[Haley O’Halloran]

in reply to: How to use the OHS Insider AI Chatbot #107333

Hi there – you just click on the speech bubble in the corner of the OHSInsider website and enter in your question!

-OHSInsider Staff

[Haley O’Halloran]

in reply to: Cross-country H&S manual #106568

Hi there! Apologies for the delayed response to this question.

It’s great that you’re thinking ahead about aligning your H&S manual across multiple jurisdictions. You’re correct in noting that the Occupational Health and Safety (OHS) requirements can vary from province to province, but there are ways to approach this strategically so that you balance compliance with efficiency.

Here are some best practices to consider for structuring your H&S manual given the range of locations you operate in:

1. Core Policies vs. Provincial Specifics
Core policies: It’s common for companies to have core safety policies that apply universally across all provinces. These are usually based on the most stringent or comprehensive provincial requirements, typically aligned with federal standards (such as the Canada Labour Code, which covers federally regulated industries).
Provincial addendums: For each province where your operations are more significant (like BC), you can create provincial addendums or annexes that cover specific requirements for that province. For instance, BC has its own Workers’ Compensation Board (WorkSafeBC), and the Occupational Health and Safety Regulation in BC differs from Ontario’s regulations. You would not need to have separate full manuals for each province, but you could note specific provincial regulations in a dedicated section.

2. Common Best Practices
Uniform Structure: Keep the structure of the manual consistent. Have a central framework (e.g., Introduction, Safety Culture, Risk Assessment, Emergency Procedures, Training) and then use province-specific addendums to supplement areas that differ (e.g., injury reporting, specific safety equipment, health surveillance).
Risk Assessment & Hierarchy of Controls: A common best practice across the country is the application of the hierarchy of controls (eliminate, substitute, engineer, administrative, and PPE). This should be part of your core policy and should not change from province to province.
Safety Committees and Representatives: Many provinces have their own requirements for safety committees and health and safety representatives (for example, Ontario requires JHSCs in certain workplaces, whereas BC requires health and safety representatives under different conditions). Include a base guideline for these committees in your core policy, with a section on province-specific requirements in the addenda.
Training & Documentation: Document any mandatory training or certifications that are province-specific, such as WHMIS in Ontario vs. specific BC certifications. It may be helpful to create a central list of required certifications for all provinces, with any province-specific variations noted.

3. Flexibility & Integration
Cross-Referencing: In your manual, consider cross-referencing provincial regulations to keep things simple. You don’t have to replicate the provincial regulations verbatim; instead, summarize them and include references to the official regulatory documents.
Templates & Forms: You can standardize the forms and templates across provinces (incident reports, risk assessments, etc.), but provide provincial addendums that note any additional information that’s required in specific provinces.
Streamline Communication: Use a centralized platform or system for tracking compliance across all provinces. This could include a training management system or a compliance dashboard to help ensure staff are aware of the differences without needing to manually reference multiple documents.

4. Streamlining Efforts & Staff Workload
Internal Reviews: Involve both your Ontario and BC teams in reviewing the H&S manual. This will help identify any gaps in alignment between the two jurisdictions. You can take the most stringent requirements and create a baseline that is comprehensive yet simple enough to apply across multiple locations.
Regular Updates: Plan for regular reviews of the H&S manual. Given that safety regulations change frequently, this ensures that your manual remains compliant across all jurisdictions, but also that it stays manageable.

5. Best Practices for Implementation
Training & Communication: Once the manual is updated, ensure that there is ongoing training and communication with your teams, especially with employees who are moving across provinces or who have mixed jurisdictional responsibilities.
Feedback Mechanism: Create a process where employees can provide feedback on how the manual is working, especially if they are in different jurisdictions, to identify any real-world challenges or inefficiencies.

By adopting this approach, you can reduce the burden on staff while ensuring that you’re meeting all the regulatory requirements for each jurisdiction you operate in. This strategy also maintains consistency, which is key when managing operations across multiple provinces.

-OHSInsider Staff

[Haley O’Halloran]

in reply to: Environmental permits or certifications #106317

Below are the permits and certifications you would require in these various jurisdictions, if you have any other questions please submit a follow-up response! I have also included some resources from OHSInsider so you can be as knowledgeable as possible on this topic going forward.

Key Environmental Permits and Certifications
1. Federal Permits (Applicable to All Provinces)
Canadian Environmental Assessment Act (CEAA): If your manufacturing plant involves activities that may impact the environment significantly (such as hazardous waste disposal or large-scale production), you may need to undergo an environmental assessment under the CEAA.

National Pollutant Release Inventory (NPRI): This is a federal program that requires companies to report the release of certain pollutants. Manufacturing plants, especially those dealing with chemicals or plastics production, may need to comply with this reporting requirement if their emissions exceed certain thresholds.

2. Quebec (Montreal)
Environmental Quality Act (EQA): Under this provincial legislation, plastics manufacturers in Quebec must obtain permits for air emissions, wastewater discharges, and waste management. The Ministry of the Environment, the Fight Against Climate Change, Wildlife, and Parks (MELCCFP) issues these permits.

Certificate of Authorization (CA): If the plastics manufacturing plant has the potential to emit pollutants or discharge waste, a Certificate of Authorization from MELCCFP is required.

Quebec Hazardous Materials Management: If your manufacturing plant handles hazardous materials, Quebec requires you to follow strict regulations related to their management and disposal. This includes reporting and tracking hazardous materials.

3. Ontario (Toronto)
Environmental Protection Act (EPA): Ontario’s EPA governs air, water, and waste management. Manufacturers in Ontario must comply with the EPA, which often requires a Permit to Take Water or Air Emissions Permit, depending on the plant’s operations.

Environmental Compliance Approval (ECA): Issued by the Ontario Ministry of the Environment, Conservation and Parks (MECP), this approval is required for facilities that discharge pollutants into the environment (such as air, water, or land). Your plastics plant may need an ECA for managing waste, emissions, or water usage.

Waste Management: Manufacturers must follow proper waste diversion or recycling protocols to comply with Ontario’s waste management laws.

4. Alberta (Edmonton)
Environmental Protection and Enhancement Act (EPEA): This act governs environmental protection in Alberta. Plastics manufacturers may need approval under this act if their operations involve significant emissions or impact water quality.

Environmental Authorization: An authorization from Alberta Environment and Protected Areas is required if your plant’s activities impact air, water, or land resources. This includes air quality assessments and water discharge permits.

Waste Management Regulations: Alberta has specific regulations around hazardous waste disposal, waste tracking, and recycling, especially important for plastics manufacturers. You will need to ensure compliance with both the Waste Control Regulation and the Dangerous Goods Transportation Act.

5. British Columbia (Vancouver)
Environmental Management Act (EMA): Under this provincial act, businesses must ensure that their operations do not harm the environment. The Environmental Protection Division issues the necessary permits for air emissions, water discharges, and waste management.

Waste Discharge Permit: If the plant releases wastewater or other discharges into the environment, a permit from the BC Ministry of Environment is required. The regulations are stricter if the waste contains hazardous chemicals, which is a concern for plastics manufacturing.

Contaminated Sites Regulation: If your operations have resulted in contaminated soil or groundwater, you will need to follow the province’s contaminated sites regulations to manage and mitigate environmental risks.

BC Greenhouse Gas Emissions Reporting: Manufacturing facilities must track and report greenhouse gas emissions in accordance with BC’s carbon pricing system, which requires annual emissions reporting for large emitters.

6. Certifications (National and Provincial)
ISO 14001 (Environmental Management System): This is an internationally recognized standard that can apply to your plastics manufacturing plants. If your plant is certified under ISO 14001, it means your operations comply with stringent environmental management practices, including pollution control and waste management. Many Canadian businesses seek this certification to demonstrate commitment to sustainable practices.

EcoLogo Certification (Canada): A certification program that recognizes products that meet specific environmental standards. Plastics products that are environmentally friendly (e.g., recyclable or biodegradable) can be EcoLogo certified, which could also apply to your company’s product line if you produce or sell such items.

LEED (Leadership in Energy and Environmental Design): If your plastics manufacturing plants have any focus on energy efficiency or green building practices, LEED certification may be relevant. LEED is applicable for new constructions, renovations, or operations that prioritize sustainable building practices and reduced environmental footprints.

Steps for Obtaining Permits and Certifications
Assess Operations: Determine whether your facilities require specific environmental permits for air emissions, water usage, hazardous waste, or discharges.

Contact Provincial Authorities: Reach out to the relevant environmental agencies (e.g., MELCCFP in Quebec, MECP in Ontario, Alberta Environment, or the BC Ministry of Environment) to begin the permitting process.

Environmental Impact Assessment (EIA): If required, conduct environmental assessments and submit documentation to the appropriate agency for review.

Ensure Waste Management Compliance: Plastics manufacturers often have specific waste management requirements, particularly for hazardous waste. It’s important to comply with both provincial and federal regulations for waste disposal.

Sustainability Certifications: If applicable, apply for ISO 14001, EcoLogo, or LEED certification based on your commitment to sustainable practices.

Check out these resources for more information: Traps to avoid with environmental permits, Federal plastics manufacturing reporting rules that will be implemented in 2025, and Do you require permits if you’re a federally regulated manufacturing plant?

Thank you for your question!
-OHSInsider

[Haley O’Halloran]

in reply to: Eye Wash Station Station Question – Federally Regulated Workplace #106244

In Canada, while there isn’t a specific national standard for eyewash stations, the Canadian Centre for Occupational Health and Safety (CCOHS) references ANSI/ISEA Z358.1-2014 as a guideline. The CCOHS emphasizes the importance of using potable water in eyewash stations to prevent additional harm during decontamination.

Given that your building’s water has lead levels exceeding safe limits, using it in plumbed eyewash stations would not comply with these standards and could pose health risks. It’s advisable to either treat the water to ensure its potability or use alternative solutions, such as self-contained eyewash stations with sterile saline or preserved water, to meet safety requirements.

Read more about emergency eyewash station laws in your province and understand our full compliance game plan to ensure you and your employees are attended to in case of an incident that requires these measures. Hope this helps!

-OHSInsider Staff

[Haley O’Halloran]

in reply to: Lead Exposue #106243

We have had previous questions asking for a lead exposure policy, and have responded as such:
Here is what you should include for both organic and inorganic lead exposure or working with lead:
*Pre-placement medical testing;
*Periodic testing at frequency to be determined on bases of pre-placement testing and other medical records; *Testing after acute exposure;
*Exit testing;
*Stipulation of clinical tests to be used for each stage of testing; and
*Stipulation of the criteria/levels calling for the worker’s removal from exposure (or other actions to protect the worker).

If you want to see the clinical details for each of these items, go to the Ontario MOL website and look up the guidelines on Medical Surveillance Programs for lead under the OHS Designated Substances Reg. (Reg 490/09), which also works outside Ontario.

For thorough steps to address lead exposure:
Isolate the Area: Restrict access to the affected zone to prevent further exposure.
Provide Medical Evaluation: Offer exposed employees prompt medical assessments to determine lead levels in their blood.
Conduct Exposure Assessment: Evaluate the extent of lead exposure through air monitoring and surface sampling. Implement Control Measures: Introduce engineering controls (e.g., ventilation), administrative controls (e.g., rotating job assignments), and personal protective equipment (PPE) to minimize exposure.
Decontamination:
Ensure Proper Hygiene: Provide facilities for employees to wash hands and face before breaks and at the end of shifts to reduce ingestion risks.
Inform Employees: Educate workers about lead hazards, safe work practices, and the importance of hygiene to prevent lead absorption.

2. Depth of Procedure for a High Lead Event: In the event of significant lead exposure, procedures should be thorough and may include:
Comprehensive Medical Surveillance: Regular blood lead level testing and health evaluations to monitor affected employees.
Detailed Documentation: Maintain records of exposure levels, medical assessments, and implemented control measures.
Enhanced Training: Provide in-depth training on lead hazards, proper use of PPE, and decontamination procedures.
Environmental Remediation: Decontaminate the workplace to remove lead sources and prevent future exposures. Reporting requirements may include:
Incident Details: Provide information on the exposure event, including duration, concentration levels, and number of employees affected.
Corrective Actions: Outline steps taken to mitigate exposure and prevent recurrence. Specific reporting obligations can vary by jurisdiction. For instance, in Ontario, employers are required to notify the Ministry of Labour, Immigration, Training and Skills Development in cases of occupational illness, including lead exposure.
Notifying Exposed Employees:
Personal Notification: Communicate directly with affected employees regarding the nature and extent of their exposure.
Medical Information: Provide details on available medical evaluations and the importance of monitoring blood lead levels.
Protective Measures: Educate on steps being taken to reduce exposure and any changes to work practices.

Check out our post on working safely with lead and take our lead quiz to make sure you are complying with all provincial and federal requirements to keep you and your workers safe.

-OHSInsider

[Haley O’Halloran]

in reply to: Industrial Racking #106104

No, there is nothing regarding specific Saskatchewan legislation that addresses maintaining or designing supports for loads places on racks or what you must have in place to ensure weight capacities are accessible. It is best to go by manufacturer suggestions and call the manufacturer for more information to ensure best safety practices!

[Haley O’Halloran]

in reply to: Industrial Racking #106100

Pallets & Storage Racks
(130) An employer, contractor, owner or supplier shall ensure that:

(a) pallets are maintained in a manner that will permit safe lifting of the pallets and the pallets’ loads by a forklift truck or other device; and
(b) racks for the storage of materials or equipment are:

(i) designed, constructed and maintained to support any load placed on the racks; and
(ii) erected on a firm foundation.

8ft = 4,000 lbs.

9ft = 3,000 lbs.

10ft = 2,700 lbs.

12ft= 2,500lbs.

14ft= 2,300lbs.

You can find this information here.

Hope this helps!

-OHSInsider

[Haley O’Halloran]

in reply to: Head Protection #105910

Workers and supervisors who work at heights, like those operating aerial lifts, must be provided with the appropriate equipment to work safely at heights. This includes fall protection equipment, like harnesses, lanyards, and hard hats, in addition to other safety equipment like gloves and safety glasses. You must ensure that all equipment is maintained and used correctly. Aerial work platform training is governed by both federal and provincial regulations is Canada, and the Canadian Centre for Occupational Health and Safety (CCOHS) provides guidelines for safe operation, including wearing hard hats.

If you want to protect your workers and avoid potentially fatal accidents, you must require employees who are operating aerial lifts to wear hard hats. Safety is paramount when operating aerial work platforms. Following best practices can significantly reduce the risk of accidents and injuries.

-OHS Insider Staff

[Haley O’Halloran]

in reply to: Modified Work – BC – Non Occupational #105909

In British Columbia, amendments were made to the Workers’ Compensation Act in January that affected return to work for injured workers. All employers and workers must cooperate with each other and WorkSafeBC to ensure an injured worker can return to their pre-injury role, a comparable role, or other suitable work within the company. There is now a “duty to cooperate” – which applies to workers and employers. The duty to cooperate means that workers and employers need to cooperate with each other and WorkSafeBC to make suitable work available to workers in a timely and safe manner following their injury. Your employee must cooperate with you to identify which modifications should be made to their job duties to ensure they can reasonably execute these duties. They cannot unreasonably refuse work when you make it available to them. You must make the necessary changes to accommodate your employee’s abilities after their injury to perform new or modified duties.

There is also the “duty to maintain employment”. If an employee is injured off the job and you regularly employ 20 or more workers and have employed the injured worker for at least one year prior to their injury, you must maintain that worker’s employment. If a worker is fit to return to the role they held before their injury, you need to offer either the pre-injury work to the worker or a comparable alternative.

If the injured employee is not complying with their modified work requirements, you can contact WorkSafeBC to intervene. Long story short? You are required to provide modified work to all injured workers, whether they were injured on or off the job. Thank you for your question!

-OHS Insider Staff

[Haley O’Halloran]

in reply to: Fire Extinguishers #105863

There are no specific requirements pertaining to team members in a Saskatchewan workplace needing to be trained by certified third party personnel to handle fire extinguishers in the workplace, you just need to ensure everyone in the workplace knows how to use them in the case of an emergency and during regular drills. Internal training should suffice, but if third party training is available, that is a great way to have all employees and managers get some hands-on experience with how to put out a fire and how to identify types of fires and extinguishers.

Per the OHS Fire Extinguisher “Know The Laws – Saskatchewan“:

An employer, contractor, or owner shall ensure that portable fire extinguishers are selected, located, inspected, maintained, and tested so that the health and safety of workers at the place of employment is protected.

(2) An employer, contractor, or owner shall ensure that portable fire extinguishers are placed not more than nine metres away from:

(a) each industrial open-flame portable heating device, tar pot or asphalt kettle that is in use; and

(b) each welding or cutting operation that is in progress. Section 36(1).

An employer or contractor shall ensure that a fire extinguisher approved for Class C fires is readily available to workers working on or near energized high voltage electrical equipment. Section 463.

For more information, see:

Provisioning Section 4.3.
Placement and Installation Section 4.4.
Monthly Inspections Section 4.5.1.
Inspection Elements Section 4.5.1.1.
General Maintenance Requirements Section 4.5.2.1.
Extinguisher Recharging Section 4.5.2.4.
Training Section 4.5.

-OHS Insider Staff

[Haley O’Halloran]

in reply to: Keeping Eye Wash Stations at a Tepid temperature #105237

Hello! In terms of the external heating unit, that sounds like more of a business expense than a compliance question. With a quick Google search I was able to find some heating units from ULINE Canada and Global Industrial under $1,000, but I recommend going with the best option that will keep your eye wash station at the safest temperatures year-round. It is much less costly to invest in more expensive appliances and products that ensure you are fully complying with health and safety requirements in the workplace rather than putting your workers at risk and potentially facing a hefty lawsuit later on in your operations.

Aquarium heating pads are a bit out of my realm of expertise, but I have left comments open in case anyone can help you out with your question. I hope this helped!

-OHS Insider Staff

[Haley O’Halloran]

in reply to: Fall Protection System- Which requires engineers? #105185

In Alberta, the fall protection systems that must be designed or stamped by a professional engineer include:

Fixed Ladders: If a fixed ladder is made of a material other than steel, the employer must ensure that the design is certified by a professional engineer as being as strong as or stronger than that required by PIP Standard STF05501.
Bolted and Welded Permanent Fixed Anchor Points: You must ensure that an anchor rated at two times the maximum arresting force is designed, installed and used in accordance with the manufacturer’s specifications, or specifications certified by a professional engineer.
Rail Systems Attached To The Ground Or A Structure: A rigid horizontal fall protection system must be designed, installed and used in accordance with either the manufacturer’s specifications or specifications certified by a professional engineer.

Handrails and double bar safety gates do not need to be designed by a professional engineer in order to be used on a work site, but you should use them in accordance with the manufacturer’s specifications. However:

Handrails must be continuously protected from falling by EITHER: (i) equipping the fixed ladder or climbable structure with an integral fall protection system that meets the requirements of one of the following:

CSA Z259.2.4-15, Fall Arresters and Vertical Rigid Rails;
CSA Z259.2.5-17, Fall Arresters and Vertical Lifelines; or
ANSI/ASSE Z359.1-2007, Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components.

Learn more about the details of Alberta’s Fall Protection Policy here to ensure your work site is safe and compliant.

-OHSInsider Staff

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