Administrative Controls and HD Program Management
Administrative controls are the policies, procedures, training, and monitoring that shape how work is done. They sit below engineering controls but above PPE in the hierarchy, and questions test whether you know what belongs in this category: written HD handling procedures, a hazard assessment, a designated HD list, training and competency records, medical surveillance, exposure and spill reporting, and waste management policy.
The candidate should recognize that an organization must maintain a list of hazardous drugs based on published criteria, review it regularly, and communicate it to staff. Training must be documented and repeated, and competency assessed. Medical surveillance is offered to workers who handle HDs, and exposure incidents are reported and investigated.
Traps: (1) treating a policy document as an engineering control; (2) assuming training alone protects workers; (3) forgetting that administrative controls include monitoring and recordkeeping, not just rules; (4) believing a single annual training satisfies competency requirements. Questions may ask which item is an administrative control, or what to do after an exposure - anchor on report, evaluate, document, and follow up.
Worked example: a new employee is assigned to HD compounding. Before independent work, the employee must complete documented training and demonstrate competency; the record is retained. Rule of thumb: if a control is a rule, record, or training requirement rather than a device or a garment, it is administrative.