Not A Replacement

OSHA offers a great e-mail feature that provides a workplace safety tip in your e-mail on a daily basis. Today’s tip was a solid reminder that while masks can help prevent spread of COVID, they are not a substitute for physical distancing and barriers.


Personal protective equipment (PPE), whether masks for COVID or hearing protection in noisy areas, is considered the last line of defense in protection of employees. Employers should attempt to use engineering controls or administrative controls to reduce or mitigate risks before relying on PPE to protect an employee.

Engineering controls involve changes to the physical workspace that change how a task is performed. When possible, engineering controls are the preferred over administrative controls because they help to mitigate risks at the source.

  • Engineering controls for COVID include physical barriers between workstations, changes to air filtration, inclusion of decontamination stations, installing drive through windows, installing contactless payment kiosks, etc.
  • Engineering controls for non-COVID related issues may include reducing the weight of objects, the use of assistive devices to handle materials, or machine guards.

Administrative controls involve changes in policies, procedures, and practices to reduce risks. Administrative controls rely on changing workers behaviors in a task and are not as effective as engineering controls.

  • Administrative controls for COVID include encouraging sick employees to stay home, use of Zoom meetings over face to face meetings, and establishing alternating workday cohort schedules.
  • Administrative controls for non-COVID related issues may include job rotation schedules, written operating procedures for a task, warning signs and alarms, etc.

With non-COVID related issues, the first steps are to identify the hazards and risks so that a decision can be made as to what engineering controls or administrative controls can be put into place. One of the job description projects that we had performed helped to expedite the purchase of an engineering control solution for a client.

County Weights and Measures personnel are responsible for testing the accuracy of pumps at gas stations and typically have performed this task using calibrated 5 gallon tanks that are filled at the pump and then poured back into the fuel storage tanks after measurement. This can be a dangerous task as it relies on drivers noticing the cones that may be placed to show that a pump is not available for service or notice the safety vest worn by the Weights and Measures employee.

After documenting this task for the custom job description, a suggestion was noted that the specialized pickup mounted collection and measurement device would reduce this risk. The device allows Weights and Measures officials to pump directly from the gas pumps into a truck mounted collection device that can be moved from pump to pump, rather than making multiple trips carrying 5 gallon containers across busy parking lots. This engineering control allows for significant reduction in risk of injury to the employee.

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