Removing hazards & cutting risk (hierarchy of controls)
Plain-language summary
Choosing controls in the right order, starting with getting rid of the hazard and only using PPE as a last resort.
What the clause is really asking
This clause enforces the hierarchy of controls, the single most important habit in good safety practice. You must work top-down: eliminate the hazard, then substitute something safer, then engineer it out, then use administrative controls, and only then rely on PPE. The intent is that the most reliable controls are tried first, because PPE depends on people getting it right every time and fails most easily.
What auditors look for
Auditors examine your controls and challenge whether you reached for PPE too quickly when you could have eliminated, substituted or engineered the hazard out. They ask why a higher control was not feasible and look for a genuine reasoning trail. Over-reliance on PPE and signage is one of the most common findings in OH&S audits.
Typical evidence
Risk assessments showing the hierarchy was considered; engineering controls such as guarding, ventilation and isolation; substitution decisions; records justifying why higher controls were not used; PPE used as a supplement, not the sole control.
How to comply — recommendations
When choosing a control, always start at the top of the hierarchy and document why you ruled out elimination, substitution and engineering before settling lower. Invest in engineering controls like guarding, extraction and isolation, which protect everyone without depending on behaviour. Treat PPE as the last layer, not the first answer. Keep the reasoning so you can show an auditor you genuinely worked down the hierarchy.
Common nonconformities
PPE used as the first and only control; hierarchy of controls not considered or not documented; feasible engineering controls ignored on cost grounds without justification; signage and procedures relied on where the hazard could have been engineered out.
Related clauses
ISO 9001 (no direct equivalent); ISO 14001 8.1
Qlause provides interpretive guidance only and is not a substitute for the standard. Refer to your licensed copy of the relevant standard for the authoritative text.