The new regulations released in February are a game changer as far as how we deal with hazards and risks in the workplace are concerned. No longer can we rely on minimisation through personal protective equipment (PPE) as a means of compliance by itself; the new hierarchy of control clearly identifies the steps that need to be taken before you can use PPE.
You must always try to eliminate any hazard or risk as your first option, this is no different from the old legislation. What has changed is the removal of isolation – there is no longer an eliminate, isolate, minimise process to follow, the only options now are to eliminate or varying degrees of minimisation.
The new regulations have five degrees of minimisation, and you must try and take one or more of the first three actions that are the most appropriate and effective way of decreasing the risk.
PPE should be used only while other more effective controls are being developed or installed, or if there are no other more effective ways to control the hazard. This is because as the risk has not been eliminated or reduced, you are normally just swapping one risk for another. If the equipment is inadequate or fails, the worker is not protected. No PPE is foolproof (for example, a respirator may be fitted with the wrong filter for the situation you are using it in – and I’m speaking from personal experience on this one after getting carbon monoxide poisoning from cutting a drainage channel to a sump in a garage). PPE is often uncomfortable and can place an additional physical burden on a worker. PPE can actually create hazards. For example, the use of respirators for long periods of time can put a strain on the heart and lungs. While there are some jobs, such as removing asbestos, where wearing adequate PPE is absolutely essential, there are many jobs where employers hand out PPE when in fact they should be using a more effective risk control method.
Any risk control selected must not substitute one hazard for another. For example, it is not acceptable to remove air contaminants from one area by venting them to another area where other workers could potentially be exposed. Using a harness as a means of fall protection is less effective than using an isolation control and in the event of someone falling off a roof while wearing a harness, it is still exposing them to a risk of potentially losing limbs if they are not rescued within 3-5 minutes. PPE is also normally the most expensive long term means of minimisation as it always has ongoing costs associated with it.
Risk control measures must eliminate or reduce the risk of a hazard occurring, to be effective.
The PCBU which implements any control measure must ensure that the measure is effective and lowers the risk rating for the hazard identified. They must ensure that the control measure is:
The PCBU must also review and if necessary, revise the existing control measures already implemented so as to maintain a work environment that is without risks to health and safety. This is essential if there has been an adverse result from health exposure monitoring such as a worker who has developed decreased hearing even though they have been issued with and are wearing hearing protection.
Richard Tattersfield, Senior Health & Safety Consultant, Progressive Consulting Ltd