A risk assessment does more than identify what could cause harm. It should also help determine what can be done to reduce the risk and how those improvements can be implemented.
This is particularly important when studying NEBOSH GIC2, the practical risk assessment unit of the 2025 specification. GIC2 requires learners to complete a workplace risk assessment and develop an action plan based on their findings. NEBOSH’s current qualification information confirms that the practical assessment involves assessing workplace risks and developing an action plan.
One useful way to improve the quality of proposed controls is to apply the hierarchy of controls.
Rather than automatically suggesting training, warning signs or PPE, the hierarchy encourages you to consider whether the hazard can be removed, replaced or controlled closer to its source first.
This article explains how to use that thinking when reviewing potential further controls for GIC2 practice.
What Is the Hierarchy of Controls?
The hierarchy of controls is a way of prioritising measures used to prevent or reduce workplace risks.
The commonly used sequence is:
- Elimination – remove the hazard.
- Substitution – replace it with something less hazardous.
- Engineering controls – isolate people from the hazard or control it at source.
- Administrative controls – change how the work is organised or performed.
- Personal protective equipment (PPE) – protect the individual from residual risk.
The ILO describes prevention and control measures as needing to follow an order of priority, beginning with elimination and source control and moving toward administrative measures and PPE where residual risks remain.
The hierarchy is therefore not simply a list to memorise. It is a way of asking:
Can this risk be controlled more effectively than it is now?
Why the Hierarchy Matters for GIC2 Action Plans
When developing a GIC2 action plan, it can be tempting to choose the easiest improvement to describe.
For example, a learner might immediately think of:
- providing additional training;
- displaying a warning sign;
- reminding workers to follow procedures;
- providing PPE.
These measures may have a role, but they should not automatically be the starting point.
A stronger control-thinking process asks whether the hazard can be addressed further up the hierarchy.
For example:
Hazard → Existing controls → Remaining risk → Possible further controls → Higher-level controls where reasonably practicable
This helps turn an action plan from a collection of general safety suggestions into a more considered set of improvements.
NEBOSH’s GIC2 guidance identifies the evaluation of existing controls and the explanation of suitable additional controls as part of the practical assessment learning outcome.
Start With the Hazard, Not the Control
One of the most important habits is to identify the actual hazard before deciding what control should be introduced.
Consider a simple example:
Workers are repeatedly exposed to a noisy piece of machinery.
Jumping straight to hearing protection focuses on PPE.
Instead, work through the problem:
- Can the noisy process be eliminated?
- Can a quieter process or piece of equipment be substituted?
- Can the machinery be enclosed or isolated?
- Can exposure time be reduced through work organisation?
- Is hearing protection still required for residual exposure?
The point is not that every hazard will have a practical elimination or substitution option.
The point is to consider the hierarchy before settling on the control.
Elimination: Can the Hazard Be Removed?
Elimination is at the top because removing a hazard can remove the associated exposure altogether.
For workplace risk assessment practice, ask:
- Does the activity need to be performed?
- Can the task be redesigned so the hazardous activity is no longer necessary?
- Can the work be completed without introducing the hazard?
- Can the hazardous step be removed from the process?
Example: Working at Height
Suppose a workplace regularly requires workers to access an elevated location for a task.
Instead of immediately thinking about ladders, harnesses or additional training, consider whether the task could be redesigned so it is completed from ground level.
The ILO gives a similar principle when discussing control selection: where possible, work can sometimes be redesigned to avoid the need for working at height altogether.
For GIC2 practice, the important lesson is to ask whether the exposure can be avoided, rather than assuming the existing method must continue.
Substitution: Can the Hazard Be Replaced?
If elimination is not reasonably practicable, consider whether the hazardous item, substance, process, or method can be replaced with a safer alternative.
Examples might include:
- replacing a more hazardous chemical with a less hazardous alternative;
- selecting a less noisy piece of equipment;
- changing a process that creates unnecessary dust;
- using a safer method of completing a task.
For chemical hazards, the ILO specifically recommends considering whether a safer substance or alternative process is available before relying on lower-level controls.
Think Beyond “Safer Product”
Substitution is not limited to replacing one product with another.
It can also involve changing the method of work.
For example, ask:
Can the task be performed using a different process that creates less exposure?
That question can reveal control opportunities that would be missed by simply checking whether workers have been issued PPE.
Engineering Controls: Can People Be Separated From the Hazard?
Engineering controls change the physical workplace, equipment or process to reduce exposure.
Examples include:
- machine guarding;
- physical barriers;
- enclosure of a hazardous process;
- local exhaust ventilation;
- mechanical lifting equipment;
- vehicle-pedestrian segregation;
- improved extraction;
- automatic systems that reduce direct worker exposure.
Engineering controls are valuable because they can reduce reliance on individual behaviour.
For example, a physical barrier between pedestrians and moving vehicles does not depend solely on every person remembering a verbal instruction.
The ILO identifies engineering controls as a way of controlling hazards at source or isolating workers from hazards.
Administrative Controls: Useful, But Often Not the First Question
Administrative controls change how work is organised or carried out.
They can include:
- safe systems of work;
- training;
- supervision;
- scheduling;
- inspection arrangements;
- maintenance procedures;
- restricted access;
- job rotation;
- information and instructions.
These controls are important, but they often depend on people following the required system.
For example, telling workers to keep pedestrians away from a vehicle route is different from physically separating pedestrians and vehicles.
Both may contribute to risk reduction, but they address the problem in different ways.
Ask This Question
When considering an administrative control, ask:
Could part of this control be strengthened by changing the workplace, equipment or process?
This simple question can help you move from a purely procedural solution toward a more robust control where appropriate.
PPE: Important, But Do Not Stop Here
PPE has an important role in workplace safety, particularly where residual risks remain after other controls have been considered.
Examples include:
- eye protection;
- safety footwear;
- gloves;
- hearing protection;
- respiratory protective equipment;
- protective clothing;
- head protection.
However, PPE generally sits at the bottom of the hierarchy because it protects the individual rather than removing or controlling the hazard at source.
The ILO advises that PPE should generally be considered a last resort where other controls do not adequately control the remaining risk.
This does not mean “never recommend PPE.”
Instead, avoid treating PPE as the automatic answer to every hazard.
Turning Existing Controls Into Better Further Controls
A useful GIC2 practice exercise is to compare what is already happening with what could reasonably be improved.
Consider this sequence:
| Question | What to consider |
| What is the hazard? | What could cause harm? |
| What is already in place? | Existing controls |
| How well do those controls work? | Reliability and effectiveness |
| What risk remains? | Exposure or potential harm still present |
| Can the hazard be eliminated? | Remove the activity or source |
| Can it be substituted? | Use a safer alternative |
| Can engineering controls help? | Isolate or control at source |
| What administrative controls are needed? | Procedures, training, supervision, scheduling |
| Is PPE still needed? | Protection against residual risk |
This approach keeps the action plan connected to the actual risk assessment.
Practical Examples of Applying the Hierarchy
The following examples are for learning and control-selection practice. They are not ready-made GIC2 assessment entries.
Example 1: Manual Handling
Imagine workers regularly move heavy materials by hand.
A weak approach might begin with:
Provide manual handling training.
A hierarchy-based thought process could ask:
- Can unnecessary manual movement be eliminated?
- Can the material be delivered closer to where it is used?
- Can mechanical handling equipment be introduced?
- Can the load or packaging be redesigned?
- Can work organisation reduce unnecessary handling?
- Is appropriate PPE required for any remaining hazards?
Training may still be useful, but the assessment should not stop there.
Example 2: Machinery
Imagine an operator works close to moving machinery.
Instead of immediately recommending additional instructions, consider:
- Can the hazardous operation be eliminated?
- Can the process be automated?
- Can the machine be guarded?
- Can access to the danger zone be physically restricted?
- Can a safe system of work support the engineering controls?
- Is PPE required for residual hazards?
This reflects the broader principle that controlling exposure at source can be more reliable than relying solely on individual behaviour.
Example 3: Chemical Use
Suppose a cleaning activity involves a hazardous substance.
Possible questions include:
- Is the substance necessary?
- Is a less hazardous alternative available?
- Can the process reduce exposure?
- Can ventilation or containment be improved?
- Are storage and handling arrangements adequate?
- Are workers trained in the safe system?
- Is suitable PPE required for residual exposure?
The ILO recommends considering safer alternatives and process changes before relying on PPE as the primary control.
Example 4: Vehicle Movement
Suppose pedestrians and workplace vehicles operate in the same area.
Instead of relying only on:
Follow the site traffic rules.
Consider whether the physical layout can be improved.
Possible control thinking could include:
- eliminate unnecessary vehicle movement;
- redesign routes;
- physically separate pedestrians and vehicles;
- improve visibility at crossing points;
- introduce suitable traffic-management procedures;
- provide relevant training and supervision.
The physical separation element may address the hazard more directly than relying only on instructions.
The Hierarchy Should Improve the Action, Not Just the Wording
Adding words such as “engineering control” to an action does not automatically make it better.
Compare the thinking behind these two approaches:
Generic:
Improve safety by providing more training.
More considered:
The existing arrangement relies heavily on worker behaviour. Consider whether the hazard can first be reduced through a physical or process change, with training supporting the revised system.
The second approach demonstrates a different way of thinking about control selection.
For GIC2 practice, focus on understanding why a control is suitable, rather than trying to make an action sound technical.
Avoid the “PPE for Everything” Trap
PPE can be one of the easiest controls to think of because it is visible and familiar.
But consider a few examples:
| Hazard | PPE may help with | Other control questions |
| Machinery | Eye/foot protection | Can access or contact with moving parts be prevented? |
| Chemicals | Gloves/eye protection | Can the substance or process be substituted or contained? |
| Noise | Hearing protection | Can noise be reduced at source or exposure reduced? |
| Falling objects | Head protection | Can the source of falling objects be eliminated or controlled? |
| Dust | Respiratory protection | Can dust generation or release be prevented or extracted? |
| Vehicle movement | High-visibility clothing | Can pedestrians and vehicles be physically separated? |
The table illustrates the main principle: PPE should not stop the control-selection process.
How to Build Better GIC2 Action-Plan Thinking
When reviewing a proposed further control, use this five-question check:
1. What exactly is the remaining risk?
Do not start with the solution.
Start by understanding what exposure or unsafe condition remains.
2. What controls already exist?
A workplace may already have several controls in place.
Reviewing existing controls prevents you from proposing actions that simply duplicate what is already being done.
3. Can the hazard be removed or replaced?
Check elimination and substitution before moving down the hierarchy.
4. Can the risk be controlled physically?
Look for engineering solutions that can reduce exposure or separate people from the hazard.
5. What administrative measures and PPE are still needed?
Once higher-level options have been considered, administrative controls and PPE may form part of the remaining control strategy.
The ILO similarly emphasises reviewing existing measures and applying the hierarchy when deciding how risks should be controlled.
Connect the Control to the Action Plan
A good control idea still needs to become a practical action.
For workplace safety generally, an action should make clear:
- what needs to improve;
- why the improvement is relevant;
- who should take responsibility;
- when it should be completed;
- how implementation can be checked.
For GIC2 learners, this means thinking beyond a sentence such as “improve controls.”
Instead, ask:
What specific improvement is needed, who can realistically implement it, and how will the workplace know that it has been completed?
This makes the action more useful as a workplace management tool.
Use the Hierarchy Without Forcing It
There is an important balance here.
You should consider the hierarchy, but you should not invent an elimination or substitution option simply because it appears higher on the hierarchy.
Some hazards cannot realistically be eliminated from a particular activity.
For example, a workplace may genuinely need to use machinery, chemicals or electrical equipment.
In such situations, the practical question becomes:
What combination of controls can reduce the remaining risk effectively?
The ILO stresses that control measures should be appropriate to the activity and that workers should be involved in developing controls so they work in practice and do not introduce new hazards.
A Simple Hierarchy-of-Controls Checklist
Before finalising a proposed control during GIC2 practice, ask:
- Have I identified the actual hazard?
- Have I considered who could be harmed?
- Have I reviewed the existing controls?
- Could the hazard be eliminated?
- Could a safer alternative be substituted?
- Could an engineering control reduce exposure?
- What administrative controls are appropriate?
- Is PPE required for residual risk?
- Does the proposed action address the actual problem?
- Is the action realistic for the workplace?
- Can responsibility and timing be assigned?
- Can the effectiveness of the improvement be checked?
This is a learning checklist, not a replacement for the current NEBOSH GIC2 guidance or submission requirements.
How This Fits Into GIC2 Preparation
NEBOSH’s current GIC2 guidance was published for the 2025 specification and provides the official guidance for learners and Learning Partners.
The hierarchy of controls should therefore be treated as part of your broader risk-assessment thinking rather than as a shortcut for producing an assessment.
For additional preparation, SFAST’s NEBOSH Risk Assessment Practical Guide can help you review the wider risk-assessment process. You can also use the related Risk Assessment Guide, Risk Assessment Template, and Hierarchy of Controls resources when revising the underlying concepts.
The goal is to understand how these concepts work in a real workplace so that you can apply them independently to the situation you actually observe.
Final Thoughts
The hierarchy of controls can improve GIC2 action-plan thinking because it encourages you to look beyond the easiest control to describe.
Instead of automatically choosing training, signs or PPE, start by asking whether the hazard can be eliminated, substituted or controlled at source. Then consider engineering, administrative measures and PPE for the risks that remain.
Most importantly, connect the control to the actual workplace observation.
A useful sequence to remember is:
Observe the hazard → review existing controls → identify the remaining risk → consider the hierarchy → select realistic improvements → turn them into practical actions.
That approach helps make risk-control decisions more systematic while keeping the focus on genuine workplace improvement.