Eliminate hazards at the design stage.  What does that mean?

Dr John F. Culvenor

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Introduction:

To “eliminate hazards at the design stage” is one of the priorities set out by the National Occupational Health and Safety Commission (2002).  The National Occupational Health and Safety Strategy states that the ‘responsibility to eliminate hazards or control risk rests at its source.  This principle applies to all sources of hazards.  Responsibility falls on a wide range of parties, including those outside of the workplace such as designers, manufacturers, constructors or suppliers (p. 9).  The parties that make design decisions that affect workplaces are very diverse.  They include members of the design community such as engineers and architects and a much larger group of all others who influence decision-making. 

Our workplace laws pivot on the notion of hazard elimination at the source.  An example is the Occupational Health and Safety Regulation 2001 (NSW).  When determining controls for hazards the following approach is required (clause 5): 1. elimination; 2. substitution; 3. isolation; 4. engineering; 5. administration; and lastly 6. personal protective equipment.

In the workplace this problem-solving model often creates a conundrum.  Most employers put hazards in place to achieve a particular function.  Often they are integrated within activities.  Their “elimination” is easily seen as counter-productive and disruptive.  On the other hand, when equipment, structures, processes and so on are being devised, there are greater opportunities for conceptual changes.  “Safe design” is sometimes used as shorthand for this work.  Safe design is often the best way, and sometimes the only way, to achieve the intent of the workplace safety legislation.

In product and public safety these are not new considerations.  They rest on well-known principles.  Those making a product or public space need to protect the public from harm.  Those they either harm or protect by their decisions are downstream.  Sometimes the affected people will be close by, but sometimes far away.  Sometimes they will be known to the decision maker but often not.  Sometimes the parties will have a contractual relationship.  Other times several steps will remove them.  What is sought in occupational safety is nothing particularly different.  Safe design is about decisions that impact positively on safety downstream.  The decision-maker might have no direct relationship with the people affected downstream. 

It was made plain even 30 years ago by the Robens committee that this kind of work was vital in order to prevent workplace accidents.  The Robens Committee wrote: “… [existing] legislation places many obligations upon employers in respect of their use of plant, machinery and equipment; but very few on those who design and manufacture the equipment.  This may be thought surprising in view of the generally accepted proposition that the first step in the promotion of safety and health at work is to ensure, so far as may be practicable, that plant, machinery, equipment and materials are do designed and constructed as to be intrinsically safe in use.’ (Committee on Health and Safety at Work 1972, p. iii).

Full Reference:

Culvenor, J. 2003, ‘Eliminate hazards at the design stage.  What does that mean?’, Safety in Australia, vol. 25, no. 3, pp. 19-27.

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