Most safety professionals practice the hierarchy of controls: Elimination/Substitution, Engineering Controls, Administrative Controls, and LASTLY Personal Protective Equipment (PPE). But there is always this thing called “feasibility” when it came to asking for capital to install “engineering controls”. Earlier this year OSHA issued a memo discussing how they would enforce 1910.95(b)(1), which requires employers to utilize feasible administrative and engineering controls BEFORE using PPE. So clearly OSHA expects us to follow the hierarchy of controls, which have been around since the inception of industrial safety. However, OSHA received a lot of pushback about the memo and withdrew it several months later (was not sure why at the time). A few months later, late summer, OSHA revised their Technical Manual by adding an entire chapter on Noise! OUTSTANDING materials for both OSHA and safety/IH professionals to use in our hearing conservation efforts. But I digress…
In this new chapter, OSHA establishes their guidelines as to what is “feasible administrative or engineering controls”. It is actually quite detailed guidance, although I am not sure what legal implications this Technical Manual has on issuing citations against 1910.95. Here is a taste of what the manual states: