Administrative Controls and Work Practices
Administrative Controls and Work Practices
This domain tests controls that change exposure time, procedures, and worker behavior. They are legitimate controls but rank below engineering controls because they depend on enforcement, training, and human performance.
Core rules
- Administrative controls include job rotation, exposure-time limits, scheduling noisy or hot tasks, permits (confined space, hot work), lockout/tagout, standard operating procedures, housekeeping, and hygiene facilities.
- Training is not a control by itself; it supports a control. A procedure without enforcement or verification is weak.
- OSHA standards set specific administrative requirements: 1910.147 lockout/tagout, 1910.146 permit-required confined spaces, 1910.1030 bloodborne pathogens exposure control plan, 1910.95 hearing conservation program, and 1910.134 written respiratory protection program.
- Work practices should be written for non-routine tasks: cleaning, maintenance, startup, and emergency response.
- Administrative controls are often appropriate as interim measures and for reducing duration while engineering controls are installed.
Worked example
A worker spends 8 hours at 100 dBA. OSHA uses a 5 dB exchange rate; permissible exposure is 2 hours at 100 dBA, so an 8-hour exposure would be 400% dose. Rotating the task to 1 hour at 100 dBA and 7 hours at 80 dBA gives a dose near 50%, or an 8-hour TWA near 85 dBA. Rotation can support a hearing conservation program, but engineering noise control is preferred.
Traps
- Treating a training session as a control that reduces exposure.
- Writing rotation schedules that are not followed or not measured.
- Using administrative controls for highly toxic substances where exposure must be captured.
- Forgetting that permits and procedures require verification and audits.