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How to Use the Hierarchy of Controls Without Stopping at PPE

Why Many Risk Assessments Stop Too Early

When new HSE learners complete a risk assessment, they often recommend Personal Protective Equipment (PPE) as the first and only control measure.

For example:

  • Wear a hard hat.
  • Wear safety gloves.
  • Wear safety glasses.

While PPE is an important part of workplace safety, relying on it alone often misses opportunities to reduce risk more effectively.

The Hierarchy of Controls encourages safety professionals to consider stronger control measures before depending on PPE. By following this structured approach, organizations can reduce workplace risks at their source rather than relying solely on workers to protect themselves.

This guide explains how to apply the Hierarchy of Controls in practical workplace situations and shows how to move beyond PPE-only solutions.

What Is the Hierarchy of Controls?

The Hierarchy of Controls is a framework used to select the most effective ways to manage workplace hazards.

The five levels are:

  1. Elimination
  2. Substitution
  3. Engineering Controls
  4. Administrative Controls
  5. Personal Protective Equipment (PPE)

Controls near the top of the hierarchy generally provide more reliable and long-term risk reduction than those lower down.

For a detailed explanation of each level, visit our Hierarchy of Controls guide.

Why PPE Should Not Be the First Answer

PPE helps reduce exposure to hazards, but it does not remove the hazard itself.

Its effectiveness depends on factors such as:

  • Correct selection
  • Proper fit
  • Worker training
  • Consistent use
  • Maintenance and replacement

If PPE is worn incorrectly or not used at all, workers may still be exposed to significant risks.

This is why risk assessments should first consider whether stronger controls are reasonably practicable.

Applying the Hierarchy: Start at the Top

Instead of asking:

“What PPE is needed?”

Ask:

  • Can the hazard be eliminated?
  • Can it be substituted with something safer?
  • Can engineering controls reduce exposure?
  • Can work procedures or supervision improve safety?
  • Is PPE still required after these controls?

This approach encourages more effective risk reduction.

Workplace Example 1: Working at Height

Hazard

Workers performing maintenance on a roof.

PPE-Only Approach

  • Safety harness
  • Safety helmet

While important, PPE relies on workers using it correctly.

Stronger Approach

Elimination

  • Complete maintenance from ground level where possible.

Substitution

  • Use equipment that reduces the need for roof access.

Engineering Controls

  • Install temporary guardrails or edge protection.

Administrative Controls

  • Permit-to-work system.
  • Worker training.
  • Supervision.

PPE

  • Harnesses and helmets where residual risk remains.

This layered approach provides better protection than PPE alone.

Workplace Example 2: Excessive Workplace Noise

PPE-Only Approach

  • Hearing protection provided.

Stronger Approach

Elimination

  • Remove unnecessary noisy processes.

Substitution

  • Replace noisy equipment with quieter alternatives.

Engineering Controls

  • Install acoustic barriers.
  • Enclose noisy machinery.

Administrative Controls

  • Rotate workers.
  • Limit exposure time.

PPE

  • Hearing protection for remaining exposure.

Reducing noise at the source is generally more effective than relying only on ear protection.

Workplace Example 3: Chemical Exposure

Hazard

Workers using cleaning chemicals.

PPE-Only Approach

  • Gloves
  • Safety goggles

Stronger Approach

Elimination

  • Remove hazardous chemicals if no longer required.

Substitution

  • Use less hazardous cleaning products.

Engineering Controls

  • Improve local exhaust ventilation.

Administrative Controls

  • Safe handling procedures.
  • Worker training.
  • Restricted access.

PPE

  • Gloves and eye protection where exposure remains.

This approach reduces dependence on PPE by controlling the hazard earlier in the hierarchy.

Workplace Example 4: Warehouse Vehicle Movements

Hazard

Forklifts operating near pedestrians.

PPE-Only Approach

  • High-visibility clothing.

Stronger Approach

Elimination

  • Separate vehicle and pedestrian routes where possible.

Substitution

  • Use alternative material handling methods for certain tasks.

Engineering Controls

  • Install physical barriers.
  • Automatic warning systems.
  • Speed control devices.

Administrative Controls

  • Traffic management plans.
  • Driver training.
  • Visitor procedures.

PPE

  • High-visibility clothing.

Physical separation offers stronger protection than relying only on visibility.

Why Layering Controls Improves Safety

Many workplace hazards cannot be controlled by a single measure.

Instead, organizations often combine controls from different levels of the hierarchy.

For example:

Hazard:
Airborne dust.

Controls:

  • Local exhaust ventilation.
  • Wet cutting methods.
  • Worker training.
  • Respiratory protection.

Layering controls creates multiple barriers that reduce the likelihood of exposure.

Common Mistakes When Applying the Hierarchy

Starting with PPE

PPE should not automatically become the first recommendation.

Always consider higher-level controls first.

Ignoring Elimination Opportunities

Sometimes a task, material, or process can be removed entirely.

This often provides the greatest reduction in risk.

Forgetting Engineering Controls

Physical changes to equipment or workplaces often provide long-term protection with less reliance on worker behavior.

Assuming One Control Is Enough

Multiple controls may be required for higher-risk activities.

Combining engineering, administrative, and PPE controls often produces better results than relying on a single measure.

Questions to Ask During Risk Assessments

When selecting controls, consider:

  • Can the hazard be removed completely?
  • Is a safer alternative available?
  • Can the workplace be redesigned?
  • Can procedures reduce exposure?
  • Is PPE still necessary after stronger controls are applied?

These questions encourage more effective risk management decisions.

Linking the Hierarchy to Residual Risk

Even after applying several controls, some risk may remain.

For example:

Hazard

Exposure to dust during cutting operations.

Existing Controls

  • Local exhaust ventilation.
  • Wet cutting method.
  • Respiratory protection.

Although the likelihood of exposure has been reduced, some residual risk may still exist.

Evaluating this remaining risk helps determine whether further improvements are required.

How Better Controls Strengthen Risk Assessments

Applying the hierarchy effectively helps organizations:

  • Reduce risk at its source
  • Improve long-term safety
  • Reduce reliance on worker behaviour
  • Strengthen action plans
  • Improve workplace safety performance

It also supports more effective decision-making during inspections, audits, and risk assessments.

For a broader understanding of workplace risk management, explore our Risk Assessment Guide.

Building Better Control Selection Skills

The Hierarchy of Controls is more than a list of control measures—it is a way of thinking about how risks can be reduced most effectively.

Instead of stopping at PPE, learners should work through each level of the hierarchy to identify stronger and more sustainable solutions.

This approach leads to better risk assessments, more effective action plans, and safer workplaces.

If you’re developing your risk assessment skills, our Risk Assessment Template provides a structured format for documenting hazards, existing controls, and recommended improvements.

Continue Your HSE Learning Journey

Applying the Hierarchy of Controls effectively is an essential skill for anyone involved in workplace risk management.

SFAST provides practical learning resources to help students, supervisors, managers, and aspiring safety professionals understand hazard identification, control selection, and internationally recognised HSE best practices.

If you’re considering NEBOSH, IOSH, or other professional HSE qualifications, the SFAST advisory team can help you identify a learning pathway suited to your goals.

Frequently Asked Questions

What is the Hierarchy of Controls?

The Hierarchy of Controls is a framework that ranks control measures from the most effective (elimination) to the least effective (PPE).

Why shouldn’t PPE be the first control?

PPE reduces exposure but does not remove the hazard. Higher-level controls often provide more reliable protection.

What is an example of an engineering control?

Installing machine guards, guardrails, ventilation systems, or physical barriers are examples of engineering controls.

Can multiple control measures be used together?

Yes. Combining engineering, administrative, and PPE controls often provides stronger protection than relying on one control alone.

How does the Hierarchy of Controls improve risk assessments?

It helps identify more effective ways to reduce workplace risks and supports stronger action planning.