In order to identify hazards you must first determine what processes take place within a facility. Examples of processes may include;
The second step is to determine what tasks are performed within the processes. For example, here are some of the tasks that are typically carried out by maintenance personnel
The third step in this process is to recognize the hazards within each task. This concept is referred to as P.E.M.E.P. because all identified hazards will fall into one of five categories. These categories are;
Once you have identified the hazards that are present, some method of prioritizing must be established to ensure controls are applied to the most serious risks first. There are a number of methods available to assist in the assessment of hazards. These methods can help committee members determine which of the identified hazards could potentially cause the most serious injury.
One example of an assessment method is to determine airborne hazards through air sampling or constant monitoring depending on the situation. Testing can be initiated by the committee because of a request made by workers; or to test and benchmark current conditions to determine the level of hazard prior to the implementation of a control; or once implemented, to evaluate a hazard control to determine its effectiveness.
The employer is responsible for having the monitoring conducted in the workplace and a committee is entitled to information from the employer about testing and the outcome.
A designated member who represents workers is also entitled to be present at the beginning of testing, to ensure the validity of test procedures and results.
When assessing a hazard we must have an idea of accepted norms in order to judge the situation. For instance, when we take a sample of air we need to know what we are looking for, the level of acceptable exposure for workers without personal protection, and when we need to consider hazard elimination, substitution or isolation techniques. In Ontario, we look to Regulation 833: Control of Exposure to Biological or Chemical Agents (a regulation made under the Act) to provide guidance. The Ontario Ministry of Labour generally accepts threshold limit values as published by the American Conference of Governmental Industrial Hygienists, a non-profit organization based in the United States. These values list acceptable exposure levels to which an average worker can be exposed to without any adverse health effects.
Hazards can be assigned a priority classification to help with scheduling and implementation of hazard controls as recommended by the committee. Many classification methods exist and it is up to the committee to adopt the most logical solution. The following is one method;
Once hazards have been identified and assessed, the next step in the process is to determine the effectiveness of existing controls and suggest improvements that may be necessary. Or, in the case of existing controls, determine their effectiveness.
Controls may be applied in a number of ways and in three different locations;
1. At the Source: Whenever possible consider the best way to control a hazard is to apply the control at the source of the hazard. The ultimate control is actual removal of the hazard from the workplace however that may not be prudent, acceptable, logical or feasible.
2. Along the Path: Controls along the path do not remove the hazard, but provide methods to alert the worker that a hazard exists. The goal is to minimize worker exposure.
3. At the Worker: Controls at the worker include personal protective equipment (P.P.E.), training in safe work methods, administrative procedures and disciplinary actions. Controls at the worker may be subject to human error and should be considered the last alternative in a list of hazard controls, especially in the case of P.P.E. Simply put, sometimes workers don’t wear their P.P.E. correctly or not at all and therefore this control can be difficult to monitor and evaluate.
A variety of hazard controls may exist in the workplace, or in many situation, a customized approach is required. There are three basic classifications of hazard controls, they are;
Priority should be given to attempts that control hazards at the source using engineering controls while ensuring the very last type of control to consider is P.P.E. at the worker. This is true because should the P.P.E. fail, nothing is left in place to protect the worker from the hazards. The best case scenario would include the implementation of multiple controls implemented with a variety of backup controls in place should any one layer of protection fail. An example of multiple controls for an environment such as a hazardous storage room may include but are not limited to;
Once hazard controls have been implemented they must be evaluated to determine their effectiveness and to assess if the intent of the control is being met. It is important that hazard control recommendations do not inadvertently introduce a subsequent hazard while taking steps to eliminate, reduce or control another. An example of this would include the introduction of anti-fatigue or ergonomic floor mats that are located a work stations throughout the plant. A slip and trip hazard may be inadvertently introduced and must be considered prior to implementation.
Committee members need to determine how a hazard control can be evaluated long before it is implemented. A good idea for a hazard control must be accompanied by a quantifiable methodology that will help to determine if the hazard control is meeting or exceeding the goals. Committee members need to consider;
The thinking behind the Occupational Health and Safety Act is that everyone in the workplace should play a role in controlling health and safety hazards. This is accomplished through participation and cooperation by employers and workers toward common goals. The philosophy behind the Act is known as the ‘internal responsibility system’ (I.R.S.) and although this phrasing is not mentioned in any legislation, the Ministry of Labour’s guide to the act makes it clear that the government expects cooperation at all levels. The I.R.S. is based on the principle that every individual in the workplace is responsible for health and safety. The driving force behind an effective health and safety management system includes a cooperative effort from all parties within the organization.
Since 1979, when the Act came into law, amendments to the Act have been introduced to establish new procedures as well as new rights and duties for workers, employers, supervisors and others in the workplace. One of the most important changes was giving the Joint Heath & Safety Committee’s the right to participate in health and safety recommendations. But that wasn’t the only established right given to workers, there are three basic rights.
Every Worker has Rights
The Ham Commission Report was instrumental in establishing the three basic rights for workers. These include;
Right to Know
Employers and supervisors must ensure workers are aware of the hazards presented by people, equipment, materials, the environment, and processes. They have the right to be trained on, and to receive information about dangerous and hazardous substances that they are exposed to, or are likely to be exposed.
Right to Participate
The right to participate is best illustrated through worker membership on the J.H.S.C. Workers have the right to ask questions about issues concerning their health and safety or that of a coworker. Workers have the right to be a part of the process of identifying, assessing and controlling workplace health and safety hazards. Participation can also be achieved by reporting unsafe conditions to the supervisor or employer.
Right to Refuse Unsafe Work
Workers may refuse work where they believe it is likely to endanger themselves, or any other worker.The Act includes a detailed process for refusing unsafe work and explains the employer’s responsibility for responding to work refusals. The Act also provides workers with protection from reprisal, or retaliation, from the employer should they decided to refuse unsafe work.
Joint Health & Safety Commttee – Employer & Worker Responsibilities
Employers who integrate the concept of internal responsibility into day-to-day activities will reduce the likelihood of workplace accidents. Employers must hold supervisors and workers accountable for the safety and wellbeing of themselves and others in the workplace. One method of ensuring compliance with applicable laws is for the employer to practice exceptional due diligence. This refers to the employer’s legal responsibility to take every reasonable precaution to protect the health and safety of the worker. The W.S.I.B. suggests this can be accomplished by ensuring the employer and the workers understand their responsibilities regarding workplace health and safety.
Employer responsibilities include;
Learning about safety hazards in the workplace
Making workers aware of hazards; and
Providing adequate first aid at every worksite, including suppliers and someone trained in first aid
Worker responsibilities include;
Knowing about hazards in the workplace and how to do their job safely
Participating in workplace health and safety
Practicing safe work procedures; and
Reporting unsafe conditions as quickly as possible
The committee carries out their functions by planning workplace inspections, communicating with management and other individuals as required, holding regular meetings and participating in testing and monitoring activities. Committees play an important role in developing, reviewing, and recommending improvements to company health and safety policies and procedures.
Committee members must meet monthly to inspect the workplace for health and safety hazards. The entire workplace must be inspected every month with everyone’s findings recorded for committee discussion, or immediate attention where a dangerous circumstance is identified. If it is unrealistic to inspect the entire workplace-both interior and exterior-once per month, a committee should establish a schedule that ensures the entire workplace will be inspected at least once a year. In other situations the Ministry of Labour may order a more frequent schedule of inspections.
During an inspection, committee members may approach workers to ask questions, to observe work in progress, or to see how each machine operates. Workers are expected to provide information and assistance as required to a committee member during a workplace inspection. A worker must not interfere or knowingly provide false information.
Inspections are performed by committee worker members, conducted preferably by a certified member and in most cases, during normal working hours while the business is operating. This allows committee members to see processes and procedures in action. Seeing the operation running may help workers identify potential or actual hazards. Inspections during off peak hours such as during plant shut downs, slower periods, or if inspections are only conducted on a night shift, may not produce the same type, level, or frequency of contributing factors as one might witness during normal work load. A business who operates multiple shifts should schedule inspections on each shift to ensure the committee observes the business operating at various times. A night shift inspection may uncover a need for additional staffing, a variation in shipping and receiving schedules, increased supervision, or new policies and procedures to lessen incidents and accidents.
The purpose of the inspection is to determine
An inspection procedure has four components;
A facility tour or inspection sheet should be used during an inspection. This document may include;
On completion of the facility inspection copies of the completed tour sheet must be distributed to the members of the J.H.S.C., to the people responsible to take corrective action, the supervisor of the department involved, and senior management and supervisors. Once hazards have been identified, a follow-up schedule must be in place, and process must be implemented that ensures hazards don’t go unchecked.
The purpose of an accident/incident investigation includes;
An accident is an undesired event that results in physical harm to a person or damage to property.An incident is an undesired event that could (or does) downgrade the efficiency of the business operation or, if the circumstances had been different, it may have resulted in an accident.
It should always be considered practical to conduct an accident investigation for all accidents and incidents however legislation indicates that only accidents that result in a critical injury or death need to be investigated. The members of a committee who represent workers shall designate one or more such members to investigate cases where a worker is killed or critically injured in the workplace. Committee members may inspect the actual place where the accident occurred and any machine, device or thing that may be associated with the event, and shall report his or her findings to a Director at the Ministry of Labour, and to the committee.
If the worker member conducting the investigation is not familiar with the area in which the accident occurred, they can request assistance from a competent individual to complete the investigation. Requesting the assistance of a qualified and license tradesperson is an excellent example of a competent individual.
In order to determine if a critical injury has occurred and for the purposes of the Act and regulations, critically injured means an injury of a serious nature that;
Secure and Manage the Accident Scene
The first priority after medical aid is provided is to ensure the accident scene is secured and managed. In the event of a critical injury or fatality, persons at the workplace must have permission from the attending Ministry of Labour Inspector before the scene can be entered or altered.
The committee must not disturb, destroy, alter or carry away any wreckage, article or thing from a scene where a critical injury or death occurs except for the purpose of;
Notice of Death or Injury
The Act states that where a person is killed or critically injured from any cause at a workplace the employer must immediately notify a Ministry of Labour Inspector, and the JHSC and trade union (if any) by written notice. The employer shall, within forty-eight hours after the occurrence, send to a Director a written report of the circumstances of the occurrence containing such information and particulars as the regulations prescribe.
Notice of Accident, Explosion or Fire Causing Injury
If a person is disabled from performing his or her usual work or requires medical attention because of an accident, explosion or fire at a workplace, but no person dies or is critically injured because of that occurrence, the employer shall, within four days of the occurrence, give written notice of the occurrence to the following;
Notice of Occupational Illness
If an employer is advised by, or on behalf of a worker, that the worker has an occupational illness or that a claim in respect of an occupational illness has been filed with the Workplace Safety and Insurance Board, the employer shall give notice in writing, within four days of being so advised;
Documenting the Accident Scene
Written notes, tape recordings, photographs, test results or any other documentation that can help identify root causation are very important to note as they may be introduced into the court of law.
Who is involved in the accident scene?
Where did the accident happen?
When did the accident happen?
What actually happened?
How did it happen?
Interviewing the Witnesses
It is very important that committee members control their own emotions during this time in order to provide a supportive environment for the witnesses. When conducting interviews it is critical that the witness does not perceive the process as pointing out blame, but rather than a step in a process of identifying the reasons why the accident happened. Witness need to understand that by learning what happened and way, we can find alternate processes, implement new policies or revise existing programs, in an effort to avoid a re-occurrence.
Workers are expected to provide information and assistance as required to a committee member during an accident investigation. A worker must not interfere or knowingly provide false information.
The following list explains are a few important steps in the interviewing process;
Analysis and Conclusions
Once the accident has been investigated, all documentations must be analyzed in order to draw conclusions to determine the contributing factors, immediate causes, and root causes.
Contributing factors could include;
Immediate causes could include;
Root causes can fall into two categories:
1. Personal Factors
2. Job System Factors
Recommendations and Follow-up
After an accident investigation is completed, the committee must decide a course of action whether they introduce a hazard control, or revise an existing control, something must be done to prevent a re-occurrence.
Once the written recommendation is received by the employer, they have a legal obligation to respond within twenty-one days with either an action plan for corrective actions, or the reasons why the recommendation for corrective action will not be considered.
With any recommendation or implementation of a hazard control, there should be a follow-up to ensure that a response was received by the employer or in the case where controls have been installed, that the controls are being evaluated to determine practicality and effectiveness.
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