The COVID-19 Hierarchy of Controls for the General Public

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What if you’re not in an essential role at a critical infrastructure organization?

What if you are isolating at home, and need to go out for some food?

What if you had a plumbing issue and have to call in the professionals?

I’ve found myself in all of these scenarios recently, and even though I have an extensive safety background, I still paused to think. This thought process is natural for me, I’m a risk management and safety professional after all! This thought process may not be natural to you, however. I’ve had family and friends reach out to ask what “people in my industry” think about COVID-19, how long we will have to isolate, and what we are doing at our workplaces.

It’s kind of cool that the general public now knows the term “PPE,” but I also worry that they may think that is all there is to safety – suiting up and putting on protective gear to “stop” something from harming a person. It made me think that the general public might be open to learning about another concept from the safety professional’s toolkit – the Hierarchy of Controls.

The National Institute for Occupational Safety and Health (NIOSH) has a great landing page on the HoC. NIOSH is a part of the Centers for Disease Control and Prevention (CDC), and was established by the Occupational Safety and Health Act of 1970 (OSHA). You can learn all about that history here.

To keep things simple and relevant, it’s best to work through the HoC with a task in mind. After you’ve identified a task, you begin to identify the hazards associated with that task. This is the foundation for another safety concept called Job Hazard Analysis (or Job Safety Analysis, Task Hazard Analysis, Activity Hazard Analysis, or other term used at your workplace).

Task: You must go to the grocery store to pickup food for the next week.

Potential hazard: COVID-19

Now let’s work through the HoC to identify controls for the hazard of COVID-19. The HoC is usually presented as an upside-down pyramid to guide you to work through the stuff at the “top” first before the bottom tippy tip which is PPE.

HierarchyControls

Elimination controls: Usually this means that you eliminate the task completely. So, don’t go out! Seriously, if you’re doing pretty well on groceries and don’t have immediate needs, eat what you have – no need to hoard. I just learned about an app called Plant Jammer that will make up vegetarian-friendly recipes for you based on what you have on hand. This is also a great way to minimize food waste.

Substitution controls: What can you do in place of the actual task? You could order shelf-stable food to be shipped to your home; order a combination of pantry and fresh food for delivery by a local service in which a shopper does the shopping for you; order for drive-up pickup. There are probably more iterations of these substitutions that involve alternate ways of shopping in which you avoid interaction with others as much as possible. You get the point, and your mileage may vary depending on if you live in a city, suburb, or rural area.

Engineering controls: These controls are the type that physically isolate a person from the hazard. This is being attempted at stores with makeshift pickup counters that have plexiglass or other physical surface between the worker and the customer. In a typical non-COVID-19 workplace setting, a great example of an engineering control is a guard on a tool – the worker still uses the tool, but there’s a physical “thing” that is in place to prevent a worker’s finger or other body part (or whole body) from coming into contact with the hazard. Another example is guardrails when there is a hazard of falling.

Administrative controls: We also call these “work practice controls” nowadays because these are ways that we change the way the worker works through education, postings, and other non-physical controls.

A great example that stores are using all over the US is the placement of markings on the floor and sidewalks to indicate 6-feet of distance. This enables people to maintain social distancing while waiting in line. A store may also put up a sign for people that enter the store to shop to maintain 6-feet of distance from others – of course, signs don’t often change behavior and that’s why your friends are posting on Facebook about people getting too close in the aisles of Target!

Another administrative control is to shop alone if you do go out. Don’t bring your child, spouse, or other adult from your household. Stores are supporting this by limiting the amount of customers allowed into a store at a given time. Many stores have also setup special hours for elderly and immunocompromised people to shop to limit their exposure to others.

If you will be using a shopping cart, bring wipes to wipe down the handle before use, and bring hand sanitizer so you can wash your hands after returning the cart and before getting into your car.

When you get home, you may want to wipe down the food packaging before bringing items into the home. Even if you order food for delivery or shipment, you may still want to wipe down the items before bringing them into your home.

PPE controls: PPE is the last resort when you work through the HoC. The goal is to NOT put a bunch of protective gear on a person to do what they need to do at work. I have the same goal for you if you choose to venture out to shop.

PPE is the last resort because it is the control that is most subject to human error. People often put PPE on incorrectly, use the wrong PPE, or don’t understand the limitations of their PPE. When a construction worker gears up in a high visibility vest, they still must pay attention when working around heavy equipment! If that vest is dirty, or the retroreflective fabric is compromised somehow, the gear may not do it’s job, and the worker has a false feeling of safety…this is not good!

For our shopping example, if you’ve worked through the HoC and have chosen that you will do the shopping on your own, by entering a store and going through the checkout, you may choose to wear PPE because you have not implemented any other controls to this point (for whatever reason). By taking on the responsibility of wearing PPE, think about what you’re going to do with it when you get home… If you have a garage, you should think about leaving yourself a clean set of clothes and shoes to change into, and leave the “store clothes” in the garage or bring into the home in a bag and put them in the laundry right away. If you wear gloves and they are not disposable, they should be laundered too. If you choose to wear a mask, wash or dispose of it after use per its instructions.

Throughout and after this process, wash your hands!

Here’s a nice article that sums up this process, without naming the HoC (but now you’ll see it!), and has more resources links for you to dive down rabbit holes as you would like (or not).

Please share your tips and let me know of any questions. Stay safe and healthy out there!

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