Setting Up Ohs Guide
Setting Up Ohs Guide
Setting Up Ohs Guide
Introduction
Introduction
Chapter 3: Identify people and resources required to deal with emergencies ____ 37
Introduction ________________________________________________________ 37 How important is it to prepare for emergencies?_____________________________ 38 What must emergency response plans do? __________________________________ 38 What authority structure must the plan set out? _____________________________ 38 What resources must the plan identify? ____________________________________ 39 How should you prepare emergency response plans? _________________________ 39 Summary ________________________________________________________ 44
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Introduction
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Introduction
Chapter 8: Develop a plan to investigate accidents, dangerous occurrences, and refusals to work _____________________________ 91
Introduction ________________________________________________________ 91 What should be in your incident investigation procedure?_____________________ 92 How can incidents be investigated?________________________________________ 94 What should be in the procedure to investigate refusals to work? _______________________________________________________ 95 Summary ________________________________________________________ 98
Chapter 10: Regularly evaluate and revise your program __________________ 105
Introduction _______________________________________________________ 105 22 (a) Write a policy that demonstrates your commitment____________________ 108 22 (b) Identify and control hazards and emergencies ________________________ 108 22 (c) Identify people and resources required to deal with emergencies________________________________________________ 109 22 (d) Prepare a statement of responsibilities_______________________________ 109 22 (e) Schedule inspections ______________________________________________ 109 22 (f) Develop plans to control chemicals and biohazards ____________________ 110 22 (g) Develop a training plan for workers and supervisors ___________________ 110 22 (h) Develop a procedure to investigate accidents, dangerous occurrences, and refusals to work _______________________________________________________ 111 22 (i) Develop a strategy to involve workers________________________________ 111 22 (j) Develop a procedure to regularly evaluate and revise your program _______________________________________________ 112 Summary _______________________________________________________ 113
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Introduction
Resources
Publications Internet sites
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______________________________________________________ 121 ______________________________________________________ 122
Acknowledgement
The Occupational Health and Safety Division thanks the Occupational Health and Safety Council, as well as the other groups and individuals who reviewed this publication before its release.
Introduction
Notes
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Introduction
Introduction
To enhance your program, consider reading occupational health and safety program publications available from local, national, and international safety associations, (IAPA, CCOHS, National Safety Council, and so forth), and leading theorists in the field, (Dr. Dan Petersen, Edward E. Adams, Frank E. Bird, George L. Germain, and so forth). Contact the Regina office of the Occupational Health and Safety Division to obtain any Occupational Health and Safety Division publications you need. Alternatively, order them over the Internet through the Sask Labour Web page at: http://www.labour.gov.sk.ca/. We welcome your ideas for making this guide better. Please fill out the Feedback sheet at the back of this guide and mail it to us.
Introduction
Introduction
Too many Saskatchewan workers are hurt on the job every year. Investigations show that accidents happen more often in workplaces that do not have effective health and safety systems. An occupational health and safety program is a systematic plan to identify and control hazards and respond to emergencies. The program lays out responsibilities, resources, and procedures for keeping the workplace healthy and safe. Its objective is to integrate health and safety into all work practices and conditions. Studies show that good health and safety programs reduce accidents and occupational illnesses. This is why The Occupational Health and Safety Act says employers in moderate to high hazard industries must develop programs in co-operation with workers. Section 22 of The Occupational Health and Safety Regulations describes program requirements. See the Appendix for a list of affected workplaces. Publications and Internet links are listed in the Resources section of this guide.
Introduction
The Division interprets consult to mean that, while not obliged to obtain the approval or permission of the occupational health committee, an employer is obliged to consider, in good faith, the views and opinions of the committee in the process of making a decision. To fulfil the obligation to consult in good faith, an employer must give the committee a real opportunity: To be informed of information essential to making a reasonable and informed assessment; To review and assess the information and possible alternatives or options; To comment and, or make recommendations on the possible options and alternatives; and To be considered. This means the employer will consider the recommendations of the committee and where applicable, give the committee credible reasons for not accepting or implementing the committees recommendations.
Introduction
Each of the programs elements must be in writing. Elements must be supported with all documents and information covering matters listed in the regulations. If elements of the health and safety program have been implemented in separate procedures and policies, those documents must be referred to in the main health and safety program document. The program must also address the health and safety of subcontractors and their workers. In situations where you have contracted with two or more outside organisations or selfemployed persons to do work, you are responsible for coordinating the health and safety programs of all employers at that place of employment.2 The program must be effectively communicated to all employees. It must be available to your occupational health committee, workers, or an occupational health officer (on request). Setting up a program is not simply about producing documents. A health and safety program is a living thing that should be constantly adapted, evaluated, and enhanced to make the workplace healthier and safer. Effective implementation and monitoring is crucial to its success. In short, to be effective, your program must: be workplace specific have commitment from the employer and senior management have input from the workers assign clear responsibilities and accountabilities have an evaluation mechanism be available and effectively communicated
A contractor means a person who, or a partnership or group of persons that, pursuant to one or more contracts, directs the activities of one or more employers or self-employed persons involved in work at a place of employment.
A sub-contractor is not defined in the legislation. In this publication, it means the employer or self-employed person hired to work under contract.
Introduction
7 A good health and safety program can dramatically reduce costs from: harm to people and damage to property retraining and replacement costs lost or delayed production reduced competitiveness increased insurance costs fines and legal costs damage to reputation and resulting lost business
Introduction
The Act also prohibits employers from imposing discipline or other sanctions on workers for fulfilling their responsibilities or exercising their rights under the Act and regulations. This helps workers to participate actively, with supervisors and employers in preventing injuries and illnesses. The internal responsibility system requires everyone, from the chief executive officer down to the newest hire, to make good occupational heath and safety practices part of everything they do at work. Because employers have the greatest degree of control over the workplace, they have the most responsibility for providing a healthy and safe workplace. However, that does not relieve supervisors and workers from their responsibility to take the necessary precautions to protect themselves and others from workplace hazards.
Introduction
In the case of an occupational health and safety program, the criteria for due diligence requires employers to: Establish a program The program should systematically identify hazards and assess their risks. It must include plans within the program to manage those risks. The plans should reduce the likelihood of the identified hazards causing harm. Ensure the program is adequate The program must meet the needs of the workplace and the workers. It is a good idea to compare your program with industry standards. Monitor and evaluate the programs effectiveness A way must exist to allow competent staff to regularly check the effectiveness of the program and how well it meets requirements.
Introduction
How should you set up your program to be duly diligent and effective?
1 Write a policy that demonstrates your commitment. 2 Have adequate systems to identify and control hazards. 3 Identify what people, resources, and procedures are needed to deal with emergencies. 4 Prepare a statement of responsibilities for health and safety (who is responsible for what). 5 Schedule regular and surprise planned inspections. 6 Develop plans to control chemical and biological hazards. 7 Develop training plans for workers and supervisors. 8 Develop a procedure to investigate accidents, dangerous occurrences, and refusals to work. 9 Develop ways to involve workers in the program. 10 Regularly evaluate and revise your program. Return to Work Plans While not required by regulation 22, you should have a plan to return injured workers to productive jobs within the workplace.
Introduction
Involve employees An effective program needs the experience and knowledge of employees. You must develop the program in consultation with the occupational health committee. Start with a planning meeting. Involve the employer, senior managers, and the committee. The meeting should: confirm everyones commitment to the health and safety program set out how employees will be involved determine who does what decide how employees will be told that a program is being developed ask employees for their input and advice ask employees how the program can be evaluated and improved
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Introduction
Hold meetings to tell employees about the program. Provide details at follow-up meetings. Use the organisations e-mail system, newsletter, and so on to keep everyone updated. Tell employees about: the human and financial costs of accidents and illnesses the requirements of occupational health and safety legislation the commitment of senior management to a safe and healthy workplace the importance of everyones input to the programs development and implementation
If you already have a health and safety program in place, take the opportunity to review it with the occupational health committee to see if the program can be improved. If you do this right, not only will it improve your health and safety efforts it will contribute to more efficient and effective production and service delivery.
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Introduction
Assign Responsibilities
Involve Workers
! Identify, Assess, and Control Hazards Health hazards Safety hazards Chemicals, biohazards, and so forth
Conduct Inspections
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Introduction
Section (1) of regulation 22 says that an occupational health and safety program must havea statement of the employers policy with respect to the protection and maintenance of the health and safety of the workers. This chapter explains what a policy statement is and what should be in it. We also provide examples of policy statements. However, remember that your policy statement is meaningless unless it is implemented.
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Your policy statement must: 1 2 3 4 Be written, communicated, and posted. Be understood by workers. Be clear about whom is responsible and accountable. Identify and allocate resources for implementing the policy.
A policy statement is usually one or two pages long. Many employers post it throughout the workplace and use it as an introduction to the written health and safety program. The policy should not take a back seat to any other policy in your organisation. It must be kept up-todate, and it must be followed in all work activities. The most senior manager in the organisation should also sign it. New hires must be made aware of the policy statement during orientation. Where appropriate, suppliers, subcontractors, and clients should be told about the statement and any relevant sections of the program.
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What are the alternatives to safety? Employees and subcontractors who knowingly violate safety rules may face disciplinary action,
dismissal or legal action. Visitors may also face legal action if they knowingly disobey safety rules. In addition, the company may face legal action and fines for violations of regulatory requirements. Those individuals who do not fulfil their safety responsibilities will become accountable for any problems their negligence creates, and may be liable under the law.
Who is responsible?
Everyone employed by this company is responsible for maintaining the safety program. Managers and supervisors are responsible for identifying safety needs, communicating safety hazards, investigating hazardous conditions and accidents, providing training, supplying or wearing appropriate safety and personal protective equipment, and ensuring all equipment is properly maintained and meets legislated safety standards. Their role is supported by input from all employees. All company employees, and others on company work sites, are responsible for obeying all safety rules, following recommended safe work procedures, wearing and using personal protective equipment when required, participating in safety training programs, and informing supervisors of any unsafe work conditions. Everyone has the right and responsibility to refuse work when unsafe conditions exist. By fulfilling our safety responsibilities, everyone who works for our company will share the benefits of a safe workplace.
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A policy statement is required by regulation 22. It should tell employees and others at work sites about your commitment to health and safety. It should also set out the principles you will use to maintain a healthy and safe workplace. Your policy statement provides guidance and direction to all other areas of the health and safety program, much like a health and safety constitution. Inform all employees about your occupational health and safety program and its policy statement. Make sure new workers are told about them during orientation. Train all employees to carry out their responsibilities. The following chapters discuss some detailed elements that should be in your program. We will begin by discussing how to identify and control hazards and potential emergencies.
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Notes
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Introduction
One of the most important elements of an occupational health and safety program is an effective system to identify and control hazards. Hazards may cause accidents, injuries, and illnesses. The employer may not be able to anticipate and prevent every accident, injury, or illness. However, the employer should take all precautions that a reasonable and prudent person would take in the circumstances. Remember that many workplace accidents can be attributed to hazards and risks that people in the workplace have come to consider routine or unimportant. Regulation 22 (b) requires employers to have an ongoing system forthe identification of existing and potential risks to the health or safety of workers at the place of employment and the measures, including procedures to respond to an emergency, that will be taken to reduce, eliminate or control those risks.
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To do this, your system must: consistently monitor the workplace for known (and potential) hazards and emergencies require workers, supervisors, and managers to report hazards assess the risk of those hazards actually hurting workers implement effective controls ensure managers and supervisors are accountable for taking effective corrective action
The risk management system need not be separate from operational procedures. To ensure accountability, responsibility must be assigned to specific employees. Knowledgeable supervisors, in consultation with experienced workers, are good candidates for leading hazard identification, assessment, and control. Your system will be more successful if the employer makes a senior manager or supervisor accountable for keeping the system effective. Workers are a valuable source of information about hazards and risks in the workplace. The occupational health committee also provides input and advice, and audits the systems effectiveness.
What is a hazard?
A hazard is any activity, situation or substance that can hurt someone. Occupational hazards are divided into two broad categories: (1) health hazards, and (2) safety hazards. What is a health hazard? A health hazard is any agent, situation or condition that can cause an occupational illness. There are five types: 1 2 3 Chemical hazards, such as battery acid and solvents. Biological hazards, such as bacteria, viruses, dusts, and molds. Biological hazards are often called biohazards. Physical agents (energy sources) strong enough to harm the body, such as electric currents, heat, light, vibration, noise, and radiation. Work design (ergonomic) hazards. Specific stressors, such as harassment, violence, shiftwork, and so forth.
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A health hazard may produce serious and immediate (acute) affects or it may cause long-term (chronic) problems. All or part of the body may be affected. Someone with an occupational illness may not recognise the symptoms immediately. For example, noise-induced hearing loss is often difficult for victims to detect until it is advanced. What is a safety hazard? A safety hazard is anything that could cause an injury. Injury caused by a safety hazard (such as a cut or fracture) is usually obvious. Safety hazards cause harm when workplace controls are not adequate. Some examples of safety hazards include: slipping/tripping hazards (such as electrical cords across floors) fire and explosion hazards moving parts of machinery, tools, and equipment (such as pinch and nip points) work at height (such as work done on scaffolds or ladders) ejection of material (such as from moulding operations) pressure systems (such as steam boilers and pipes) vehicles (such as forklifts and trucks) lifting and other manual handling operations materials falling from height, rolling, shifting, or caving-in unsafe use of explosives workplace violence hazards posed by working alone or in isolated workplaces
What is severity?
Severity is the seriousness of the harm that could result from a hazard. It is often described as: catastrophic (death and/or permanent) critical (serious injury) marginal (minor injury) negligible (no injury)
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What is a risk?
Risk describes the odds that a hazard will cause harm. It refers to the probability and severity of potential accidents, dangerous occurrences (near accidents that are also sometimes known as near misses), and emergencies (fires and so forth).
Discuss concerns with workers This includes: arranging for supervisors to hold regular crew meetings and tool box talks requiring and encouraging workers to report concerns about potential hazards so they can be promptly and thoroughly investigated taking workers concerns and suggestions seriously discussing concerns with workers everyday planning regular meetings of the occupational health committee to discuss concerns and recommend corrective action
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Review documents This includes: material safety data sheets (MSDSs) and product labels compensation claims accident and inspection reports maintenance reports product literature (users guides, maintenance books, and so forth) committee minutes legislation, industry best practices, municipal bylaws, relevant safety standards, and so forth
Use a job safety analysis A job safety analysis (JSA)3 involves: breaking down each job into its steps analysing the hazards present at each step developing controls for those hazards writing safe work procedures based on each analysis testing, revising, and implementing the written work procedures regularly reviewing each job procedure and keeping it current
Product literature, industry publications, legislation, and health and safety publications are useful starting points for developing JSAs. A job safety analysis usually involves observing an expert, safetyconscious worker doing the selected job. Ask for volunteers. Explain to each volunteer why the JSA is being done and how it will be done. Make it clear that the job and not the worker, is being studied. Some workplaces use group discussions to perform JSAs on new procedures and infrequently performed jobs. Some work procedures consist of several complex tasks. Several JSAs may therefore be needed.
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You can also conduct informal interviews with workers to get information on accidents or near accidents that affect them, or that they witnessed or heard about. What is the role of the occupational health committee? Regular occupational health committee inspections and meetings are a good source of information about workplace hazards. Committees are useful for encouraging workers to discuss their concerns and suggest solutions. Committee inspections can focus on the general physical conditions of the workplace. Committees can support the health and safety activities of supervisors and workers by finding defects workers and supervisors have become used to. In some case, committee inspections may focus on special problems in the workplace.
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What are the steps in investigating concerns? 1 Require and encourage workers to bring specific concerns to their supervisor and general concerns to the committee. For example, a defect in a machine should be promptly drawn to the attention of the local supervisor. A concern about the adequacy of orientation provided to new workers can be brought to the occupational health committee. If the problem cannot be resolved with the supervisor or manager, take it to the local committee for investigation. Keep the worker and supervisor informed during the investigation. The committee can help the worker and employer by gathering information on the risks posed by each identified hazard and various alternative courses of control action. Information can be obtained from industry safety associations, the Divisionand from equipment, tool and material suppliers. Recommendations should be taken to the employer for corrective action. Workers should be kept informed. The committee can help everyone concerned by monitoring the effectiveness of the corrective action taken by the employer.
For more information, see Chapter 3 in the Occupational Health Committee Manual.
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Hazards with a risk of serious injury, and hazards to which workers are exposed frequently or for long periods of time, are your top priority for control.
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Slightly Harmful
Trivial Risk Marginal Risk Moderate Risk
Harmful
Marginal Risk Moderate Risk Substantial Risk
Extremely Harmful
Moderate Risk Substantial Risk Unacceptable Risk
Moderate Risk
Substantial
Unacceptable
Definitions
Slightly harmful examples Superficial injuries, minor cuts and bruises, eye irritation from dust. Harmful examples Lacerations, burns, concussion, serious sprains, minor fractures. Extremely harmful examples Amputations, major fractures, poisonings, multiple injuries, fatal injuries, occupational cancer, other severely life shortening diseases, acute fatal diseases. Note: Marginal here means the risk has been reduced to the lowest level that is reasonably practicable.
Reasonably practicable means practicable unless the person on whom a duty is placed can show that there is a gross disproportion between the benefit of the duty and the cost, in time, trouble and money, of the measures to secure the duty.
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It is more effective to totally integrate health and safety into normal work procedures than it is to have one procedure for safety and another for production or customer/client service.
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How can you control a hazard along the path to the worker? Hazards that cannot be isolated, replaced, enclosed, or automated can sometimes be removed, blocked, absorbed, or diluted before they reach workers. Usually, the further a control keeps a hazard away from workers, the more effective it is. Barriers A hazard can be blocked. For example, proper equipment guarding can protect workers from contacting moving parts. Screens and barriers can block welding flash from reaching workers. Machinery lockout systems can protect maintenance workers from physical agents such as electricity, heat, pressure, and radiation. Absorption Baffles can block or absorb noise. Local exhaust ventilation can remove toxic gasses, dusts, and fumes where they are produced. Dilution Some hazards can be diluted or dissipated. For example, general (dilution) ventilation might dilute the concentration of a hazardous gas with clean, tempered air from the outside. Dilution ventilation is often quite suitable for less toxic products. However, it is not effective for substances that are harmful in low concentrations. It may spread dusts through the workplace rather than removing them. How can you control a hazard at the level of the worker? Control at the level of the worker includes personal protective equipment (PPE), safe work procedures, training, and so forth. This control usually does not remove the risk posed by a hazard. It only reduces the risk of the hazard injuring the worker and lessens the potential seriousness of an injury. Therefore, most safety experts consider control at the level of the worker to be the least effective.
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What are administrative controls? These include introducing new policies, improving work procedures, and requiring workers to use specific personal protective equipment and hygiene practices. For example, job rotations and scheduling can reduce the time that workers are exposed to a hazard. Workers can be rotated through jobs requiring repetitive tendon and muscle movements to prevent cumulative trauma injuries. Noisy processes can be scheduled when few workers are in the workplace. Standardised written work procedures can ensure that work is done safely. Employees can be required to use shower and change facilities to prevent absorption of chemical contaminants. The employer is responsible for enforcing administrative controls. Safe work procedures Safe work procedures state how to perform each job safely, step-by-step. Use a job safety analysis to develop each procedure. Involve workers because they must use the procedures on the job. Describe each step in positive terms, pointing out the reasons why the job must be performed this way. Refer to any required rules, regulations, and personal protective equipment. Make sure workers understand safe work procedures. Use one or more of these techniques: if there are written work procedures for a job, make them available to each worker who must do that job cover applicable safe work procedures during orientation post procedures on bulletin boards explain safe work procedures in meetings coach workers and conduct one-on-one training sessions explain procedures in coaching and one-on-one training sessions hold managers, supervisors, and workers accountable for safe work procedures
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Install devices that allow locks to be applied. Develop written procedures that describe a step-by-step process for locking out all required points on the equipment, getting rid of trapped energy in the mechanism and checking that the locked-out equipment cant be operated or started accidentally. Train workers in the procedures and document the training. Post the procedures at each applicable place of employment. Issue locks to the workers. Post signs on or near the equipment reminding workers that lockout procedures are required for servicing the equipment. Watch the workers the first few times that they use the procedures. Ensure they know how to repair the equipment safely. Monitor the lockout procedures from time to time to ensure that workers are using the required practices. Correct unsafe work practices on the spot and provide refresher training as necessary. Coach the worker in the correct procedures to use. supervisors, and workersand hold them accountable.
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10 Develop and use a system to monitor the health and safety performance of managers, 11 Review your lockout program at least once every year to determine its effectiveness. 12 Document the review process and corrective action you take.
*Lockout means to shut off the power to the machine, get rid of any residual energy trapped in the mechanism, and block parts that could crush or entangle workers repairing the mechanism. A lock for each worker repairing the machine is usually put on the power sources, switches, or starting devices. This protects workers who must work on the equipment.
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Training Supervisors can be trained to apply modern safety management and supervisory practices. Workers can be trained to use standardised safe work practices. Refresher training should be offered periodically. The employer and supervisors are expected to ensure that employees follow safe work practices. The committee should help the employer periodically review and update operating procedures and worker training. Supervision The employer must provide enough competent supervisors to protect workers.5 New and inexperienced workers must be supervised closely. Housekeeping, repair and maintenance programs This includes cleaning, waste disposal, and spill cleanup. Tools, equipment, and machinery are less likely to cause injury if they are kept clean and well maintained. Hygiene practices and facilities Hygiene practices can reduce the risk of toxic materials being absorbed by workers or carried home to their families. Street clothing should be kept in separate lockers to avoid contamination from work clothing. Eating areas can be segregated from work areas. Eating, drinking, and smoking should be forbidden in toxic work areas. Where applicable, workers may be required to shower and change clothes at the end of the shift. Personal protective equipment (PPE) and clothing This is used: where other controls aren't feasible, (for example, when using chainsaws) where additional protection is needed where work is temporary (such as periodic maintenance work)
PPE is much less effective than engineering controls since it does not eliminate the hazard. It must be used, properly and consistently to be effective. Awkward or bulky PPE may prevent a worker from working safely. In some cases, PPE can even create hazards, such as heat stress.
Competent means possessing knowledge, experience and training to perform a specific duty. Competent worker, with respect to a particular task or duty, includes a worker who is being trained to perform that task or carry out that duty and who is under close and competent supervision during that training.
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It is the job of the employer, managers, and supervisors to require workers to use PPE wherever workplace procedures require it. Workers must be trained to use, store, and care for their equipment properly. The employer, supervisor, and workers must understand the limitations of their personal protective equipment. Use coaching and progressive discipline to ensure PPE is used properly. How can you keep controls effective? Monitor the effectiveness of controls during inspections and other health and safety activities. Ensure engineering controls, (ventilation systems and so forth), are regularly maintained by competent people.
When an emergency occurs, decisions must be made quickly. Injury and suffering are made worse when time, resources, trained responders, and equipment are lacking. For example, a Saskatchewan logger was seriously injured deep in the bush during winter. Adequate plans for transporting injured workers had not been prepared. The employer had to take the injured worker to hospital in the back of an open halfton truck. The worker contracted pneumonia and nearly died. Effective written plans should be made to handle emergencies and prevent or minimise fatalities, injuries, and loss. Assemble adequate resources. Train everyone to follow procedures and use appropriate equipment. Provide refresher training regularly. Make sure your organisation has the necessary people, procedures, and resources in place. Clearly define who is responsible for what. Make a senior manager accountable for emergency planning. How to prepare emergency response plans is discussed in the next chapter. 34
Summary Regulation 22 requires a system to identify, assess, and control hazards and emergencies. The system should be built into all production and service procedures. Your system must monitor known hazards, look for potential hazards, and introduce effective controls. Make a senior manager or supervisor accountable for the system and involve workers in drawing it up and monitoring it. A hazard is anything that could hurt someone. Hazards are divided into two groupshealth hazards, and safety hazards. Health hazards cause occupational illnesses. Safety hazards cause physical injuries. To identify hazards and potential emergencies organise inspections, discuss concerns with workers, review documents, and use JSAs to develop written safe work procedures. To assess the risk of hazards injuring workers, measure the probability of each hazard harming workers against the severity of the injuries each hazard could cause. Once hazards have been identified and assessed, set control priorities. Communicate information about each hazard to the workforce. Make sure everyone knows what to do to prevent injury. Develop and implement controls at the source, along the path to the worker, or at the level of the work. Use whatever controls will be most effective under the circumstances. Emergencies usually are accidents or disasters. You should have effective written emergency response plans to protect workers. Pay the same attention to emergency planning as you do to any other activity of the organisation. The next chapter will discuss how to prepare systems to ensure you have the people and resources required to handle emergencies. For more information about hazards and the hazard control process, see Chapter 2 of the Occupational Health Committee Manual. 35
Notes
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Introduction
The last chapter discussed how to identify and control hazards and emergencies. In order to do this, your health and safety program must identify the people and resources needed to support the emergency response. Regulation 22 (c) requires a plan for the identification of internal and external resources, including personnel and equipment, that may be required to respond to an emergency. An emergency is usually an accident or disaster causing serious injury or damage. Emergencies commonly include: fires and explosions major releases of hazardous material or organisms major traffic accidents and train derailments natural disasters such as floods and wind storms
Your organisation must prepare effective emergency response plans and be able to support them if necessary. Effective plans prevent or minimise fatalities, injuries, and loss. Make sure your organisation has the necessary people, procedures, and resources in place. Clearly define who is responsible for what. Train everyone to follow procedures and use appropriate equipment. Provide refresher training regularly. The employer sets up the plans. A senior manager or supervisor should be accountable for keeping plans effective. The committee provides input and monitors the plans effectiveness. Document your plan and keep copies on file.
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The plan must include the following requirements of the regulations: a fire safety plan required by regulation 360 any applicable mine rescue requirements emergency procedures required by regulation 310 to deal with accumulations, spills, or leaks of hazardous chemicals or biological substances
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Set up clear responsibilities for managing each emergency. Pay special attention to emergencies that may happen at remote places of employment. Establish clear responsibilities for communicating from the organisations command centre to workers, the authorities, (fire, police, hospital, and government), and the media. Make sure those in charge will be able to talk to each other during an emergency. Plan how to compassionately and effectively deal with the families of workers who could be endangered by an emergency. Think about what substances could be released, how, where they could reach workers, and how seriously workers could be affected. Use this information to decide what personal protective equipment and supplies are needed and where to make information available to workers. Consider how to prevent crosscontamination of work areas through the ventilation system, or otherwise. Carefully equip, train, and prepare decontamination teams, fire suppression crews, and other specialised units where needed. Make sure replacement members are available for absent personnel. Have a system in place to allow staff to rapidly access information on toxic or infectious materials, and toxic decomposition products.6 List external sources of information. Keep the list current.
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10 Write out decontamination procedures and prepare decontamination areas (either indoors or outdoors). 11 Prepare plans for special problems. For example, think about how to handle chemical spills, or what special fire fighting techniques are needed for chemical fires. 12 Assemble resources for each emergency. For example, make sure you have the proper products readily available to fight chemical fires that could occur at your workplace. Keep products fresh. 13 Make sure all employees know what to do in each emergency. Train all employees to carry out their responsibilities competently. If possible, regularly rehearse each emergency response drill to keep skills current.
Toxic decomposition products are harmful substances given off during the breakdown (such as by heat, chemical reaction, or rotting) of chemicals or substances.
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14 List equipment suppliers, chemical suppliers, and other vendors. Keep the list current. 15 Find out what emergency responders serve your area, such as ambulance services, fire and rescue personnel, medical facilities, trauma counselling services, and other agencies. Find out how long it will take emergency services to reach your facility. Decide which ambulance services and hospitals will care for casualties. Keep your lists current. 16 Make sure the authorities (fire services and so forth) know what emergencies could occur at your workplace. Tell them about any special techniques and protective equipment that must be used (such as techniques to combat hazardous decomposition products that could be given off during a fire at your workplace). Tell the medical authorities about any special antidotes or medical aid that casualties may require. Prepare to provide MSDSs and so forth to the authorities as required. Keep information current. 17 Hold regular practice sessions with emergency response organisations. 18 If an emergency occurs, ensure that the workplace is safe before allowing workers to return to work.
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Recognition of fire/fire hazard All occupants in a building will be trained to respond to a fire emergency. Individuals should know where the alarm switches are and how to use them. They should know: what the fire alarm sounds like, where both the primary and alternate exits are, and what escape routes must be used. Evacuation procedure Once alerted, each person must move at a fast walk (do not run) to the assigned exit. If it is blocked, go to the alternate clear exit for your area. Make sure that exits, doors, and routes throughout the facility are unblocked. Shut down operating machines, close filing drawers, cabinets, and doors as you leave the work area. Designate people in each area to ensure everyone leaves during a drill or an emergency. Check washrooms, storage areas, and other places where employees are likely to be alone. Assembly and roll call Identify designated locations where employees and occupants must assemble after leaving the building. Identify everyone in the assembly area. This will ensure no one is left in the building. Report missing individuals to the fire officer in charge. Do not re-enter the building until the all clear is given by those in charge. Safe re-entry At this time, evacuees will return to the building. Further instructions will be given to employees and other building occupants. Everyone will be told when the officials finally declare the building safe. If the building is not safe to enter, other work arrangements will be made. Debriefing The emergency planning co-ordinators will evaluate all facets of the emergency response, and where necessary, improve the plans. Emergency drills Drills ensure that the plans and procedures will be effective in an actual emergency. Drills give everyone the skills needed in an emergency. Studies show that employees panic and are seriously hurt when they do not know what to do. However, they will act appropriately when regular drills are conducted. The rewards of a quick, orderly response to an emergency outweigh the inconveniences caused by drills.
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Summary
You must have effective written emergency response plans to minimise suffering and loss. The employer is responsible for putting plans into effect. The committee provides input and monitors the plans effectiveness. Plans must identify when an emergency exists and what people, resources, and actions must be brought into play to protect workers and control the situation. Effective plans need a clear and effective chain of command. Everyone in the command structure must know what to do and be trained to do it properly. Identify what resources your plan requires. Keep adequate resources on hand or provide a system to access them quickly from vendors. Detail exactly what must be done to control each emergency you could have at the workplace. Identify and involve local emergency response agencies. Regularly monitor and update your plans carefully. The next chapter talks about how you can ensure everyone knows what they are responsible for in your emergency plans and health and safety activities
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Introduction
We have discussed how to prepare systems to control hazards and respond to emergencies. This chapter talks about how to make sure everyone knows their health and safety duties. Your health and safety programs success depends on clear responsibility and accountability. This is why regulation 22 (d) requires your program to includea statement of the responsibilities of the employer, the supervisors and the workers. Employers, supervisors, and workers are all legally responsible for health and safety in the workplace. Everyone must be individually accountable for carrying out his or her responsibilities. The greater the authority, the greater the responsibility. Sections 3 and 4 of the Act and regulations 12, 13, and 17 state the general duties of employers, supervisors, and workers. Subcontractors, owners, and suppliers also have duties for health and safety. Everyone must work together to control hazards and prevent emergencies.
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Health and safety should be handled like any other activity. Duties should be assigned accordingly. Health and safety is not an extra part of each job, it is an integral component. Put responsibilities for health and safety into every job description in the organisation. Hold a senior manager accountable. Make specific managers and supervisors accountable for implementing each program element. For example, name the employee(s) responsible for ordering safety equipment, managing maintenance, and supplying the resources required for work to be done safely. Your statement must: assign specific responsibilities and put them in writing accompany assignments with a monitoring system to ensure compliance state what consequences follow when health and safety responsibilities are not carried out
Have the committee provide input and audit the effectiveness of the system. Document your statement and keep copies on file. Do this with each element of your safety program. We will begin with a discussion of responsibility and authority. Next we will discuss the health and safety program responsibilities. See the Introduction for more information about responsibilities within the internal responsibility system (IRS).
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Once the organisation has put these elements in place, health and safety performance should be measured in regular performance reviews. We will now discuss general responsibilities within a health and safety program. Specific responsibilities and lines of authority will reflect the needs of the workplace.
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providing a plant that does not endanger the health and safety of anyone working in, on or near the plant8 knowing and following health and safety requirements
Owner includes: (i) a trustee, receiver, mortgagee in possession, tenant, lessee or occupier of any lands or premises used or to be used as a place of employment; and (ii) any person who acts for or on behalf of a person mentioned in subclause (i) as that persons agent or delegate.
Section 2(1) (x) of the Act defines plant as including any premises, site, land, mine, water, structure, fixture or equipment employed or used in the carrying out of an occupation. Equipment means any mechanical or non-mechanical article or device, and includes any machine, tool, appliance, apparatus, implement, service or utility, but does not include the personal property owned by an individual unless that property is used in the carrying on of an occupation.
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A contractor means a person who, or a partnership or group of people that, pursuant to one or more contracts, directs the activities of one or more employers or self-employed people involved in work at a place of employment.
A subcontractor is not defined in the legislation. In this publication, it means the employer or self-employed person hired to work under contract.
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Summary
Your programs success depends on clearly defined responsibilities and accountabilities. Handle health and safety responsibilities like responsibilities in any other area of the organisation. Responsibility means being accountable for carrying out a task. Authority is the right to direct others. Specific responsibilities reflect the needs of the workplace. The employer at the workplace remains accountable for the health and safety program. Managers are responsible for implementing the employers health and safety program. This includes ensuring their subordinates have adequate training, resources, and time to carry out their responsibilities properly. Supervisors run the program in each work area. Workers carry out their responsibilities within the program, such as following safety rules, using correct tools, personal protective equipment, and so forth. If you hire an outside company or self-employed person on a contract and direct their activities, then you become a contractor under Saskatchewans health and safety legislation. You and the subcontractor need to set up a system of shared responsibility for the health and safety of all workers. When working for another employer, subcontractors are responsible for work they control. This includes a duty to inform others about any hazards their work could create. Suppliers are responsible for providing safe products, when used as directed. This includes a duty to provide instructions for the safe assembly, use, and disassembly of their products or equipment. Owners are expected to make sure that their work areas, buildings, and so forth that are being used by others are safe. This includes a responsibility to warn others of hazards. Safety co-ordinators (professionals) are expected to help everyone to carry out their duties properly. Everyone must know and follow applicable sections of the Act and regulations. The next chapter discusses how you can use inspections to check on the effectiveness of your programs systems.
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Notes
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Schedule inspections
What types of inspections should be done? Who is responsible for what within the inspection schedule? When should inspections be carried out? What should be inspected? What checklists and reporting procedures should be used? What training is required? How can defects be corrected?
Introduction
Inspections are one of the most common and effective tools for identifying and correcting problems before they cause accidents. Inspections should also be used to draw attention to and encourage good health and safety practices. That is why regulation 22 (e) requires your health and safety program to includea schedule for the regular inspection of the place of employment and of work processes and procedures. Generally speaking there are two types of inspectionsinformal inspections and formal, planned inspections. Informal inspections These really boil down to conscious awareness of health and safety hazards and controls as people do their jobs. Informal inspections are an important part of an effective system of hazard identification and control that should be done by workers, supervisors, and managers. Since workers are often the first to see things happen, they should be required and encouraged to report hazards. Two important steps for encouraging this are taking concerns seriously, and keeping workers informed about the status of remedial action (when and how the correction will be made, or why the corrective action has been delayed or denied). Formal, planned inspections A formal inspection is a planned walk through or examination of a workplace, selected work area or particular hazards, machinery, tools, equipment and work practices. Formal inspections must include an inspection of work processes and procedures to ensure the adequacy of safe work procedures.
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In any workplace, day to day activities create health and safety hazards. People, equipment, materials, and the environment constantly change. Some environmental changes remove hazards, while other changes create new hazards. Inspections help focus attention on change, and help solve problems before they cause accidents. Formal, planned inspections help to: identify potential problems before they cause accidents identify equipment problems resulting from such things as wear and tear or improper use identify improper work practices draw attention to good health and safety practices identify new hazards resulting from changes in the workplace identify inadequacies in corrective action that has been taken
This chapter deals with planned inspections. We will summarise the inspection process. For detailed information about how to conduct inspections, see Chapter 7 of the Occupational Health Committee Manual. The Occupational Health and Safety Division also offers a course on how to conduct inspections. For more information, contact the Regina office of the Division. Regulation 23 requires the employer to arrange for regular examinations of any plant under the control of the employer.10 Regulation 28 requires the employer to enable the occupational health committee to inspect the place of employment at reasonable intervals. The Division recommends that your committee inspect the workplace before each regularly scheduled meeting.
Regulation 23 Inspections Regulation 28 Inspections
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Section 2(1) (x) of the Act defines plant as including any premises, site, land, mine, water, structure, fixture or equipment employed or used in the carrying out of an occupation. Equipment means any mechanical or non-mechanical article or device, and includes any machine, tool, appliance, apparatus, implement, service or utility, but does not include the personal property owned by an individual unless that property is used in the carrying on of an occupation.
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Regulation 23 Inspections Inspections by: " managers, supervisors, workers, operators, and maintenance personnel " health and safety co-ordinators " employers and owners
Your inspection schedule must: identify what will be inspected, (work areas, equipment, tools, procedures, practices, and so forth), by whom, and how frequently include inspections of work procedures and production processes state what inspection records must be produced to ensure accountability provide for correcting defects found during each inspection state what training those who carry out inspections require
Document your inspection activities and keep copies on file. Do this with each element of your safety program.
attention to good health and safety practices, and to identify potential problems before accidents happen. These inspections may be done monthly or quarterly. However, if there is a higher level of risk, or the workplace is changing rapidly, they should be done more frequently. 6 Senior management inspections These inspections help reinforce the importance of good health and safety practices, and keep senior management in touch with health and safety issues in the workplace. They are not comprehensive inspections; instead they are tours of work areas specifically designed to focus on particular health and safety issues. Regular occupational health committee inspections These should complement inspections done by managers, supervisors, and workers. It is a good idea for a committee to conduct an inspection before each regular meeting. Committee inspections can focus on the general physical conditions of the workplace, thereby auditing the effectiveness of the inspection schedule or other elements of the occupational health and safety program. Committees can support the health and safety activities of supervisors and workers by finding defects supervisors and workers have become used to. In some cases, committee inspections may also focus on special problems in the workplace. When an occupational health committee brings a problem or concern to the attention of an employer, the employer is required to resolve the problem or address the concern. If that cannot be done, the employer is required to give the committee a written reason for not resolving the problem or addressing the concern.
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the frequency and scope of those inspections. Your program must identify what is to be inspected and who will do each inspection. Make sure anyone given inspection responsibility gets the training they need to fulfil their responsibilities.
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Provide a place on your inspection recording and reporting forms to classify hazards and identify recommendations for corrective action. Keep file copies of inspection reports and checklists. You or the committee may need them someday to track corrective action and review the history of specific concerns.
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Summary
Inspections are one of the most common and effective tools for identifying and correcting problems before they cause accidents. Generally speaking there are two types of inspectionsinformal inspections and formal inspections. Informal inspections really boil down to conscious awareness of health and safety hazards and controls as people do their jobs. A formal inspection is a planned walk through or examination of a workplace, selected work area or particular hazards, machinery, tools, equipment and work practices. Regulation 23 requires the employer to arrange for regular examinations of any plant under the control of the employer. Workers, operators, supervisors, maintenance personnel, safety professionals, and others can carry out regulation 23 inspections. Regulation 28 requires the employer to enable the occupational health committee to inspect the place of employment at reasonable intervals. The employer must schedule regular inspections of items such as work processes and procedures to find hazards and potential hazards in the place of employment. Your inspection schedule should be as good as any other schedule in the organisation. The work performed determines what requires inspecting and when inspections should be conducted. Organise an inspection system that will effectively review the safety of every hazardous or potentially hazardous area of the organisation. Make or purchase and adapt appropriate checklists and inspection reporting forms. Document and keep good records of your inspection activities. Provide the training inspectors need to be competent. Correct life-threatening dangers found on inspections at once. Use the principles of hazard assessment and control to develop solutions to all hazards. Search for the root causes of defects.
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Ask workers and supervisors for suggestions about how to fix defects. Keep employees who have raised concerns informed. Use normal communications channels to provide information to the workforce. Regularly evaluate your inspection schedule, just as you evaluate other activities of the organisation. For detailed information about how to conduct inspections, see Chapter 7 of the Occupational Health Committee Manual. The Occupational Health and Safety Division also offers a course on how to conduct inspections. For more information, contact the Regina office of the Division. The next chapter discusses how you can control the hazards of chemical and biological substances. Use this information when planning inspections.
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Occupational Health and Safety Division Chapter 6, Control Chemicals and Biohazards
Introduction
Most workplaces have some chemical hazards and biological hazards (biohazards). Exposures harm Saskatchewan workers every year. In order to control them, you must have a clear idea of what they are, how they act, and where they are in the workplace. That is why your occupational health and safety program must includea plan for the control of any biological or chemical substance handled, used, stored, produced or disposed of at the place of employment and, where appropriate, the monitoring of the work environment. The employer sets up the plan. The committee provides input and advice. Use occupational health committee inspections and other activities to audit the plans effectiveness. Include the plan in your safety program and document your activities. Keep file copies. A successful plan requires the commitment and leadership of the employer. A senior manager should run the plan. Everyone should have clear responsibilities and accountabilities.
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Your plan to control chemical and biological substances must meet these requirements: Part XXI of the regulations: Chemical and Biological Substances. The employer must protect workers from the hazards of chemical and biological substances. Pay attention to the general duties of the employer set out in regulation 302. Your plan must carry them out. Part XXII of the regulations: Workplace Hazardous Materials Information System (WHMIS). The employer must protect workers from products controlled under WHMIS. Regulation 85 in Part VI: General Health Requirements. The employer must protect workers from biohazards that are either known or suspected causes of human infections.
This chapter will discuss these topics and help you prepare your plan. For detailed information, read the Divisions publication: A Guide to the Chemical Substances Regulations.
Besides causing illness, chemical hazards can impair judgement, reduce reaction time, and increase the risk of accidents. Read product labels carefully. Know the hazards. 66
Occupational Health and Safety Division Chapter 6, Control Chemicals and Biohazards
What are biological hazards? Biohazards are living things, or substances produced by living things, that can illness or disease. Examples include: micro-organisms (such as bacteria and viruses) fungi (simple plants that feed on dead plant or animal tissue) parasites (these live in the bodies of plants or animals) plants (substances given off by some plants can cause allergies. Several plants contain poisonous substances)
Workers in food processing, sewage disposal, laboratories, agriculture, and other industries handle potentially hazardous biological substances. Examples of possible biohazards include animal tissues, plant materials, and micro-organisms. Biological substances include products or extracts of plants, animals, and micro-organisms. Some can be ingredients in workplace products. For example, bacterial enzymes are in some industrial detergents. What about indirect exposures? Sometimes workers dont use, produce, or handle chemical and biological substances directly. But, they can be exposed to them when the substances are released into the workplace. For example, hazardous products can be given off during welding, sawing or grinding, dry-cleaning, and during oil drilling and well servicing operations. Health care workers, emergency response workers, animal handlers, and others may be exposed to infectious biological substances when they deal with infectious people or animals. Hazardous substances may be released from structural materials such as insulation, new carpeting, and furniture. Bacteria and fungi may grow on moist furnishings and structural materials. They can grow in water near ventilation intakes and in ventilation systems. Micro-organisms, (and in some cases their spores, toxins, and other products), can get into the workplace air. They can settle on food and objects in the workplace and get into workers bodies.
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Workers may also be exposed to stored chemicals or chemicals that have spilled, leaked, or accumulated. Your chemical and biohazards plan must identify and control any of these hazards in your workplace.
What responsibilities and accountabilities are required? The plan must assign responsibilities to those who order, purchase, and receive chemical and biological substances. Those responsible must obtain appropriate hazard information and ensure worker protection and training is adequate. A centralised or structured hazardous product ordering system may help do this.
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Occupational Health and Safety Division Chapter 6, Control Chemicals and Biohazards
What additional measures must be taken? Your plan must also ensure that: releases of hazardous substances into the work environment are prevented or minimised containment and ventilation systems are regularly serviced the workplace is cleaned and decontaminated properly contaminated workers are decontaminated promptly personal protective equipment is inspected, used, cleaned, maintained, and stored properly spills, leaks, accidents, and so forth are investigated properly adequate response plans are in place for spills, leaks, and other emergencies the work environment is effectively assessed for contaminants
What about information for workers? Information about chemicals and biohazards must be: readily available to workers used to set up adequate hazard controls, educate workers, and monitor the work environment for contaminants kept current
What is required by regulation 85? Regulation 85 discusses hazards caused by exposures to infectious materials or organisms listed in Table 14 of the Appendix to the regulations. Exposure is defined as any harmful contact by: inhalation (for example, breathing in mould spores) ingestion (for example, swallowing bacteria with food or smokes) absorption through the skin (for example, entry through pores) 69
Regulation 85 requires the employer to implement a written control plan that: identifies workers who may be exposed sets out how those workers could be exposed sets out disinfection procedures and other hazard controls specifies what training and information workers must have
Several Occupational Health and Safety Division publications provide more information.
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Occupational Health and Safety Division Chapter 6, Control Chemicals and Biohazards
Reduce or prevent exposure whenever reasonable and practical.11 Reduce contamination of workers and the workplace as much as you can. Whenever you can, use engineering methods to control hazardous substances at the place they are produced. Use personal protective equipment (PPE) as a last resort. When reasonable and practical, eliminate hazardous substances, or replace them with less hazardous ones whenever substitutes are available. Use information from suppliers and your industry to help you decide what to do. Take all practicable steps to prevent workers from being harmed by these substances. Re-engineer work procedures, production process, and work flows to make them safer and healthier. Build health and safety into all work procedures. Develop safe work practices where needed. Train workers to handle hazardous substances safely. Tell them: how each substance causes harm what harm is involved how serious the harm can be the risks of being harmed how to reduce exposure how to prevent harm what to do during an accident or emergency
6 7 8 9
10 The committee provides advice and audits the effectiveness of the training. 11 Determine how safely flammable, unstable, highly reactive, and corrosive substances are stored by your organisation. Correct any defects. See regulation 314 for more information. 12 Prepare emergency plans. Include them in your safety program. Think about what could happen if there is an accident with a hazardous substance. What emergency response plans are required? See regulation 310 for more information.
Section 2(1)(y) of the Act defines practicable as possible given current knowledge, technology and invention. Section 2(1)(aa) defines reasonably practicable as practicable unless the person on whom a duty is placed can show that there is a gross disproportion between the benefit of the duty and the cost, in time, trouble and money, of the measures to secure the duty.
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Set up a centralised ordering or receiving system. This will help ensure that the right information is received. Assign a competent person(s) to track the flow of information and make sure it is used properly. What issues must the WHMIS plan address? 1 How to ensure an acceptable MSDS (complete and less than three years old) arrives with each controlled product. The content of an acceptable MSDS is set out in regulations 325-329. How to make relevant MSDSs readily available to workers who need them. Regulation 327 sets out the details. How to ensure that correct WHMIS labels (supplier and workplace) are attached to each container of controlled products. See regulations 319-324 for labelling requirements. How to develop and deliver a training program on: the WHMIS system the hazards of controlled products safe handling requirements, emergency procedures, and processes for dealing with fugitive emissions12
2 3
12
A fugitive emission is a chemical that is given off as an unintended by product of a process, or during the use of a chemical.
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Occupational Health and Safety Division Chapter 6, Control Chemicals and Biohazards
Regulation 318 sets out the content for WHMIS training programs. Training program content is explained in the Division publication WHMIS Requirements for Worker Training.
What about hazardous products exempt from WHMIS? Some hazardous workplace products are exempt from WHMIS requirements for supplier labels and MSDSs. Consumer products, explosives, pesticides, drugs, cosmetics, and radioactive substances are subject to labelling and disclosure requirements under other federal legislation. Hazardous waste is exempted from WHMIS MSDS requirements. Employers must collect and record the hazards of these substances and determine how to safely handle them. Containers must be clearly labelled. Workers must be told about hazards and trained to handle the materials safely. The plan must state how information about the hazards of these products will be collected and built-into WHMIS training.
What about chemical and biological substances with assigned Workplace Contamination Limits (WCLs)?
Workplace Contamination Limits (WCLs) state exposure limits for specific chemical and biological substances. There are both 15 minute WCLs and 8 hour WCLs. Fifteen minute WCLs measure exposures over 15 minute time periods. Eight-hour WCLs measure average exposures over the shift. Worker exposures must not exceed either WCL. The regulations assign WCLs to many workplace chemicals and to some biological substances. Substances with WCLs are listed in Table 21 of the Appendix to the regulations. Regulation 307 states how the employer must protect workers from substances with regulated WCLs. Workers must not be exposed to average airborne concentrations of these substances above the WCLs. The employer must take all reasonably practicable steps to ensure that these limits are not exceeded in any area where a worker is usually present.
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Airborne concentrations can be lowered by engineering controls, such as ventilation or enclosures. When properly engineered and maintained, these controls usually prevent or minimise releases of substances into the work environment. Sometimes it may not be reasonably practicable to use engineering controls. For example, say a substance is used only once a year during maintenance. If so, the employer would not usually have to install a mechanical exhaust system to keep exposure below the WCL. The employer could protect the workers in other ways. For example, the employer could provide workers with personal protective equipment and require its use. What monitoring is needed? Monitoring (air sampling, personal assessment of exposure, and so forth) measures contaminants in the workplace. Monitoring can help assess the risks faced and the adequacy of hazard controls. The program must have a monitoring plan where: 1 The work environment may not be safe because of: 2 lack of information about how badly the workplace is contaminated; fluctuations in concentrations of contaminants; variations in how often workers are exposed to contaminants; or
Workers have complained about their health, or may have become ill, because of exposures to workplace contaminants; and existing monitoring test results are suspect or unsatisfactory.
Monitoring is not required where there is no standard method of obtaining reliable results or the results obtained with a standard method do not provide meaningful measures of the risk. What about extended shifts and workweeks? Eight-hour WCLs may not protect workers on extended shifts (more than 8 hours a day) or extended workweeks (more than 40 hours). This is because a larger cumulative (total) dose is received over a shorter time. In these cases exposure should be limited to a proportion of each applicable WCL. For example, 2/3 of the WCL should be assigned for a 12-hour shift, unless there is solid evidence that the lower exposure limit is not justified.
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Occupational Health and Safety Division Chapter 6, Control Chemicals and Biohazards
What about multiple exposures? WCLs are designed to measure exposure to one chemical at a time. Sometimes workers are exposed to several substances that harm the same body organs in similar ways. The combined harm is called an additive effect. Although the concentration of each chemical is lower than each chemicals WCL, the combined effects may be hazardous. In these cases exposures must be limited to a fraction of each chemicals WCL. For more information, see the Division publication, A Guide to The Chemical Substances Regulations. What corrective action is required? The employer must protect workers from unusual and prolonged exposures. Protective measures must include action to protect workers working extended shifts and workers exposed to several chemicals. The employer must develop and implement an appropriate work procedure that reduces the risks. The committee provides input and advice during development of the procedure. The procedure must identify:
the substances involved conditions under which workers will be required or permitted to work the frequency and length of exposure to the substances steps the employer will take to ensure no workers personal exposure exceeds the equivalent of the WCL for each substance involved
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Occupational Health and Safety Division Chapter 6, Control Chemicals and Biohazards
Where blood or potentially infectious body fluids is involved, the employer must take prescribed actions to protect workers. Actions include arranging confidential post-exposure counselling, medical evaluation, or medical intervention by a qualified person. Actions and interventions must be acceptable to the Department of Health. These follow-up actions are provided when the exposed worker requests them. They must be conducted during the workers normal working hours. Alternatively, time spent in the post-exposure followup by the worker can be credited as time at work. In other words, the worker loses no pay or benefits for spending time in a post-exposure follow-up. The plan must meet all other requirements in regulation 85.
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What about pregnant workers and workers who are hypersensitive or unusually responsive to a substance?
Workers who may be hypersensitive or are unusually responsive to a substance, or who are pregnant, may require additional protection. If there is a substance present in a form and to an extent that may harm these workers, and the worker notifies the employer of their condition or their response to the substance, the employer must take steps to minimise the exposure. What happens if the worker requests alternate work? The worker may request less hazardous work. If reasonable measures will not minimise exposure, the employer must provide less hazardous work, if available. Sometimes reasonable measures do not completely protect a hypersensitive worker. Alternative work may not be available. If so, the employer usually is not expected to take further action. Your plan should include a process to address these situations. Regulation 308 provides more information.
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Occupational Health and Safety Division Chapter 6, Control Chemicals and Biohazards
Summary
You must have a plan to control chemical and biological hazards. These plans must carry out the duties set by parts XXI, XXII, and section 85 of the regulations. Your plan must address how appropriate information about hazards will be obtained and communicated to workers. Use standard hazard control techniques to identify, assess, and control these hazards. Use the resulting information to develop safe work procedures and production or client service procedures. Ensure workers receive adequate training about chemical and biological hazards in the workplace. They must know how to control the hazards they face and respond to emergencies. Assign clear responsibilities for setting up your plan and keeping it working properly. Pay special attention to controlling the hazards from regulated substances. Ensure workers are not exposed to limits beyond listed WCLs. Protect pregnant, hypersensitive, and unusually responsive workers. Provide alternate work when requested, if other controls are not effective. Finally, provide your plan with good leadership and clear objectives.
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Notes
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Introduction
Effective training is essential to good health and safety. Remember, health and safety is about how your organisation functions. It is about doing jobs right the first time. Your occupational health and safety program will not work unless supervisors and workers know what to do and how to do it. This is why regulation 22 (g) requiresa plan for training workers and supervisors in safe work practices and procedures, including any procedures, plans, policies or programs that the employer is required to develop pursuant to the Act or any regulations made pursuant to the Act that apply to work of the workers and supervisors. This chapter will help you develop the training employees need to carry out their responsibilities in your health and safety program. We will begin by defining what training means. Next, we will discuss what your training plan should do and who needs training. At the end of the chapter, we provide a chart listing regulatory information to include in your training plan. Put a senior manager or supervisor in charge of your training plan. Work with the occupational health committee to develop the training plan. Have the committee audit its effectiveness. Maintain training records (for workers, supervisors, and committee members). Include the date of the training, participants, and a summary of the content.
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What is training?
Training means more than providing information. It requires a practical demonstration that each employee has acquired the skill or knowledge related to the job.
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What is the role of the occupational health committee? One of the duties of the committee is to establish, promote, and recommend the means of delivery for health and safety training for the education and information of workers. As you consult the committee in developing your health and safety program, this will be an area of particular interest to the committee. The committee: works with the employer on setting up the training plan helps the employer to promote training makes sure co-chairpersons and members are trained are trained in their roles and the functions of the committee recommends how training and information should be delivered applies the training its members receive to audit the effectiveness of the training plan and other elements of the occupational health and safety program
Do not forget your managers. They provide resources to supervisors and set supervisory priorities. They must know their role in the health and safety program too!
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Also, supervisors are often responsible for training their workers. If this is the case, supervisors should have the necessary training and skill to: instruct workers prepare a proper plan of instruction explain why each step in a safe work procedure must be followed
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Competent means possessing the knowledge, experience, and training to perform a specific duty.
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Regulations
196(1)(b) 198(3) 204(2)(b) & 205(1)(b) 207(1)(b) 208(6)(a) 209(2)(b) 228(b) 242(2) 253(3) 263(7) 272(3) 274(4)(a)(7)(c) 279(1)(b) 302(3)(a)(b) 304(2) 310(c) 316(4) 318(3) 322 324(6)(7) 327(4)(c) 337(2)(c) 341(4) 343 360(2)(d)(3)(a)
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Regulations
363(2) 371(1)(c) 374(3) 376(1)(a) 388(c) 392(2)(b) 412(2)(h) 448(b) 467(3) 470(1)(f) 471(7)(b) 472(2)(a) 476(b) 477(4)(b)(i) 478 482
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Summary
Your health and safety program needs a training plan to be effective. Training requires trainees to demonstrate they have acquired the knowledge or skills taught. Orientate and train workers to work safely. Your training plan must build your health and safety program into jobs, work procedures, and production processes throughout the organisation. Like other plans, it must have a mechanism to deliver the training, assign responsibilities, and monitor effectiveness. The committee assists the employer and audits the plans effectiveness. Train everyone with duties under the legislation and your program.
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Introduction
Previous chapters talked about health and safety program elements, how to prevent accidents, near accidents, refusals to work under section 23 of the Act, and so on. Unfortunately, there may be occasions when something goes wrong and an accident or work refusal occurs. Investigations of accidents and dangerous occurrences provide valuable information needed to prevent recurrences. Proper investigations of work refusals are crucial to resolving the refusal and correcting any circumstances that led to the refusal in the first place. An effective investigation procedure can find root causes and prevent recurrences. This is why regulation 22 (h) requiresa procedure for the investigation of accidents, dangerous occurrences and refusals to work pursuant to section 23 of the Act at the place of employment. An accident is any unplanned event that causes injury. A dangerous occurrence (see regulation 9) is any event that could have injured someone, but did not. Dangerous occurrences are often called near misses or near accidents. We will use the term incident in this chapter to describe both accidents and dangerous occurrences. A refusal to work is defined under section 23 of the Act asthe right to refuse to perform any particular act or series of acts at a place of employment where the worker has reasonable grounds to believe that the act or series of acts is unusually dangerous to the workers health or safety or the health or safety of any other person at the place of employment until: (a) sufficient steps have been taken to satisfy the worker otherwise; or (b) the occupational health committee has investigated the matter and advised the worker otherwise.
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This chapter will help you prepare procedures to investigate incidents and refusals to work. Chapters 3, 4, 8, and 9 of the Occupational Health Committee Manual have more information. The Divisions Level I course covers investigating refusals to work. The Level II course covers how to conduct inspections and incident investigations. For more information, phone the Regina office.
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What must be investigated? Regulation 29 requires the employer to arrange the investigation of accidents that: 1 2 Cause the death of a worker; or Require a worker to be admitted to a hospital as an in-patient for 24 hours or more.
The investigation must be done as soon as is reasonably possible by the committee co-chairpersons or their designates. Regulation 31 sets similar requirements for investigating dangerous occurrences. What else should be investigated? Your procedure must also include investigations of potentially harmful exposures to any substance listed in Table 19 or 20 of the regulations. Examples include exposures resulting from accumulations, spills, or leaks. Regulation 311 lists the content of investigation reports. Your occupational health and safety program should also provide for the investigation of injuries, illnesses, and conditions that do not require hospitalisation. Examples include chronic illnesses, musculoskeletal injuries, and exposures to infectious materials. In summary, the Division recommends you investigate any incident that hurts someone, or could hurt someone. What incidents must be reported to the Division? Regulations 8 and 9 require the employer to notify the Division of accidents and dangerous occurrences that resulted, or could have resulted, in: 1 2 Death; or Hospitalisation of a worker for more than 72 hours.
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2.
Direct The direct cause(s) usually occurs immediately before the incident. For example, a direct cause might be a collapsing jack that dropped a car onto a worker. Indirect Indirect cause(s) set the stage for an accident and can include: lack of training and supervision inadequate tools, equipment, and materials departures from safe work procedures
Root An incident may or may not have one ultimate root cause, such as an inadequate health and safety program. Root causes allow indirect and direct causes to develop. The committee and employer should try to find if there were any symptoms before the incident. If so, why did the internal responsibility system fail to correct the problem? 3. 94 Write a report recommending corrective action
Review what happened at each step in the incident. Prepare a report describing what happened. Use photos and drawings to illustrate key points. Recommend corrective action, including both short and long-term controls, to prevent the same thing from happening again. Short-term controls should prevent a recurrence until longer-term controls can remove the root causes. File a copy of the report and post summaries for the information of workers. The employer should take appropriate corrective action based on the report and inform the committee. The committee should audit the effectiveness of the corrective action. For detailed information, read Chapter 8 of the Occupational Health Committee Manual.
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What is unusually dangerous work? Under section 23 of the Act, each employee has the right to refuse work that the worker has reasonable ground to believe is unusually dangerous. The unusual danger may threaten workers or others. An unusual danger could include: a danger that is not normal for the job a danger that would normally stop work a situation for which the worker is not properly trained, equipped, or experienced
Remember these key points about the right to refuse: section 23 applies only to health and safety issues refusing to work is an individual decision (not a group decision) it must be based on personal belief the personal belief must be based on reasonable grounds that the disputed work is unusually dangerous
To determine if there are reasonable grounds, ask this question: would an average workerwith the same training and experience and using honest, professional judgementagree that the disputed work presents an unacceptable risk? If the refusal is used for legitimate health and safety reasons, the worker is legally protected from discipline or other sanctions taken by the employer. For more information, see section 27 of the Act. The refusal may continue until either the worker is satisfied the job is no longer unusually dangerous or an occupational health officer has ruled against the refusal. During the refusal, the refusing worker must remain at the workplace unless the employer advises otherwise.
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How should a refusal to work be investigated? The refusing worker should inform the supervisor that the work is being refused for health and safety reasons. The worker should help the supervisor to solve the problem. The refusing worker should not leave the site without the permission of the employer. If the supervisor and worker cannot resolve the concern, the committee co-chairpersons may be asked to help. The co-chairpersons have no right to rule on whether the disputed job is unusually dangerous. Their role is to help the worker and supervisor resolve the problem and to collect information for the rest of the occupational health committee. If they are unable to satisfy the refusing worker, the committee must decide on the refusal. Occupational health committees are expected to investigate refusals. During the investigation, principles set out in Part IV of the Act must be followed. During the investigation, anyone involved may contact the Division for help and advice. However, the committee must try to resolve the matter internally first. Once involved, the committee should take the following steps to investigate a refusal. 1 Hold an emergency committee meeting If the refusing worker is not satisfied, have the full committee investigate. Hold an emergency committee meeting and vote on the refusal. Contact the Division If the refusing worker is not satisfied, then contact an occupational health officer. Inform workers Inform employees about the investigations findings, or the officers ruling. Anyone involved may appeal the officers ruling to the Director of the Division. The officers decision stands unless an appeal overturns it. Monitor the effectiveness of corrective action The effectiveness of corrective action should be checked by the committee during inspections, conversations with workers, and other activities.
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Summary
You must have a procedure to investigate incidents and refusals to work. Like other parts of the health and safety program, you should identify what must be done and who must do it. You must investigate accidents and dangerous occurrences described by regulations 29 and 31. You must investigate accidental exposures to substances listed in Table 19 or 20 of the Appendix to the regulations. You should also investigate all lost time injuries, illnesses, and conditions. In summary, it is a good idea to investigate anything that hurts someone, or could hurt someone. There are many different incident investigation models. Select one that fits the needs of your workplace. Whatever model you use, make sure it helps you find the incidents root causes. Your procedure should have an effective mechanism to identify and resolve concerns before they escalate. The committee can be invaluable in helping the employer and workers talk about issues and find solutions. Your procedure to investigate refusals to work should follow the steps outlined in this chapter. Chapter 3 of the Occupational Health Committee Manual explains the procedure in more detail. The next chapter will help you develop a strategy to involve workers to avoid incidents and refusals to work.
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Introduction
An effective health and safety program needs worker commitment and participation. It must be developed in consultation with your occupational health committee. But more than that, all employees need to be involved in your efforts to prevent accidents and occupational diseases. This is especially important in small organisations, where there may not be the same access to professional health and safety expertise as there is in many large organisations. Workers must be familiar with the program, know their rights and responsibilities, and understand how to handle concerns. Your program should encourage workers to suggest ways to make the workplace safer and healthier. If workers are going to actively participate in reporting hazards and suggesting improvements, they must know they will not be subjected to reprisals, and that their concerns and suggestions will be taken seriously. The deeds of managers and supervisors speak louder than words. The last chapter talked about incidents and refusals to work. This chapter will help you involve your workers. A good worker participation strategy will minimise the risk of an incident or refusal happening in your workplace. Your program wont work without the support of employees, from senior managers to new hires. Everyone must know: their role in the health and safety program their rights and responsibilities how to report/deal with concerns how to suggest improvements in the health and safety program
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This is why regulation 22 (i) requiresa strategy for worker participation in occupational health and safety activities, including audit inspections and investigations of accidents, dangerous occurrences and refusals to work pursuant to section 23 of The Occupational Health and Safety Act, 1993. Like other strategies within your program, effectiveness depends on the commitment and leadership of the employer, senior management, and supervisors. Your program must also address how the occupational health committee will be kept effective. Methods include: training committee members enhancing communication between the committee, workers, and senior management responding promptly to problems or concerns raised by the committee considering the committees recommendations during the development of plans, policies, programs, and procedures required by the legislation
The employer is required to resolve the problem or address the concern. If that cannot be done, you must give the committee a written reason for not resolving the problem or addressing the concern. The occupational health committee should be the internal auditor of the occupational health and safety program and should advise the employer on the participation strategy.
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5 6
Protecting workers from reprisals for raising concerns or making suggestions. Responding promptly to concerns and suggestions raised by workers, and keeping workers informed about the status of corrective action.
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What about health and safety incentives? Leading organisations encourage and reward excellent health and safety performance in the same way that excellence in other areas is encouraged and rewarded.
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Summary
Successful occupational health and safety programs have a strategy to involve employees and get their commitment. Do this by setting up an effective committee. Consult workers directly where appropriate. As well, build health and safety into the culture of the organisation and each job. Treat it like any other activity. Treat health and safety incentives just like incentives in other areas of the organisation. The next chapter will help you develop a procedure to evaluate your program and keep it effective.
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Notes
104
Introduction
Previous chapters have talked about how to set up plans to make your health and safety program work. But how will you know if it is working properly? How will you keep it current? This is why regulation 22 (j) requiresa procedure to review and, where necessary, revise the occupational health and safety program at specified intervals that are not greater than three years and whenever there is a change of circumstances that may affect the health or safety of workers.
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The evaluation should ensure that the program achieves its objectives and addresses new or emerging issues. Your procedure should state how: the program and each of its elements will be reviewed and revised what methods will be used when each program element will be reviewed and revised what the role of the committee will be who will take what actions and keep what documents
At the minimum, the program must be reviewed and revised within three-year intervals. This does not prevent you from reviewing and revising your program on an ongoing basis. Conduct additional reviews whenever: 1 There are changes in the workplace that may affect health or safety. Changes include the introduction of new technologies, production methods, or hazards. Review the program when you discover new hazards in the workplace. Problems develop. Problems may be identified through inspections, concerns, audits, and investigations. You become aware of better ways to do the job.
2 3
This chapter will help you review each element in your health and safety program. Each heading is based on a clause in regulation 22. Adapt the material to suit your needs. The entire program does not have to be evaluated at once. You may wish to evaluate your program one element at a time. The objective of the review procedure is to ensure that your program works properly and controls new hazards.
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General questions to consider # Is senior management directly involved in the program? # Does senior management set an example? # What is the nature and degree of the accidents and emergencies that could occur in the organisation? # How does your organisation compare with others in your industry? # Is the work environment clean, well ventilated, adequately lit, and so forth? # Is every effort made to purchase tools, equipment, and machinery with modern safeguards and hazard controls? # Can existing tools, equipment, and machinery be retrofitted to include modern hazard controls and safety guarding devices? # Are tools, equipment, and machinery adequately maintained and serviced? # Are the numbers of workers that supervisors must supervise too high? # Are written policies, procedures, and plans followed and if so, are they working properly? # Are workers and supervisors involved in setting health and safety objectives and measurements? # Are health and safety targets and measurements clear, crisp, and clearly communicated? # Does everyone know what is expected? # Are people rewarded for excellence in health and safety performance as they are for excellence in other areas? # Is the organisation prepared to ensure managers, supervisors, and workers carry out their responsibilities?
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22 (h) Develop a procedure to investigate accidents, dangerous occurrences, and refusals to work
# Are responsibilities clearly assigned and put in writing? # Are adequate training records kept? # Are responsibilities for keeping records clear? # Are written investigation procedures in place? # Are written reports produced, kept, and used effectively? # Does everyone know who is responsible for following-up on corrective action to ensure it is working?
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Ask yourself these and other questions about the worker involvement: # Are employees regularly provided with information and asked for feedback? # Are workers reporting hazards? # Is senior management prepared to discuss concerns with workers during committee meetings, on the shop floor, in supervisory meetings, and so forth? # Are safety expectations discussed with new hires? # Does the organisation use a variety of technologies and tools to communicate with workers about health and safety? # Are successes communicated with the same intensity as information about incidents and failures in the IRS? # Are workers active in the occupational health committee?
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Summary
You must have a procedure to evaluate your health and safety program. You must evaluate your program completely every three years after it is set up. Evaluate and revise your program procedures gradually over each three-year period. Additional reviews must be undertaken when there are changes in the workplace that may affect health or safety, or when problems develop. The committee must be involved in evaluating and revising the program and each program element. How you evaluate and revise your program is up to you. Apply the same principles to evaluating and revising your health and safety program as you have to developing each program element. The next chapter will deal with Return-to-Work programs. Returnto-Work programs are not required by the occupational health and safety regulations. However, your program should have a mechanism to return injured to productive work within a reasonable time.
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Notes
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Introduction
Your occupational health and safety program is designed to prevent injury and illness. However, once an injury or illness happens, the focus is to return the injured/ill worker to a productive working life as soon as medically possible. Using a Return-to-Work program in the rehabilitation process can help do this.14 Successful Return-to-Work programs include the following steps: 1 2 3 4 5 6 Reporting injuries and illnesses. Filing required claims forms. Monitoring the recovery process. Implementing the return-to-work plan. Analysing injury and illness trends. Taking preventative measures.
The Workers Compensation Act, 1979 sets out the following duties for employers and workers.
Return-To-Work programs are not part of The Occupational Health and Safety Act or regulations. This information is provided by the Saskatchewan Workers Compensation Board. For more information, contact the Prevention, Safety and Return-to-Work Unit of the Board in Regina at 787-6916.
14
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1 2
Investigate/review the accident or illness to prevent recurrence. Provide immediate support (through the occupational health nurse, personnel officer, human resources personnel or a health and safety professional), to the injured/ill worker and his or her family. Schedule continuing contacts with the injured/ill worker to demonstrate the concern of the employer about the workers recovery and return to work. Participate in the development and implementation of the Returnto-Work Plan, and communicate commitment to the injured/ill worker. Provide assistance in the rehabilitation effort and access to employment. This will encourage the injured/ill worker to return to work as soon as possible. Notify the Saskatchewan Workers Compensation Client Service Representative of any changes in the injured/ill workers job status, other job opportunities and/or alternative (temporary) employment.
1 2 3 4
Seek timely and appropriate health care to treat the injury/illness. Follow the instructions and recommendations of the health care provider. Participate in the rehabilitation process, and in the development and implementation of the Return-to-Work plan. Maintain a positive attitude about returning to work when appropriate. Understand the benefits of accepting appropriate work during the rehabilitation process so that the focus can be shifted from disability to regained abilities. Inform the employer and WCB about how recovery is progressing.
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Summary
Leading organisations have effective Return-to-Work programs. A Return-To-Work program helps injured or ill workers return to productive employment sooner. Your documented program will provide a process to ensure injuries are promptly reported, treatment begins quickly, and steps are taken to return the injured/ill worker to productive employment as quickly as medically appropriate. The Saskatchewan Workers Compensation Board can help you develop a program. Contact the Prevention, Safety and Return-toWork Unit of the Board in Regina at 787-6916.
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Appendix
119
Appendix
Notes
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Resources
Resources
This publication is not a stand-alone guide. Review this section to select the extra publications and resources you need. See the Saskatchewan Department of Labour Web page for a list of online documents, and a list of publications. Internet links are listed on the next page.
Publications
Bird, Frank E. and Germain, George L. Practical Loss Control Leadership. Det Norske Veritas (USA), Inc. 4546 Atlanta Highway, Loganville Georgia, 30249, August 1996. Canadian Centre for Occupational Health and Safety (CCOHS), 250 Main Street East, Hamilton, Ontario L8N 1H6. A Basic Occupational Health and Safety Program. P86-9E, 1986. Manitoba Labour, Workplace Safety and Health Division, 1000-330 St. Mary Avenue, Winnipeg, Manitoba R3C 3Z5. A Workplace Safety and Health Self-Audit. Petersen, Dan. Analyzing Safety System Effectiveness, Third Edition. New York: Van Nostrand-Reinhold, 1996. Saskatchewan Workers' Compensation Board, #200, 1881 Scarth Street, Regina, Saskatchewan, S4P 4LI. Your Return to Work ProgramA How to Guide for Returning Injured Workers to the Workplace.
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Resources
Occupational Health and Safety Division publications and legislation A Guide to The Chemical Substances Regulations How to Conduct an Accident Investigation (training manual) How to Conduct an Inspection (training manual) Lab Chemical Storage Occupational Health and Safety Representatives Guide Occupational Health Committee Manual The Occupational Health and Safety Act, 1993 and The Occupational Health and Safety Regulations, 1996
Division WHMIS Publications How to Determine What is a Controlled Product WHMIS Requirements for Worker Training
These publications are available from Division offices in Regina and Saskatoon. For a complete listing of Division publications, contact the Regina office or visit the Saskatchewan Labour Web site. Copies of the Act and regulations are also available from the Queens Printer in Regina.
Internet sites
CCOHS: http://www.ccohs.ca/oshanswers/hsprograms/hsprograms.htm Manitoba Workplace Safety and Health Division. Workplace Safety and Health Self-Audit publication: http://www.gov.mb.ca/labour/safety/publicat/other/selfaudit.html Saskatchewan Labour homepage: http://www.labour.gov.sk.ca/ Office of the Queens Printer (Saskatchewan Justice): http://www.qp.justice.gov.sk.ca/ Saskatchewan Workers Compensation Board homepage: http://www.wcbsask.com/ Workers Compensation Board of British Columbia: http://www.wcb.bc.ca/index.html
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Index
Index
A
Accident (see also Dangerous Occurrences and Incidents) Accidents that must be investigated ........................................ 93 Definition ................................................................................ 91 Evaluation of investigation procedure................................... 111 Requirement for investigation procedure................................ 91 Additive effect..................................................................................... 75 Administrative hazard controls ........................................................... 31 Alternative work.................................................................................. 78 Approved training agency ................................................................... 86 Authority, definition of ....................................................................... 46
B
Biological hazards/biohazards (see Chemicals and biohazards)
C
Centralised hazardous product ordering system............................ 68, 72 Checklists, inspection ......................................................................... 60 Chemicals and biohazards (see also WHMIS and Infectious substances) Accountabilities for control..................................................... 65 Biohazard Controls for ................................................................. 68 Definition .................................................................... 67 Evaluation of control plan ......................................... 110 Requirements for control plan............................... 68, 70 Setting Up An Occupational Health and Safety Program 123
Index
Types of....................................................................... 67 Contents of control plan .............................................. 70 Information for workers .............................................. 69 Chemical hazards Definition .................................................................... 66 Types ......................................................................... 66 Control plans, requirements of .......................................... 68, 70 Protection from unusual and prolonged exposures ................. 75 Committee, Occupational Health Duty of employer to ensure training for.................................. 86 Role in auditing plans to control chemicals and biohazards ... 71 Keeping effective .................................................................. 101 Overall role in program ........................................................... 49 Role in dealing with concerns ................................................. 25 Role in auditing inspection schedule....................................... 58 Role in training plan................................................................ 83 Role of in investigating concerns ............................................ 25 Specific training for................................................................. 86 Communicating hazard information.................................................... 28 Concerns, investigations of ................................................................. 25 Competent ......................................................................... 33
Contractors and subcontractors Definition and overall role in health and safety program.......... 5 Responsibilities in program..................................................... 52 Criteria 124 4
Index
D
Dangerous occurrences (see also Accidents and Incidents) Definition ......................................................................... 91
Requirements for investigating ............................................... 92 Designated substances......................................................................... 76 Documentation of occupational health and safety program Requirements for ....................................................................... 5 Documents to keep .................................................................. 23 Due diligence ........................................................................... 8
E
Emergency response plans Authority within emergency plan............................................ 38 Evaluation of ....................................................................... 109 Example of emergency response plan..................................... 42 Examples of emergencies........................................................ 37 How to prepare response plans................................................ 39 Objectives of ......................................................................... 38 Requirements for a plan to identify emergencies.............. 19, 37 Resources required by plan ..................................................... 37 Equipment, definition of ..................................................................... 50 Exposures to chemicals and biohazards Exposure, definition ................................................................ 69 Exposure, indirect.................................................................... 67 Extended shifts and workweeks .......................................................... 74
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Index
F
Fugitive emissions ......................................................................... 72
H
Hazards Controls ......................................................................... 29
Keeping controls effective .......................................... 34 Hazard, definition of ............................................................... 21 Identification of ....................................................................... 22 Types of ......................................................................... 20
Ranking systems...................................................................... 27 Requirements for a system to control...................................... 19 Elements of control system ......................................... 20 Housekeeping ......................................................................... 33
I
Incentives, health and safety ............................................................. 102 Information for workers about chemical and biological hazards ........ 69 Infectious substances ......................................................................... 77 Inspections Correcting hazards found on ................................................... 62 Definition of inspections ......................................................... 55 Examples of items to include on a checklist ........................... 61 Evaluation of inspection schedule......................................... 109 Purpose of inspections............................................................. 55
126
Index
Types of inspections................................................................ 55 Recording forms for inspections ............................................. 60 Regulation 23 and 28 inspections............................................ 56 Requirements for an inspection schedule................................ 55 Responsibilities for inspections............................................... 58 Timing ......................................................................... 59
Training of employees carrying out inspection....................... 62 What to inspect........................................................................ 60 Internal responsibility system (IRS)...................................................... 7
J
Job safety analysis (JSA)..................................................................... 23
M
Managers, responsibilities of......................................................... 47, 48 Monitoring requirements..................................................................... 74 Multiple exposures ......................................................................... 75
N
Notifiable and designated substances.................................................. 76
O
Occupational health committee (see Committee, occupational health) Orientation, of workers ....................................................................... 84 Owners, definition of ......................................................................... 50
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Index
P
Part XXI and XXII of the regulations ................................................. 66 Personal protective equipment ............................................................ 33 Policy, occupational health and safety Components Definition ......................................................................... 14 ......................................................................... 13
Providing information about ................................................... 15 Required content ..................................................................... 15 Requirements for ..................................................................... 13 Plant, definition of ......................................................................... 56
Practicable, definition of ..................................................................... 71 Prescribed places of employment Requirements for a program...................................................... 2 Table 7 of the Appendix to the regulations ........................... 119
R
Reasonably practicable, definition of.................................................. 71 Refusals to work Requirements for procedure to investigate.............................. 91 Steps in investigation .............................................................. 95
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Index
Regulation Regulation 85 General requirements .................................................. 66 Regarding exposures to infectious materials............... 69 Regulation 302 General requirements .................................................. 66 Protecting workers from chemicals and biohazards.... 70 Reports Accident Inspection ......................................................................... 93 ......................................................................... 60
Responsibilities (see also Statement of responsibilities) Responsibilities for control of chemical and biological hazards............................................................. 68 Responsibilities of employers and senior managers ............... 47 Responsibilities of managers and supervisors......................... 48 Responsibilities of contractors ................................................ 51 Responsibilities of owners ...................................................... 50 Responsibilities of safety co-ordinators .................................. 50 Responsibilities of subcontractors and the self-employed ...... 52 Responsibilities of suppliers ................................................... 52 Responsibilities of workers ..................................................... 49 Responsibility, definition of................................................................ 46
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Index
Return to work plans Role in program......................................................................... 9 Duties of employer within..................................................... 116 Duties of worker within......................................................... 116 Workplace return to work programs ..................................... 116 Rights of workers (all employees) ........................................................ 7 Right to refuse (see also Refusals to work) Description of ........................................................................... 7 Requirements for investigating ............................................... 91 Risk Assessment Definition ......................................................................... 26 ......................................................................... 22
S
Safe work procedures ......................................................................... 31 Safety co-ordinators ......................................................................... 50 Self-employed, responsibilities of....................................................... 52 Severity, definition of ......................................................................... 21 Statement of responsibilities Components of ........................................................................ 46 Evaluation of ....................................................................... 109 Requirements for ..................................................................... 45 Strategy To involve employees ............................................................. 99 Other involvement strategies................................................. 102 Subcontractors and the self-employed (see Responsibilities) 130
Index
T
Training Definition ......................................................................... 82
Evaluation of training plan.................................................... 110 Legislated requirements .......................................................... 87 Objectives of training plan ...................................................... 82 Requirements for a training plan............................................. 81 Role of occupational health committee................................... 83 Training for committee members............................................ 86 Training for employees who carry out inspections ................. 62 Training for subcontractors ..................................................... 85 Training for supervisors .......................................................... 85 Training for workers................................................................ 84
U
Unusually dangerous work (see also Refusals to work) Definition ......................................................................... 96
W
WCLs ..................................................................................... 73
WHMIS Requirements for WHMIS plans............................................. 72 Exemptions from WHMIS ...................................................... 73 Work procedures, example.................................................................. 32 Workers Evaluation of involvement strategy....................................... 111 Pregnant, hypersensitive, or unusually responsive to a substance ......................................................................... 78 Setting Up An Occupational Health and Safety Program 131
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Check ( ) your answers for each statement in the space to the right Write NA (not applicable) for anything not applying to you 1. 2. 3. 4. 5. 6. 7. 8. 9. The content fits the needs of my workplace. I knew what was expected of me after I read the guide. The content was easy to read and understand. I could find what I was looking for easily. The resources listed were adequate. The introduction helped me to understand why a program is valuable. Chapter 1 (Policy) will help us write/improve our workplace policy. Chapter 2 (Hazard Id) will help us identify and control hazards at our workplace. Chapter 3 (Emergency) will help us prepare/improve our emergency plans.
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10. Chapter 4 (Responsibilities) will help us prepare a statement of responsibilities. 11. Chapter 5 (Inspections) will help us prepare/improve an inspection procedure. 12. Chapter 6 (Chemicals) will help us prepare/improve our systems to protect workers. 13. Chapter 7 (Training) will help us prepare/improve our worker/supervisor training. 14. Chapter 8 (Accidents and Refusals) will help us investigate accidents and refusals. 15. Chapter 9 (Involvement) will help us involve our employees more effectively. 16. Chapter 10 (Evaluation) will help us evaluate/audit our health and safety program. 17. Chapter 11 (Return-to-Work) will help us prepare Return-to-Work programs. 18. I will make use of the Internet links cited in the resources section.
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