Health and Safety

Workplace Wellness by Design: Applying the Hierarchy of Controls to Mental Health

July 2, 2020

While there have been increasing concerns over mental health for many years, the pandemic has applied unique stressors that have exacerbated existing mental heath issues and created entirely new ones. According to a recent survey by SunLife, 50% of Canadian’s report that their mental health has been negatively impacted by the COVID-19 pandemic. And many government bodies (e.g. StatsCan), health organizations (e.g. World Health Organization), and independent research houses (e.g. are predicting an unprecedented mental health disaster – one that is likely to have long-lasting implications. Yet, what do we hear the most about? How to put on a mask. How to wash our hands. How to physically distance. But what about how to proactively manage mental health issues? As business leaders, we can and we must better manage mental health concerns. How? Well if you are an HR leader, a solution has been staring us in the face for a long time…

We should use the Hierarchy of Controls (HoC)! Yes, that upside down triangle model we all know and love.
I know what you’re thinking: the Hierarchy of Controls is focused on reducing workplace injuries, illnesses, and fatalities (Source: CDC), what does that have to do with mental health?

Well, by using a modified version of the Hierarchy of Controls (HoC), we can assess mental health hazards with similar processes and procedures as physical health. This will help us deal with mental health issues more effectively and efficiently by eliminating or limiting systemic hazards FIRST, before we move to less effective, front-line controls. It will also help our organizations minimize their risk profiles relating to employer liability. Increased effectiveness and efficiency? Reduced risk? Sounds like an easy sell to the CFO, COO, or business owner. But wait, we need to think this through a bit. For one thing, a physical hazard like a dangerous height, a toxic chemical, or a sharp edge on a tool is obvious, whereas mental hazards can be invisible, episodic, and difficult to detect. 

If someone cuts a finger off on an industrial cheese slicer, the impact is obvious: there’s screaming and blood. Lots of blood. With mental health, it’s just not that simple. Blood becomes tears. The missing finger becomes anxiety. The treatment isn’t stitches and ice, but medication and self-imposed isolation. Add the complication that some people still maintain a dated opinion that mental health is “just in your head” or that crying is a sign of weakness. Combine these factors and you have the perfect cocktail for a mental health crisis: chronic symptoms coupled with societal stigma. That’s a difficult problem with no easy solutions. But humans didn’t decide to go to the moon because it was easy…

Although mental health hazards can be difficult to identify, there are common things you can look for: overwork, unclear priorities, unpredictable work shifts, understaffing, and exposure to violence or harassment. These can all harm or worsen mental health – and they are all hazards employers have substantial control over.

HRdownloads Hierarchy of Controls (HoC) for Mental Health is a systematic, effective approach to mental health management:

Let’s explore how the model works using some common examples:

  1. Eliminate the hazard. Always the first and best option – remove the hazard entirely.
    • Hazard: You determine that unpredictable scheduling is causing stress and anxiety for employees.
    • Action: Implementing firm schedules or committing to one week’s notice of any schedule change would eliminate the hazard.
  2. Substitute the hazard. When you can’t eliminate a hazard entirely, try to at least replace it with a less dangerous version. Often this can be done by rejigging processes and procedures.
    • Hazard: You identify that one department is understaffed and at risk of burnout.
    • Action 1: You can’t afford to hire additional full-time staff, so you hire an additional part-time employee to ease the burden. The hazard still exists, but you’ve lessened its severity. OR
    • Action 2: You can’t afford to hire any additional staff, so you decide to partner with a past competitor. You arrange to send them overflow orders for a ‘finders fee’. (Note: This could also eliminate the hazard if employee workloads were brought to a normal level.)
  3. Reduce exposure to the hazard. If you can’t change the hazard, engineer the role to reduce its negative impact.
    • Hazard: You identify that handling store returns is particularly stressful for customer service reps. Consistently performing that task leads to burnout and turnover.
    • Action: You decide to rotate employees through the job so no employee is overwhelmed. Not only does this reduce the hazard, it also promotes cross-training, making it easier to cover shifts if someone falls ill or takes a leave or vacation.
  4. Fortify employees against the hazard. If you can’t modify the role to provide protection, help employees increase their resistance to the hazard.
    • Hazard: You identify that difficult customers are causing your financial services reps to experience debilitating stress. In times of market instability, the problem is exacerbated along with the negative mental health impact.
    • Action: You decide to help employees better manage the interaction with the customer by providing training on managing difficult conversations and defusing hostile customers. You also offer your employees help to reduce internalization of these interactions, such as training in mindfulness or meditation classes.
  5. Treat the negative impacts of the hazard. Where you can’t eliminate or reduce exposure to a hazard, introduce measures to lessen the negative impact of exposure.
    • Hazard: You identify an employee who is suffering from depression due to difficult personal circumstances.
    • Action: Offer services through your Employee Assistance Program (EAP) to support the employee in reducing the symptoms of exposure, such as massages or therapy.

It’s important to follow the hierarchy: always try to eliminate a hazard first. The lower levels of controls can help, but are seldom good long-term solutions. Identify the root causes of hazards, and never presume a hazard cannot be eliminated.

Ultimately, employers have the greatest responsibility for health and safety because they have the most power to make impactful changes. By using the Hierarchy of Controls for Mental Health, we can create healthier employees and workplaces by design.

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