The OSHA 1910.1018 Inorganic Arsenic standard states, “Employee rotation is not required as a control strategy before respiratory protection is instituted” and the 1910.120 Hazardous Waste Operations and Emergency Response standard states, “The employer shall not implement a schedule of employee rotation as a means of compliance with permissible exposure limits or dose limits except when there is no other feasible way of complying with the airborne or dermal dose limits for ionizing radiation.”

If the preferred hierarchy of controls is engineering, administrative, then PPE, why do you think OSHA specifically prohibits this one administrative control? What other administrative controls could be used if employee rotation is prohibited or not required? As an employer, how should administrative controls be administered and enforced? Should they be relied on for reducing exposure? Why or why not?

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