1. Hierarchy of Controls
A hazard control system is an organized set of measures or methods applied to eliminate or minimize exposure to hazards. For work-related driving, it's the steps that people in your organization take to prevent crashes. Such a system can include equipment and tools, work practices and safe work procedures, and safety meetings and training – all aimed at controlling driver exposure to hazards.
When it comes to deciding which measures to apply, there may be several options available. How do you know which ones will control exposure? Which ones will work best to minimize risks? It is helpful to use a systematic approach to prioritize possible actions. One common approach is the Hierarchy of Controls (see image below).
This framework ranks control measures based on their effectiveness and sustainability, and by how much supervision and individual driver effort is required to apply the control.
Elimination is simply removing the hazard from the workplace. Eliminating a hazard is clearly the most effective and sustainable way of dealing with it. Whether the hazard is a faulty brake system, an unacceptable driving practice or a distracting smart phone, once you eliminate it from the workplace, it cannot generate a risk. The administrative or supervisory efforts attached to that hazard also become zero.
Substitution involves replacing a hazardous condition or process with one that has no associated hazards, or has hazards that pose lower risks. Replace worn out tires with new ones. Rather than using 15-passenger vans with inherent instability problems, proactive employers have switched to buses to transport employees. There are still hazards associated with transporting those workers, but substituting a more stable vehicle lowers the risk of injury due to a crash caused by vehicle instability.
Engineering controls do not directly eliminate the hazard. Instead, they reduce risks by separating or isolating the driver from exposure to the hazard. Examples include physical barriers between the driver and passenger compartments that protect taxi drivers from an attack by a passenger, divided highways that isolate motorists from the risk of colliding with oncoming vehicles, and vehicle safety features such anti-lock braking systems, back-up cameras and lane departure warning systems.
Administrative controls are the policies, operating procedures, rules and practices that describe the way driving is done at your workplace. A policy that simply prohibits cell phone use while driving does not remove the source of the hazard - drivers will still carry their phone and possibly use it while driving. By adding a procedure that describes how and when a driver can use their smart phone (i.e. when safely parked), drivers get a clearer picture of what is required of them to avoid that hazard. An effective check-in procedure does not eliminate the risk that a driver will be stranded after running out of gas in an area with no cell phone coverage. However, it reduces the potential severity of the consequences – once they miss their check-in call, administrative measures are in place to ensure that help is on its way.
Personal Protective Equipment (PPE) is the least effective type of control. This is particularly true for driving because there aren’t any true PPE items for driving-related hazards. Seatbelts, airbags and other in-car safety features surely protect vehicle occupants, but they are engineering controls. Personal gear that can assist drivers includes sunglasses to minimize glare and prevent eye fatigue, footwear that improves one’s ability to operate the pedals, or gloves that ensure a firm grip on the steering wheel.
2. Applying the Framework
Apply the framework from the top down - eliminating the hazard is always your best choice. Substituting a less hazardous condition or process is the second most effective type of control, and so on through the hierarchy. PPE is the least effective type of control, so it is the last place you look for solutions.
Sometimes, you will be able to eliminate a driving-related hazard in a single step. Looking through your road hazard inventory, several of the vehicle hazards fit into this category. If the vehicle has a cracked windshield or faulty brake lights, simply eliminate those hazards by making necessary repairs. If your employees can’t safely complete driving requirements of their job because of equipment that is not up to its intended tasks, eliminate those hazards by getting the right equipment.
More often, driving hazards involve dynamic external factors that an individual driver or employer can’t really control - like other drivers, foul weather and changing road conditions. However, employers can control whether their employees drive during foul road conditions. Drivers can control how they drive and how they respond to difficult traffic conditions. It’s tough to eliminate some driving hazards, but there are plenty of measures and combinations of measures available to control exposure to hazards, and factors that contribute to crashes.
The questions below should prompt you on possible controls you can implement to address hazards. Working with your road safety team, refer to your road hazard inventory and choose a few priority hazards. For each one, ask the following questions.
- How can we eliminate this hazard? What can we do to make sure our employees don’t encounter this hazard? Is this trip necessary? If it is, can we use a safer means of transit, perhaps a bus or plane? Is the vehicle road-worthy?
- Can we use substitution to reduce the risks? Can we use a driver with specific training or proven skills for these driving circumstances? Is this the right vehicle for this application? What equipment will make this safer? Can we use a different route or schedule to reduce traffic and road condition risks?
- Can we re-design our work processes to minimize risks caused by driving-related hazards? Can we reduce the amount of driving our employees do? What vehicles safety features are available to isolate or protect drivers if they have a crash?
- What well-targeted training can we provide to our employees to make sure they have the right skills and behaviours when they are driving for work? What specific tools, resources and motivation can we provide to help drivers manage hazards? Are our safe driving procedures effective? Do our drivers know and follow them?
- If we can’t prevent exposure to the hazard and there is no true driving PPE, what personal gear might help?
Example One - Hazard: collision due to employee speeding
Almost all vehicles can exceed speed limits. Speed-limiting Intelligent Speed Adaptation devices might help when they are available, but it is nearly impossible to eliminate the risk that your employee might drive faster than they should, and that speed could contribute to a crash. Certainly, if you know an employee is a chronic speeder, you should not assign them any duties that include driving. Use an employee that has the driving behaviours you need. You also have to ask the question: What motivates our employees to drive faster than they should?
If speeding occurs because employees think their supervisor wants them to get the job done more quickly and speeding will help with that, or if they think “management doesn’t care if I speed”, new policies and practices (administrative controls) can help make necessary corrections to your company culture. Changing employee perceptions will reduce road safety risks.
Some of the practical measures you might employ to control speeding hazards involve a combination of administrative and engineering controls. For example, you can educate drivers about the risks and potential consequences of speeding, adopt rules that prohibit speeding, implement procedures for optimal route selection and scheduling, equip vehicles with GPS devices that actively monitor vehicle speed, and support those with a consistent discipline policy.
Example Two - Hazard: collision associated with poor driver visibility in foggy conditions
Driving environments are dynamic. Even with the most thorough risk management procedures, your drivers can encounter unexpected hazards. The company might have robust procedures designed to prevent employees from driving in dangerous foggy conditions. Your drivers understand and follow it. However, even though they diligently check road and weather conditions and plan accordingly, there is still some risk they will experience foggy conditions. It’s helpful to have a series of supporting controls that will help drivers deal with those circumstances.
- Elimination – Make sure each driver knows he or she is responsible to make sound driving decisions. Provide drivers with decision criteria so they know when conditions are too risky, and know how to safely suspend driving until the fog has lifted and good visibility returns.
- Substitution – Have a Plan B. Identify and use a different route that is sure to avoid the dense fog, or has lane and roadside markers that enhance visibility during light fog conditions.
- Engineering – Choose vehicles that are visible (colour, head light / tail light arrangement, reflectors). If drivers regularly encounter fog, equip vehicles with fog lights. Make sure start of shift inspections include cleaning the windshield inside and out. Are there windshield treatments that provide superior visibility?
- Administrative – Implement a safe work procedure for foggy conditions. Include guidance on how to avoid severe fog. Identify preferred (lower risk) routes. Train drivers with necessary decision-making and driving skills. Have tailgate meetings to discuss tips on lane positioning, adjusting following distance, speed selection, etc.
- There is really no PPE to use here.
Example Three - Hazard: driver not familiar with vehicle operating procedures
ABC Bus Company just took delivery of their first LE5000 low-emission bus. The manufacturer assures ABC that many of the features on the LE5000 are the same as on the older buses ABC operates, but says there are several important differences. Tom is one of ABC’s senior drivers. Having proven his skills on other ABC buses, Tom will be assigned an LE5000. He is excited to drive it on his usual route on Monday. Unfortunately, the manufacturer provides almost no product orientation or support. It looks like Tom may have to learn about those important differences on his own.
- Elimination – Tom’s supervisor can’t authorize Tom to operate the new bus until Tom has been oriented on procedures to operate the new bus, and demonstrated his abilities to his supervisor. There might be other hazards that cause Tom to be involved in a collision, but once Tom is familiar with new features on the LE5000, there is far less risk such a crash will be the result of a knowledge gap.
- Substitution – Until Tom is familiar with the LE5000, allowing him to operate the LE5000 on a “safer” route or with fewer passengers won’t lower the risk to an acceptable level. The substitution available is to use the old bus until Tom and his supervisor are confident Tom is ready.
- Engineering controls – The new bus is equipped with an on-board systems that monitors bus functions and alerts the driver to potential collision risks plus an adaptive collision avoidance system. These features can be very effective - once the driver understands how they work.
- Administrative controls – To guard against future training shortfalls, ABC’s bus purchasing policy should stipulate that the vendor must be able to provide training to company supervisors and drivers. If it doesn’t already, the ABC procedure should require that supervisors assign only suitably oriented and trained drivers to new buses, and describe the process to orient drivers and confirm competency.
- PPE – There are no practical PPE options available to protect Tom, or his passengers.