In my three decades as a safety professional, I've seen the devastating consequences when construction teams get hazard control wrong. I've also seen remarkable results when they get it right.
Construction sites remain among the most hazardous work environments in America. The numbers tell a sobering story: in 2023, construction had the highest number of workplace fatalities of any industry, with 1,075 deaths. That's almost three workers dying from falls every single day.
Throughout my career in project safety management and compliance auditing across industrial markets, I've watched construction managers struggle with a fundamental question: how do we actually protect our workers from these hazards? Many default to the least effective methods, handing out PPE and hoping workers follow safety rules. But the hierarchy of controls offers a better way.
In this guide, I'll share what I've learned about applying OSHA's hierarchy of controls on real construction sites, with examples from the field and practical advice that actually works.
What You'll Learn About OSHA Hierarchy of Controls
- What the OSHA hierarchy of controls is and why it matters for construction projects
- How construction managers can apply each level of control on active job sites
- Real examples from common construction hazards like falls, silica exposure, and trenching
- How to choose the most effective control for your project conditions
- Mistakes to avoid when implementing controls
- When temporary or outsourced safety support can help fill gaps in hazard control
- Tools and checklists to strengthen your hazard control decisions
What the OSHA Hierarchy of Controls Is
The hierarchy of controls is a systematic approach for managing and reducing workplace hazards. Endorsed by OSHA and the National Institute for Occupational Safety and Health, it prioritizes hazard prevention methods in a structured order, starting with the most effective solutions.
According to OSHA's recommended practices, the hierarchy consists of five levels:
- Elimination - Physically removing the hazard
- Substitution - Replacing the hazard with a safer alternative
- Engineering Controls - Isolating people from the hazard through equipment or design
- Administrative Controls - Changing the way people work through procedures and policies
- Personal Protective Equipment (PPE) - Equipment worn to minimize exposure to hazards
The hierarchy works from most effective (elimination) to least effective (PPE). At the top, a worker doesn't need to play an active role to stay safe. Further down the hierarchy, the worker becomes more responsible for their own protection, which is why these controls are considered less reliable.
What I've learned over the years is that OSHA expects employers to select controls according to this hierarchy, choosing engineering solutions first, followed by safe work practices and administrative controls, and finally personal protective equipment. When used together, multiple controls from different levels often provide the best protection.
Why the Hierarchy of Controls Matters in Construction
Let me be direct: the construction industry has a serious problem. The data I review every year confirms what I see in the field. Private construction firm workers accounted for nearly 20% of all workplace deaths in 2022, despite representing only 7.5% of employment. Falls, slips, and trips alone accounted for 39.2% of all construction fatalities.
Here's what keeps me up at night: most of these deaths are preventable with proper hazard controls.
Under OSHA's General Duty Clause, employers have a legal responsibility to provide employees "a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm." This isn't optional. Taking a systematic approach to hazard control doesn't just protect workers from harm, it also safeguards your business from the legal and financial consequences of accidents.
Through my work with contractors across Louisiana and the Gulf Coast, I've seen how the hierarchy of controls matters for several critical reasons:
Owner Requirements: Major project owners increasingly require contractors to demonstrate proactive hazard management. They want to see evidence that you're using the most effective controls available, not just PPE and safety rules. In my consulting practice, I've watched contractors lose bids because they couldn't demonstrate adequate hazard control strategies.
OSHA Enforcement: As I learned during my time serving on safety committees and working with OSHA officials, inspectors evaluate whether you've implemented feasible higher-level controls. Relying solely on administrative controls or PPE when better options exist can result in citations, even if workers are using the required PPE properly.
EMR and TRIR Impact: Your Experience Modification Rate and Total Recordable Incident Rate directly affect your ability to bid on projects. I've helped numerous clients improve these metrics through effective hazard controls, which makes them more competitive in the marketplace.
Project Efficiency: Here's something many construction managers don't realize: higher-level controls like elimination and engineering solutions often improve productivity. They don't slow down work or depend on individual compliance. Workers can focus on the task instead of managing their own protection.
How I Apply the Hierarchy on Construction Sites
Over the years, I've developed a systematic process that works in the real world. Here's the workflow I use with my clients:
Start with Job Hazard Analysis: Before work begins, I conduct thorough hazard assessments with the project team. We identify what could go wrong, who could be injured, and under what circumstances. I always involve supervisors, competent persons, and experienced workers. The best insights often come from the crews doing the work.
Identify Feasible Controls at Each Level: For each hazard, we brainstorm controls starting at the top of the hierarchy. I ask: Can we eliminate this hazard entirely? If not, can we substitute something safer? What engineering controls are available? Only after exploring higher-level controls do we consider administrative measures and PPE.
Evaluate and Document Feasibility: According to OSHA, a control is feasible if it can protect workers and can be implemented successfully. I help construction managers evaluate technical possibility, economic reasonableness, and project appropriateness. I always insist on documenting this evaluation. This documentation has saved my clients from OSHA citations more times than I can count.
Monitor Effectiveness: After implementing controls, I conduct regular inspections to verify they're working as intended. Engineering controls must be maintained, administrative procedures must be followed, and PPE must be used correctly when needed.
Real Construction Examples from My Experience
Understanding the hierarchy in theory is one thing. Applying it to actual construction hazards is another. Let me share real-world examples from projects I've worked on that show how each level works in practice.
Elimination: Silica Exposure
I worked with a concrete contractor who was requiring workers to wear respirators while dry cutting concrete, generating dangerous silica dust. Instead, I helped them redesign their process to specify precast concrete components that arrived pre-cut to size, eliminating cutting operations on site entirely. The hazard simply disappeared. No respirator fit testing, no equipment maintenance, no reliance on worker compliance. According to NIOSH, elimination is the preferred solution because no exposure can occur.
Substitution: Fall Hazards During Steel Erection
On a structural steel project, workers were accessing high elevations using ladders and lifts, requiring personal fall arrest systems on every worker. I recommended installing prefabricated stair towers early in the project, providing inherently safe access to upper levels. The stair tower replaced the hazardous access method without requiring individual workers to manage their own fall protection.
Engineering Controls: Fall Protection at Roof Edges
I've reviewed too many projects where contractors established warning line systems that depended on workers staying away from roof edges. This rarely works. I always recommend installing guardrail systems at all roof perimeter edges before workers begin roof activities. Guardrails provide passive protection whether or not workers take any action. The system doesn't rely on individual behavior, training compliance, or vigilance.
Engineering Controls: Trench Protection
I once arrived at a site where workers were entering trenches deeper than five feet with only training on watching for soil instability. This is incredibly dangerous. I immediately stopped work and brought in trench boxes and aluminum hydraulic shoring to create a protective barrier. The protective system physically prevents soil from reaching workers if a cave-in occurs, providing reliable protection independent of worker actions.
Administrative Controls: Heat Illness Prevention
On Gulf Coast construction projects, heat illness is a constant concern. Rather than relying on workers to take breaks when they feel overheated, I implement scheduled work-rest cycles based on temperature and workload. For example, in temperatures above 95°F, I mandate 15-minute rest breaks every hour in shaded areas. This removes the decision-making burden from individual workers and creates accountability for supervisors to enforce breaks.
PPE: Electrical Arc Flash
When electricians must perform energized work that could produce an arc flash, and engineering controls like de-energizing equipment are deemed infeasible, I specify arc-rated clothing, face shields, and insulated gloves rated for the voltage level. PPE provides a final barrier when higher-level controls cannot eliminate or adequately reduce the hazard. However, it requires proper selection, maintenance, and consistent use to be effective, making it inherently less reliable than higher-level controls.
Common Mistakes I See Construction Teams Make
After conducting hundreds of safety audits and working with contractors across multiple industries, I've seen the same mistakes repeated over and over. Recognizing these errors has helped me guide my clients toward better practices:
Choosing PPE First: This is the most common mistake I encounter. Construction managers jump straight to PPE without considering whether the hazard could be eliminated or controlled through better means. I always remind them: PPE should never be your first choice unless higher-level controls are truly infeasible.
Not Reassessing Controls as Projects Change: I've watched projects where the control strategy worked perfectly during rough framing but completely failed during finish work. Your control strategy needs to evolve with the project. Failing to reassess hazards and controls as phases change leaves workers unprotected.
Subcontractors Working Outside the Control Strategy: This drives me crazy. General contractors establish effective controls for their own crews but fail to enforce the same standards with subcontractors. I insist that all trades follow the project's hazard control plan, and I help my clients build this requirement into their contracts.
Failing to Document Administrative Controls: When you rely on administrative controls, documentation is essential. I've seen contractors get cited by OSHA because they couldn't prove their procedures were actually being followed. Procedures must be written, training must be documented, and enforcement must be recorded.
Treating Training as a Control: Training is essential for workplace safety, but it's not a control measure by itself. I explain to my clients that training supports controls by teaching workers how to implement them, but you can't mistake training for an actual hazard control.
Ignoring Maintenance of Engineering Controls: Engineering controls only work if they're properly maintained. I've seen guardrails with missing midrails, ventilation systems that aren't operating, and machine guards that have been removed. When I find these conditions during inspections, I know the entire safety program is at risk.
Why Staffing Gaps Stop the Hierarchy from Working
Understanding the hierarchy of controls is one thing. Having the resources to implement it consistently is another. Throughout my career, I've seen how staffing and expertise gaps undermine even the best safety intentions.
Many construction projects struggle to apply the hierarchy effectively because they lack adequate safety expertise or staffing. Here's what I observe regularly:
Undermanned Supervisory Teams: When supervisors are stretched thin across multiple job sites or manage too many workers, they simply cannot effectively monitor hazard controls. I've been called to projects where one supervisor was responsible for three different sites. The result? Controls were being bypassed because no one had time to enforce them.
No Onsite Safety Lead: Projects without a dedicated safety professional often default to the easiest controls rather than the most effective ones. Without someone specifically responsible for hazard control evaluation, teams take shortcuts. This is where my construction safety management services make the biggest difference.
Lack of Specialist Knowledge: Certain high-hazard activities require specialized expertise. For example, implementing proper controls for excavation, confined space entry, or crane operations requires technical knowledge that typical site supervision may not possess. With my background across petrochemical, oil and gas, and construction industries, I bring this specialist knowledge to projects that need it.
Poor Oversight of Subcontractors: Coordinating hazard controls across multiple subcontractors requires dedicated attention. When no one owns this responsibility, each trade implements their own approach, creating gaps and inconsistencies.
This is where our safety consulting services provide real value. As a Certified Safety Professional with experience since 1996, I can offer several advantages:
- Expertise in Control Selection: I understand how to evaluate feasibility of different controls and document the rationale for control selection in ways that satisfy OSHA requirements.
- Implementation Support: I can specify the right equipment, develop procedures, train workers, and verify controls are functioning properly.
- Subcontractor Coordination: A dedicated safety professional ensures all trades follow consistent hazard control standards.
- Continuous Monitoring: I conduct regular inspections to verify controls remain effective throughout the project lifecycle.
- Regulatory Compliance: As someone who has worked with OSHA officials and served in safety leadership roles, I stay current on requirements and can ensure your control strategies meet regulatory expectations.
For more information on when bringing in additional safety support makes sense, see our guide on when general contractors should hire a safety consultant.
Tools and Resources I Recommend
Implementing the hierarchy of controls effectively requires practical tools. Here are resources I use with my clients:
Job Hazard Analysis Template: A structured form for identifying hazards and evaluating control options at each level of the hierarchy, with columns for the task, identified hazards, current controls, and recommended improvements.
Hazard Control Selection Checklist: A decision-making tool that walks through feasibility questions for each level of control, helping document why higher-level controls were or were not selected.
Daily Safety Briefing Prompts: Questions for toolbox talks that reinforce hazard awareness and verify controls are in place, such as "What are the fall hazards for today's work?" and "Are guardrails installed where needed?"
For comprehensive support in developing and implementing these tools on your projects, consider our construction safety management services. We help construction teams build robust hazard control programs that protect workers and meet regulatory requirements.
FAQ Section
What is the purpose of the OSHA hierarchy of controls?
The hierarchy provides a framework for selecting the most effective ways to eliminate or reduce workplace hazards. It prioritizes solutions that provide inherent protection (elimination and engineering controls) over those that depend on individual worker behavior (administrative controls and PPE). OSHA uses this framework to guide employers in making sound worker protection decisions.
Is PPE acceptable if higher level controls are too expensive?
Cost alone doesn't justify using a less effective control. OSHA requires employers to implement feasible controls, meaning controls that are both technically capable of reducing the hazard and economically reasonable. However, "economically reasonable" is evaluated in the context of your industry. If competitors successfully use higher-level controls, OSHA may expect you to do the same. Always document why higher-level controls aren't feasible.
What are examples of engineering controls in construction?
Engineering controls in construction include guardrail systems at roof edges, trench boxes and shoring for excavation protection, machine guards on power tools, local exhaust ventilation for dust control, and safety nets for fall protection. These controls physically prevent workers from being exposed to hazards.
How does a construction manager choose between administrative and engineering controls?
Always implement engineering controls first. They provide more reliable protection because they don't depend on workers remembering procedures or following rules. Choose administrative controls only when engineering controls aren't feasible or as a supplement. For example, use both guardrails (engineering) and job site rules about working near edges (administrative) for comprehensive fall protection.
Does OSHA require elimination or substitution whenever possible?
While OSHA doesn't explicitly require elimination or substitution in most standards, the General Duty Clause requires employers to provide a workplace "free from recognized hazards." When elimination or substitution is feasible and would significantly reduce risk, OSHA expects employers to implement these controls.
How do I know if I need a safety professional to help with control implementation?
Consider bringing in a safety consultant when you're starting high-hazard operations you haven't performed before, when your team lacks expertise in evaluating control options, when facing complex regulatory requirements, or when coordinating controls across multiple subcontractors. Professional support is particularly valuable during project planning when you can most easily implement elimination and substitution controls.
Do subcontractors have to follow the same hierarchy of controls as GC employees?
Yes. OSHA holds general contractors responsible for coordinating safety on multi-employer worksites, including ensuring all contractors use appropriate hazard controls. Your contract documents and pre-construction meetings should specify control requirements. For help coordinating subcontractor safety, explore our custom safety management services.
Conclusion:
After working in safety since 1996, I can tell you that the OSHA hierarchy of controls provides the most effective framework I've found for protecting construction workers from serious hazards. By systematically evaluating hazards and selecting controls from the top of the hierarchy down, you implement more effective protection while often improving project efficiency.
The key is making this evaluation process routine. Don't default to PPE and safety rules when better controls exist. Ask whether you can eliminate hazards during planning, substitute safer materials or methods, or implement engineering solutions that provide inherent protection. When you do this consistently, you build a safety program that actually prevents incidents rather than just responding to them.
Through my work at SafetyPro Resources, I've helped countless construction teams implement these principles successfully. If you need help evaluating hazards, selecting appropriate controls, or implementing them on your projects, I can provide the expertise and support you need. My team understands construction operations and can help you develop practical hazard control strategies that protect your workers and satisfy regulatory requirements.
Ready to strengthen your hazard control program? Schedule a free consultation with me to discuss your specific challenges and how we can help you implement the hierarchy of controls effectively on your projects.
Lance Roux is the founder and principal consultant at SafetyPro Resources, LLC. He is a Certified Safety Professional (CSP) with nearly three decades of experience in project safety management, compliance auditing, and program development across industrial markets including construction, oil and gas, chemical processing, and refineries.
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