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Engineering Controls

Definition

Engineering controls eliminate or reduce exposure to a chemical or physical hazard through the use or substitution of engineered machinery or equipment. Examples include self-capping syringe needles, ventilation systems such as a fume hood, sound-dampening materials to reduce noise levels, safety interlocks, and radiation shielding.

Additional Info

When substitution of hazardous chemicals or processes is simply not possible, additional measures to control employee exposure need to be taken.

While personal protective equipment (PPE) such as respirators can help protect an individual from a hazardous material, engineering controls protect all workers by reducing or eliminating the hazard. For example, someone who is spray-painting can wear a respirator to avoid inhaling toxic fumes, but nearby workers without any respiratory protection will be exposed. Through the use of proper local exhaust ventilation everyone can be protected.

In fact, the OSHA standard on Air Contaminants, 29 CFR 1910.1000, requires the use of either engineering or administrative controls if any such controls are feasible:

"...administrative or engineering controls must first be determined and implemented whenever feasible. When such controls are not feasible to achieve full compliance, protective equipment or any other protective measures shall be used to keep the exposure of employees to air contaminants within the limits prescribed in this section. Any equipment and/or technical measures used for this purpose must be approved for each particular use by a competent industrial hygienist or other technically qualified person. Whenever respirators are used, their use shall comply with 1910.134.

Note: In certain circumstances, administrative controls can be successful in controlling employee exposure to contaminants; e.g., maintenance operations involving toxic substances can sometimes be performed at night in the absence of the usual production staff (but not to comply with the PEL of OSHA-regulated carcinogens).

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This does not mean that engineering and other types of controls (including PPE) are mutually exclusive. Employers may need to use multiple types of controls to prevent employee overexposure. Also note that the degree to which engineering controls are required depends on the particular standard. For example, 29 CFR 1910.95(b)(1) Occupational Noise Exposure, allows employers to rely on personal protective equipment (PPE) and a hearing conservation program rather than engineering and/or administrative controls if hearing protectors will effectively reduce the noise hazard to acceptable levels.

OSHA considers economic feasibility to be a major issue with engineering controls. Requirements that would threaten the economic viability of an entire industry cannot be considered economically feasible under the OSH Act. OSHA may permit PPE in lieu of engineering controls (at least until engineering controls become a less significant burden for the company) when all of the following apply:

  1. If significant reconstruction of a single establishment involving a capital expenditure which would seriously jeopardize the financial condition of the company is the only method whereby the employer could achieve effective engineering controls;
  2. If there are no feasible administrative or work practice controls; and
  3. If adequate personal protective equipment or devices are available.

When employers complain that implementation of engineering controls will present an unbearable economic burden, they must present evidence that addresses the reasonableness of the estimated costs of engineering or administrative controls. This includes installation, maintenance, and lost productivity, as well as their progress compared to their industry peers. The evidence may also include the relative costs of engineering or administrative controls versus PPE.

In those limited situations where there are no feasible engineering or administrative controls, full abatement can be allowed by PPE.

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Entry last updated: Monday, February 3, 2020. This page is copyright 2000-2020 by ILPI. Unauthorized duplication or posting on other web sites is expressly prohibited. Send suggestions, comments, and new entry desires (include the URL if applicable) to us by email.

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