[vickyp]

in reply to: indoor-air-quality #103239

Yes, Andree, well said. I completely misspoke. The qualifier indeed only covers the Sec. 2.21 to 2.24 requirements dealing with Operations, Equipment Standards and such, items that a tenant not owning the HVAC system can’t control. The remaining requirements, including maintenance instructions and INVESTIGATIONS apply to “all employers.” I apologize for my carelessness and thank you for your judgment in not trusting my answer at face value and looking at the matter yourself. We should switch roles. Thanks for the schooling and be assured that I will be far more diligent with future Qs. Our users deserve no less. Happy holidays to you and your family and stay well. Glenn

[vickyp]

in reply to: indoor-air-quality #103238

Good morning,
I have a follow up question regarding IAQ.  Section 2.20 indicates that “Sections 2.21 to 2.24 apply to every work place that
is equipped with an HVAC system and that is under the employer’s control.”  However, the investigation procedures are found in section 2.27 which does not fall within the limitations of 2.21 to 2.24.  Can you please provide a little more detail as to why the investigation requirements would not apply’  With COVID, as I am sure you can appreciate, this is a BIG issue.
Many thanks! Andrée

Question:  If the Employer is not responsible for the ventilation system (i.e. rented space), are they required to have an IAQ policy and investigation procedure’  The Employer is federally regulated.

Question Tags: ONTARIO

Answer: No. Section 2.20 of the federal COHS Regs. specify that the IAQ requirements “apply to every work place that is equipped with an HVAC system and that is under the employer’s control” (emphasis added). Since your landlord controls the HVAC system, you’re not bound by the investigation and other IAQ rules listed in those parts of the Regs.

[vickyp]

in reply to: indoor-air-quality #103237

No. Section 2.20 of the federal COHS Regs. specify that the IAQ requirements “apply to every work place that is equipped with an HVAC system and that is under the employer’s control” (emphasis added). Since your landlord controls the HVAC system, you’re not bound by the investigation and other IAQ rules listed in those parts of the Regs.

[vickyp]

in reply to: Is a federall-regulated workplace operating in Ontario required to complete pre-entry COVID-19 screening? #103236

Yes

[vickyp]

in reply to: Best practices for Workplace observations? #103235

Here’s what I was able to find
Checklist https://www.mydatascope.com/en/template/mining/visible-felt-leadership-vfl’id=121071
Template from actual company https://www.angloamerican.com/~/media/Files/A/Anglo-American-PLC-V2/documents/approach-and-policies/safety-and-health/the-anglo-american-safety-way-final.pdf
Observations policy/procedure https://etenders.treasury.gov.za/sites/default/files/tenders/32-407%20Behavioural%20Safety%20Observations.pdf
Activities Assessment sheet, https://www.google.com/search’q=%22Felt+Leadership%22+template+forms&rlz=1C1GGRV_enUS783US783&ei=zk3RX7r0Gd6v5NoP98i_gAM&start=10&sa=N&ved=2ahUKEwi6k-zL98HtAhXeF1kFHXfkDzAQ8tMDegQIEBA1&biw=1455&bih=688
VFL Observation Card template https://lumiformapp.com/templates/field-safety-observation-card-visible-felt-leadership_10627
Hope this helps. Glenn

[vickyp]

in reply to: Private: Is it possible to send an example of our hazard assessment to be reviewed? #103234

I’ll be happy to review it. Pls send it to glennd@bongarde.com and I’ll give it a look. If you did already send it, please list your gmail so I can check if it landed in Spam. Thanks.

[vickyp]

in reply to: AB #103233

Do you mean for COVID’ If so, the answer is yes. But if you have another site-specific hazard assessment in mind, the answer may be different. Can you please clarify’ Thanks.

[vickyp]

in reply to: Private: covid-19-secondary-close-contact-disclosure-requests #103232

Yes. Under current public health guidelines, employers not only can but MUST screen employees and so-called non-essential visitors–such as vendors or contract workers, but not customers–about COVID symptoms and recent contacts with confirmed or probable cases. The third risk factor is travel outside Alberta. If the employee/non-essential visitor answers YES to the close contacts question, you can and must send them home for self-isolation. However, you can’t ask them to disclose the names of their close contacts UNLESS the employee/non-essential visitor is confirmed as having COVID, in which case you can obtain that information and notify the listed contacts that a person with whom they’ve had recent contact has COVID and suggest they get tested and self-isolate. In making that disclosure, you must limit the information to the minimum necessary to ensure the contact is notified. If possible, don’t reveal the employee’s name or other info that can be used to identify him/her.
Hope that answers all your questions. If not, feel free to contact me at glennd@bongarde.com   Glenn

[vickyp]

in reply to: Working Alone Best Practice – Alberta #103231

There’s a lot of good stuff on the OHSI site addressing this, including a Model Working Alone Policy based on Alberta OHS laws that I’ve pasted in below.
I’d start with this Special Report, which provides a great overview, even though it’s not Alberta-specific
https://ohsinsider.com/wp-content/uploads/OSHI-Working-Alone-final.pdf
Here are some other TOOLS:
Hazard Assessment Checklist (Potential for violence should also be listed as a risk factor): https://ohsinsider.com/safety-checklist-for-lone-workers-working-alone/
Safe Work Procedure https://ohsinsider.com/wp-content/uploads/Model-Safe-Work-Procedure-for-Working-Alone.pdf
Training Records: https://ohsinsider.com/sample-training-record-for-working-alone/
And here’s the Model Policy
Safety Policy for Working Alone
Purpose
To protect the safety of Workers who work alone as required by Part 28 of the Alberta Occupational Health and Safety Code (“Code”) as well as the Occupational Health and Safety Act (“Act”), Occupational Health and Safety Regulation (“Regulation”), the XXXX Occupational Health and Safety Program (“Safety Program”), and other applicable requirements and standards.
Definitions
For purposes of this Policy:

 “Reasonably Practicable” means a standard used to determine whether a specific safety measure is appropriate and viable for use by XXXX to control a specific hazard at its workplace applied by XXXX management on a case-by-case basis and which involves determination of:

• “Reasonableness,” an evaluation that weighs factors such as degree of risk to workers, nature of the hazard, length and frequency of exposure, number of workers exposed, and severity of consequences the hazard can result in; and
• “Practicability,” an evaluation of whether a particular method of controlling the hazard is technologically feasible, affordable, cost-effective for the particular hazard, suited to the circumstances of the workplace, or otherwise viable.

To be deemed not “reasonably practicable,” a measure must be more than simply inconvenient or costly but impossible to adopt or which could be adopted but only by investing time, energy, money, and other resources that are disproportionate to the safety benefits the measure would provide.
“Working alone” means a situation where:

1. A Worker is working by himself or herself; AND
2. Assistance is not readily available in an emergency or the Worker gets injured or ill.

Policy
XXXX recognizes that working alone without co-workers to watch their back may expose Workers to additional risks by making them more vulnerable to attack or injury and leaving them without help in case they do get injured or ill. Where reasonably practicable, XXXX will adopt measures that eliminate the need for Workers to work alone, e.g., by implementing mandatory buddy systems. The following Policy applies when completely eliminating the need to work alone is not reasonably practicable.
Working Alone Safety Precautions
XXXX has taken or will take the following measures to protect Workers who work alone:

• Performance of a hazard assessment under Part 2 of the Code, with the involvement of the workplace Joint Health and Safety Committee, Health or Safety Representative, and/or directly with the Workers, to identify:
  • Whether Workers in the workplace work alone; AND
  • If so, what hazards they face because they work alone.
• Where reasonably practicable for the work site, establishment of an effective communication system that enables the company to stay in contact with the Worker working alone consisting of:
  • Radio communication;
  • Landline or cell phone communication; OR
  • Another effective means of electronic communication that requires a designated Supervisor, Worker, or XXXX management official to make regular contact with the Worker at regular intervals depending on the hazards posed by the work—the more hazardous the work, the more frequent these regular electronic communications with the Worker must be.
• Where effective electronic communication with the Worker is not reasonably practicable for the work site, establishment of a procedure that requires:
  • A designated Supervisor, Worker, or XXXX management official to visit the Worker at regular intervals depending on the hazards posed by the work; OR
  • The Worker who works alone to make contact with a designated Supervisor, Worker, or XXXX management official at regular intervals depending on the hazards posed by the work.
• Implementation of other measures to reduce the identified risks to Workers who work alone, including safe work procedures for working alone.
• Requiring affected Workers to familiarize themselves with the above safe work procedures and complete safety training before allowing them to work alone.

Roles and Responsibilities
XXXX
Owners/corporate officers and directors/upper management, and other individuals at XXXX who may be considered an “employer” under the Act will comply with their OHS duties by ensuring that:

• The hazard assessment for working alone is carried out using the Section 04 – Working Alone Hazard Assessment Form.
• The hazard assessment is reviewed at least once a year or more frequently after significant changes to work operations, the work environment, or other conditions take place that render or may potentially render the previous hazard assessment unsuitable or out of date.
• Where reasonably practicable, the required electronic communication system is developed and effectively implemented.
• Where an electronic communication system is not reasonably practicable for the work site, the required visitation or Worker contact system is developed and effectively implemented instead.
• Safe work procedures for working alone are developed and implemented effectively.
• Affected Workers receive training in the safe work procedures before being allowed to work alone.
• Hazard assessments and re-assessments are carried out with the involvement of the workplace Joint Health and Safety Committee, Health and Safety Representative, or directly with Workers if there is no Committee or Representative.

The Site Manager
The XXXX Safety Coordinator, facility manager, or other individual(s) in charge of safety at the workplace will be responsible and held accountable for the overall implementation and enforcement of this Working Alone Policy.
Supervisors
Supervisors shall:

• Conduct or participate in the hazard assessment required under this Policy which may include conducting and documenting job hazard analyses determining if particular positions involve hazards of working alone.
• Conduct and document a job hazard analysis/ hazard assessment for each specific type of work.
• Participate in the development of effective methods and systems of communicating with Workers who work alone.
• Write or participating in the writing of safe work procedures for working alone.
• Train affected Workers to implement the above safe work procedures.
• Determine the emergency supplies that may be needed by Workers working alone or in isolation.
• Ensuring that all affected Workers receive the training and instruction they need to implement the safe work procedures before being called on to work alone.

Workers
Affected workers shall:

• Participate in the working alone/in isolation hazard identification either directly or through the Safety Committee or Representative for the workplace;
• Receive training on the hazards of working alone or in isolation and the measures taken to control them;
• Receive training and become competent in the use of the emergency equipment required by the safe work procedure;
• Be familiar with and faithfully carry out their roles and responsibilities under the working alone or in isolation safe work procedure whether as the worker working alone or in isolation, the contact for communication with a co-worker working alone or in isolation, or in any other role.

When Working Alone Is Prohibited
The following operations must never be performed by a Worker working alone:

• Confined space entry.
• Installation or operation of equipment with a nominal voltage of 300 volts or more.
• Application or use of chemicals or substances described by the Material Safety Data Sheet as being quick-acting acutely toxic material.
• Operations requiring use of supplied air respiratory equipment or self-contained breathing apparatus.
• Use of a vehicle, crane or similar equipment near a live power line.
• Operations involving mobile equipment that require the presence of a traffic control person.
• Welding operations that require the presence of a fire watcher.
• Any other tasks indicated in the safe work procedure as requiring a safety attendant or other person.

Application to Prime Contractors, Contractors, & Subcontractors

• XXXX will ensure that any contractors and subcontractors it hires to perform work where workers are required to work alone at XXXX work sites are:
  • Notified of the working alone hazards posed to those workers
  • Notified of the terms of this Policy and working alone procedures in place
  • Required to ensure that their own workers are made aware of and follow this Policy and safety procedures for working alone
• Prime Contractors for work at XXXX work sites where workers must work alone will:
  • Be notified by XXXX of the working alone hazards
  • Receive from XXXX a copy of the most recent working alone hazard assessment for the work site
  • Ensure that the protections required by this Policy are provided to all exposed workers engaged in the work by applying either this Policy directly to workers involved in the work or an equivalent policy that provides at least the same amount of protection

Training
Training will be conducted based on the Training Profile of the Workers and their job position.
Evaluation
A review of this Policy will be conducted at least once a year or more frequently where circumstances suggest review is necessary, e.g., after incidents, or changes to operations and equipment affecting Workers working alone.
****
Hope this helps. If not, let me know and I’ll see what I can do. Glenn

[vickyp]

in reply to: health-and-safety-management-system-ohsms #103230

Here are some materials from the OHSI website that should be pretty useful.
https://ohsinsider.com/managing-ohs-program-use-matrix-key-leading-indicators-improve-safety-performance/
https://ohsinsider.com/key-leading-indicator-matrix/
https://ohsinsider.com/why-you-should-base-your-ohs-program-on-a-voluntary-standard/
https://ohsinsider.com/managing-ohs-program-using-leading-indicators-measure-ehs-performance/
https://ohsinsider.com/making-business-case-safety-value-setting-long-term-ehs-goals/
https://ohsinsider.com/making-business-case-ehs-new-report-shows-value-actively-managing-chemicals/

[vickyp]

in reply to: Emergency Supply #103229

I don’t think there is any such requirement, especially for an office business. The reason I asked your industry was to determine whether there might be an industry-specific regulation somewhere. Minimum supplies for fixed buildings certainly isn’t anything required by the general OHS Regulations.

[vickyp]

in reply to: Emergency Supply #103228

This would be for the head office of a management consulting company

[vickyp]

in reply to: Emergency Supply #103227

Can you tell me what kind of business it is?

[vickyp]

in reply to: Private: Violence and Harassment – Training #103226

Investigators will need to complete special training in investigative techniques. However, the Regs don’t prescribe the type of training or standard, e.g., training from XYZ Association, or anything like that. However, I suspect that the government will eventually issue guidelines clarifying this and require investigators to complete specific programs from specific organizations. But they haven’t yet. The one thing I’ll add, though, is that it’s not up to employers to train investigators the way they have to train employees, DRs, etc. Training will need to come from outside.

[vickyp]

in reply to: Private: Violence and Harassment – Training #103225

Funny you should ask. I was just looking into that and I didn’t find anything. The Regs just prescribe the topics training must include but don’t delve into the details the way some OHS training requirements do, e.g., JHSC member certification or falls from heights training in Ontario. There’s no approved template and I doubt there will be one. Basically, the training you currently provide should be OK as long as you develop it jointly with the applicable partner, provide and review it according to the required timetables and cover the required topics, including grounds of discrimination under the Canadian Human Rights Act. Section 8 of our Model Policy basically captures everything:

1. TRAINING

ABC Company will appoint a competent person to work jointly with the applicable partner to develop or identify the workplace harassment and violence training to be provided to employees, ABC Company management and executive leadership and the designated recipient.
8.1 Training Elements
Employee training must be specific to the culture, conditions and activities of the workplace and include:

• The elements of this workplace harassment and violence prevention Policy;
• A description of the relationship between workplace harassment and violence and illegal discrimination under the Human Rights Act, i.e., discrimination on the basis of race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, genetic characteristics, disability and conviction for an offence for which a pardon has been granted or in respect of which a record suspension has been ordered;
• A description of how to recognize, minimize, prevent and respond to workplace harassment and violence.

8.2 When Training Must Be Provided
Employees must receive the above training:

• Within 3 months after the day on which their employment begins;
• At least once every 3 years after that; and
• After being assigned to a new role or activity that involves greater risk of workplace harassment and violence; and
• After changes are made to any of the training elements in accordance with Section 8.3 below.

The designated recipient must receive the above training before assuming his/her designated recipient duties and at least once every 3 years after that.
ABC Company management and executive leadership must receive the above training by December 31, 2021 and at least once every 3 years after that.
8.3 Review of Training
A competent person appointed by ABC Company and the applicable partner must jointly review and, if necessary, update the training at least once every 3 years and as necessary in response to any change to a training element.

[Author]

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