ISO 45001 Clause 8.1.2: Apply the Hierarchy of Controls

What clause 8.1.2 requires in practice

Clause 8.1.2 asks the organisation to run a working process for removing hazards and lowering OH&S risk, and to apply a fixed order of preference when choosing how. The order runs from the strongest protection to the weakest: remove the hazard altogether; replace the process, operation, material or equipment with a less hazardous one; apply engineering measures and reorganise the work; apply administrative measures, which include training; and, last, provide adequate personal protective equipment.

The clause is about a decision method that actually operates, not a form. Its output is a set of controls in use at the workplace, chosen by working down the order and explained when a stronger level was not adopted.

The standard adds a note that in many countries the law, or other requirements the organisation has accepted, expects protective equipment to be supplied to workers free of charge. Check which expectation applies where you operate.

Start by asking whether the hazard can be removed

Elimination addresses the presence of the hazard itself. Consider whether the activity, interaction or source can be removed through a different design or way of accomplishing the business need. Examining this early, before purchasing or project decisions become fixed, can reveal options that are harder to introduce later.

If elimination is not achieved, consider substitution with a less hazardous process, operation, material or equipment. A substitution needs assessment of its own effects. An alternative can reduce one exposure while introducing another, so the label “safer” needs a basis rather than being accepted as a supplier's general description.

Engineering controls and work reorganisation

The next level includes engineering controls and reorganisation of work. These can change the relationship between people and the hazard or the conditions under which exposure occurs. They need suitable design, implementation and maintenance. A physical measure that is bypassed or poorly maintained may not provide the protection assumed in the assessment.

Involve workers who understand the activity and competent technical personnel who can evaluate options. Consider the whole work cycle, including cleaning, maintenance, unusual conditions and relevant emergencies. A control selected only for normal production may leave other necessary activities insufficiently considered.

Why clause 8.1.2 matters to the business

Control choices decide whether a hazard keeps hurting people or stops existing. An organisation that defaults to instructions and equipment spends money repeatedly on training, supervision and replacement, while the exposure remains. One that looks upstream, at design, purchasing and work organisation, often finds a cheaper permanent answer and fewer interruptions to production or service. Customers and regulators also notice the difference after an incident: an investigation that finds stronger options were never considered is hard to defend. For group businesses, a shared selection logic gives sites a common language when they compare notes, and gives top management a credible reason to approve spending on design changes rather than another round of reminders.

How to implement clause 8.1.2

Treat the order of preference as a routine step inside planning and purchasing, so it is used before a control is fixed rather than reviewed afterwards. One practical route is below.

1. Take each significant hazard from your assessment and name the activity that creates it, in the words of the people who do the work.
2. Ask first whether the activity or its source can be removed or designed out, and record the answer even when it is no.
3. Where removal fails, examine substitutes and assess what new exposure each substitute brings before adopting it.
4. Consider engineering measures and changes to how work is sequenced, staffed or laid out, and involve competent technical people in judging them.
5. Use instructions, training and supervision to support, not replace, those stronger measures, and test whether workers can realistically follow them.
6. Provide protective equipment where it remains necessary, with attention to suitability, fit, maintenance and the legal expectation about supply.
7. Decide how you will confirm the control works in practice, then review it when incidents, changes or new knowledge challenge the original reasoning.

Evidence an auditor expects for clause 8.1.2

Illustrative manufacturing example: repeated manual interaction

Administrative controls and personal protective equipment

Administrative controls include measures such as instructions and training. They can be necessary, but often depend on people remembering, understanding and consistently applying a rule. Evaluate whether workload, language, time pressure or conflicting instructions could undermine them. A signature confirms acknowledgement only to the extent established by the process.

Suitable personal protective equipment is the final level in the hierarchy. Its adequacy, use and relevant support still matter where it is required. The hierarchy does not mean that equipment is unnecessary; it means stronger options must receive proper consideration rather than being bypassed because issuing equipment seems simpler.

Illustrative IT example: maintenance in an occupied office

A hypothetical IT business plans office refurbishment involving panel cutting near occupied desks. The team identifies potential exposure to dust and noise. Facilities staff, workers and the contractor first consider eliminating that on-site cutting by specifying panels prepared elsewhere, alongside options for separating affected office work from the remaining installation activity.

In this illustration, the project selects pre-cut panels after competent review of suitability and the remaining installation risks. The responsible owner checks that delivery and work methods match the approved arrangement and that on-site cutting has not quietly reappeared. Worker feedback and site observations inform follow-up. An email asking staff to take care would not remove the dust-generating activity; additional controls for residual risks still require assessment.

Verify the control rather than only its installation

Define what evidence will show the control is implemented and effective. Depending on the activity, this might involve observation, suitable monitoring, maintenance evidence and worker feedback. The method should answer the risk-control question. Counting equipment purchased or people trained may not show whether exposure was adequately addressed.

Clause 8.1.2 does not prescribe a standalone hierarchy form. Other requirements address operational information, risk assessment, competence and evaluation. Preserve enough evidence to explain the control decision and demonstrate that relevant arrangements operate. Review when incidents, changes or new knowledge challenge the original assumptions.

Common selection mistakes