Why there’s caution tape around administrative controls
Ever walked into a bank and wondered why they don’t keep stacks of money in the lobby? Of course not! It’s obvious the reason banks don’t do this is because people would steal it. Banks keep their money locked in vaults because there has to be some sort of impenetrable barrier between the money and everyone else. We can and should apply this same analogy to the fall protection hierarchy of controls. One of the more unfavorable methods on the hierarchy is administrative controls. The purpose of an administrative control is to create an environment which triggers a behavioral response from a worker, which in theory, should deter them from exposing themself to the hazard. Putting caution tape around a leading edge is an example of this. So do you think putting caution tape around stacks of money is going to stop people from stealing it?
The fall protection hierarchy of controls exists as a road map for safety professionals to use when determining what type of fall protection will best protect their workers from a fall hazard. The more favorable methods of fall protection are those that most distance workers from a fall hazard, hence why elimination is ranked number one. Administrative controls aim to create a mental barrier between a worker and the fall hazard. A warning light, caution tape, and audible alarms are all examples of this. Although helpful, these will not physically stop someone from falling and getting injured, rather just deter them from exposing themselves to the hazard.
Caution tape exists for a reason... Right?
The major advantage administrative controls have over the other methods is cost and convenience. It’s a lot less work and money to put up caution tape than it is to install a guard rail. Consider this - say your facility is performing some maintenance on an underground utility, which requires excavation to access. If the work is estimated to last less than 8 hours, administrative controls are probably the easiest way to mitigate the fall hazard. It becomes an issue when these short term solutions become permanent fixtures. If that repair will last for multiple days you’re now putting a lot more trust in that caution tape.
Managing administrative controls the right way
In the event administrative controls are utilized the user should understand how to manage them correctly. Since administrative controls typically rely on visual queues to alert nearby workers to the hazard, it’s important to routinely inspect that the visual queues are still functioning (i.e. warning lights are operational, caution tape visible and intact). This is especially important in outdoor environments where weather can deteriorate those types of controls. It’s also important that anyone who will be working or traveling in the immediate area of the administrative controls has a proper understanding of what they mean. This may require that those individuals receive training. The training should identify what administrative controls are and what your expectations are with regards to approaching them. Part of this is also to have a plan in place to be able to retrofit another method of fall protection if you feel it’s needed. In the example outlined above, if unexpected additional repairs are needed that push the job time to several days it may be necessary to upgrade the fall protection around the job site. In the example outlined earlier, putting up portable guard rails or Jersey barriers is an easy way to make a more robust long-term fall protection solution.
Approaching a problem the right way
Look at your hierarchy during JHA’s and talk through the reasons why you can’t implement those control methods in the order listed. Make a physical checklist to complete during hazard reviews and always keep an open dialog between key members of any project (safety manager, engineer, contractor, operations). Make your opinions clear. Lastly, try not to fall into the trap of using administrative controls as a permanent bandage. It’s tempting in a pinch, but if your facility has suitable portable passive fall protection on hand, the risk of serious injury becomes much less. Go out and take a quick inventory.
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