JouleCheck reference
What counts as a direct control
A direct control is specifically targeted at the energy source, effectively prevents contact or release when installed, verified and used, and still works when someone makes a mistake. That last part is the test that most answers fail: training, signage, attentiveness and everyday PPE all assume nobody has a bad day. The examples below show the difference for each energy source. Qualifying examples are typical, not exhaustive, and site procedures decide what is acceptable.
Gravity
Qualifies
- Exclusion zone under the load path, physically marked and maintained.
- Tool tethers and secondary retention on items at height.
- Installed edge protection with toe boards.
Does not qualify alone
- Watching the load.
- Hard hats alone.
- A spotter shouting warnings.
Motion
Qualifies
- Physical segregation between plant and people on foot.
- Wheel chocks and skate stops applied before work near the load.
- Traffic routes closed and barriered during heavy moves.
Does not qualify alone
- High-visibility clothing alone.
- Driver vigilance.
- A banksman with no exclusion behind them.
Mechanical
Qualifies
- Fixed guards over rotating and moving parts.
- Isolation locked and verified before intervention.
- Restraint applied before tension or spring load is released.
Does not qualify alone
- Standing clear by judgement.
- Gloves.
- Working quickly.
Electrical
Qualifies
- Isolation locked, tagged and proven dead at the point of work.
- Insulated barriers over adjacent live parts.
- Rated insulated tools and covers for work on systems that cannot be de-energised.
Does not qualify alone
- Assuming dead because it was dead yesterday.
- Signage alone.
- Experience.
Pressure
Qualifies
- Depressurisation verified at a gauge or vent at the point of work.
- Exclusion zone during pressurisation and testing.
- Whip restraints on temporary hoses and connections.
Does not qualify alone
- Cracking a joint carefully.
- Trusting a single gauge without verification.
- Standing to the side.
Chemical
Qualifies
- Lines and vessels proven empty before connections are broken.
- Physical segregation of incompatible substances.
- Local exhaust or forced ventilation for the substance in use.
Does not qualify alone
- Generic PPE not matched to the substance.
- Smelling for vapour.
- Working fast to limit exposure.
Thermal
Qualifies
- Combustibles removed or physically protected before hot work.
- Guarding or barriers on hot and cryogenic surfaces.
- Verified cool-down before contact work starts.
Does not qualify alone
- A fire watch with combustibles left in place.
- Warning signs on hot pipework.
- Care.
Sound
Qualifies
- A quieter method or tool substituted for the noisy one.
- Enclosure or physical separation of the noisy work.
- Noisy work scheduled away from occupied areas.
Does not qualify alone
- Hearing protection alone.
- Limiting exposure by judgement.
Radiation
Qualifies
- Controlled area established and cleared before the source is exposed.
- Shielding in place between source and people.
- Welding screens physically positioned around arc work.
Does not qualify alone
- Looking away from the arc.
- Keeping exposure short by judgement.
Biological
Qualifies
- Stagnant systems drained and flushed before opening.
- Sealed handling and disposal of contaminated material.
- Verified disinfection before work in affected systems.
Does not qualify alone
- Gloves alone.
- Holding your breath.
- Washing afterwards.
PPE is the last barrier, not a control strategy. It reduces harm after every other layer has failed, which is exactly why Energy-Based Safety asks for a direct control first on every high-energy hazard. The narrow exception in the EEI guidance is specialised equipment-grade PPE, such as rated insulating gloves used within a verified live-working system, which can form part of a direct control.