Enhancing Administrative and PPE Controls with Engineered Reliability

When we think about the Hierarchy of Control, administrative controls and personal protective equipment (PPE) are often considered the weakest. They are labelled “low-order” controls because they rely heavily on people doing the right thing every time—following procedures, wearing the right gear, and remembering to complete inspections or tasks.

But does that mean they have to be weak or ineffective? Absolutely not. With the right engineering solutions, you can build consistency, accountability, and reliability into even the lowest-order controls.

The Problem with Administrative and PPE Controls

Administrative controls and PPE are often criticised for their dependency on human behaviour. This reliance leads to inconsistencies and vulnerabilities caused by factors such as:

• Fatigue

• Distraction

• Forgetfulness

• Motivation

• Knowledge and skill

By their nature, administrative controls and PPE do not eliminate hazards or provide physical barriers. Instead, they rely on people to do the right thing, every time. This is particularly problematic for high-risk activities, where failure can result in serious harm or fatality.

Enhancing Reliability with Engineering

Engineering solutions aren’t limited to elimination, substitution, or isolation controls. They can be applied to enhance the effectiveness of administrative controls and PPE by introducing automated systems, monitoring technologies, and fail-safe mechanisms.

Here are some practical examples:

1. Personal Protective Equipment (PPE)

While PPE is traditionally seen as the last line of defence, engineering solutions can make it far more reliable:

• Maintenance Management Systems (MMS): Automating inspection or replacement schedules through an MMS ensures work orders are generated and tracked. Missed inspections or replacements are flagged automatically, providing clear accountability.

• Smart PPE Systems: Wearable technology such as RFID-tagged helmets, smart gloves, or wearable sensors can detect when PPE is not being worn in restricted areas or when workers enter hazardous zones without the proper protection.

• Purchasing Systems: Tracking PPE usage patterns, ensuring the purchasing system has automatic re-ordering when stocks are low.

These measures help bridge the gap between expecting compliance and ensuring compliance.

2. Training and Competency (Administrative Control)

Training is essential, but relying on training records or manual competency checks is risky. Instead, consider:

• Access Control Systems: Installing interlocks or access control devices that only permit trained and competent personnel to enter areas or operate machinery. If their training is not current, access is denied. No exceptions, no human error.

• Digital Competency Tracking: Systems that automatically update training records and provide real-time alerts when certifications are about to expire.

• Real-Time Data Provided to Supervisors: Supervisors who are assigning high-risk tasks have access to real-time competency data to ensure that their resources are adequately licenced, authorised and competent.

Engineering solutions like these remove the opportunity for human error, making the control itself more reliable.

3. Inspections and Audits (Administrative Control)

Inspections and audits are critical for maintaining safety and compliance. However, they are often prone to being missed, forgotten, inaccurately recorded or don't trigger an adequate or timely response. Solutions include:

• Maintenance Management Systems (MMS): Automating inspection schedules through an MMS ensures work orders are generated and tracked. Missed inspections are flagged automatically, providing clear accountability.

• Digital Checklists: Using tablets or smartphones to complete inspections with automated data uploads, removing the risk of lost paperwork or illegible handwriting.

• Integrated Management Systems: Systems that automatically activate a Trigger Response Plan (TARP) immediately after the inspection has been recorded.

• Integrated Reporting Systems: Systems that generate reports instantly and highlight trends or recurring issues, making ongoing improvement easier.

4. Signage or Barrier Tape (Administrative Control)

Sometimes signage and/or barrier tape are the only control used to warn of hazards and hope that workers can read and understand the instruction. Here are some solutions to making these controls more reliable:

• Motion Detection and Alarm Systems: If the signage or barrier tape are "protecting" workers from a temporary, high-consequence risk, consider alarming the area so that workers are warned that they have entered into a danger zone.

Why Engineering Solutions Work

Applying engineering to enhance administrative and PPE controls is about building layers of reliability. It transforms lower-order controls from “hoping people do the right thing” to “designing systems where failure is much less likely.”

Incorporating engineering into these areas also provides:

• Better accountability through automated tracking and reporting.

• Improved consistency by eliminating reliance on memory or individual discretion.

• Data-driven insights that help identify weaknesses and improve processes over time.

Administrative and PPE Controls Don't Have to Be an Unavoidable Weakness

Despite the clear benefits, many organisations continue to treat administrative controls and PPE as unavoidable weaknesses rather than opportunities for improvement. But with the right approach, these controls can be significantly strengthened.

Instead of accepting that administrative controls and PPE are “low order,” why not use engineering solutions to make them reliable and effective?

Final Thoughts

Engineering solutions are not just for eliminating hazards or building physical barriers. They can be just as effective for enhancing the reliability of administrative controls and PPE. By integrating technology and automation, organisations can ensure these controls work consistently, accurately, and without fail.

Accept the Challenge - Enhancing Administrative and PPE Controls with Engineered Reliability

Next time you review your risk registers or risk assessments, challenge your administrative and PPE controls. If you can't implement higher-order controls, think about the solutions that would make the administrative and PPE controls more effective.