DOS & DON’TS: [√] Train Workers on New Procedures

An effective OHS program can’t be static. That is, you can’t develop safe work procedures, train workers on them and then never give those procedures a second thought. You should always be looking for ways to improve your procedures and make them even safer, particularly when new hazards are identified. And when you do revise or update your safe work procedures, don’t just post the new steps or process in the workplace. Make sure that you train workers on the new procedure to ensure that they fully understand the changes. Simply posting a new procedure without training workers on it could result in an OHS order, violation or even an injury.

Look what happened to an Ontario employer that operated buses. Concerns were raised to the JHSC about the brakes on the buses. The employer updated its Standard Operating Procedure on how to handle a complete brake system pressure loss to address the problem. It then posted the update procedure on information boards and video screens in the workplace. An MOL inspector asked whether all affected workers had been trained on the updated procedure. The employer said affected workers should read the posted update. Because the inspector was concerned that the employer couldn’t prove that all impacted workers were aware of the new procedure or how it was to be applied, he ordered the employer to “provide instruction and training” on the updated procedure. The employer appealed the order, arguing that there was no suggestion that the workers didn’t understand the updated procedure or that they weren’t aware of it. So the inspector’s order should be suspended pending the appeal.

But the Ontario Labour Relations Board disagreed, ruling that the failure to train or instruct workers on the updated procedure could endanger their safety. The training didn’t put an onerous burden on the employer. So the mere posting of the procedure wasn’t sufficient. In short, the Board held that the employer should take “the few minutes it would take to provide instruction or training” on the new procedure to workers. So it refused to suspend the training order [London Transit Commission v Amalgamated Transit Union, [2014] CanLII 68423 (ON LRB), Nov. 6, 2014].