The Definition of Work Practice Controls

Definition of Work Practice Controls

Work practice controls are methods that reduce workers' exposure to a hazard by changing the way a task is performed. They do not change the equipment or the workplace itself. Instead, they set out specific, required ways of doing the work, such as keeping the head out of a welding plume, using wet methods when cutting concrete, or never recapping a used needle with two hands.

OSHA's bloodborne pathogens standard, 29 CFR 1910.1030, defines work practice controls as controls that reduce the likelihood of exposure by altering the manner in which a task is performed. The term appears in many other OSHA health standards, including those for lead, cadmium, asbestos and respirable crystalline silica.

Work practice controls are usually grouped with administrative controls in the hierarchy of controls. They are less reliable than elimination, substitution and engineering controls because they depend on people following them every time, but they are more protective than relying on PPE alone.

Examples of Work Practice Controls

• Healthcare: disposing of needles directly into sharps containers without recapping, using one-handed scoop techniques when recapping is unavoidable, and washing hands after removing gloves.
• Dust control: using water to wet surfaces during cutting or grinding, and cleaning with HEPA vacuums or wet methods instead of dry sweeping or compressed air.
• Lead and other metals: not eating, drinking or smoking in work areas, washing before breaks and changing out of work clothes before going home.
• Welding: positioning the body so fume rises away from the face and placing extraction hoods correctly.
• Manual handling: keeping loads close to the body, using team lifts for heavy items and using mechanical aids when provided.
• Chemicals: keeping containers closed when not in use and dispensing liquids in ways that limit splashing and vapors.
• Machine operation: following set procedures for clearing jams, including lockout/tagout where required.

Work Practice Controls in OSHA Standards

Many OSHA health standards require employers to use engineering and work practice controls as the main way to keep exposures below the permissible exposure limit, with respirators used only when those controls are not feasible or not enough. For example:

• The bloodborne pathogens standard requires engineering and work practice controls to eliminate or minimize exposure.
• The construction silica standard, 29 CFR 1926.1153, includes Table 1, which sets out specific engineering controls and work practices, such as using integrated water delivery systems, for common construction tasks.
• The lead standards require hygiene practices such as clean change areas and handwashing.

Making Work Practice Controls Work

• Write them down: include the required practice in procedures, a job hazard analysis or work instructions.
• Train and explain why: workers are more likely to follow a practice if they understand the hazard it controls.
• Make it easy: provide the tools, water supply, containers and time needed to follow the practice.
• Supervise and observe: check that practices are followed and correct drift early.
• Look for better controls: if a practice is hard to follow, look for an engineering solution that removes the need for it.

Example of Work Practice Controls

A masonry contractor cut concrete block with handheld saws. Air sampling showed respirable silica exposures above the permissible exposure limit. The contractor bought saws with integrated water delivery, an engineering control, and set work practice controls to go with them.

Workers had to check that the water flow was set as the manufacturer directed before each cut, cut outdoors when possible, stand upwind of the cutting, and clean up slurry with wet methods rather than letting it dry and sweeping it. Supervisors checked these practices during daily walks, and follow-up sampling showed exposures well below the limit.

Frequently Asked Questions: Work Practice Controls

Are work practice controls the same as administrative controls?

They are closely related and often grouped together. Work practice controls focus on how a specific task is performed, while administrative controls can also include scheduling, job rotation, signage and training.

Why are engineering controls preferred over work practice controls?

Engineering controls reduce the hazard at the source and do not rely on each worker doing the right thing every time. Work practice controls can fail when people are rushed, tired or not trained.

Can work practice controls replace PPE?

Sometimes. If work practice and engineering controls reduce exposure enough, PPE may not be needed. Otherwise, PPE is used as an additional layer.