It's All Under Control

“…Hierarchy? Hah, watch me as I wave my magic wand and tell you how to engineer the greatest of all engineering controls..”

Ah, the life of an IH. The many expectations, the many pressures, and the unique ability to recommend controls, sometimes on the spot. Hierarchy? Hah, watch me as I wave my magic wand and tell you how to engineer the greatest of all engineering controls (if only).

Admittedly, I’m no wicked witch of any particular coast but have often been praised for my so called “magic”, praise that I associate with my proudest success stories at work places that took the initiative and implemented my suggested recommendations with success.

One of the biggest joys of my career is the fact that work places in which I visit pick my brain and require my expertise to suggest implementation of control measures, whether simple wet methods for dust suppression, complicated enclosures for noise attenuation, or respirators as a last resort (really sorry about your beards, granite counter-top cutters). The truth of the matter is, we sometimes have to tread lightly between our suggestions that may otherwise be easy to recommend on our end, yet the feasibility in which our client can actually implement it on their end is in question. This is typically due to financial reasons, overly complex recommendations, or the dreaded “corporate won’t listen or pay for it” response that I get way too often from on-site EHS managers (I hear you, I’ve been on that end).

A recent example in which I can speak upon is a facility in which building materials (floor boards etc.) for new houses are fabricated. Imagine a facility with no hearing protection. Suddenly, you go out there, shoot your shot, do your tests, and realize, “hey..they probably need (aka they REALLY need) hearing protection.”

“..Yet, as an IH, I’m often obligated to suggest SOMETHING. But as I sit with my client at a fancy wooden conference table feeling like I'm being given the VIP treatment, I find myself theorizing complex controls..”

Let’s rewind. The position of these employees is rather unique. Without getting into detail and incriminating myself relative to my position, there are no specific control measures that make sense, or even if they do, they would be unlikely to reduce to the noise to adequate and safe levels. Yet, as an IH, I’m often obligated to suggest SOMETHING. But as I sit with my client at a fancy wooden conference table feeling like I'm being given the VIP treatment, I find myself theorizing complicated controls and dumping ideas on the table (no fancy wooden tables were harmed) and at that very time I slow down, I breathe, and I think..“no”. Does it really make sense to suggest complex control measures that are otherwise costing this company an arm and a leg (or ear drum) when all I can simply say is…“hey guys, just wear hearing protection”. Sure, don’t get me wrong, as OSHA says, try engineering/administrative controls first, and I always try to do so. But there’s a difference between feasible and realistic expectations.

And there it is…the client looks at me, and although he or she may be viewed as the “big bad safety officer” at the facility that has to implement hearing protection (glad I’m just consulting and not in-house), he or she knows it will be the easiest thing to do and more feasible than any control. They already offer adequate hearing protection as is, but try telling employees to replace their ear buds with ear plugs. Of course, what seems easy and practical to us, may not be for that same client/site manager that has never had to implement the hearing protection. Now suddenly, employees require it.

The conclusion, to all my IH friends, is that there is no right or wrong answer, necessarily. My intention is not to stir controversy or avoid control measures (on the contrary, the challenge it presents is one of my favorite aspects of being an IH) but rather to have a moment to think. Understandably, OSHA requires controls to be explored and implemented even when PPE is already used and does the job.

“Sure, I am there as a consultant and what they ultimately decide to do is on them, but I care.”

Controls are fun, Noise? Enclosure! Silica? HEPA vac and Wet methods! We make it sound easy. We should, even if it isn’t. While it all depends on our industry and clients, sometimes it does not hurt to take a step back. I will always respect the hierarchy of controls, but even when I explain “feasible” controls in a conference room to a client, there are times where I am thinking, “this is going to cost them big time” or “will they even bother with this or skip straight to the PPE”. Sure, I am there as a consultant and what they ultimately decide to do is on them, but I care. Thus, is a consultant’s conundrum. Thus, is keeping your clients happy. And, thus, is another day in the life of an IH. #positivexposure #IamIH