ISO 45001 – Hierarchy of Controls (HOC) – Should it be a Requirement?

Section 8.1.2 of ISO/DIS 45001 requires that organizations “shall establish a process and determine controls for achieving reduction in OH&S risks using the following hierarchy:

  1. occupational_health_safetyeliminate the hazard
  2. substitute with less hazardous materials, processes, operations or equipment
  3. Use engineering controls
  4. use administrative controls
  5. provide and ensure use of adequate personnel protective equipment

The US Technical Advisory Group at its recent meeting in Dallas, TX Feb 22-26, 2016 had lengthy and at time heated discussion about requiring the use of the HOC.  The basic question is should the phrase “ using the following hierarchy” be revised to soften it by saying “considering the following hierarchy”.

Many of the seasoned OH&S professionals in the group believe that the language should remain as “use” . They believe the HOC is well accepted in the industry and it is also required by law.  Others on the US TAG with experience in drafting and auditing ISO standards like ISO 14001 think the use of the HOC should be optional.  They maintain that it will be difficult during audits to prove that the HOC was used and that additional control is not possible or practical.

The standard also requires that the OH&S Policy “includes a commitment to control OH&S risks using the hierarchy of controls.

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