It is that time of year again! As we enter 2020, many businesses will take the time to audit their Health and Safety policies and procedures to ensure compliance with OHSA. To help you out, we have created a checklist of things that you are required to have in place or should be doing.
Our commitment to you is to help ensure that your company continues to meet compliance and as such, we have included some points of interest that you may wish to consider.
The following list may not be all-inclusive but more of a snapshot of what the Ministry of Labour, Training and Skills Development (MLTSD) would expect to see should they drop by for a safety audit of your business. We will talk about a more comprehensive assessment toward the end of this blog.
1. Health & Safety Policy Statement
Ensure it has been reviewed by the highest signing authority at your company, signed, dated and posted. You can download a free fillable template below if you don’t currently have one.
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2. Violence & Harassment Policy Statement
Ensure it has been reviewed by the highest signing authority, signed, dated and posted. If your policy statement has not been amended within the past 3 years, it probably is not meeting the requirements of the MLTSD (Ministry of Labour, Training and Skills Development) Code of Practice Harassment.
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3. Violence Risk Assessment
This must be done and reviewed as often as is deemed necessary to ensure it still captures the possibility of violence towards your staff. Every business must conduct this risk assessment as it is required by law in section 32.0.3 of the OHSA. This risk assessment must also be shared with your H&S Rep and/or JHSC. If you have not done this, Let us know, and we can assist you in conducting a violence risk assessment.
4. Monthly Safety Inspections
It’s a good idea to have a your monthly inspections posted as well as a schedule that states when you are going to do your safety inspections. If your company is required to have a JHSC, ensure that the minutes of the last safety meeting are posted. Make sure that the last meeting in no more than 3 months old.
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5. Health & Safety Rep and First Aid Persons are Posted
Make sure the names of your Health & Safety reps and First Aid persons are posted where everyone is able see them.
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We also have a list of everything that has to be posted and clearly visible in your workplace. There has been changes to some of the postings in the past few years.
6. Health & Safety Program
If your company has a Health & Safety Program in place, which is required under section 25(2)(j) of the OHSA, you are required to review that program annually. In our experience, not all companies are doing these reviews. This is the best time of the year to review your safety program to make sure that it is still working for you and to see if the changes in OHSA would impact your policies and procedures.
- If you are not sure if your safety program meets current standards, we can take a look and advise you on what you may need to do to bring it up to speed.
- If you do not have a safety program in place, let us know and we can help you figure out if you even need one (most businesses do). Our new health and safety programs are structured to many of the topics that are outlined in the WSIB’s new Excellence Program.
This is the time of year that you should take a look at what training you will have to do this year so that you can plan for when and who needs the training. You can request from us a list of who has been trained at your workplace and when they may need to be updated.
It is a good practice to identify what is needed and who needs training this time of year. That way if budget is required for approval, you will have enough time to do it. Don’t just plan for the training that you have to budget for, but also the training that you will do in-house, on-boarding of new staff, safety talks, and things that would promote safety during the next fiscal year.
Lastly, the new year is always a good time to review any outstanding recommendations that may be waiting approval. Review the safety meetings, monthly safety inspections, and previous recommendations to see if new goals need to be set for the next year.
Other things that you should consider:
Mandatory Worker and Supervisor Training
the regulation 297 Occupational Health and Safety Awareness and Training came out in 2013. As you know, this is the online training that all workers and supervisors must take. A lot of companies did the training when the law first came out, but we are finding that a lot of businesses have stopped doing this. We are also hearing from our clients that the MLTSD is still asking if business owners are doing this training or verifying that new hires have received it in the past.
Check to see if everyone at your workplace has taken this course.
Something we have discovered during interviews with supervisors is that a surprising amount of them have no idea if the company has a health and safety program in place. The company may have policies and procedures in place, but no one is following them because they are not aware of their existence. I had one supervisor tell me that he knows that there are safe work instructions developed for his workers to follow, and he ensures that they have been trained in those, but he admitted that he has never actually read them himself.
It really looks bad on a company and the employer if there is an accident in the workplace, and the company had policies in place to prevent accidents/ incidents, but nobody was following them. Please ensure that your management team is well aware of the companies H&S policies and procedures
WSIB Health & Safety Excellence Program
In 2016 the CPO was given the ability by the MLTSD to recognize employers with a health and safety program containing specific elements and issue an accreditation, found under section 7.6.2 of the OHSA. Employers have always had to develop Health & Safety Programs as you have done, but there was never any financial benefit to doing so. With this new law, the CPO states that if you have a functioning safety program in place, you could get accredited and be eligible for rebates on your WSIB premiums and a possible reduction in your annual premiums.
You could save a good amount of money if your program meets the standards required, and you can show that you are applying the policies, procedures and rules. There will also be other benefits by getting accredited by the Chief Prevention Officer (CPO) including being part of their list of companies that have demonstrated proper use of their managed safety program.
If this accreditation by the CPO or the possible WSIB rebates interests you, contact us and let us review your program so we can get you up to speed on the latest standards and requirements.
Randy Dignard | President
