Controls and PPE

The Hierarchy of Control for Hazardous Substances

Why PPE Comes Last: Applying the Hierarchy of Control in a Kitchen or Bar

Quick answer

The hierarchy of control is the order in which you should reduce exposure to a hazardous substance, and it is the single idea that turns a COSHH assessment from a list of gloves into a genuine plan for protecting people. The Control of Substances Hazardous to Health Regulations 2002 require you to prevent exposure where you reasonably can, and only to control it where prevention is not practicable. That order matters because personal protective equipment, the option most businesses reach for first, is actually the weakest and least reliable control. This article works through each level of the hierarchy with hospitality examples, so you can see how to design controls that do not depend on every member of staff remembering to put their gloves on every single time.

The hierarchy of control sets the order for reducing exposure: eliminate, substitute, engineering controls, administrative controls, then PPE.
Elimination and substitution are the strongest controls because they remove risk at source rather than relying on people.
Engineering controls such as ventilation and automatic dosing protect everyone in the area at once.

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Key takeaways

The hierarchy of control sets the order for reducing exposure: eliminate, substitute, engineering controls, administrative controls, then PPE.

Elimination and substitution are the strongest controls because they remove risk at source rather than relying on people.

Engineering controls such as ventilation and automatic dosing protect everyone in the area at once.

Administrative controls and PPE depend on people behaving correctly every time, which is why they sit lowest.

PPE is essential for residual risk but should be the final layer, never the only control for a high-risk substance.

Elimination and Substitution First

The most effective control is to stop using the hazardous substance altogether, and the next best is to swap it for something less harmful. In a kitchen this is more achievable than it sounds. A corrosive oven cleaner carrying the corrosion pictogram can often be replaced with a less aggressive caustic product or a soak-tank method that needs far less handling. Concentrated sanitiser bought in bulk and decanted by hand can be replaced with a pre-diluted ready-to-use product, which removes the decanting step where most splashes happen. Powder descalers can be swapped for tablets that are dropped in rather than poured. Every time you eliminate or substitute, you remove risk at the source rather than relying on a person to manage it. This level of the hierarchy is also the one inspectors notice, because it shows you have thought about the substance rather than just buying protective equipment for it.

Controls and PPE

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Engineering Controls and Ways of Working

Where you cannot remove or substitute the substance, the next step is to control exposure at source through engineering and the way work is organised. In hospitality the clearest example is local exhaust ventilation over a warewasher or a canopy that carries chemical mist and steam away from the people working under it. Dosing systems on dishwashers and laundry machines are an engineering control too, because they dilute concentrate automatically and stop anyone handling the neat product. Beyond hardware, the method of work matters: wiping a diluted sanitiser onto a cloth rather than spraying it into the air reduces the mist you breathe in, and decanting over a sink rather than a worktop limits where a splash can land. These controls protect everyone in the area at once, which is why they sit above protective equipment in the hierarchy.

Administrative Controls

Administrative controls reduce exposure by changing how and when people work rather than by changing the substance or the equipment. Examples in a hospitality setting include cleaning a hot extraction canopy at the end of service when the kitchen is empty rather than during prep, limiting who is allowed to use the corrosive products to trained staff only, and writing clear safe systems of work for the high-risk jobs. Training, supervision, and signage all sit here. The weakness of administrative controls is that they depend on people following them consistently, which is why they sit below engineering controls. They work best as a layer on top of substitution and engineering, not as a substitute for them. A rule that only trained staff handle the drain cleaner is sensible, but it is far stronger when the drain cleaner has also been chosen to be the least aggressive product that does the job.

Personal Protective Equipment as the Last Line

Personal protective equipment is the bottom of the hierarchy because it protects only the person wearing it, only while they wear it correctly, and only if it is the right type and in good condition. Gloves get holes, aprons get left on the hook, and eye protection gets pushed up onto the forehead. None of that makes PPE optional: it is essential for the residual risk that the higher controls cannot remove, such as the splash risk when handling a corrosive product even after you have switched to the mildest one available. The point of the hierarchy is that PPE should be the final layer over good substitution, engineering, and working practices, not the only thing standing between a kitchen porter and a chemical burn. If your COSHH assessment lists gloves and nothing else for a high-risk substance, you have started at the wrong end.

What to do next

Review your highest-risk substances for substitution

Take the corrosive oven cleaners, drain unblockers, and concentrates and ask whether a milder product, a pre-diluted version, or a different method would do the job.

Use automatic dosing instead of hand-decanting

Fit dishwashers and laundry machines with dosing systems so staff never handle neat concentrate, removing the step where most splashes happen.

Check that PPE is the last entry, not the only entry

For each high-risk substance, make sure your assessment lists a substitution or engineering control above the gloves and apron.

Common mistakes to avoid

Mistake

Listing gloves as the only control for a corrosive product

Instead

Gloves protect one person if worn correctly. Work up the hierarchy first: switch to a milder product, control the dosing, and improve ventilation before relying on PPE.

Mistake

Treating training as a substitute for safer products

Instead

Training is an administrative control near the bottom of the hierarchy. It supports safer products and equipment but cannot make a dangerous handling method safe on its own.

Frequently asked questions

What is the hierarchy of control under COSHH?

It is the order in which you should control exposure to a hazardous substance: eliminate it, substitute a safer one, use engineering controls such as ventilation, apply administrative controls such as safe systems of work, and only then rely on personal protective equipment. Each step down is less effective than the one above.

Why is PPE the last resort in COSHH?

Personal protective equipment protects only the wearer, only while it is worn correctly, and only if it is the right type and in good condition. Higher controls remove or reduce the hazard for everyone, so the regulations expect you to use them before relying on PPE.

Can I just give staff gloves instead of changing the chemical?

No. COSHH requires you to prevent exposure where reasonably practicable before controlling it. If a milder product or a safer method is available, you are expected to use it rather than defaulting to gloves for a hazardous product you could have avoided.

What are engineering controls in a kitchen?

Engineering controls reduce exposure through the design of equipment and the environment. In a kitchen they include local exhaust ventilation over canopies and warewashers and automatic dosing systems that dilute concentrate without anyone handling the neat product.

Controls and PPE