The Hierarchy of Cs

In her first column for COS, health and safety expert Lee-Anne Lyon-Bartley tells us about other essential "Cs" to consider outside of the traditional hierarchy of controls

The Hierarchy of Cs
Our new columnist Lee-Anne on expanding the traditional hierarchy of controls.
Lee-Anne Lyon-Bartley

One of the concepts that OHS professionals have known about for a long time is the hierarchy of controls (HOC), meaning the elimination, engineering, administrative and PPE controls that a business can put in place to help minimize the spread of COVID-19. It’s been amazing to see this heightened awareness. Any time I’ve seen that colourful, inverted pyramid, it has brought a smile to my face. 

As I reflect on my years in safety, I realize that, in different conversations and at different times, we have tried to influence the improvements in occupational health and safety in our organizations through these 5 Cs, which complement the traditional HOC as we know it. Here is my version of the “Hierarchy of Cs.”


Cash will have to be spent by any business that has workers. There isn’t much way around it. Every business has OHS hazards that will need to be addressed. There will be costs for workers’ compensation coverage, training, PPE… In some businesses, there will be occupational health tests that need to be completed.

If we think about our traditional HOC, how can we talk about getting engineering controls in place if leaders aren’t willing to spend money to make the workplace safer?


I couldn’t talk about the foundational pieces without talking about legislative compliance. Cue in the yawns. Yes, it’s one of the least sexy but most necessary parts of the job. In order to embed occupational health and safety into the business processes, you have to know with which laws you’ll need to comply.

In the traditional HOC, many of the engineering, administrative and PPE controls are straight out of legislative requirements. That could be a T-shirt or album cover: “Straight Outta Legislation.” Requirements such as machine guards, PPE, exposure limits… can all be found directly in acts and regulations. You need to be aware, and this is where the next rung in our pyramid plays a big role.


I would think that most safety professionals would agree that the more competent the workforce is, the more resilient they are in dealing with the day-to-day challenges that arise and I’ve also seen firsthand that the rate of incidents decline.

Competence shows up in our traditional HOC under the administrative controls. Looking at elimination on the HOC, you can’t eliminate hazards without knowing and understanding hazards in your workplace. Training and education are usually an administrative control for just about everything, that’s why in my opinion it deserves its own rung threading through everything on the traditional HOC. 


How many times have you heard that everyone is responsible for health and safety? Well, let me add one more time for you to hear it again: Everyone is responsible for health and safety in the workplace. As we all know, our health and safety legislation is built on the philosophy of the internal responsibility system that says employers, supervisors and workers should work together to carry out their workplace duties as outlined in legislation. 

Workplace health and safety works best when people in the workplace are working together to manage health and safety.


When we talk about the business reasons for OHS management, we mention the moral reasons, which to me really means that businesses need to care about their people, the customers and clients they serve. They also need to care about the reputation of their business. 

I’ve seen CEOs speak at health and safety conferences. When you hear them speak about the importance of health and safety in their business, you can feel that they want to see their employees go home to their loved ones. I think we’re beginning to appreciate more and more that work is not just the place we go to make money. The workplace is a place where many of us build relationships and many of us spend more time with the people we work with than we do with our own families.

The workplaces that understand this and try to create an organizational culture that cares about the health and safety of its people will probably be more likely to use the traditional HOC as well as their hierarchy of Cs.

Whether you look at this “Hierarchy of Cs” or the traditional HOC, think about the leaders of the business you support; how would they answer the question: “You down with HOCs?” Hopefully, the answer will be: “Ya, you know me!”


Lee-Anne Lyon-Bartley, BASC (Ryerson), CRSP, CP-FS, is mom to Cameron and currently executive vice president, HSEQ at Dexterra group. She is NEBOSH and IEMA certified. She was a regular guest on the Steven and Chris show (CBC), volunteers with WOHSS, WSPS on an advisory committee, My Safe Work and Threads of Life, awarded the Women in EHS award from eCompliance and featured on Breakfast TV Toronto and Vancouver and Global News.


This article originally appeared in the March/April 2021 issue of COS.