Biohazard Control Policy

This Model Exposure Control Policy is a basic and fairly generic template that OHS managers will need to adapt for specific substances and the specific OHS regulatory requirements of their particular province.

PURPOSE

ABC Company has adopted this Policy to ensure that all workers understand and are able to protect themselves from the health and safety hazards posed by the controlled products containing biohazards used, stored, produced, and handled at ABC Company’s workplace in accordance with the [insert jurisdiction] Occupational Health and Safety Act (“Act”), Occupational Health and Safety Regulations (“Regulations”), the ABC Company Occupational Health and Safety Program (“OHS Program”) and other applicable requirements and standards.

DEFINITIONS

For purposes of this Policy:

“Biological substance” means a substance containing living organisms, including infectious micro-organisms, or parts of living organisms in their natural or modified forms;
“Chemical substance” means any natural or artificial substance, whether in the form of a solid, liquid, gas, or vapour, other than a biological substance;
“Competent” means possessing knowledge, experience, and training to perform a specific duty safely and effectively;
“Controlled product” means a product, material, or substance specified by the Controlled Products Regulations made under Section 15(1)(a) of the Hazardous Products Act (Canada) (“HPA”) to be included in any of the classes listed in Schedule II of the HPA, and for which WHMIS training and identification is required;
“Designated chemical substance” means:

- Any mixture containing less than 1% of notifiable chemical substance; or
- Any chemical substance listed in the Regulations;

“Director” means the director of the [name of ministry, department or agency that enforces the OHS laws in your jurisdiction];
“Notifiable chemical or biological substance” means:

- Any chemical substance or mixture containing 1% of such chemical substance listed in the Regulations; or
- Biological substance that is a genetically modified microorganism;

“Practicable” means possible given current knowledge, technology and invention;
“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.

POLICY STATEMENT

The management of ABC Company is committed to providing workers a safe and health working environment and ensuring that at any workplace containing chemical or biological substances, all reasonable steps are taken to identify, assess, and control the hazards posed by such substances as required by OHS laws and the OHS Program.

SCOPE

4.1. Workers This Policy Is Intended to Protect

The intent of this Policy is to ensure that all workers working at ABC Company work sites in which chemical or biological substances are present are protected from hazards associated with exposure to chemical or biological substances, regardless of who pays or employs those workers, including:

Full- or part-time workers employed by ABC Company;
Temporary employees placed by an outside agency to work at the site;
Contract labourers engaged to perform work at the site;
Volunteers who work at the site for free; and
Workers employed by prime contractors, contractors, and subcontractors to perform work at the site under a contract with ABC Company.

4.2. Substances This Policy Is Intended to Cover

The intent of this Policy is to establish a general system to protect workers from exposure to an array of harmful chemical or biological substances. This Policy does not purport and does not intend to provide comprehensive protection against asbestos, flammable substances, silica, explosives or other designated chemical or biological substances or classes of substances that require additional and special controls under the Regulations. Where such designated substances are present at the workplace, ABC Company will develop and implement specific policies to providing the additional and specific protections required by the Regulations.

ROLES & RESPONSIBILITIES

5.1. Employer

Owners, corporate officers and directors, upper managers, and other representatives of ABC Company who may be defined as an “employer” under the Act are responsible for overall implementation of this Policy, including ensuring that:

The resources necessary to implement this Policy effectively are provided;
The assessment and inventorying of chemical and biological substances required by Section 6 of this Policy are carried out and appropriately reviewed and revised;
Appropriate controls are selected and implemented to protect workers from chemical and biological substances, including but not limited to the development and implementation of safe work procedures and processes for use, handling, storage, production, and disposal of such substances required under Section 8 of this Policy;
Workers are trained in and required to comply with safe work procedures and processes;
The exposure limits required by this Policy are effectively implemented, including but not limited to substance-specific exposure limits under Section 9.2.;
Adequate notification is provided to and approval received from the Director before notifiable chemical or biological substances are handled, used, stored, disposed of, produced, or distributed in accordance with Section 11.1.;
The monitoring and measuring of workers’ exposure to chemical and biological substances required by this Policy is properly carried out and documented;
Where reasonably practicable, substitution and engineering controls are used to control chemical or biological substance hazards;
All of the emergency equipment, personal protective equipment (“PPE”), and protective clothing required is provided and properly used;
Workers are allowed to participate in the identification, assessment, and inventorying of chemical and biological substances and selection of control measures, either directly or, where one exists, through their workplace Joint Safety and Health Committee (“Safety Committee”) or Health and Safety Representative (“Safety Representative”);
All exposed workers receive the information and training required by this Policy;
This Policy is appropriately reviewed.

5.2. Safety Coordinator, Site Manager

The safety coordinator, facility manager, or other person designated as being in charge of safety at the workplace is responsible for ensuring the effective implementation of the chemical and biological safety measures required by this Policy, including ensuring that:

The assessment and inventorying of chemical and biological substances required by Section 6 of this Policy are carried out and appropriately reviewed and revised;
Appropriate controls are selected and implemented to protect workers from chemical and biological substances, including but not limited to the development and implementation of safe work procedures and processes for use, handling, storage, production, and disposal of such substances required under Section 8 of this Policy;
Workers are trained in and required to comply with safe work procedures and processes;
The exposure limits required by this Policy are effectively implemented, including but not limited to substance-specific exposure limits under Section 9.2.;
Adequate notification is provided to and approval received from the Director before notifiable chemical or biological substances are handled, used, stored, disposed of, produced, or distributed in accordance with Section 11.1.;
The monitoring and measuring of workers’ exposure to chemical and biological substances required by this Policy is properly carried out and documented;
Where reasonably practicable, substitution and engineering controls are used to control chemical or biological substance hazards;
All of the emergency equipment, PPE, and protective clothing required is provided and properly used;
Workers are allowed to participate in the identification, assessment, and inventorying of chemical and biological substances and selection of control measures, either directly or, where one exists, through their workplace Joint Safety Committee or Safety Representative);
All exposed workers receive the information and training required by this Policy;
This Policy and any safe work procedures developed under it are applied to prime contractors, contractors, and subcontractors hired to perform work at ABC Company sites involving exposure to chemical or biological hazards in accordance with Section 16 of this Policy;
All records required to implement this Policy are kept and retained;
This Policy is appropriately reviewed.

5.3. Supervisors

Supervisors are responsible for day-to-day implementation of many of the measures provided by this Policy, including ensuring that:

All workers exposed to chemical or biological substances receive, understand, and follow their WHMIS or training or equivalent training provided under Section 7;
Safe work procedures and processes for using, handling, storing, producing, and disposing of hazardous chemical or biological substances are created and implemented;
Workers are trained in and required to comply with safe work procedures and processes;
Workers are not exposed to unsafe levels of chemical or biological substances;
Workers are held accountable for complying with this Policy and carrying out any applicable safe work procedures, including where necessary via the imposition of discipline for infractions;
This Policy is properly applied to workers of prime contractors, contractors, and subcontractors hired to work at ABC Company work sites where chemical or biological substances are present;
This Policy is appropriately reviewed.

5.4. Workers

Workers are responsible for knowing, cooperating, and complying with this Policy by:

Using their WHMIS training, including but not limited to, for reading WHMIS labels and Safety Data Sheets (“SDSs”), when working with chemical or biological substances;
Being aware of and carrying out safe work procedures for use, handling, production, storage, and disposal of chemical or biological substances;
Wearing any supplied protective clothing;
Washing effectively before each work break and at the end of the work shift;
Showering at the end of the shift, if required;
Refraining from eating, drinking, smoking, putting on cosmetics, or storing food in any work area where the work process is carried out;
Properly decontaminating themselves and their clothing and not removing contaminated clothing from the workplace;
Properly using, inspecting, and storing any PPE or respiratory protective equipment they are required to use;
Reporting any chemical or biological hazards to their supervisor or manager.

5.5. Safety Committee/Safety Representative

ABC Company will consult with and secure the participation of the workplace Safety Committee, Safety Representative, or where no Committee, or Representative exists, the affected workers at the site in developing and implementing this Policy, including with regard to:

Assessment of chemical and biological substances;
Development of WHMIS training;
Development of safe work procedures and processes;
Selection and monitoring of hazard controls;
Selection and installation of emergency washing equipment and PPE;
Investigation of exposure incidents;
Review of this Policy.

5.6. Visitors

Visitors to ABC Company worksite covered by this Policy are responsible for:

Staying away from areas of the work site where chemical or biological substances are present unless they:
- Are authorized to be in those areas;
- Follow all applicable safe work procedures while in those areas;
- Use all required PPE or respiratory protective equipment;
Refraining from engaging in any conduct that distracts or interferes with the implementation of the procedures and protections set out in this Policy.

INVENTORY

6.1. Preparation of Chemical & Biological Substances Inventory

ABC Company will perform an assessment to identify:
- All chemical and biological substances that are regularly used, handled, stored, produced, or disposed of during work processes carried out at itsworkplaces that may be hazardous to workers’ health and safety; and
- Any other chemical and biological substances that may be present at the workplace of concern to the workers;
The results of the above assessment will be used to prepare an inventory of chemical and biological substances at the workplace and denote which of them are controlled products;
The assessment will be carried out and the inventory prepared by competent ABC Company personnel in consultation with the Safety Committee or Safety Representative, or if no Safety Committee or Safety Representative exists, directly with the workers at the workplace;
ABC Company will keep a copy of the inventory at the workplace and make it readily available to workers.

6.2. Reassessment & Revision of Inventory

ABC Company will perform a new assessment if there is a change in workplace conditions potentially affecting health and safety;
ABC Company will revise the inventory whenever new chemical or biological substances not listed on the inventory are introduced to the workplace or chemical or biological substances that are listed on the inventory are removed;
Any time ABC Company revises the inventory, it will submit a copy of the revision to the Safety Committee or Safety Representative.

WORKERS’ RIGHT TO KNOW

ABC Company will take the following steps to ensure that workers are able to effectively exercise their WHMIS right to know with regard to any chemical or biological substances that they work with or near:

As noted above, the inventory will denote any identified chemical or biological substance that is a controlled substance. Relying on this designation, ABC Company will divide identified chemical or biological substances into 2 groups:
- Group A: Substances considered controlled products that are covered by WHMIS Regulations;
- Group B: Substances considered controlled products that are not covered by WHMIS Regulations and/or substances that are not considered controlled products;
Substances in Group A will be identified by SDSs, supplier or workplace labels, placards, and other methods of identification and covered in the training required by WHMIS;
Because substances in Group B are not covered by WHMIS, ABC Company will ensure that workers receive protection equivalent to the WHMIS right to know with regard to these substances by taking all reasonable steps to:
- Determine and record the hazards that may arise from the workplace handling, use, storage, production, or disposal of these substances;
- Determine and record the precautions necessary to ensure the safe handling, use, storage, production, or disposal of these substances;
- Clearly mark the container holding the substance with the name of the substance as set out in the inventory;
In addition, ABC Company will, in consultation with the Safety Committee or Safety Representative, or directly with workers if no Safety Committee or Safety Representative exists at the workplace, develop a program to instruct workers about the hazards posed by the substances in Group B train them in the precautions necessary to guard against those hazards.

SELECTION OF CONTROLS

ABC Company will assess the hazards posed by chemical and biological substances present at the workplace and select and implement control measures at the workplace to eliminate or minimize those hazards. Such control measures will include:

Monitoring the use or presence of, and/or a worker’s exposure to, any chemical or biological substance that may be hazardous to a worker’s health or safety;
Where reasonably practicable, replacing hazardous chemical or biological substances with safer substitutes;
Reducing workplace contamination by chemical or biological substances to the extent reasonably practicable; and
Developing and implementing safe work procedures and processes that make the use, production, storage, handling, and disposal chemical and biological substances as safe as reasonably practicable;
Implementing any required additional controls for designated chemical substances in accordance with Section 11.1. below and/or notifiable chemical or biological substances in accordance with Section 11.2. below.

LIMITING WORKER EXPOSURE

9.1. General Controls

ABC Company will take all practicable steps to prevent workers from harmful or potentially harmful exposure to:
- A chemical or biological substance that may be hazardous by itself; and/or
- Chemical or biological substances that may be hazardous in a mixture or when otherwise present with another chemical or biological substance;
ABC Company will ensure that workers who are exposed to hazardous or potentially hazardous chemical or biological substances:
- Are informed about the nature, degree, and potential health effects of exposure to the chemical or biological substance during work;
- Receive proper safety training on:
- Any safe work procedures or processes developed in accordance with Section 7 above; and
- The proper use of any required PPE or respiratory protective equipment.

9.2. Substance-Specific Exposure Limits

Where a chemical or biological substance subject to a specific contamination limit listed in Table 21 of the Regulations is present at the workplace, ABC Company will:
- Provide adequate engineering controls to ensure, to the extent reasonably practicable, that the contamination limit set for the particular substance in the OHS Regulations is not exceeded in any area where a worker is usually present; and
- Take all practicable steps to ensure that no worker’s personal exposure to the substance exceeds the contamination limit for the substance set out in the OHS Regulations;
Where a chemical or biological substance listed in the OHS Regulations is present at the workplace in an airborne concentration that may be hazardous to a worker who either: i. is regularly required or allowed to work more than 8 hours in a day or 40 hours in a week; or ii. may be exposed to a combination of association of OHS Regulation-listed substances that have similar toxicological effects when acting on the same organ or body system, ABC Company will develop and implement, in consultation with the Safety Committee or Safety Representative, a written procedure that identifies:
- The substances to which a worker may be exposed;
- The conditions under which a worker will be required or allowed to work, including the frequency, quantity, and duration of exposure to the substances; and
- The steps to be taken by ABC Company ensure, to the extent reasonably practicable, that no worker is exposed above the contamination level for the substance set out in the Regulations.

9.3. Respiratory Protective Devices

Where it is not reasonably practicable to reduce a worker’s exposure to a substance listed in the OHS Regulation to the contamination level for the substance listed in the Regulations for that particular substance, ABC Company will provide and require workers to use approved respiratory protective devices that meet the requirements of the Regulations.

EXPOSURE & CONTAMINATION RECORDS

ABC Company will keep and make available to the Safety Committee or Safety Representative, or where no Safety Committee or Safety Representative exists at the workplace, the workers:

The results of any measurements of worker exposure to, and contamination of a workplace by, a chemical or biological substance; and
Any steps taken to reduce workplace contamination or eliminate or reduce worker exposure to a chemical or biological substance.

ADDITIONAL CONTROLS

In addition to the general controls set out in Section 7 to 10 above, ABC Company will implement any additional controls required by the Regulations for particularly hazardous substances or operations.

11.1. Notifiable Chemical or Biological Substances

Where workplace processes or operations involve substances considered to be notifiable chemical or biological substances, ABC Company will:

Send the Director a written notice of any actual or intended handling, use, storage, production, distribution, or disposal of the notifiable chemical or biological substance;
Refrain from handling, using, storing, producing, distributing, or disposing of the notifiable chemical or biological substance without:
- Getting the Director’s written permission; and
- Complying with any condition the Director sets for such handling, use, storage, production, distribution, or disposal.

11.2. Designated Chemical Substances

Where workers are required to handle, use, store, produce, or dispose of any chemical substances considered to be designated chemical substances, ABC Company will:

Provide adequate engineering controls to prevent, to the extent reasonably practicable, the release of the substance into the workplace; and
Take other measures and provide PPE and respiratory protective equipment that meets the requirements of the Regulations to prevent, to the extent reasonably practicable, any significant risk posed to workers by the substance.

11.3. Special Protections for Highly Vulnerable Workers

Where a chemical or biological substance is present at the workplace in a form or amount that may be harmful to workers who are pregnant, sensitized, or unusually responsive to the substance, ABC Company will, as soon as reasonably practicable after being notified of the worker’s condition:

Where reasonably practicable, take steps to minimize the worker’s exposure to the substance; or
If the worker requests it, assign the worker to less hazardous alternate work to the extent such work is available.

11.4. No Exposure of Workers under Age 16

ABC Company will ensure that no person under age 16 is assigned or allowed to perform work involving exposure to a chemical or biological substance that is likely to endanger their health or safety.

INCIDENT RESPONSE

If there is a possibility of an accumulation, spill, or leak of a chemical or biological substance that may be hazardous to a worker at the workplace, ABC Company will:

Establish and implement a chemical incident response procedure that meets the requirements of the Regulations; and
Ensure that any spilled or leaked materials that may pose a hazard are removed from the workplace by a suitable method as soon as practicable.

WRITTEN REPORT OF WORKER EXPOSURE

In the event of a workplace accumulation, spill, or leak of a notifiable chemical or biological substance or designated chemical substance resulting in a potentially harmful exposure to a worker, ABC Company will:

In consultation with the Safety Committee or Safety Representative, investigate the incident as soon as reasonably practicable;
Prepare a written report that includes:
- A description of the incident, including the date and all affected workplaces;
- The names and characteristics of each substance released;
- For each substance released, an estimate of the extent and duration of each worker’s exposure;
- The name of each worker exposed and the manner in which the substance entered the worker’s body;
- The causes of the incident; and
- Any corrective actions taken to prevent occurrence of a similar incident in the future;
Provide a copy of the written report to any worker exposed to the released substance;

PERSONAL HYGIENE & DECONTAMINATION

Where a worker’s work clothing or skin is likely to be contaminated by a hazardous substance, ABC Company will:
- Supply and require workers to use protective clothing and head cover appropriate to the work and hazard;
- Provide a suitable changing area; and
- Ensure that clothing and head cover are safely handled and cleaned or disposed of;
Where a worker’s skin is likely to be contaminated by a hazardous substance as part of the regular work processes at the workplace, ABC Company will:
- If reasonably practicable, provide and maintain suitable, adequate, and clean change and shower facilities; and
- Allow sufficient time, during normal work hours without loss of pay or other benefits, for workers to use the facilities;
here work processes involve the use of substances that may contaminate a worker’s body, clothing, or food, ABC Company will:
- Provide an eating area that is separate from the site of the potential contamination and close to washing facilities; and
- Ban workers from eating, drinking, smoking, putting on cosmetics, or storing food in any work area where the potential for contamination exists.

EMERGENCY WASHING EQUIPMENT

15.1. Emergency Showers

Where there may be a risk of substantial contamination of a worker or a worker’s clothing from corrosive or other harmful substances, ABC Company will provide and maintain an approved and readily accessible means of bathing or showering workers in lukewarm water.

15.2. Eye Flushing Facilities

Where there may be a risk to a worker’s eyes from corrosive or other harmful substances, ABC Company will provide, at readily accessible locations, approved equipment to flush the worker’s eyes with lukewarm water or another appropriate fluid.

Where PPE, including respiratory protective equipment is used as a control measure, it meets the requirements of the Regulations.

PRIME CONTRACTORS, CONTRACTORS & SUBCONTRACTORS

ABC Company will ensure that any prime contractors, contractors, and subcontractors hired to perform work at an ABC Company work site where chemical or biological substances are present, are, before such work begins:
- Notified of the presence of those substances and the hazards posed by each one;
- Notified of the monitoring regime, safe work procedures, and control measures taken to protect workers from harmful exposure to such substances, including the exposure limits for each chemical or biological substance present;
- Required to make their own workers aware of and ensure their compliance with such safe work procedures and control measures, including but not limited to using the required PPE and respiratory protection equipment in conducting the work;
- Prime contractors, contractors, or subcontractors in control of work at an ABC Company site in which chemical or biological substances are present will be required to provide workers engaged in the contract work who are exposed adequate protection that is at least equivalent to this Policy by either:
- Directly applying this Policy and ABC Company’s safe work procedures developed under it to the contract work and assuming all of the employer obligations this Policy assigns to ABC Company; or
- Developing and implementing an equivalent policy and set of work procedures that meet the requirements of the Regulations, is suitable for the workplace, and is coordinated with this Policy and safe work procedures.

EVALUATION

This Policy will be reviewed at least once a year and more often in response to changes affecting workers’ health and safety.