace is not eliminated
• The protection provided can be inadequate if it’s not properly selected for the hazard
• Protective equipment can fail or even cause additional hazards if the worker is not fitted and trained on its proper use
• A lot of PPE isn’t made with multiple body types in mind
• PPE can be uncomfortable and place additional physical stress on workers
• PPE relies on individuals to use it correctly and consistently

Additionally, while it’s common for jobsites to have PPE like gloves or safety glasses, it’s less common to have equipment that actually fits every worker. In a survey by CPWR – the Center for Construction Research and Training, only 19 percent of respondents said they were always provided with safety equipment in sizes that fit them, for instance.

[The LHSFNA and other industry partners have been vocal about the need for properly fitting PPE for every worker, and after several rounds of comments, OSHA recently finalized its PPE Fit rule to better protect workers. Learn more here: OSHA Finalizes Rule for Personal Protective Equipment Fit in Construction.]

Despite its weaknesses, PPE still plays a vital role in keeping workers safe on the job. Using a combination of PPE and other controls is often the best way to mitigate hazards and avoid injuries and incidents. For more on PPE, check out our Tools & PPE resource page, where we discuss PPE in the workplace and link to relevant publications and articles.

[Hannah Sabitoni]