The Hierarchy of Controls
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The hierarchy of controls is the order in which you must consider ways to control a risk, set out in reg 36 of the WHS Regulations. From most to least effective: eliminate the hazard, substitute it with something safer, isolate people from it, use engineering controls, use administrative controls, and use personal protective equipment last. You must work from the top down and only rely on lower controls when higher ones are not reasonably practicable. PPE alone is almost never an acceptable primary control.
The six levels, most to least effective
- ✓ Eliminate: remove the hazard completely, for example do the work at ground level so there is no fall risk
- ✓ Substitute: replace it with something less hazardous, for example a less toxic product
- ✓ Isolate: separate people from the hazard, for example barriers around an excavation or a locked-out circuit
- ✓ Engineering controls: physical changes such as guard rails, ventilation, or a tool with on-board dust extraction
- ✓ Administrative controls: procedures, training, signage, permits, and safe work method statements
- ✓ Personal protective equipment: gloves, glasses, hearing protection, respirators, worn as the last line
Why the order matters
The higher controls remove or reduce the hazard for everyone, all the time, without depending on a person doing the right thing in the moment. PPE only protects the person wearing it, only if it is worn correctly, and does nothing to the hazard itself. That is why a SWMS that jumps straight to "wear gloves and glasses" where isolation or an engineering control was practicable gets knocked back: it skipped the levels that actually work.
How the hierarchy drives a SWMS
Every control in a Safe Work Method Statement should be written in hierarchy order, and a reviewer checks for exactly this. For each hazard, the SWMS should show the highest-order control that is reasonably practicable, with PPE listed as a backstop rather than the main defence. SWMS Pack generates controls in this order automatically and an adversarial review pass rejects any draft that offers PPE where a higher control belonged.
Common questions
▸What is the most effective control in the hierarchy?
Elimination: physically removing the hazard so the risk is gone. If you can design the work so the hazard never exists, no other control is needed.
▸Why is PPE the last resort?
PPE only protects the individual wearing it, depends on correct use every time, and leaves the hazard in place. It is a backstop for the risk that higher controls could not remove, not a first choice.
▸Is the hierarchy of controls a legal requirement?
Yes. Reg 36 of the WHS Regulations requires duty holders to work through the hierarchy when deciding how to control a risk, using higher-order controls so far as is reasonably practicable.
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