COVID-19 Hazard Assessment Policy

PURPOSE

To establish a cost-effective, workable, scalable, and flexible system to identify, assess and control workplace COVID-19 infection hazards at ABC Company workplaces in accordance with the requirements of the [province] Occupational Health and Safety Act (“Act”), associated OHS Regulations (“Regulations”), orders and guidelines from the government and public health agency (“Guidelines”) and other applicable requirements and standards.

DEFINITIONS

For purposes of this Policy:

“Administrative controls” means the provision, use, and scheduling of work activities and resources in the workplace, including planning, organizing, staffing, and coordinating, for the purpose of controlling COVID-19 risk;

“Board” means the [province] Workers Compensation Board;

“Competent” means possessing knowledge, experience, and training to perform a specific duty safely and effectively;

“Engineering controls” means the physical arrangement, design, or alteration of workstations, equipment, materials, production facilities, or other aspects of the physical work environment, for the purpose of controlling risk.

SCOPE

The intent of this Policy is to identify, assess, and control hazards that endanger the health and safety of not only workers but also all persons present at ABC Company facilities and work sites, including but not limited to clients, customers, contract workers and visitors.

RAC SYSTEM

ABC Company will use a 3-phase system to protect workers, visitors, and others from COVID-19 the hazards of the workplace based on the principles of RAC:

R ecognition, i.e., identifying COVID-19 hazards;

A ssessment, i.e., evaluating the urgency of and prioritizing hazards identified; and

C ontrol, i.e., selecting appropriate measures to eliminate or control identified hazards.

PHASE 1. COVID-19 HAZARD RECOGNITION

The objective of the Recognition phase of the RAC system is to identify all COVID-19 hazards and potential hazards in the workplace in accordance with the following principles:

Hazard identification will be conducted before work begins at a work site;
Hazard identification will be done by a competent person who is familiar with the Act, Regulations and Guidelines;
Where safe and reasonably practicable, workers at the work site will participate in hazard identification via the workplace Joint Health and Safety Committee (“JHSC”) or Health and Safety Representative (“Representative”), or if no JHSC or Representative exists, direct participation;

After completion of hazard identification, a written report will be prepared listing an inventory of COVID-19 hazards by job classification.

PHASE 2. COVID-19 HAZARD ASSESSMENT

The objective of the Assessment phase is to analyze the COVID-19 hazards identified during the Recognition phase and determine urgency.

6.1 Job Classification Exposure Assessment

Using the inventory of hazards created at the end of the Recognition phase, a competent person will assess the identified hazards by completing the ABC Company COVID-19 Hazard Assessment Form (a copy of which is attached to this Policy as Attachment A) rating each job classification by level of exposure as:

Very high;
High;
Medium; or

Such assessments will be based on COVID-19 risk factors, including:

Physical distance of workers from co-workers, customers and other persons at the site between and/or employees and customers;
Effectiveness of current ventilating, air circulation and HVAC systems;
Operations requiring close contact, e.g., sharing of vehicles;
Age, respiratory or immune disorders, or other chronic medical conditions or physical characteristics making persons at the site unusually susceptible to COVID-19 infection; and
Availability of respirator masks and other necessary PPE.

6.2 Field Level Hazard Assessments

Before work begins, a competent worker or supervisor at the site will perform a field level hazard assessment by completing the Field Level Hazard Assessment Form (a copy of which is attached to this Policy as Attachment B).

PHASE 3. COVID-19 HAZARD CONTROL

ABC Company will ensure all reasonably practicable steps are taken to control COVID-19 hazards identified in Phase 1 on the basis of the assessment performed in Phase 2 in accordance with the following principles:

If reasonably practicable, ABC Company will eliminate COVID-19 hazards. Where total elimination is not reasonably practicable:

Reasonably practicable engineering controls will be used to control the hazard;
Administrative controls will be used where engineering controls are not reasonably practicable or as a supplement to engineering controls to minimize the COVID-19 hazard;
Gloves, masks, aprons and other personal protective equipment will be used as a last resort or as a supplement to engineering and administrative controls.

REVIEW & EVALUATION

The following monitoring and review measures will be taken for as long as the COVID-19 pandemic lasts or until such time that COVID-19 infection no longer poses a significant risk:

8.1 Review of Hazard Identification & Assessment

COVID-19 hazard identification and assessment required by Phases 1 and 2 will be repeated:

At reasonable intervals to prevent the development of unsafe and unhealthy work conditions;
When a new work process is introduced;
When a work process or operation changes;
Before construction of significant additions or alterations to the work site; and/or
In response to changes to Guidelines.

8.2 Review of Safety Controls

The effectiveness of COVID-19 hazard controls will be reviewed:

As part of monthly workplace inspections carried out;
In response to circumstances suggesting that conditions have changed and that controls might no longer be effective, including but not limited to:
- The occurrence of injuries, illnesses, incidents, accidents, or near-misses;
- Complaints or concerns expressed by workers at the site, either directly or through their JHSC or Representative;
- After significant changes to the affected job or process’s location, procedures, required equipment, etc.; and
- In response to changes to the Guidelines or regulatory requirements.

Attachments

Attachment A: ABC Company COVID-19 Hazard Assessment Form

Attachment B: ABC Company COVID-19 Field Level Hazard Assessment Form

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Attachment A: ABC Company COVID-19 Hazard Assessment Form

PART A: SHOULD THE WORKER BE ALLOWED AT THE WORK SITE?
1. Does worker have fever, cough, shortness of breath, trouble breathing, sore throat or runny nose?
[ ] No—Go to Question 2	[ ] Yes—Worker must be at home in self-isolation for 14 days after symptoms completely disappear
2. Has worker traveled outside Canada within last 14 days?
[ ] No—Go to Question 3	[ ] Yes—Worker must be at home in self-isolation for 14 days
3. Has worker tested positive for COVID-19?
[ ] No—Go to Question 4	[ ] Yes—Worker must be at home in self-isolation for 14 days
4. Has worker had any known exposure to COVID-19, e.g., near infected person without PPE?
[ ] No—Go to Question 5	[ ] Yes—Worker must be at home in self-isolation for 14 days
5. Does worker perform an essential service?
[ ] No—Go to Question 6	[ ] Yes—Worker must undergo risk assessment under Part B
6. Can worker perform the job remotely?
[ ] No—Go to Question 7	[ ] Yes—Company must implement work-at-home agreement for worker
7. Do work schedules + physical work environment ensure social distancing of at least 6 feet apart?
[ ] No—Perform risk assessment under Part B	[ ] Yes—Company must develop physical distancing operational plan that works for its business
PART B: PERFORM COVID-19 RISK ASSESSMENT
Complete the following risk assessment to identify: How workers may be exposed to COVID-19, e.g., via contact with co-workers, customers + general public Workers’ individual risk factors, e.g., age, chronic medical conditions, pregnancy *Controls necessary to eliminate or minimize risk
Job-Related Risk Levels for COVID-19
Exposure Risk Level	Description of Jobs
Very High	Frequent + direct exposure to COVID-19, e.g., health care workers + lab personnel working with COVID-19 patients
High	Indirect exposure to COVID-19, e.g., ambulance staff or hospital workers entering COVID-19 patients’ rooms
Medium	Frequent/close contact (within 6 feet) with potentially infected people who aren’t COVID-19 patients, e.g., at airports or retail stores
Lower	No required frequent/close contact with people who may be infected
PART C: SELECT CONTROL MEASURES (in order of preference)
[ ] Eliminate hazard: Remove task, equipment, chemical or action that causes hazard, e.g., having workers work remotely [ ] Substitute: Replace hazardous work process, substance, tool or equipment with a less hazardous one [ ] Eliminate hazard: Remove task, equipment, chemical or action that causes hazard, e.g., having workers work remotely [ ] Engineering controls: Design work site, equipment or process to eliminate, minimize or isolate the hazard, e.g., ventilation or use of physical barriers [ ] Administrative controls: Safe work procedures, training and other methods of limiting hazard by controlling how work is done, e.g., social distancing, requiring frequent hand washing, staggering work shifts to minimize number of workers present at any time [ ] PPE: Respirators, gloves, aprons + other protective equipment required based on exposure risk level
PART D. IMPLEMENT HAZARD CONTROLS
Identified Hazard	Control Method






PART E: MONITOR EFFECTIVENESS OF CONTROL MEASURES
[ ] Create a plan to monitor that each control measure is working, e.g., safety inspection checklist [ ] Correct measures found not to be working effectively [ ] Seek JHSC or worker input in monitoring and taking corrective action

Name: ______________________________________________

Title: _______________________________________________

Date of Completion: __________________________________

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Attachment B: ABC Company COVID-19 Hazard Assessment Form

Reassess and update as circumstances change or new hazards are identified.

Worker Name: Worker: Signature:	Supervisor Name: Supervisor Signature:		Assessment Date:
Company:		Occupation/Trade:
Work Site:		Location:
If you answer NO to any of these questions, tell your supervisor and DON’T begin work at the site Yes No ☐ ☐ Can you maintain a distance of 6 feet/2 meters between yourself and others? ☐ ☐ Is soap and water or hand sanitizer available? ☐ ☐ Do you have the required Personal Protective Equipment (PPE)? ☐ ☐ Do you know the procedure and schedule for sanitizing work areas and items that are frequently touched (door handles, printers, hand tools and equipment, telephones, keypads, etc.)? ☐ ☐ Have you disinfected surfaces and equipment that you will work on, or around? Use the table below to note the hazards and document the controls you will implement at the site.
Considerations for field work: ☐ Is the task or service considered “essential”? ☐ Can you substitute the task or service with a safer way of operating (for example, telephone or email orders instead of in‐person)? ☐ Can you create a barrier to reduce your risk of exposure to COVID‐19 (for example, put up clear plastic sheeting or Plexiglas between staff and customers or clients)? ☐ Can you put administrative controls in place that staff, customers, and clients must follow? Examples of administrative controls include:  Screening employees, customers, and clients for COVID‐19 with a self‐assessment.  Reminding customers or clients to remain 2 meters from staff using markings or signs.  Implementing strict cleaning protocols.  Having a process to minimize staff contact with customers or clients (for example, setting up a pick‐up and drop‐off location, or reducing the hours the business is open to the public).  Delivering items to a drop‐off area then calling to advise that the order is there. ☐ Do you have the required PPE) (which may include disposable gloves, respirators, Tyvek suits, masks or face shields that you can change and dispose of after any interaction with an item, client, or customer)?
Does this information need to be communicated to: ☐ Co-workers ☐ Supervisors ☐ Site or building owners ☐ Others		Communication method: ☐ Email ☐ Phone call ☐ Text ☐ Other (describe):

Hazard Control Table

Reassess and update as circumstances change or new hazards are identified.

Hazard that Leads to Exposure	Control Method












For each control, you should be able to answer YES to all of these questions: ☐ Have you discussed the hazards and controls with the workers? ☐ Have provided training for these control measures? ☐ Have you saved a copy of this risk assessment?