Introduction: How to Use This Tool
The original OHS laws were all about machines, chemicals, electricity and other traditional industrial hazards. What few recognized at the time is how social issues and behaviours in the workplace could also constitute a hazard. For the past decade or so, provincial governments have been in catch-up mode, changing their laws to require employers to have written policies to prevent workplace violence, bullying and harassment. But once more, our understanding of workplace social hazards is moving faster than our laws. The newest stage is the evolution of a workplace psychological safety policy that looks at social and behavioural hazards broadly and proactively. Although it’s not a legal requirement, the psychological safety policy is a best practice (encapsulated in CSA standard CSA-Z1003-13, Psychological health and safety in the workplace — Prevention, promotion, and guidance to staged implementation). Here’s a template of a Psychological Safety Policy based on Alberta law that you can adapt for your own use.
WORKPLACE PSYCHOLOGICAL SAFETY POLICY
ABC Company has adopted this Policy as part of its commitment to furnish a workplace that is psychologically healthy and safe for all of its workers. The specific objective of the Policy is to ensure that individuals recognize their rights to work in such a workplace and that ABC Company deems any harm to their psychological health and safety a serious offence that must be addressed swiftly and effectively by providing assistance and support to victims and the imposition of appropriate discipline on offenders.
For purposes of this Policy:
- Psychological health means a state of well-being in which the individual is capable of realizing his/her own abilities, coping with the normal stresses of life, working productively and contributing to the community;
- Psychological health and safety management system means an organizational management system consisting of policies, procedures, and practices implemented to promote a psychologically healthy and safe workplace;
- Psychologically healthy and safe workplace means a workplace that promotes workers’ psychological well-being and actively works to prevent harm to their psychological health due to negligent, reckless, or intentional acts;
- Workplace harassment means any objectionable or unwelcome conduct, comment, or action that a person knows or ought reasonably to know will or would cause offence or humiliation to a worker, but excludes any reasonable conduct of an employer or supervisor in respect of the management of workers or the workplace;
- Workplace violence means threatened, attempted or actual conduct of a person that causes or is likely to cause physical injury. Examples:
- Threatening behaviour such as shaking fists, destroying property or throwing objects;
- Verbal or written threats (any expression of intent to cause harm);
- Physical attacks such as hitting, shoving, pushing or kicking.
- POLICY STATEMENT
While it is fully committed to complying with its obligation to prevent workplace violence and harassment under Part 27 of the Alberta OHS Code and other applicable laws and regulations, ABC Company is also committed to going beyond legal requirements and providing a physically and psychologically healthy and safe workplace. The management of ABC Company recognizes that workers and the Company have a shared responsibility to promote the principles of mutual respect, confidentiality and cooperation, as outlined in this Policy. Any act that can cause harm to worker psychological health is unacceptable and will not be tolerated.
- SCOPE OF POLICY
4.1. Workers This Policy Is Intended to Protect
The intent of this Policy is to ensure that all workers engaged to work at ABC Company work sites are afforded a psychologically safe workplace regardless of who pays or employs those workers, including:
- Full- or part-time workers employed by ABC Company;
- Temporary employees placed by an outside agency to work at the site;
- Contract labourers engaged to perform work at the site;
- Volunteers who work at the site for free; and
- Workers employed by prime contractors, contractors, and subcontractors to perform work at the site under a contract with ABC Company.
4.2. Source of Psychological Harms
The intent of this Policy is to protect workers from workplace stressors and potential psychological harm from all sources, including:
- ABC Company personnel at any level including executives, officers, managers, supervisors, and workers;
- ABC Company customers, clients, suppliers, vendors, prime contractors, contractors, and subcontractors that workers encounter as part of their job duties; and
- Visitors to ABC Company work sites.
4.3. Workplaces Covered
For purposes of this Policy, the conception of workplace is to be construed broadly as encompassing any location in which ABC Company workers are likely to encounter stressors or sources of psychological harm while conducting their duties:
- Within ABC Company facilities, premises, and work sites;
- Inside ABC Company vehicles; and
- At off-site locations where workers are required to perform their duties, including but not limited to client offices, sites of business conferences, and ABC Company-sponsored retreats, affairs, and social events.
- ROLES & RESPONSIBILITIES
ABC Company management is responsible for creating a psychologically healthy and safe workplace by:
- Fostering an organizational culture that promotes psychological health and safety;
- Ensuring that a psychological health and safety management system is in place to provide a work environment that is free from psychological harm;
- Ensuring compliance with occupational health and safety, human rights, and other applicable laws;
- Ensuring that workers are trained to recognize and respond to situations involving psychological harm;
- Ensuring that every reported incident of psychological harm is investigated in a fair, objective and timely manner;
- Ensuring that problems, mistakes and potential areas of improvement are identified;
- Ensuring that workers who report psychological injuries or adverse symptoms from psychological harm are advised to consult a health professional;
- Maintaining the confidentiality of the individuals concerned, except where disclosure is necessary to investigate the complaint or take disciplinary measures in responding to the complaint;
- Providing appropriate support for affected workers.
Supervisors and line managers are responsible for implementing the psychological health and safety management system and creating a psychologically healthy and safe workplace by:
- Exhibiting leadership behaviours to support workers’ psychological wellbeing;
- Helping to identify workplace stressors and conduct workplace psychological harm risk assessments;
- Looking out for and responding to signs and symptoms of psychological harms exhibited by their workers;
- Promoting a culture in which workers who exhibit or report psychological harms are met with support rather than stigma;
- Offering immediate and ongoing support to staff involved in traumatic or stressful incidents, complaints or claims;
- Providing additional support to workers experiencing stress outside work, e.g., due to bereavement or separation;
- Working with ABC Company to ensure the provision of confidential counselling for workers experiencing psychological harms at work;
- Assisting in the evaluation of the psychological health and safety management system.
Workers are responsible for creating a psychologically healthy and safe workplace by:
- Treating one another with dignity, courtesy and respect at all times;
- Being familiar with and following the ABC Company policies and procedures in place to protect their psychological health;
- Receiving and apply training and instruction on psychological hazards provided by ABC Company;
- Immediately reporting violations of this Policy to their supervisor;
- Co-operating in the investigation of complaints;
- Participating in work site hazard assessments and implementing controls and procedures to eliminate or control the associated hazards.
- COMPLAINTS & REPORTS OF VIOLATIONS
Workers who feel that they or a co-worker have been subject to workplace harassment, bullying, violence or other stressors or behaviours that can inflict psychological harms in violation of this Policy must immediately notify their supervisors. Exception: If the supervisor is the source of the alleged behaviour, the worker will instead notify the ABC Company HR Office.
6.2. Non-Retaliation Assurance
No worker will suffer any discipline or retaliation of any kind for reporting a violation of this Policy. This protection against retaliation also applies if ABC Company determines that the complaint is unfounded as long as it was reasonable and not made maliciously or in bad faith.
6.3. Complaint Not Workers’ Only Legal Recourse
Giving workers the right to file complaints under this Policy is not intended to discourage them from pursuing their rights under other laws, including but not limited to filing a discrimination complaint with the Alberta Human Rights Commission if they believe they have been subjected to harassment or bullying on the basis of their race, religious beliefs, colour, gender, gender identity, gender expression, physical disability, mental disability, age, ancestry, place of origin, marital status, source of income, family status or sexual orientation.
ABC Company will not disclose the name of an individual who files a complaint under this Policy nor the name of the alleged source of psychologically harmful behaviour unless disclosure is necessary to:
- Investigate the complaint;
- Take corrective action; or
- Required by law.
All complaints will be investigated by ABC Company supervisors or managers who are qualified to conduct such investigations and who are not directly involved in the alleged violation or otherwise in a position where their objectivity is suspect. After the investigation, a supervisor or manager will notify the worker and accused of the results of the investigation.
- DISCIPLINARY ACTION
If the investigation determines that a violation occurred, appropriate steps will be taken to discipline the person who engaged in the conduct in accordance with the terms of the ABC Company progressive discipline policy and any applicable collective agreements or employment contracts.
- INSTRUCTION & TRAINING
ABC Company will provide workplace psychological safety training to the workers it employs covering:
- Minimizing the risk of psychological harms in the workplace;
- Recognition of potential sources of workplace psychological harms;
- Responding to workplace harassment, bullying, violence or other stressors or behaviours that can inflict psychological harms;
- How to report complaints; and
- How complaints are investigated and resolved.
- PRIME CONTRACTORS, CONTRACTORS & SUBCONTRACTORS
ABC Company’s commitment to provide a psychologically safe workplace extends not just to its own employees but to the workers of prime contractors, contractors, and subcontractors hired to perform work at ABC Company worksites. By the same token, ABC Company also recognizes that providing a psychologically safe workplace for its own employees requires that measures be taken to ensure that such outside workers be aware of and obliged to comply with the terms of this Policy.
Prime contractors or contractors hired to control work at ABC Company worksites will be required to respect the rights of all workers engaged in the work to a psychologically safe workplace either by:
- Directly following the employer requirements set out in this Policy; or
- Implementing alternative measures and controls that are consistent with this Policy, suitable for the workplace, and provide workers at least the equivalent protection as this Policy provides.
ABC Company will review this Policy in consultation with the workplace Joint Health and Safety Committee, Health and Safety Representative, or, if there is no Committee or Representative, workers at the workplace at least once a year or more often in response to changes and developments affecting workers’ health and safety.