The traditional Hierarchy of Controls (HoC) can be misleading for safety practitioners. Many find it challenging to implement higher-order controls, such as engineering solutions, and instead default to administrative measures. This often happens for several reasons: higher-level controls may not be obvious, the person managing risk mitigation may lack engineering expertise, or there is simply a habit of defaulting to procedural solutions.
A common example is the universal requirement in many organisations for team leaders to complete a risk assessment before work begins. Whether called a Job Safety Analysis (JSA) or a Safe Work Method Statement (SWMS), these assessments typically focus on following procedures rather than identifying engineering controls. In most cases, teams lack the authority to modify tools, improve safety barriers, or redesign workflows. As a result, risk mitigation often defaults to the bottom of the HoC, relying on administrative controls and personal protective equipment (PPE). And we all know that frontline workers rarely consult these procedures—they simply “get on with the job.”
The process below is designed to push risk mitigation actions higher up the HoC, making the traditional framework obsolete. Following these four phases leads to a more sustainable risk reduction process.
Phase 1: Eliminate the Hazard at Its Source
The first step is to remove the hazard entirely whenever possible. This may involve eliminating the task or activity altogether, using alternative equipment that eliminates the hazard, or modifying the sequence of actions to make the hazard irrelevant. The focus is entirely on eliminating the hazard, not just mitigating it by reducing the likelihood of harm.
This phase mirrors the traditional HoC but emphasises focusing on the hazard itself—whether a condition, activity, or situation—ensuring this critical phase is not overlooked.
Phase 2: Modify the Hazard to Reduce Risk
If elimination is not feasible, the next step is to physically alter the hazard to make it less severe or to reduce the likelihood of injury. This can be achieved by installing machine guards, blunting sharp objects, implementing ventilation or isolation systems, substituting with safer equipment, automating hazardous tasks, or improving ergonomics and containment measures. While engineering controls could reduce either the severity and likelihood of harm, priority should always be given to reducing potential severity first.
This phase aligns with substitution and engineering controls in the traditional HoC but ensures the focus remains on modifying the hazard itself.
Phase 3: Optimising Worker Capabilities
If the risk remains above acceptable levels, workers must be empowered to manage it by reducing the likelihood of harm occurring. This involves developing their ability to recognise and avoid hazards, minimising exposure through optimised scheduling and task design, ensuring access to proper facilities and technology, supporting physical and mental well-being (including fatigue management), and involving them in decisions about sequencing, resource allocation, and workflow design.
A key principle here is real-world skill development—not classroom training or digital procedures. Workers must practice hazard recognition and risk mitigation in their natural workgroups until it becomes second nature. No generic procedures are issued at this stage. Furthermore, Phase 3 does not change the severity of a hazard but reduces the likelihood of harm occurring.
Phase 4: Critical Activities with Prescribed Procedures
Some tasks expose workers and others to extreme risk due to both the severity of potential harm and the difficulty of avoidance. These risks are so critical that their execution must follow strictly defined procedures due to regulatory or operational necessity. This includes activities such as switching on or isolating an electrical network, aircraft take-off and landing, confined space entry, chemical mixing or hazardous material handling, lockout/tagout procedures, administering anaesthesia in surgery, and decontaminating hazardous spills.
For these activities, specific procedures must be developed, trained, and practiced in real-life conditions. Additionally, error-proofing mechanisms should be implemented to enhance reliability, including second-person oversight either on-site or remotely from a control room, checklists and visual aids, and decision-support tools that help workers execute procedures accurately. However, the goal is not merely robotic adherence but understanding the intent behind each step. For example, an electrical switching procedure varies each time, and both the operator and their second-person support must grasp the logic of the sequence to execute it intelligently.
Not all workplaces will require Phase 4 procedures. Some lower-risk environments may mitigate risks so effectively in Phases 1–3 that critical procedures are unnecessary. For example, forklift operations in a well-controlled environment may not require rigid procedural controls if the risk has been sufficiently reduced through earlier phases.
Leadership Commitment and Systemic Influences
Risk mitigation is not only a frontline responsibility—it is deeply influenced by leadership decisions and systemic factors. Scheduling, resourcing, and operational constraints can either enable or hinder worker safety. Management priorities shape the feasibility of hazard elimination or modification, while investments in engineering solutions determine how effectively risks are reduced before they reach the worker level. Acknowledging these systemic influences ensures that safety strategies are holistic and effective, rather than shifting responsibility onto workers alone.
Summary
The concepts introduced in this paper require a deeper exploration—not only to grasp their theoretical foundations but also to understand their practical implications. This marks the beginning of a much broader realignment of traditional perceptions in health and safety. Unlike conventional approaches, this framework shifts the starting point by placing those with the most at stake—the frontline workers—at the center of harm prevention.
Some may cynically view this as shifting responsibility onto workers, but nothing could be further from the truth. Rather, this approach acknowledges their proximity to risk and focuses on equipping them with the tools, skills, and authority to actively manage it. It is about empowerment, not burden.
In my book, Safety 2.1: The Safety Envelope, I delve deeper into these concepts and, most importantly, explore how they can be practically implemented in real-world environments.