Basic OH&S Program Elements

A health and safety program is a definite plan of action designed to prevent accidents and occupational diseases. Some form of a program is required under occupational health and safety legislation in most Canadian jurisdictions. A health and safety program must include the elements required by the health and safety legislation as a minimum.

Because organizations differ, a program developed for one organization cannot necessarily be expected to meet the needs of another. This document summarizes the general elements of a health and safety program. This approach should help smaller organizations to develop programs to deal with their specific needs.

An organization's occupational health and safety policy is a statement of principles and general rules that serve as guides for action. Senior management must be committed to ensuring that the policy is carried out with no exceptions. The health and safety policy should have the same importance as the other policies of the organization.

The policy statement can be brief, but it should mention:

• Management's commitment to protect the safety and health of employees.
• The objectives of the program.
• The organization's basic health and safety philosophy.
• Who is accountable for occupational health and safety programs.
• The general responsibilities of all employees.
• That health and safety shall not be sacrificed for expediency.
• That unacceptable performance of health and safety duties will not be tolerated.

The policy should be:

• Stated in clear, unambiguous, and unequivocal terms.
• Signed by the incumbent Chief Executive Officer.
• Kept up-to-date.
• Communicated to each employee.
• Adhered to in all work activities.

The following is an example of an occupational health and safety policy statement:

ABC Transport

To all employees January 1, 2015

At ABC Transport the safety and health of our employees comes first. Management is committed to doing everything possible to prevent injuries and to maintain a safe and healthy environment.

To this end:

1) all supervisors are responsible for ensuring that their employees are trained in approved work procedures and to ensure that employees follow safe work methods and all related regulations;

2) all personnel are required to support the OSH program and make safety and health a part of their daily routine and to ensure that they are following safe work methods and relevant regulations;

3) all personnel will be held accountable for implementing this program; and

4) all relevant laws and regulations are incorporated in our program as minimum standards

Signed by President

While organizations will have different needs and scope for specific elements required in their health and safety program, the following basic items should be considered in each case:

• Individual responsibility.
• Joint occupational health and safety committee.
• Health and safety rules.
• Correct work procedures.
• Employee orientation.
• Training.
• Workplace inspections.
• Reporting and investigating accidents/incidents.
• Emergency procedures.
• Medical and first aid.
• Health and safety promotion.
• Workplace specific items.

Health and safety is the joint responsibility of management and workers. Management is accountable for non-compliance to health and safety legislation.

Responsibility may be defined as an individual's obligation to carry out assigned duties. Authority implies the right to make decisions and the power to direct others. Responsibility and authority can be delegated to subordinates, giving them the right to act for superiors. It is important to note that, while some responsibilities can be delegated, the superior remains accountable for seeing that they are carried out.

Individual responsibilities apply to every employee in the workplace, including the Chief Executive Officer. All employees will then know exactly what is expected of each individual in health and safety terms.

To fulfill their individual responsibilities, the people must:

• Know what these responsibilities are (communication required).
• Have sufficient authority to carry them out (organizational issue).
• Have the required ability and competence (training or certification required).

Once all these criteria have been met, safety performance can be assessed by each individual's supervisor on an equal basis with other key job elements. Health and safety is not just an extra part of an employee's job: it is an integral, full-time component of each individual's responsibilities.

Examples of responsibilities of workers include:

• Using personal protection and safety equipment as required by the employer.
• Following safe work procedures.
• Knowing and complying with all regulations.
• Reporting any injury or illness immediately.
• Reporting unsafe acts and unsafe conditions.
• Participating in joint health and safety committees or as the representative.

Examples of responsibilities of first-line supervisors include:

• Instructing workers to follow safe work practices.
• Enforcing health and safety regulations.
• Correcting unsafe acts and unsafe conditions.
• Ensuring that only authorized, adequately trained workers operate equipment.
• Reporting and investigating all accidents/incidents.
• Inspecting own area and taking remedial action to minimize or eliminate hazards.
• Ensuring equipment is properly maintained.
• Promoting safety awareness in workers.

Examples of responsibilities of management include:

• Providing a safe and healthful workplace.
• Establishing and maintaining a health and safety program.
• Ensuring workers are trained or certified, as required.
• Reporting accidents/incidents and cases of occupational disease to the appropriate authority.
• Providing medical and first aid facilities.
• Ensuring personal protective equipment is available.
• Providing workers with health and safety information.
• Supporting supervisors in their health and safety activities.
• Evaluating health and safety performance of supervisors.

Examples of responsibilities of safety coordinators include:

• Advising all employees on health and safety matters.
• Coordinating interdepartmental health and safety activities.
• Collecting and analyzing health and safety statistics.
• Providing health and safety training.
• Conducting research on special problems.
• Attending joint health and safety committee meetings as a resource person.

An effective safety program needs the cooperative involvement of all employees. A joint health and safety committee is a forum for cooperative involvement of employees representing both labour and management. Such committees are statutory requirements for organizations of a specified minimum size in most Canadian jurisdictions. The responsibilities of members are generally spelled out in the health and safety legislation across Canada.

A joint health and safety committee brings together labour's in-depth, practical knowledge of specific jobs and management's larger overview of job interrelationships, general company policies and procedures.

To function properly, the committee needs an appropriate structure, a clear statement of purpose and duties, and standard procedures for meetings. An employer does this by establishing terms of reference for the committee and by allocating adequate resources.

The employer must establish a committee is organized and operates in compliance with the law, is effective, involves the widest range of employees, and provides resources (e.g., time, money, meeting rooms) so the committee can do its work. These requirements are known as "terms of reference". Common terms of reference include:

• Stating senior management's commitment to act on the committee's recommendations.
• Defining how long a person will serve on the committee (if not specified by legislation).
• Establishing how a committee member will be chosen, etc.

Each organization should set up their own terms of reference. More information is available in the Health and Safety Committee documents listed below:

• What is a Joint Health and Safety Committee?
• Joint Health and Safety Committee - Creation
• Joint Health and Safety Committee - Effective and Efficient
• Joint Health and Safety Committee - Measuring Effectiveness
• Joint Health and Safety Committee - Structure

Once the committee members have been chosen, the committee should participate in decisions on the details of its structure, duties, and procedures.

Establish a reporting structure. In a general sense, each committee member is responsible to the chairperson(s), and the committee as a whole to all employees for fulfilling their duties. However, if prompt follow-up to recommendations is to be expected, one individual should be named as a person in authority. The best choice is usually a member of senior management. This individual should have sufficient authority to be able to take or expedite direct action as required.

The joint health and safety committee members should be active participants in the development, implementation, and monitoring of all phases of the health and safety program.

Governmental health and safety regulations represent minimum requirements. In almost all cases, organizations will have to augment these regulations with specific rules.

We need rules – to protect the health and safety of workers – but there are dangers in having either too few or too many rules. Too few rules may be interpreted as a sign that health and safety are not important, or that common sense is all that is required to achieve them. Too many rules may be seen as not treating employees as thinking adults and makes enforcement of all rules less likely. Following are some guidelines for establishing rules:

• Rules should be specific to health safety concerns in the workplace.
• The joint health and safety committee should participate in their formulation.
• Rules should be stated in clearly understandable terms.
• Rules are best stated in positive terms ("employees shall" not "employees shall not").
• The reasons for the rule should be explained.
• Rules must be enforceable, since disregard for one rule will lead to disregard for others.
• Rules should be available to all employees in written form, in the languages of communication of employees.
• Rules should be periodically reviewed to evaluate effectiveness and to make changes for improved effectiveness.

Compliance with health and safety rules should be considered a condition of employment. Rules must be explained to new employees when they start work or if they are transferred or retrained. After a suitable interval, these employees should be briefed to ensure they understand the rules applicable to their work.

The employer must establish procedures for dealing with repeat rule violators. Supervisors are responsible for correcting unsafe acts, such as a breach of rules, and they must be supported in this duty. Points that should be considered in establishing procedures on this issue are:

• Ensure that employees are aware of the rule.
• Ensure that employees are not encouraged, coerced, or forced to disregard the rule by fellow employees.
• All rules are to be observed.
• No violation will be disregarded.
• The role of discipline is that of education, not punishment.
• Action is taken promptly.
• While having guidelines for penalties for the first offence or infractions may be desirable, some flexibility is required when applying the guidelines since each case will vary in its circumstances.
• Action is taken in private, and recorded.

Correct work procedures are the safest way of doing a job, job instruction, monitoring performance, and accident investigation.

Job safety analysis (JSA), also known as "job hazard analysis", is the first step in developing the correct procedure. In this analysis, each task of a specific job is examined to identify hazards and to determine the safest way to do the job. Job safety analysis involves the following steps:

1. Select the job.

2. Break down the job into a sequence of steps.

3. Identify the hazards.

4. Define preventive measures.

The analysis should be conducted on all critical tasks or jobs as a first priority. Critical jobs include:

• Those where frequent accidents and injuries occur.
• Those where severe accidents and injuries occur.
• Those with a potential for severe injuries.
• New or modified jobs.
• Infrequently performed jobs, such as maintenance.

Job safety analysis is generally carried out by observing a worker doing the job. Members of the joint health and safety committee should participate in this process. The reason for the exercise must be clearly explained to the worker, emphasizing that the job, not the individual, is being studied. Another approach, useful in the analysis of infrequently-performed or new jobs, is group discussion.

A work procedure may consist of more than one specific task. In such cases, each separate task should be analyzed to complete a job safety analysis for that procedure. The final version of the correct work procedure should be presented in a narrative style format that outlines the correct way to do the job in a step-by-step outline. The steps are described in positive terms, pointing out the reasons why they are to be done in this way. Reference may be made to applicable rules and regulations and to the personal protective equipment required, if any. Employees who carry out the tasks should be consulted in developing the procedure.

Applicable Legislation:

OH&S Act and Regulations: ___________________________
(refer to the act and regulations in your jurisdiction)

Date: ____________________________________________

Developed by: _____________________________________

Health and safety education should start with employee orientation when an employee joins the organization or is transferred to a new job. It has been found that inexperienced workers, in general, are involved in accidents at a higher rate than others. While experience can only be gained through time, both health and safety education and job skills training can be used to improve this record. Orientation sessions normally cover such items as explanation of the function of the work unit, organizational relationships, administrative arrangements, and miscellaneous policies and rules.

Items related to health and safety that should be included are:

• Emergency procedures.
• Location of first aid stations.
• Health and safety responsibilities, including those specified by legislation.
• Reporting of injuries, unsafe conditions and acts.
• Use of personal protective equipment.
• Right to refuse hazardous work.
• Hazards, including those outside own work area.
• Reasons for each health and safety rule.

A new employee can be expected to absorb only a certain amount of information in the first few days. A brochure outlining the points covered in the orientation sessions is useful as a handout to employees. It also serves as a checklist for the person conducting the orientation. A buddy system is a useful follow-up to the initial orientation. This system allows for on-the-job reinforcement of the information presented to the new employee. This process also promotes the safety awareness of the experienced workers who are the "buddies".

New, inexperienced or transferred employees should be encouraged to ask questions at any time when doubt exists as to correct procedures. The new employee orientation may include a set of questions, such as the following:

• What are the hazards of the job?
• Is job safety training available?
• What safety equipment do I need to do my job?
• Do I need to wear personal protective equipment (PPE)? Will I receive training on how to use the PPE?
• What do I do in case of fire or another emergency?
• Where do I find fire extinguishers, first aid kits, first aid rooms and emergency assistance?
• What are my responsibilities regarding health and safety?
• If I notice something wrong, to whom should I report?
• Who is responsible for answering safety-related questions?
• What do I do if I get injured or have an accident?

Soon after the orientation sessions, employees should be assessed on their understanding of the items discussed. In this way, both the quality of training and the level of understanding can be evaluated.

The objective of training is to implement health and safety procedures into specific job practices and to raise awareness and skill levels to an acceptable standard.

Occasions when employee training may be required are:

• Commencement of employment.
• Reassignment or transfer to a new job.
• Introduction of new equipment, processes, or procedures.
• Refresher, annual, or periodic education and training to ensure skills and knowledge.
• Inadequate performance.

CSA Standard Z100-13, Occupational Health and Safety Training, also outlines suggested training for supervisors. The standard states that a supervisor "should be competent (i.e., have adequate knowledge, training, and experience) on all processes and tasks over which he or she is exercising authority. Organizations should define what constitutes an acceptable combination of knowledge, training, and experience in relation to the supervision of others performing tasks." Topics that may be included in supervisor training include:

• Roles and responsibilities - legal and corporate.
• Internal responsibility system.
• Hazard identification, hazard control, risk assessment.
• Emergency procedures.
• Incident investigation.
• Conducting planned inspections.
• Auditing skills.
• Training.
• Planned task observation.
• Communication skills.
• Motivation and discipline.
• Managing troubled employees.
• Off the job safety.
• Problem solving skills.
• First aid.
• WHMIS/chemical safety.
• Industrial hygiene and medical surveillance programs.
• Duty to accommodate.

When providing training, an instructor should:

• Receive training in how to instruct.
• Prepare an orderly plan for instruction.
• Explain reasons why each step must be done in a certain way.

All instructors should:

• Plan the session beforehand; break the job down into steps; have training aids available.
• Explain what is to be done.
• Describe all the hazards and protective measures.
• Demonstrate each step, stress key points, and answer any questions.
• Have the employee carry out each step, correct errors, and compliment good performance.
• Check frequently after the employee is working independently to ensure correct performance.

Documented correct work procedures are very important in job skills training.

Workplace inspections help to identify existing hazards so that appropriate corrective action can be taken. Health and safety legislation requires workplace inspections as a proactive action to ensure workplace health and safety.

Supervisors and workers are responsible for reporting and taking action on unsafe conditions and acts as they are encountered. The frequency of planned formal inspections may be set out in legislation. Records of previous accidents and the potential for serious accidents and injuries are factors to be included when determining if more frequent inspections are needed.

Joint health and safety committee members are obvious choices of personnel to carry out formal inspections, especially if they have received training or certification. Other criteria for selecting the inspection team are:

• Knowledge of regulations and procedures.
• Knowledge of the hazards in the workplace.
• Experience with work processes involved.

Pre-planning any inspection is always worthwhile. Documents, such as previous inspections, accident investigations, maintenance reports, and committee minutes, should be consulted. If a checklist is to be used, it should be reviewed and changed to meet specific needs of the workplace.

Checklists are useful aids in that they help ensure that no items are overlooked in an inspection. One type of checklist is the "critical parts inventory". This inventory itemizes parts and items that may result in a serious accident if they fail. While many ready-made checklists are available in safety literature, it is best to adapt these to local conditions. The joint health and safety committee should participate in the preparation of these tailor-made checklists.

Sample Inspection List

Date: ________________________________________________

Location/Department:  ___________________________________

Notes:

______________________________________________________

______________________________________________________

______________________________________________________

During the actual inspection, both work conditions and procedures should be observed. If a hazard that poses an immediate threat is discovered, preventive action must be taken right away, not after the inspection. Notes are made, specifying details of the hazard, including its exact location. When completing the inspection report, it is a good idea to classify each hazard by degree of possible consequences (for example: A = major, B = serious, C = minor). In this way, priorities for remedial action are established.

Workplace Inspection Report

Location:_______________________________________________

Department/Areas covered: _________________________________

Date of Inspection: ________________________________________

Time of Inspection: ________________________________________

Priority Codes: A - do immediately; B - do within 3 days; C - do within 2 weeks; D - other

Inspections serve a useful purpose only if remedial action is taken to correct shortcomings. Causes, not symptoms alone, must be rectified. Corrective action should be taken immediately, with the emphasis on engineering controls, management failures, or need for worker education, whatever applies.

Occupational health and safety legislation in all Canadian jurisdictions requires that specific injuries and certain categories of accidents/incidents must be reported. There may be minimum legal requirements for their investigation. Many organizations investigate other events (e.g., where damage did not involve injuries) and "near misses." The health and safety program should specify:

• What is to be reported.
• To whom it will be reported.
• How it is reported.
• Which incidents are investigated.
• Who will investigate them.
• What forms are used.
• What training investigators will receive.
• What records are to be kept.
• What summaries and statistics are to be developed.
• How often reports are prepared.

Accidents and incidents are investigated so that measures can be taken to prevent a recurrence of similar events. Investigation represents an "after-the-fact" response for any particular mishap. However, a thorough investigation may uncover hazards or problems that can be eliminated "before-the-fact" for the future. After causes have been determined, prompt follow-up action is required to achieve the purpose of the investigation.

Emergency procedures are plans for dealing with emergencies such as fires, explosions, major releases of hazardous materials, violent occurrences, or natural hazards. When such events occur, the urgent need for rapid decisions, shortage of time, lack of resources, and trained personnel can lead to chaos.

The objective of the plan is to prevent or minimize fatalities, injuries, and damage. The organization and procedures for handling these sudden and unexpected situations must be clearly defined.

The development of the plan follows a logical sequence.

• Compile a list of possible hazards or scenarios (for example: fires, explosions, floods).
• Identify the possible major consequences of each (for example: casualties, damage).
• Determine the required countermeasures (for example: evacuation, rescue, firefighting).
• Inventory the resources needed to carry out the planned actions (for example: medical supplies, rescue equipment, training personnel).
• Based on these considerations, establish the necessary emergency organization and procedures.

Communication, training, and periodic drills are required to ensure adequate performance when the plan must be implemented.

First aid facilities and the provision of medical aid is generally prescribed under health and safety legislation or workers' compensation legislation. The OSH program must include the following information:

• Location of first aid stations and medical facilities.
• Identification of first aid attendants.
• Identification of other staff trained in first aid.
• Policy on pre-employment and follow-up medical examinations.
• Procedures for transporting injured employees to outside medical facilities.
• Provision of first aid training.
• Procedure for recording injuries and illnesses.

A policy on return to work after a lost-time accident might appropriately be included in this section of the program.

In general, if injured workers are offered alternative employment:

• The work should be suitable and productive.
• The worker's physician must agree that such employment will not harm the worker or slow down the recovery.
• The worker will pose no threat to other workers.
• The policy is applied to off-the-job injuries as well.

Under no circumstances should the reduction of severity ratings be a reason for initiating a "modified work" program.

Once the health and safety program has been set in place and the program appears to be running smoothly, effort is still required to maintain enthusiasm and interest.

Safety awareness can be enhanced by:

• The setting of realistic goals and monitoring progress.
• Distribution of all pertinent information.
• Individual recognition for superior performance.
• Continuing education and training, including general meetings, tailgate talks, and one-on-one coaching.

The elements of OH&S programs discussed so far apply to all basic health and safety programs. In addition, specific items may be needed to address workplace specific activities. Examples of such items are:

• Workplace Hazardous Materials Information System (WHMIS).
• Lock out procedures.
• Confined space procedures.
• Hot-work permits.
• Material handling rules.
• Plant maintenance.
• Fire safeguards.
• Vehicle safety rules.
• Off-the-job safety.
• Working alone guidelines.
• Personal protective equipment requirements.
• Engineering standards.
• Purchasing standards.
• Preventive maintenance.

A good health and safety program provides a clear set of guidelines for activities that, if followed rigorously, will reduce accidents and cases of occupational disease. The key to success is the manner in which the program is implemented and maintained.

Senior management must demonstrate commitment and support the program by:

• Providing resources such as time, money, and personnel.
• Ensuring that employees receive training or certification as required.
• Making all applicable health and safety information available to all employees.
• Including health and safety performance as part of employee performances appraisals at all levels.
• Attending health and safety meetings.

The program must be communicated to all employees. Special emphasis should be given to new workers, newly appointed supervisors, and new members of the joint health and safety committee. Revisions to policies and procedures should be publicized. The program should be available in a single written document. However, if separate manuals have been developed for various elements, such as accident/incident investigation procedures, their use should be referred to in the main document.

Accident frequency and severity rates are not always the only measures to use for evaluating the effectiveness of a health and safety program. Cases of occupational disease are often under-reported in these statistics. The emphasis is usually on injury-producing accidents, not all events. Since accidents/incidents are rare events, in small organizations the basis for comparison may be limited.

It is desirable to use an audit as a before-the-fact measure of the effectiveness of an OH&S program. An audit uses a checklist in which each element is subdivided into a series of questions. Each question is given a weighting factor depending on its importance. Records, observations, interviews, and questionnaires are used to evaluate performance for each sub-element.

A number of audit systems are available.

Annual audits appear to be more common, but reviewing critical elements in the program more frequently may be advisable. The audit team, which should include representation from the joint health and safety committee, must receive appropriate training in audit procedures.

The audit identifies weaknesses in the health and safety program. Little is achieved unless a procedure is established to ensure prompt follow-up on deficiencies. This procedure should include provision for target dates for remedial action and checks to confirm completion.