Ontario Compliance Alert: Which Employers Should Be on OHS Inspection High-Alert?

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QUESTION
How likely is the government to inspect your workplace in the first 3 months of 2018?

The answer to that question depends in large part on the kind of inspection you’re talking about:

Unscheduled Inspections

The inspectors will pay you a visit in response to:

  • Reports of imminent dangers or incidents about to happen;
  • Actual incidents that caused or could very easily have caused fatalities or serious injuries;
  • Complaints by workers.

Because there’s no way to know whether these triggering events will take place, unscheduled inspections are impossible to predict.

Scheduled Inspections

Inspections scheduled in advance can be predicted with some reliability as long as the government agency that does them is transparent about its inspection schedule. The problem is that in most provinces, agencies keep their planned inspection targets a tight secret. The notable exception is Ontario where the Ministry of Labour publishes inspection plans for different sectors months in advance. Now that the MOL’s 2017-18 Sector Plans are out, we know who and what the agency will be targeting for the first 3 months of the year.

Note: While BC also announces its targeted inspection initiatives in advance, the 2018 schedules aren’t yet out. OHS Insider will provide a complete briefing for BC employers when the schedules do come out.

The Ontario Inspection Strategy

The MOL carries out 2 layers of targeted inspections:

Province-wide blitzes and initiatives focus on high-priority hazards spanning multiple sectors. The difference between a blitz and an initiative is that the MOL publishes detailed results of the former after the blitz ends.

Regional initiatives are carried out by one of the MOL’s regional offices and limited in geographical scope.

In each case, the MOL announces the initiative and types of workplaces targeted in advance without disclosing the actual companies to be inspected. From now through March 31, 2018, MOL will not only kick off some new initiatives but continue some of the ones it began last spring.

Getting Ready

Although we don’t know exactly who the MOL will be inspecting and when, what we can tell you is:

  • What initiatives will be carried out in each sector;
  • Which workplaces each initiative will target;
  • What MOL inspectors will be checking for; and
  • Where to find resources to prepare and enhance your chances of passing inspection without citations, fines or orders.

INDUSTRIAL SITES (Now thru March 31, 2018)

Topic Type of Initiative Target Sites What MOL Will Ask OHSI Resources to Help You Prepare
Noise Hazards Continuation of Provincial Initiative launched April 1, 2017 *Wood products

*Metal fabrication

*Automotive repair & services

*Other manufacturing sites

*Municipal operations, including operators of powered equipment, heavy equipment and maintenance shops

Do You:

*Have a Hearing Conservation Plan (HCP)

*Limit noise exposure to 85 dBA measured over 8-hour work day

* Provide proper hearing protection devices (HPD)

* Train workers in HPD use

*Post proper warning signs

*How to Create HCP

*Model HCP

*HCP Annual Review Form

*HCP Checklist

* Noise Survey Form

*MOL Guide to Noise Regulation

Struck By Injuries Continuation of Provincial Initiative launched April 1, 2017 * Automotive

*Logging

*Ceramics, glass & stone

*Chemical, rubber & plastics

*Wholesalers including building supply centres

* Wood & metal fabrication

Do you comply with OHS requirements on:

*IRS awareness training

*Traffic safety

* Lift truck safety

*Equipment maintenance

*Stacking & storage

*Robots

*Training & supervision

*Pre-Start Reviews

*How to Create Traffic Safety Plan

*Model Traffic Safety Plan Form

*How to Comply with Storage Requirements

*How to Ensure Safe Stacking of Materials

*How to Comply with Lifting Device Requirements

*Forklift Inspection Checklist

*Powered Mobile Equipment Operator Competency Checklist

*How to Comply with Industrial Robotics Safety Laws

Machine Guarding & Electrical Hazards Blitz from Jan. 15 to Feb. 28, 2018 *Wood & metal fabrication

* Manufacturing

*Chemical & plastics

*Automotive plants

Do you comply with OHS requirements on:

*Machine guarding

*Lockout

*Locking & blocking

*Electrical injuries

*Power line contact

*Musculoskeletal disorders (MSDs)

*Worker training & education, including awareness training

*How to Comply with Machine Guarding Laws

*How to Select Right Machine Guard

*Machine Guarding Checklist

*How to Comply with Lockout Laws

*Model Lockout Policy

*Electrical Safety Program Checklist

*Ergonomics Compliance Centre

Ergonomics Continuation of Provincial Initiative launched April 1, 2017 *Food processing & manufacturing

*Tire handling & storage

*Other sites where materials are handled manually

*Sites with high MSD rates

Do you comply with OHS requirements on:

*Safe lifting, lowering, pushing, pulling & carrying of materials

*Ladder use for materials handling

*Keeping routes of access and egress clear & obstruction-free

*Housekeeping

*Materials storage & racking

*Training & education

*Ergonomics Compliance Centre

*How to Protect Workers from MSDs

*Model Ergonomics Policy

*Model Housekeeping Policy

*Housekeeping Checklist

*How to Comply with Storage Requirements

WHMIS/GHS Continuation of Provincial Initiative launched April 1, 2017 Any sites where hazardous products are manufactured, used or stored Do you comply with new GHS Rules re:

*Supplier & workplace labels

*MSDS/SDS

*Hazard classification

*Training & education

*WHMIS/GHS Compliance Centre

8 Ways to Prepare for GHS

*GHS Pictograms

*How to Comply with GHS Label Rules

*How to Comply with New GHS SDS Rules

*GHS Training Checklist

Temporary Workers Continuation of Central West Regional Initiative launched June 1, 2017 Construction sites that use workers supplied by temporary labour agencies Do You:

*Provide proper health and safety training to temp workers

*Protect temp workers from exposure to hazardous products

*GHS Training Checklist

* CEO Briefing on Temp Worker Training

*5 Tips for Protecting Temp Workers

*Webinar on OHS Duties to Protect Temp Workers

 

CONSTRUCTION SITES (Now thru March 31, 2018) 

Topic Type of Initiative Target Sites What MOL Will Ask OHSI Resources to Help You Prepare
Noise Hazards Continuation of Provincial Initiative launched April 1, 2017 Any construction sites where noise hazards may be present Do You:

*Have a Hearing Conservation Plan (HCP)

*Limit noise exposure to 85 dBA measured over 8-hour work day

* Provide proper hearing protection devices (HPD)

* Train workers in HPD use

*Post proper warning signs

*How to Create HCP

*Model HCP

*HCP Annual Review Form

*HCP Checklist

* Noise Survey Form

*MOL Guide to Noise Regulation

WHMIS/GHS Continuation of Provincial Initiative launched April 1, 2017 Any construction sites where hazardous products are used, handled or stored Do you comply with new GHS Rules re:

*Supplier & workplace labels

*MSDS/SDS

*Hazard classification

*Training & education

*WHMIS/GHS Compliance Centre

8 Ways to Prepare for GHS

*GHS Pictograms

*How to Comply with GHS Label Rules

*How to Comply with New GHS SDS Rules

*GHS Training Checklist

Fall Protection Continuation of Provincial Initiative launched May 1, 2017 Any construction sites where workers work at heights, including roofing and the underground economy Do you comply with new GHS Rules re:

* Working-at-heights training

* Fall protection equipment

*Inspection of fall protection equipment

*Emergency response & rescue plans

*How to Comply with New Working-at-Heights Training Rules

*Working-at-Heights Training Checklist

*Fall Protection Equipment Inspection Checklist

*Fall Protection Plan Template including Rescue Procedures

Ergonomics Continuation of Provincial Initiative launched April 1, 2017 Construction sites where materials are handled manually Do you comply with OHS requirements on:

*Safe lifting, lowering, pushing, pulling & carrying of materials

*Ladder use for materials handling

*Keeping routes of access and egress clear & obstruction-free

*Housekeeping

*Materials storage & racking

*Training & education

*Ergonomics Compliance Centre

*How to Protect Workers from MSDs

*Model Ergonomics Policy

*Model Housekeeping Policy

*Housekeeping Checklist

*How to Comply with Storage Requirements

 

Temporary Workers Continuation of Central West Regional Initiative launched June 1, 2017 Construction sites that use workers supplied by temporary labour agencies Do You:

*Provide proper health and safety training to temp workers

*Protect temp workers from exposure to hazardous products

*GHS Training Checklist

* CEO Briefing on Temp Worker Training

*5 Tips for Protecting Temp Workers

*Webinar on OHS Duties to Protect Temp Workers

Electrical Contact Continuation of Central West Regional Initiative launched April 1, 2017 Construction sites in West Region Do you:

Adequately protect workers from contact with exposed and overhead power lines

*How to Comply with Lockout Laws

*Model Lockout Policy

*Electrical Safety Program Checklist

 

MINING SITES (Now thru March 31, 2018)

Topic Type of Initiative Target Sites What MOL Will Ask OHSI Resources to Help You Prepare
Noise Hazards Continuation of Provincial Initiative launched April 1, 2017 Any mining sites where noise hazards may be present Do You:

*Have a Hearing Conservation Plan (HCP)

*Limit noise exposure to 85 dBA measured over 8-hour work day

* Provide proper hearing protection devices (HPD)

* Train workers in HPD use

*Post proper warning signs

*How to Create HCP

*Model HCP

*HCP Annual Review Form

*HCP Checklist

* Noise Survey Form

*MOL Guide to Noise Regulation

WHMIS/GHS Continuation of Provincial Initiative launched April 1, 2017 Any mining sites where hazardous products are used, handled or stored Do you comply with new GHS Rules re:

* Working-at-heights training

* Fall protection equipment

*Inspection of fall protection equipment

*Emergency response & rescue plans

*WHMIS/GHS Compliance Centre

8 Ways to Prepare for GHS

*GHS Pictograms

*How to Comply with GHS Label Rules

*How to Comply with New GHS SDS Rules

*GHS Training Checklist

PPE & High Visibility Clothing New Blitz which begins Feb. 1, 2018 Mines & mining plants Are your workers:

* Trained on care & use of PPE

*Furnished with PPE is adequate to protect them

*Furnished with proper high visibility safety apparel

* Aware that traffic management programs have identified distracted driving as a high risk to operators of equipment

*Model PPE Policy

*PPE Hazard Assessment Checklist

*8 Ways to Get Workers to Wear Their PPE

*MOL High Visibility Safety Apparel for Mines and Mining Plants

*Model Distracted Driving Policy

*Mobile Equipment in Mines Video

* Vehicle/Mobile Equipment and Visibility Hazards in Mining Workplaces

*High Visibility Safety Apparel MOL Guideline

 

 

Ergonomics Continuation of Provincial Initiative launched April 1, 2017 Mining sites where materials are handled manually and/or which have high MSD rates Do you comply with OHS requirements on:

*Safe lifting, lowering, pushing, pulling & carrying of materials

*Ladder use for materials handling

*Keeping routes of access and egress clear & obstruction-free

*Housekeeping

*Materials storage & racking

*Training & education

*Ergonomics Compliance Centre

*How to Protect Workers from MSDs

*Model Ergonomics Policy

*Model Housekeeping Policy

*Housekeeping Checklist

*How to Comply with Storage Requirements

 

Joint Health & Safety Committees Continuation of Provincial Initiative launched April 1, 2017 Mines & mining plants Questions MOL Will Ask:

*Does your site have functioning JHSC or health safety representative (HSR)

* Do JHSC members/HSR get required safety + certification training

*Are JHSC members properly elected

*Are names of JHSC members/HSR properly posted

*Are JHSC meetings held

*Are JHSC meeting minutes kept

*Do monthly JHSC/HSR  inspections take place

*JHSC Compliance Centre

*JHSC Compliance Self-Assessment Questionnaire

*Avoid 10 Common JHSC Mistakes

*How to Comply with JHSC Member Training Requirements

*Model JHSC Rules of Procedure

Ground Control Continuation of Provincial Initiative launched April 1, 2017 Surface & underground mines Do you comply with OHS requirements on:

*Ground control plan

*Unsupported underground openings

*Ground support quality control

*Ground instability record keeping

*OHS Mining Regulation

*MOL Guidance on Ground Control in Mines

Mine Hoist Plants Continuation of Provincial Initiative launched April 1, 2017 Surface & underground mines Do you comply with OHS requirements on:

*Shaft inspection procedures

*Shaft log book entries

*Conveyance guides measured for wear

*Frequency of measurements

*OHS Mining Regulation

*MOL Guide to Mines & Mining Plant Safety

 

HEALTH CARE SITES (Now thru March 31, 2018)

Topic Type of Initiative Target Sites What MOL Will Check OHSI Resources to Help You Prepare
Noise Hazards Continuation of Provincial Initiative launched April 1, 2017 Health care facilities where workers are exposed to hazardous levels of noise Do You:

*Have a Hearing Conservation Plan (HCP)

*Limit noise exposure to 85 dBA measured over 8-hour work day

* Provide proper hearing protection devices (HPD)

* Train workers in HPD use

*Post proper warning signs

*How to Create HCP

*Model HCP

*HCP Annual Review Form

*HCP Checklist

* Noise Survey Form

*MOL Guide to Noise Regulation

WHMIS/GHS Continuation of Provincial Initiative launched April 1, 2017 Any health care sites that produce, use, handle or store hazardous products Do you comply with new GHS Rules re:

* Working-at-heights training

* Fall protection equipment

*Inspection of fall protection equipment

*Emergency response & rescue plans

*WHMIS/GHS Compliance Centre

8 Ways to Prepare for GHS

*GHS Pictograms

*How to Comply with GHS Label Rules

*How to Comply with New GHS SDS Rules

*GHS Training Checklist

Ergonomics Continuation of Provincial Initiative launched April 1, 2017 Sites where patients are lifted, positioned or transferred and/or which have high MSD rates Do you comply with OHS requirements on:

*Safe lifting, lowering, pushing, pulling & carrying of materials

*Ladder use for materials handling

*Keeping routes of access and egress clear & obstruction-free

*Housekeeping

*Materials storage & racking

*Training & education

*Ergonomics Compliance Centre

*How to Protect Workers from MSDs

*Model Ergonomics Policy

*Model Safe Handling of Patients Policy

*Model Housekeeping Policy

*Housekeeping Checklist

*How to Comply with Storage Requirements

Outstanding Rejected X-ray installation applications Continuation of Provincial Initiative launched April 1, 2017 *Hospitals

*Radiology facilities

*Radiology clinics

Not specified *Ionizing Radiation Exposure Infographic

*Radiation Exposure on Body Infographic

*MOL Radiofrequency & Microwave Exposure Guidelines

*Take 7 Steps to Protect Workers from Radiation

 

SPECIALIZED PROFESSIONAL SERVICE SITES (Now thru March 31, 2018)

Topic Type of Initiative Target Sites What MOL Will Check OHSI Resources to Help You Prepare
Noise Hazards Continuation of Provincial Initiative launched April 1, 2017 Any facilities or sites where workers are exposed to hazardous levels of noise Do You:

*Have a Hearing Conservation Plan (HCP)

*Limit noise exposure to 85 dBA measured over 8-hour work day

* Provide proper hearing protection devices (HPD)

* Train workers in HPD use

*Post proper warning signs

*How to Create HCP

*Model HCP

*HCP Annual Review Form

*HCP Checklist

* Noise Survey Form

*MOL Guide to Noise Regulation

WHMIS/GHS Continuation of Provincial Initiative launched April 1, 2017 Any facilities or sites that produce, use, handle or store hazardous products Do you comply with new GHS Rules re:

* Working-at-heights training

* Fall protection equipment

*Inspection of fall protection equipment

*Emergency response & rescue plans

*WHMIS/GHS Compliance Centre

8 Ways to Prepare for GHS

*GHS Pictograms

*How to Comply with GHS Label Rules

*How to Comply with New GHS SDS Rules

*GHS Training Checklist

Ergonomics Continuation of Provincial Initiative launched April 1, 2017 Any facilities or sites where materials are handled manually and/or which have high MSD rates Do you comply with OHS requirements on:

*Safe lifting, lowering, pushing, pulling & carrying of materials

*Ladder use for materials handling

*Keeping routes of access and egress clear & obstruction-free

*Housekeeping

*Materials storage & racking

*Training & education

*Ergonomics Compliance Centre

*How to Protect Workers from MSDs

*Model Ergonomics Policy

*Model Housekeeping Policy

*Housekeeping Checklist

*How to Comply with Storage Requirements

Outstanding Rejected X-ray installation applications Continuation of Provincial Initiative launched April 1, 2017 *Hospitals

*Radiology facilities

*Radiology clinics

Not specified *Ionizing Radiation Exposure Infographic

*Radiation Exposure on Body Infographic

*MOL Radiofrequency & Microwave Exposure Guidelines

*Take 7 Steps to Protect Workers from Radiation

 

STAY TUNED FOR MORE PROVINCE-SPECIFIC OHS INSPECTION ALERTS

OHS Insider will furnish similar briefings to employers in other provinces if and when they announce their OHS targeted inspection plans. We’ll also update the Ontario schedule as soon as the MOL announces its blitz and provincial initiatives for the remainder of 2018 and beyond.