In South Africa, the legislation governing workplace health and safety is the Occupational Health and Safety Act 85 of 1993, formally abbreviated as the OHS Act, and sometimes referred to informally as ‘OSHA’ or the ‘OSH Act’. Whichever shorthand you use, every employer in the country has a legal duty to meet the requirements of the OHS Act.
One of the most important sections of the OHS Act (or ‘OSHA’) is Section 8: General duties of employers to their employees. Section 8 clearly states that employers are required to provide a work environment that is safe and without risks to the health of employees. To do this, employers must take steps to proactively identify hazards and put measures in place to control the risks associated with those hazards.
The Hierarchy of Controls is an internationally recognised approach to managing and controlling workplace risks. Correctly implementing the Hierarchy of Controls can help employers control workplace risks and thereby meet some of the core requirements of Section 8 of the OHS Act.
What is the Hierarchy of Controls?
The Hierarchy of Controls is a prioritised framework for managing workplace risks. Rather than treating all risk control measures as equally effective, it ranks them from most to least effective, and directs employers to work from the top down, looking to implement higher-level controls before resorting to lower-level ones.
The five levels, from most to least effective, are:
Level 1: Elimination
Elimination is the most effective control measure because it removes the hazard entirely. There is nothing left to manage, mitigate, or protect against.
In practice, elimination could look like:
- Discontinuing a process that generates a hazardous substance
- Removing a piece of dangerous machinery that is no longer needed
- Redesigning a work layout to remove a fall risk entirely
Elimination is not always possible, but it should always be the first question asked: Can we remove this hazard completely? If the answer is yes, this is the most effective method for controlling associated risks.
Level 2: Substitution
Where elimination is not possible, the next step is substitution: replacing the hazard with something that presents a lower risk.
Practical examples may include:
- Replacing a toxic solvent with a less hazardous alternative
- Substituting a manual lifting process with a mechanical lifting aid
- Using a less abrasive material that generates less harmful dust
Level 3: Engineering Controls
When a hazard cannot be eliminated or substituted, engineering controls physically change the work environment or equipment to reduce exposure. These controls are built into the workplace or process itself, and do not rely on employee behaviour to be effective.
Common engineering controls include:
- Machine guards that prevent contact with moving parts
- Local exhaust ventilation systems that extract fumes or dust at the source
- Noise enclosures around loud machinery
- Barriers and edge protection on elevated work platforms
Engineering controls are preferable to administrative controls and PPE because they work independently of human action. This reduces the likelihood of human error resulting in ineffective risk control.
Level 4: Administrative Controls
Administrative controls manage risk through changes to how work is organised, scheduled, and performed. They do not change the hazard, they change how and when people are exposed to it.
Examples include:
- Job rotation to limit the duration of exposure to a repetitive strain risk
- Safe work procedures and standard operating procedures (SOPs)
- Permit-to-work systems for high-risk tasks
- Scheduling noisy work during periods when fewer workers are present
- Health and safety training and supervision
Administrative controls are important and necessary, but they depend on consistent human compliance to be effective. A procedure that is not followed provides no protection. This is why administrative controls sit below engineering controls in the hierarchy.
Level 5: Personal Protective Equipment (PPE)
PPE is the last line of defence. Under the OHS Act’s General Safety Regulations, employers are legally required to identify work activities that require PPE and to supply appropriate equipment to employees at no cost. Requiring workers to purchase their own PPE or deducting the cost from wages is a direct contravention of the Act.
PPE includes:
- Hard hats and safety helmets
- High-visibility clothing
- Safety footwear
- Gloves, eye protection, and face shields
- Hearing protection
- Respiratory protective equipment
The critical limitation of PPE is that it does not eliminate or reduce the hazard itself, it only reduces the individual’s exposure to it. If the PPE is removed, damaged, incorrectly fitted, or not worn, the full risk immediately returns.
The role of training in the Hierarchy of Controls
Occupational health and safety training is an essential component of any risk control system and sits within Administrative Controls (Level 4 of the Hierarchy of Controls). OHS training tells employees how to work safely within the context of their workplace.
Where OHS training is required, for example for First Aiders, Fire Wardens, Evacuation Marshals, and Health and Safety Representatives, it must be delivered by accredited training providers. First Aid, Fire and Safety Training offers the full range of accredited OHS training, from First Aid NQF Level 1 through to a comprehensive 10-day Health and Safety Officer course, delivered by experienced practitioners and aligned to South African legislation.
Applying the Hierarchy of Controls in your workplace
The Hierarchy of Controls is not a theoretical framework, it is a practical decision-making tool that should be used in every risk assessment your organisation conducts. For each hazard identified, work through the levels in order:
- Can we eliminate this hazard entirely?
- If not, can we substitute it with something less dangerous?
- Can we engineer out or contain the risk?
- What administrative procedures and training do we need?
- What PPE is required as a final layer of protection?
Document your reasoning at each level. This documentation is part of your Health and Safety File and demonstrates to DoEL inspectors that your approach to risk management is systematic, considered, and legally sound.
First Aid, Fire and Safety Training provides accredited OHS training
First Aid, Fire and Safety Training (FAFST) supports South African employers across the full spectrum of OSH/OHS Act compliance, providing OHS management services alongside accredited health and safety courses delivered by experienced instructors.
FAFST’s course offering includes:
- First Aid training: DoEL-approved first aid training (CI 511/3/12/1) including First Aid NQF Level 1 and our First Aid Combination Levels 1, 2 & 3 courses.
- Firefighting and Advanced Firefighting: Practical, hands-on training in fire prevention and firefighting.
- Evacuation Planning: Equipping Evacuation Marshals to manage safe, efficient workplace evacuations and assist with emergency preparedness.
- Health and Safety Representative: Training H&S Reps to fulfil their legal duties under the OHS Act.
- Health and Safety Officer (10-day course): A comprehensive programme covering the OHS Act, risk assessment, incident investigation, first aid, firefighting, evacuation planning, and health and safety management systems, priced at R9,895 (ex VAT).
- HAZMAT, HIV/AIDS Awareness, Stacking and Storage, and other specialist workplace health and safety courses.
All FAFST courses are delivered by experienced practitioners, combining theoretical knowledge with hands-on, practical assessment. Training is available at our well-equipped training centres or on-site at your premises for groups of eight or more delegates, with national coverage across South Africa.