The OHS Program: Use Your OHS Policy to Hold Supervisors Accountable for Safety
WHAT’S AT STAKE
Are you holding your supervisors accountable for safety? That’s what Ontario inspectors will be asking this month when visiting construction sites under the MOL’s new “Supervisors” Blitz. But the question is equally important to all sites and employers, regardless of industry or location.
WHAT ACCOUNTABILITY IS ALL ABOUT
“Accountability” is a fancy word for telling people exactly what you expect them to do and making sure they do it. In OHS law context, accountability is rooted in the Individual Responsibility System (IRS), the theory that workplace safety is a collective responsibility in which all stakeholders play a crucial role. Accordingly, the OHS laws list specific duties of the different stakeholders, including not just employers but supervisors and workers.
THE OHS POLICY STATEMENT
Transforming supervisor accountability from theory to practice begins with an OHS Policy Statement that includes a description of the safety-related roles and responsibilities of supervisors (as well as the other stakeholders).
WRITING A SUPERVISOR ROLES & RESPONSIBILITIES STATEMENT
There are two crucial elements you need to include in the Supervisors’ Roles and Responsibilities section of your OHS Policy Statement. (Click here for Model Language you can use based on the laws of your own jurisdiction.)
- Description of Who a Supervisor Is
OHS supervisor duties are based not on individual titles but actual responsibilities. So your “roles and responsibilities” section should make it clear that a supervisor is any person who exercises control or direction over how the work is done and the workers who carry it out, regardless of title.
- List of Supervisor Safety Duties
The basic duty of supervisors is to exercise competent supervision and take all measures reasonable under the circumstances to protect the health and safety of the workers they supervise (as well as others affected by the work). Your OHS Policy Statement should break this down into specific tasks, based on the supervisors’ duties section of your jurisdiction’s OHS Act. Although there are some minor geographical differences, supervisor duties generally include:
- Knowing the OHS and other safety laws that apply to the work they oversee;
- Notifying workers of hazards to which they’re exposed;
- Delivering the competent supervision, instruction and safety training necessary to help workers manage those hazards;
- Ensuring workers are aware of and follow the required safe work procedures;
- Ensuring workers have and properly use required personal protective equipment and safety equipment;
- Ensuring that all required field inspections and hazard assessments are properly carried out;
- Correcting unsafe acts or conditions;
- Holding workers accountable for complying with OHS laws and organization safety rules;
- Leading by example by always working safely and in accordance with OHS and company safety rules.