Reducing Risks in the Workplace - Going Beyond a Generic Policy

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Employers must meet the requirements of all applicable legislation, including occupational health and safety (OHS), human rights, and employment standards. An effective approach to occupational health and safety is multi-layered, collaborative, and based on the hazards and risks present in your workplace. Think beyond a generic policy statement and look at each potential hazard, activity, or area in which the work is being done, so you can the identify hazards and assess the specific risks.

A Risk-Based Occupational Health and Safety Program

An occupational health and safety program is a framework implemented by an employer to prevent injuries and illnesses that may occur from work. An essential component of this program is hazard prevention.

Hazard prevention seeks to identify hazards and mitigate the risks to workers. A hazard is any source that may lead to harm (e.g., injury, illness, property damage, or environmental degradation). Most hazards fall under one of the following types:

  1. Biological (viruses, bacteria, fungi, parasites, toxins, animals)
  2. Chemical (exposure to hazardous substances)
  3. Ergonomic (inefficient tool use, poor work design, repetitive motions)
  4. Physical (noise, vibration, energy, heat, cold, radiation, contact with moving objects)
  5. Psychosocial ( incivility and disrespect, unclear expectations, poor workload management)
  6. Safety (slipping and tripping hazards, inappropriate machine guarding, equipment malfunctions or breakdowns)

Part of assessing the hazard includes evaluating the risk it poses. The risk is a combination of the hazard’s severity and the probability (or likelihood) of it causing harm.

When mitigating (i.e., eliminating or minimizing) risks, the employer should attempt to lower both the severity and probability of occurrence. A risk-based approach will identify relevant hazards, those who may be exposed, and the control measures required to reduce the risk. When applying control measures, determine which measure or combination of measures (sometimes referred as layers) will adequately reduce the risk.

Applying Policy Based on Risk

A health and safety policy statement should include the organization’s approach to health and safety, how it will comply with (or exceed) applicable legislation, and a commitment to protect the health and safety of workers. This document is supported by other policies and programs such as workplace harassment and violence prevention, personal protective equipment (PPE), or environmental policy statement.

By basing your organization's health and safety program on identified risks, the related policies can be applied in such a way to best protect all workers while preserving human rights and complying with employment standards. Generic application of health and safety policies may not always be possible or equitable.

For example, a company with an office and workshop may have a PPE policy that requires hard hats in the workshop but not in the office.

Respecting human rights

In Canada, human rights are protected under each jurisdiction’s human rights laws. Employers have a duty to accommodate workers based on many protected grounds including race, religion, and sex.

When applying a health and safety policy, you must consider if any human rights are impacted and the degree of risk.

Before concluding that a worker cannot safely perform a job or be reasonably accommodated, you should perform a risk assessment and apply the most effective control measures. When evaluating various control measures, determine if the residual risk (the risk level after applying control measures) is low enough to allow the worker to work safely without infringing on their human rights.

To comply with human rights legislation, employers should accommodate workers whenever possible. If a work requirement is a genuine (bona fide) occupational requirement and a control measure or accommodation cannot be provided without undue hardship, you may be justified in applying it to all workers equally, even if it infringes on a worker’s human rights. For example, when a head injury is a risk associated with a job, and no control measure or accommodation can reasonably be made to reduce that risk, a worker whose religious practice restricts the wearing of suitable protective headwear may not be able to fulfill the requirements of that job. Human rights are not absolute and accommodations may not be possible in some circumstances.

Recognize, Assess, Control, and Evaluate

Hazard identification and risk assessment is key to understanding and controlling the hazards in the workplace. One approach is to use RACE - which stands for Recognize, Assess, Control, Evaluate.

  • Recognize: Look at all job tasks then identify and classify the hazards. Consider the risk factors and determine who might be affected and how. Also determine who is doing the work and what protections they might require. For example, control measures in place for a pregnant women may be different from other workers.

  • Assess: Determine the severity and probability of impacts and rank the risk. A risk matrix with severity and probability axes can help with visualization. As a simple example, using a 3x3 matrix, severity and probability can be scored low, medium, or high. Risk is the product of severity and probability.

    Table 1: Risk Matrix graph
  • Control: What control measures are currently in place? Adjust these control measures or propose new ones that will reduce risks or eliminate the hazards. Use the hierarchy of controls when selecting control measures. Meet or exceed minimum legal requirements. Consider all factors, including human rights, when selecting and applying appropriate controls. It is possible that control measures for each hazard may differ between workers.

    In the example of a pregnant worker, exposure to some workplace conditions may be harmful to the health of the worker or the unborn child. You must consider protected human rights grounds.

    Ask questions such as:

    • Has the level of risk been assessed thoroughly, or has it been assumed there is a risk?
    • Can the same job be moved to a safer location instead of changing the worker’s tasks?
    • Are there any alternative control measures that are equally effective?
  • Evaluate: Determine the residual risk that remains after control measures have been implemented. Risk must be reduced to a tolerable level or eliminated entirely. As severity or probability decreases based on the control measures selected, so does risk.

Risks should be re-assessed periodically, at least annually or whenever conditions change. You should communicate the results of these risk assessments to all workers exposed to the hazard and use them in the development, implementation, and continual improvement of your health and safety program and policies.

Applying the Hierarchy of Controls

Control measures are changes to work or work environment which reduce risks or eliminate hazards. Not all controls are equally effective. The hierarchy of controls prioritizes control measures in order of effectiveness, from most effective to least effective.

Hierarchy of Controls graph

Layering control measures reduces the chance that a worker is exposed to a hazard. Control measures from all levels of the hierarchy may not exist for each hazard. The most effective measures should be implemented to reduce the risk to workers to an acceptable level.

Consider the characteristics of the workforce before implementing control measures. Not all controls are suited to all workers or workplaces. For example:

  • A workplace moves loads overhead by crane. To control the hazard, they confine overhead work to one area, eliminating the head injury risk to those workers outside of this lifting zone. Erecting barriers to restrict access to the lifting zone offers an additional layer of protection (engineering control). Workers are also informed of the hazards in the lifting zone through training and signs (administrative controls). PPE is still required but only within the lifting zone. Thus, there is no need to wear protective headwear when a worker is outside the lifting zone and not exposed to other head injury hazards.

The controls may, therefore, be applied differently to workers:

  • Lifting operation workers: Must be trained on workplace hazards and wear appropriate protective headwear.
  • Workers not involved in lifting operations (e.g., office workers or drivers): Must be trained on the relevant workplace hazards but protective headwear is not required unless they enter the overhead work area (lifting zone).

Learn more about using personal protective equipment as a control measure

Additional considerations when choosing control measures

Each workplace is unique and, with considerations that may vary even between organizations in the same sector or industry. For example, a logistics company has several workplaces across different provinces and territories. Some locations may have more diverse workforces and risk assessments may yield different results. Control measures must relate to the level of risk for each task and location.

Due to workforce diversity, generic policies may not be ideal. Appropriate control measures should be guided by risk and must consider:

  • Protected human rights (religion, age, sex, etc.)
  • Individual risk factors (state of health, etc.)
  • Employment standards (time taken to put on PPE, participation in toolbox talks or training must be counted as working time; eating periods must break up consecutive work to allow for rest, etc.)
  • Additional company policies (ensure policies do not contradict each other or create additional hazards)