The Joint Health and Safety Committee, Part 2 Five Steps for Effective Workplace Inspections

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The best way to keep workers healthy and safe is to prevent workplace incidents. One of the most important things a safety coordinator can do to prevent incidents as well as compliance orders and violations is to make sure that regular inspections of the workplace are conducted. The name of the game: Find and eliminate hazards before they cause an incident (or before OHS inspectors find them for you). As we discussed in Part 1, a company’s JHSC can be a valuable resource in unearthing hidden hazards and evaluating the effectiveness of your existing safety controls. It can also make a valuable contribution to addressing these hazards by recommending workable solutions to problems that the inspection uncovers.

As safety coordinator, it’s up to you to oversee the inspection process and coordinate the JHSC’s involvement—whether it’s conducting the inspections or merely participating in them. Part 1 explained the OHS law requirements governing JHSCs and inspections. But there’s more to workplace safety and effective inspections than simply doing what the law says. We’ll explain the five steps regular workplace inspections should include. And we’ll give you an inspection worksheet you can photocopy and give to the members of your inspection team to help them document the hazards they uncover during inspections.

Defining Our Terms
Remember, that for purposes of this article, “inspection” means formal inspections or walkthroughs of the workplace that are conducted internally on a regular basis, as opposed to investigations of incidents or inspections carried out by OHS regulatory officials.

INSPECTION BASICS
The OHS laws typically say that workplace inspections should be conducted but don’t specify how. Many provinces have issued guidelines that provide more details on what a regular workplace inspection should involve. Naturally, the specifics vary from province to province. However, in general, an effective regular workplace inspection requires the same basic five steps:

Step #1: Plan the Inspection
Regular workplace inspections don’t just happen by themselves; they have to be planned and scheduled. The key planning considerations:

How often to inspect. Some OHS laws specify how often workplaces have to be inspected. For example, federally-regulated, NB and ON workplaces must be inspected monthly. In AB, workplaces that have JHSCs must be inspected at least once before each regular JHSC meeting. (To determine how often regular inspections are required in your province, but most jurisdictions simply require “regular” inspections or inspections at “reasonable intervals.” What exactly do terms such as “regular” and “reasonable intervals” mean?

The answer depends on the size of the workplace and the level of risk involved in the work performed there, says Ontario OHS consultant Yvonne O’Reilly. Some safety professionals say monthly inspections are adequate for most workplaces. But high risk workplaces or high risk areas within workplaces should be inspected more frequently—even if monthly inspections are all that the OHS law requires, she advises. For example, you might inspect the assembly line in a factory—a high risk area—weekly, but only inspect the factory’s administrative offices—a low risk area—a few times a year.

When to inspect. Most jurisdictions don’t specify when inspections should be conducted. (Exception: As noted above, in AB, workplaces with JHSCs must be inspected at least once before each regular JHSC meeting.) The choice of when to conduct an inspection depends on the workplace and what’s most convenient for the members of the inspection team.

Who should participate in the inspection. As discussed in Part 1 of this series, OHS law may specify who has to conduct or participate in the workplace inspection, such as a designated member of the JHSC or the employer. Regardless of legal requirements, a joint inspection involving both management and worker representatives is often the optimal approach and should ideally include:

  • JHSC member(s);
  • Worker representative(s);
  • Employer representative(s); and
  • The safety coordinator.

Depending on the workplace, the inspection team might also include engineers, industrial hygienists and/or other specialists. (Throughout this article, we’ll refer to the group conducting the inspection as the “inspection team.”) In addition to its composition, the size of the inspection team can be a key factor in its effectiveness. If the team is too large, things can get unwieldy, notes O’Reilly. So keep inspection teams small. If your team is large, consider breaking it into smaller groups assigned to inspect specific sections of the workplace, she suggests.

Which parts of the workplace should be inspected. In many workplaces, the entire workplace can and should be inspected in each regular inspection. However, a strategy of inspecting every department or area in every inspection might not be workable in a large workplace. In that case, inspect part of the workplace in each inspection so that the entire workplace is inspected at least once a year (or as often as the law requires). In fact, federal and ON OHS law allow for this approach in large, difficult to inspect workplaces, although the preference is that the whole workplace be inspected every month. But again, high risk areas in workplaces should be inspected more frequently than the rest of the workplace, notes O’Reilly.

Step #2: Prepare for the Inspection
An inspection’s effectiveness depends on theability of the inspection team to identify hazards. Ideally, the members of the inspection team should get training on how to conduct a workplace inspection so that they do it well and correctly, says O’Reilly. The governments of some provinces, such as NB, offer specific courses on conducting inspections, she says. And in ON, certified members of the JHSC must get training in a number of areas, including general workplace hazards and hazards specific to the workplace’s particular industry, she adds.

Regardless of any training the inspection team members have received, before each inspection, O’Reilly recommends that they review:

  • The relevant safety laws and regulations, especially any new or updated legal requirements or hazard alerts issued by regulatory agencies or officials;
  • Minutes from previous JHSC meetings, especially the parts addressing specific hazards and the effectiveness of safety systems in current operation;
  • Reports or worksheets from prior inspections; and
  • Reports on incidents that have occurred since the last inspection.

Step #3: Conduct the Inspection
While conducting the inspection, the team should pay attention to all aspects of the workplace that have the potential to cause illness or injury to workers, including:

The physical structures or buildings that make up the workplace, such as doors, HVAC systems, flooring, loading docks, fire exits, storage racks, elevated structures and parking lots;

  • Tools, machinery and equipment;
  • Confined spaces;
  • Materials handling and storage;
  • Processes and procedures; and
  • Workers.

During the inspection, team members should look for:

  • New hazards, including safety (such as cords a worker could trip over), mechanical (such as inadequate guards), biological (such as mould), chemical (such as improperly labelled hazardous materials) and ergonomic hazards (such as workstations at awkward heights).
  • They should also monitor the physical environment, including lighting, noise levels and extreme temperatures;
  • Potential hazards, such as machinery or tools that are showing signs of wear and tear; and
  • Hazards that were previously identified but haven’t been addressed.

For example, the team should note whether machinery, equipment and tools are working properly and are being regularly and appropriately maintained. It should also note whether hazardous materials are properly stored and labelled and whether other materials are safely stored. The team should determine whether adequate rules are in place to ensure that processes and procedures are safely conducted. And it should note whether workers are using machinery and tools in a safe and appropriate manner, wearing required PPE and following company safety rules and procedures. Plus, it should check relevant records, such as maintenance logs, pre-use inspection reports and training records.

Inspectors should learn to use not only their eyes but also their ears. Team members conducting inspections should make it a point to talk to workers and supervisors about any safety or health concerns they have, advises O’Reilly. Workers and supervisors may, in fact, have suggestions for health and safety improvements. Team members should also verify that workers are aware of first aid, emergency response and reporting procedures.

Step #4: Document the Inspection
The inspection team could simply jot down any hazards it sees on any old piece of paper. But a better idea is to use a worksheet to note any hazards or potential hazards. A worksheet ensures that identified hazards aren’t forgotten after the inspection. It also ensures that basic information about the inspection is documented. Having a written record of the hazards identified, when they were identified and what was done to address them will help the employer prove due diligence if it’s ever accused of an OHS violation.

Click here to view a worksheet you can photocopy and give to the inspection team to use in its inspections. Many companies use checklists when inspecting the workplace. That’s not what this worksheet is. In order to be effective, checklists must be specifically designed for a particular workplace and type of work. The worksheet we’ve provided will help the inspection team keep track of the hazards it’s identified and follow-up action taken in response to those hazards by documenting:

  • Which departments or areas of the workplace were inspected;
  • The time and date the inspection was conducted;
  • Who participated in the inspection;
  • Areas, equipment, machinery, processes and other items identified as having hazards;
  • What hazards were identified;
  • Whether these hazards were repeat items—that is, whether they were identified in prior inspections; and
  • Recommended actions for addressing the identified hazards, such as installing a guard, providing a different kind of PPE, setting a new procedure for a certain process, taking air samples or perhaps investigating the hazard further.

Step #5: Follow Up on Identified Hazards
The most important part of the inspection process may actually occur after the inspection is done. If an inspection has revealed any hazards— or even potential hazards—the employer is under an obligation to take steps to address those hazards. So it’s important that the inspection team informs the employer of any hazards or potential hazards it’s identified and suggests ways those hazards can be addressed. Copies of the inspection worksheet should be given to the employer, the safety coordinator and anyone else in a position to address the identified hazards, such as the supervisor of the area or workers affected by the hazard. They can then use the worksheet to document any follow-up actions taken to address the identified hazards, including:

  • What actions were taken;
  • By whom; and
  • When.

Again, such documentation could be crucial evidence of due diligence in an OHS prosecution.

Conclusion
The primary objective of every OHS program is to prevent injuries, incidents and legal violations. Of course, some OHS programs are better at prevention than others, partly because of luck. But, as Winston Churchill said, luck is the residue of design. Luck—and prevention—require work. Regular inspections are a big part of that work. If you really want to separate the outstanding OHS programs from those that are average, look no further than their inspection process. Companies that do an outstanding job of inspecting are the ones most likely to be successful in preventing problems. And companies that actively involve their JHSCs in regular inspections are the most likely to achieve inspection excellence. So as safety coordinator, you should make sure that the members of the JHSC understand the importance of regular inspections and how critical their participation is to the success of such inspections and ultimately the prevention of safety incidents.

INSIDER SOURCE
Yvonne O’Reilly, CRSP: O’Reilly Health and Safety Consulting,
www.ohsconsulting.ca;
info@ohsconsulting.ca

Click here to view a Model Form – Workplace Inspection Worksheet