Safety, Risk Management, and Environmental Controls
Apply the hierarchy before buying PPE
The hierarchy of controls ranks risk reduction: elimination, substitution, engineering controls, administrative controls, and personal protective equipment (PPE). PPE is last because it depends on human behavior and fit. Risk management means identifying hazards, assessing risk, implementing controls, and evaluating residual risk. Environmental controls follow a similar logic: identify aspects (activities, materials, emissions) and impacts (air, water, land, community). Use pollution prevention, secondary containment, spill response, waste segregation, monitoring, and permit compliance. Emergency response must match credible scenarios.
Traps that appear in questions
- Selecting PPE first or counting administrative controls as engineering controls.
- Treating risk transfer (insurance, contractor) as risk reduction.
- Ignoring fugitive emissions, stormwater pathways, or incompatible waste storage.
- Assuming a permit is a control; a permit is an administrative requirement, not an engineering barrier.
- Forgetting that residual risk must be communicated and accepted by the right authority.
Worked example
For solvent storage, the hierarchy gives: eliminate the solvent or reduce inventory; substitute a less hazardous material; engineer closed containers, ventilation, and secondary containment; add administrative procedures and training; finally specify PPE for residual exposure. A plan that begins with respirators and gloves has inverted the hierarchy and will be questioned.