h6 Hierarchy of Control

HIERARCHY OF CONTROL
H6
How to use the hierarchy of control to

effectively reduce workplace risks
This chapter explains how the hierarchy of control can

help you to prioritise risk control measures so that you can
effectively eliminate or minimise risks in your workplace.
What is the purpose of the hierarchy of control?�� H 6/3

How to use the hierarchy of control�� H 6/3
Example: Minimising risks using the hierarchy of control�� H 6/5
Step-by-Step: How does the hierarchy
of control fit in the risk management process?�� H 6/6
Are you required to use the hierarchy of control?�� H 6/8
Case Study: Using the hierarchy of control to manage risks�� H 6/9
Prioritising control measures�� H 6/10
How to determine if the cost is grossly disproportionate to the risk�� H 6/11
Involving your workers in the risk management process�� H 6/13
Step-by-Step: How to implement control measures effectively�� H 6/13
Checklist: Ensuring your controls remain effective�� H 6/15
TEMPLATES AND SAMPLES

Template: Implementing the Hierarchy of Control�� H 6/16
The mouse icon indicates that an editable document is available for

download. You can download it from the Subscriber Zone at
www.healthandsafetyhandbook.com.au/subscribers using the password
on the front cover of the latest Health & Safety Handbook update.
0415
H 6/2 Hierarchy of Control
INDEX
controls personal protective equipment
- how to monitor ��H 6/7 - definition�� H 6/4
- prioritising ��H 6/10
person conducting a business or
- determining when cost is
undertaking
grossly disproportionate ��H 6/11
- definition��H 6/8
- how to implement
effectively�� H 6/13; H 6/15 reasonably practicable
- definition ��H 6/7
health and safety representative
- definition ��H 6/13 risk assessment
- definition ��H 6/6
hierarchy of control
- definition ��H 6/3 risk management process
- purpose of ��H 6/3 - how to implement ��H 6/6
- how to use �� H 6/3; H 6/5 - involving workers in ��H 6/13
- when required ��H 6/8 safety management system
- managing risks with ��H 6/9 - definition ��H 6/3
- training workers in��H 6/13
- Template: Implementing
the Hierarchy of Control ��H 6/16
For further references to these terms, please refer to the full word index.
Authors: Michael Selinger LLB, BA (Hons) (ANU)

Partner, Holding Redlich Lawyers
Andrew Douglas LLB (Hons) (Tas), Grad Dip Corps and Sec (Melb)
Principal, M+K Lawyers, FSIA (Hons)
HEALTH&SAFETY HANDBOOK
Hierarchy of Control H 6/3
WHAT IS THE PURPOSE OF THE HIERARCHY OF CONTROL?
Definition: Hierarchy of Control

The hierarchy of control is a risk control method that sets out six
stages you should consider to control workplace risks, in order of
implementation.
The hierarchy of control requires you to consider the most

effective control measures first. It focuses on the best remedy
rather than the cheapest and quickest outcome.
Consider the
Its purpose is to discourage you from considering less effective
most effective
measures until you have fully assessed the possibility of
control
implementing more effective controls.
measures first
The hierarchy of control is one part of the safety management
system (other parts include conducting audits and reviews to
check that controls are working effectively).
Definition: Safety Management System

A safety management system is a set of policies and procedures
designed to address health and safety issues in a systematic and
integrated way.
Important: By using the hierarchy of control, you will be able

to demonstrate that your business takes risk management
seriously and has a safety management system in place.
In particular, you can demonstrate how you attempted to take
all reasonably practicable steps (see page H 6/7) to control risks
in the workplace.
HOW TO USE THE HIERARCHY OF CONTROL

The hierarchy of control provides a structured approach for
selecting appropriate control measures to eliminate or reduce
risks you have identified in your workplace.
Stages higher in the hierarchy are generally more effective
at minimising risks. Aim to implement the higher stages first
before considering stages lower on the list.
0415
Tip: It is often necessary to use a combination of controls.
The following table explains how to implement each stage:
Stage How to implement
Stage 1 − Elimination Remove the risk of exposure to the hazard completely.
Control the risk by substituting it with a less hazardous or

Stage 2 − Substitution
non-hazardous alternative.
Stage 3 − Isolation Reduce the risk by enclosing or isolating it.
Stage 4 − Engineering Put engineering controls in place to eliminate or reduce the risk.
Stage 5 − Administration Implement administrative controls to minimise the risk.
Require your workers to wear personal protective equipment

Stage 6 − Personal
(PPE) (e.g. safety goggles, gloves, iridescent vests and safety
protective equipment (PPE)
boots, while in the vicinity of the risk).
Definition: Personal Protective Equipment (PPE)

Personal protective equipment is equipment used or clothing worn
by workers to reduce the risk of illness or injury from exposure to
workplace hazards.
Stages 5 and 6 (administration and PPE, respectively) are

the lowest stages of the hierarchy and should not be used
exclusively to control a risk − they are rarely effective if used
alone. You should only use these stages to control any residual
risk that remains after stages higher in the hierarchy have
been put in place.
Important: Do not just consider control measures that are

easy or cheap to implement. Instead, you should construct an
action plan that aims to control the risk most effectively in the
long term.
If long-term controls cannot be implemented immediately,

put temporary controls in place to reduce the risks until the
long-term controls can be implemented (see page H 6/10).
EXAMPLE: MINIMISING RISKS USING THE HIERARCHY OF

CONTROL
The following example demonstrates how to use the hierarchy
of control to reduce the risk of a worker or pedestrian being
injured by a forklift:
Stage How to implement
If possible, eliminate the risk altogether by no longer requiring

Stage 1 − Elimination
the forklift to be used.
Consider whether less hazardous plant, such as an unpowered

Stage 2 − Substitution
forklift, can be used to move materials and supplies.
Isolate the area where the forklift will be used.

For example, consider whether you can:
Stage 3 − Isolation • install barriers to separate pedestrians from the path of

moving forklifts; or
• isolate areas where forklifts operate from other work areas,
e.g. loading bays.
Consider whether it is possible to engineer out the need for

the forklift, e.g. by moving materials through the workplace on
conveyor belts or fixed tracks.
Alternatively, consider whether you can reduce the risk by
engineering risk controls. For example, consider whether you can:
• arrange racks in the warehouse so that pedestrians and
Stage 4 − Engineering forklift drivers always have a clear view of each other;
• install lighting in the work environment to increase the
visibility of forklifts;
• install signs, flashing lights and beepers to identify the
presence of a forklift; and/or
• paint pedestrian walkways on factory floors.
If a residual risk still remains, consider implementing the

following administrative controls in your workplace:
• identify areas in your health and safety policies where
Stage 5 − Administration pedestrian access is not allowed;
• train staff in those policies; and
• provide workers with adequate supervision.
If the risk cannot be completely controlled by using one or more

Stage 6 − Personal of the stages above, issue all workers and visitors to the site
protective equipment (PPE) with PPE, such as high-visibility clothing, to be worn in areas
where forklifts operate.
0415
STEP-BY-STEP: HOW DOES THE HIERARCHY OF

CONTROL FIT IN THE RISK MANAGEMENT PROCESS?
You are required under health and safety legislation to take

all reasonably practicable steps (see page H 6/7) to remove any
health and safety risks in your workplace. You can do this by
implementing a risk management process, which involves the
following four steps:
Step 1: Identify hazards

Identify existing hazards in your workplace by:
regularly inspecting your workplace;
How to consulting workers about their health and safety
identify concerns; and
workplace
reviewing relevant safety information, such as
hazards
incident reports, health monitoring records and
complaints about workplace safety.
Please refer to hazard identification and inspections in the word
index for more information.
Step 2: Conduct a risk assessment

Assess the potential for the hazards to cause harm by
conducting a risk assessment.
Definition: Risk Assessment

Risk assessment is the process of evaluating:
the consequences expected from an incident arising out
of a hazard, e.g. a fatality, permanent disability or injury
requiring medical/hospital treatment, first aid and/or
time off work; and
the probability of this incident occurring.
Important: Always look out for a change in work practices

that might require you to undertake a new risk assessment,
e.g. relocating or modifying plant.
Please refer to risk assessment in the word index for more

information.
Step 3: Control risks using the hierarchy of control

Use the hierarchy of control to effectively control the risk of
injury or illness arising from a hazard. If possible, eliminate
the risk altogether. If elimination is not reasonably practicable,
minimise the risk using one or more controls.
Definition: Reasonably Practicable

Reasonably practicable, in relation to health and safety, refers
to what is reasonably able to be done when ensuring health and
safety, taking into account and weighing all the relevant matters,
including:
a. the likelihood of the hazard or risk occurring;
b. the degree of harm that may result from the hazard or risk;
How to
c. what the person concerned knows or ought reasonably to determine
know about:
what is
(i) the hazard or risk; and reasonably
practicable
(ii) ways of eliminating or minimising the risk;
d the availability and suitability of ways to eliminate or
minimise the risk; and
e. the cost associated with available ways of eliminating or
minimising the risk, including whether the cost is grossly
disproportionate to the risk (see page H 6/11).
Tip: Check retail catalogues of safety equipment supplies for

information about effective control measures.
Step 4: Monitor and review controls

Once a control has been implemented, monitor the control to
ensure it is minimising risks effectively. When monitoring
controls, ensure that:
the risk management process was conducted in a
thorough and effective manner;
0415
the control measures have been properly implemented;

your workers comply with the control measures;
the control measures continue to adequately manage
Monitor the risks; and
controls to
ensure they the control measures have not introduced any other
are effective problem or hazard into your workplace.
ARE YOU REQUIRED TO USE THE HIERARCHY OF

CONTROL?
The Work Health and Safety (WHS) Regulations expressly
provide that a PCBU must use the hierarchy of control to
manage risks. A PCBU must follow:
the general principles of the hierarchy of control; and
the specific regulatory requirements.
Definition: Person Conducting a Business or Undertaking

(PCBU)
Under the WHS Act, a PCBU is a person, corporation, partnership
or association that conducts a business or undertaking. The
business or undertaking can either be for profit or not-for-profit,
and may be conducted by a single person or by multiple people, e.g.
in partnerships, each partner is a PCBU.
Example
The regulation ‘Remote or isolated work’ requires one or more of the
six stages of the hierarchy of control to be implemented. This is a
general requirement and must be implemented in conjunction with
the specific requirements of the WHS Regulations, which include
providing a safe system of work and effectively communicating
with workers who work in remote or isolated locations.
Although health and safety legislation in Victoria and WA does

not expressly require the hierarchy of control to be used, it is
best practice to use the hierachy in these States to assess which
controls should be implemented to effectively minimise risks.
Tip: Familiarise yourself with any guidelines and codes of

practice issued by health and safety regulators or industry
associations that apply to the type of work that your business
conducts, as these will provide up-to-date information
on controls you can implement in accordance with the hierarchy
of control.
CASE STUDY: USING THE HIERARCHY OF CONTROL TO

MANAGE RISKS
The following case highlights the importance of applying the
hierarchy of control to risk management, particularly where
there is a foreseeable risk of human error.
The case demonstrates that if you put reasonable steps in place

to manage risks, which results in no direct harm or likelihood
of harm occurring, you will not be liable for a penalty under
health and safety legislation:
In WorkCover v Orica Pty Ltd (2015), Orica engaged Downer

Australia Ltd to repair a faulty valve on its steam lines. A worker
employed by Downer Australia cut into a live steam line with an
angle grinder, releasing high-pressure steam in the vicinity of two
other workers. No one was injured.
Following an investigation, the Court found that Orica failed

to properly implement its primary safe work procedure, which
was to isolate the relevant steam line from the mains steam
pressure before work was performed. Orica relied on its shutdown
coordinator to do this, but it was not properly carried out.
Case Law:
Orica’s shutdown coordinator was a highly experienced and Shutdown
well-trained worker who had previously performed thousands coordinator
of successful shutdowns. However, in this case, the shutdown failed to follow
coordinator failed to accurately identify the circuits by which the safe work
steam entered the particular steam line. procedure
Nevertheless, the Court found Orica was not liable for this failure
because it had used the hierarchy of control to implement a
back-up safety system to deal with the potential scenario that
0415
the steam line was not isolated properly. This back-up safety
system included:
preparing a job safety analysis for the particular task,
which identified the residual risk that the isolation
control may not be effective;
Orica used requiring workers to wear appropriate personal
the hierachy protective equipment;
of control to
performing a ‘nick’ test, in which a small nick was made
implement
into the pipe away from the body to permit the harmless
a back-up
escape of any hazardous material; and
safety system
completing and discussing a work permit that recorded the
potential for the release of high-pressure steam and fluid.
The third step was an important precaution, in which the worker

employed by Downer Australia was required to treat all lines as
live. This was done in order to guard against the possibility of
human error, which occurred in this case. The fourth step ensured
that this procedure was performed.
In relation to the incident, the worker gave evidence that he

deliberately positioned his body away from the nick when cutting
into the pipe, so that when hazardous substances were emitted
from the pipe he was “out of the line of fire”. This meant that
neither he nor his co-workers were directly exposed to a risk of
being burnt.
The Court found that the work practices and controls instituted
by Orica were adequate to ensure that the release of high-pressure
steam did not expose the workers to a serious risk. On that basis,
the Court dismissed the charge against Orica.
PRIORITISING CONTROL MEASURES

Health and safety legislation does not always require you
to completely eliminate risks, as this is not always possible
or practicable. Instead, you are required to take ‘reasonably
practicable’ steps to minimise the risk as much as possible
(see page H 6/7 for a definition).
Caution: Never ignore a risk once it’s been identified.

Always implement some form of control that prevents
anyone in your workplace from being injured by it.
Once you have identified the risks associated with each hazard,
conduct a risk assessment to determine the most serious risks;
these should be managed first. If you cannot control these
risks immediately, it is critical that you implement temporary
control measures, e.g. turning off a machine or preventing
entry to a hazardous site, to immediately control risks until
more effective controls can be put in place.
Example
A guard needs to be replaced on a machine, but that part isn’t
immediately available and delivery could take up to 2 weeks. In
the meantime, prohibit the use of the machine and, if necessary,
barricade the area.
Eliminating a risk altogether can be cheaper in the long term.
Lower level controls that only reduce the risk may seem
easier to implement at the time, but may require ongoing
resources to monitor and enforce, e.g. inducting, training and
supervising workers.
Caution: Do not allow people in your workplace to be
exposed to a hazardous situation while long-term controls
are being implemented. Remember, short-term controls
still need to be effective. For example, if a machine needs
to be guarded, switch it off and lock it out. Don’t simply
require operators to wear gloves while they use it.
Do not rely on short-term control measures longer than you
need to. The sooner long-term measures can be implemented,
the better.
HOW TO DETERMINE IF THE COST IS GROSSLY

DISPROPORTIONATE TO THE RISK
As an employer, you are expected to invest money in risk
controls. The amount of money you spend on control measures Invest more
should be proportionate to the level of risk associated with the money in
hazard. This means you are expected to spend more money controlling
on risks that could be fatal or create lifelong health problems, serious risks
especially if they are likely to occur.
0415
Important: Cost can only be a reason for refusing to eliminate

or reduce a risk if it is ‘grossly disproportionate’ to the level of
harm and the chance of an incident occurring.
Example
At John Duff Brick Factory Pty Ltd, there is a crack in a large
concrete floor where bricks are dried. It is a small tripping hazard,
with one side of the crack elevated 5 millimetres. Currently the
crack is only 50 centimetres long, but it will continue to grow.
Example: The process of eliminating the hazard altogether would involve

Cost of ripping up the entire concrete floor and laying a new one. However,
eliminating a short-term control of grinding off the crack and filling it will
the risk eliminate the immediate risk.
is grossly
Regular observations will allow a continuation of the grinding
disproportionate
and filling process to continue for many years and render the floor
safe. The cheaper solution would therefore be better, as the cost of
replacing the floor is grossly disproportionate in the circumstances.
While it may make financial sense to delay the implementation

of expensive measures, they should not be put off indefinitely
for serious risks. It is no defence to say that a risk control
measure is too expensive if there is a high probability of injury
resulting from the identified hazard (see page H 6/6).
Important: If you can’t afford to eliminate or control serious

risks, you should stop the work process that creates the risk.
Tip: Sometimes the most cost-effective way of controlling risks is

to design a safer workplace in the first place. Implementing control
measures in response to a risk can be more expensive than building
safety into the workplace design from the start, or selecting safer
equipment in the planning phase.
Please refer to workplace design and modification in the word

index for more information.
INVOLVING YOUR WORKERS IN THE RISK MANAGEMENT Develop

PROCESS risk control
Ensure that health and safety committee members and health
strategies in
consultation
and safety representatives (HSRs) undergo training in risk
with workers
management processes, including how to use the hierarchy of
control. Encourage them to use the hierarchy to assess safety
issues raised by other workers.
Definition: Health and Safety Representative (HSR)

A health and safety representative is a worker who is elected by
a group of workers to represent the health and safety interests of
the work group.
Tip: You should also educate other workers in your business

about the hierarchy of control. Encourage them to consider it on a
daily basis to improve safety in your business.
Use the hierarchy of control to help you develop risk control

strategies with your workers. To do this, talk through each
stage of the hierarchy with your workers and encourage them
to contribute. For example, a worker may have a suggestion as
to how a risk could be completely eliminated rather than simply
reduced.
STEP-BY-STEP: HOW TO IMPLEMENT CONTROL

MEASURES EFFECTIVELY
Once you have used the hierarchy of control to determine

suitable control measures (see page H 6/3), take the following
steps to effectively implement the controls in your workplace:
Step 1: Determine whether the controls could create

additional risks
Assess the control measures for any risks that may result
from their implementation. If necessary, rethink or rework the
control to prevent it from creating other risks in your workplace.
0415
Example
To reduce the risks associated with forklifts, XYZ Co is considering
installing seatbelts on all forklifts. However, there is a chance this
could increase the risk of a crush injury, as it could prevent the
driver from quickly exiting the forklift if it rolls over.
To best control the risks, the company has decided to install an

engineering control that prevents the forklift from exceeding
a fixed speed limit of 5 kilometres per hour. This significantly
reduces the risk that the forklift will roll over.
Step 2: Train workers in the controls

Inform affected workers of the control measures and train
them in the relevant safe operating procedures.
Definition: Safe Operating Procedure

A safe operating procedure is a written document that provides
step-by-step instructions on how to safety perform a task or
activity in the workplace.
Please refer to safe operating procedures in the word index for

more information.
Step 3: Update monitoring, reporting and auditing

documents
Ensure that the control measures are included in all relevant
monitoring, reporting and auditing documents in your
business, including inspection checklists and maintenance
records.
Step 4: Supervise workers to ensure the controls are

being implemented effectively
Monitor the controls by supervising workers to ensure they are
implementing the control measures effectively.
Review controls Step 5: Regularly review the controls

regularly Review the controls regularly to determine whether they
to ensure are working effectively to eliminate or reduce the risk (see
they remain page H 6/7).
effective
If the risk is not being adequately reduced, consider

implementing additional control measures using the hierarchy
of control (see page H 6/3).
CHECKLIST: ENSURING YOUR CONTROLS REMAIN

EFFECTIVE
Use this checklist to make sure you are doing all you can to
maintain effective risk controls:
❏❏ Ensure your managers are held accountable for health

and safety in the workplace, and that this can this
be demonstrated. For example, obtain data on lost
time injuries in the area for which the manager is
responsible and assess your manager’s performance Regularly
based on those results. consult with
workers
❏❏ Consult with your workers regularly about the controls about the
in place and how to implement them effectively. controls
❏❏ Train workers, health and safety committee members
and HSRs in the control measures.
❏❏ Ensure all information about workplace hazards is

kept up-to-date, including the controls used to
minimise risks.
❏❏ Regularly inspect your workplace and any plant you

use to determine whether additional controls may be
required.
Please refer to inspections in the word index for more information.
0415
TEMPLATE: IMPLEMENTING THE HIERARCHY OF CONTROL
Download the full, editable template from

www.healthandsafetyhandbook.com.au/subscribers.
You can find the password on the front cover of the latest
Health & Safety Handbook update.
IMPLEMENTING THE HIERARCHY OF CONTROL
Task:__________________________________________________ Date:____________________________
Hazard/s identified:_______________________________________________________________________
Risk/s:__________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
If you answer yes to any of the below, complete the fourth column.
Hierarchy of control Yes No Provide details
___________________________________________
Stage 1: Can you eliminate the ___________________________________________
¨ ¨
risk altogether?
___________________________________________

___________________________________________
Stage 2: Can you substitute the
hazard for a less hazardous ¨ ¨ ___________________________________________
process or plant?
___________________________________________
___________________________________________
Stage 3: Can you isolate the ___________________________________________
¨ ¨
hazard, e.g. by using barriers?
___________________________________________

___________________________________________
Stage 4: Can you engineer
¨ ¨ ___________________________________________
controls to reduce the risk?
___________________________________________

Stage 5: Do you need to ___________________________________________

implement administrative
¨ ¨ ___________________________________________
controls, e.g. signs, updated
policies? ___________________________________________

This document is a starting point to help you develop a document appropriate to your individual situation. It will need to be tailored to your specific
circumstances in light of any applicable laws that apply in your jurisdiction. You should seek your own advice about the necessary amendments.
© Portner Press, 2015


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HIERARCHY OF CONTROL

How to use the hierarchy of control to

This chapter explains how the hierarchy of control can

What is the purpose of the hierarchy of control?����������������������������������������������������������� H 6/3

TEMPLATES AND SAMPLES

The mouse icon indicates that an editable document is available for

Authors: Michael Selinger LLB, BA (Hons) (ANU)

WHAT IS THE PURPOSE OF THE HIERARCHY OF CONTROL?

Definition: Hierarchy of Control

The hierarchy of control requires you to consider the most

Definition: Safety Management System

Important: By using the hierarchy of control, you will be able

HOW TO USE THE HIERARCHY OF CONTROL

Tip: It is often necessary to use a combination of controls.

The following table explains how to implement each stage:

Stage How to implement

Stage 1 − Elimination Remove the risk of exposure to the hazard completely.

Control the risk by substituting it with a less hazardous or

Stage 3 − Isolation Reduce the risk by enclosing or isolating it.

Stage 5 − Administration Implement administrative controls to minimise the risk.

Require your workers to wear personal protective equipment

Definition: Personal Protective Equipment (PPE)

Stages 5 and 6 (administration and PPE, respectively) are

Important: Do not just consider control measures that are

If long-term controls cannot be implemented immediately,

EXAMPLE: MINIMISING RISKS USING THE HIERARCHY OF

Stage How to implement

If possible, eliminate the risk altogether by no longer requiring

Consider whether less hazardous plant, such as an unpowered

Isolate the area where the forklift will be used.

Stage 3 − Isolation • install barriers to separate pedestrians from the path of

Consider whether it is possible to engineer out the need for

If a residual risk still remains, consider implementing the

If the risk cannot be completely controlled by using one or more

STEP-BY-STEP: HOW DOES THE HIERARCHY OF

You are required under health and safety legislation to take

Step 1: Identify hazards

Step 2: Conduct a risk assessment

Definition: Risk Assessment

Important: Always look out for a change in work practices

Please refer to risk assessment in the word index for more

Step 3: Control risks using the hierarchy of control

Definition: Reasonably Practicable

Tip: Check retail catalogues of safety equipment supplies for

Step 4: Monitor and review controls

 the control measures have been properly implemented;

ARE YOU REQUIRED TO USE THE HIERARCHY OF

Definition: Person Conducting a Business or Undertaking

Although health and safety legislation in Victoria and WA does

Tip: Familiarise yourself with any guidelines and codes of

CASE STUDY: USING THE HIERARCHY OF CONTROL TO

The case demonstrates that if you put reasonable steps in place

In WorkCover v Orica Pty Ltd (2015), Orica engaged Downer

Following an investigation, the Court found that Orica failed

The third step was an important precaution, in which the worker

In relation to the incident, the worker gave evidence that he

PRIORITISING CONTROL MEASURES

Caution: Never ignore a risk once it’s been identified.

HOW TO DETERMINE IF THE COST IS GROSSLY

Important: Cost can only be a reason for refusing to eliminate

Example: The process of eliminating the hazard altogether would involve

While it may make financial sense to delay the implementation

Important: If you can’t afford to eliminate or control serious

What is the purpose of the hierarchy of control?�� H 6/3

the control measures have been properly implemented;