If any of you have read the MLTSD "Occupational Health and Safety in Ontario (April 2019 - March 2020) - An annual report on Ontario's health and safety system activities," you will have no doubt focused on the potential cost savings it mentions in regards to WSIB premiums. Specifically, "Ontario's Safe Employers (SOSE) program," which speaks to accredited safety programs by the CPO, and the WSIB's "Health and Safety Excellence Program (HSEP)" where these potential savings can be found. A health and safety program is nothing new. In fact, OHSA S. 25(2)(j) states that "an employer shall, prepare and review at least annually a written occupational health and safety policy and develop and maintain a program to implement that policy." The distinction between the regulation, the SOSE, and the HESP is that there is now an MLTSD recognized accreditation process, rather than being left to the employer to create. Guidelines were always available through many safety associations, with the end goal to best support the internal responsibility system. The actual documentation is the easy part (unless you are the one tasked with writing it, of course). What I would like to consider here is the human element's addition – how has my organization implemented the program? How much of the program is reflected in our safety culture? If an inspector, or JHSC member on inspection, asked workers about the organization's health and safety program's contents – would it be a passing or failing grade? People are the most significant contributing factor to the success of an organization's safety culture, and it's what I would like to take a few minutes and examine here.
When teaching a JHSC course, listed in the CPO standard are the five contributing factors of workplace hazards: people, materials, equipment, environment, and process. The idea here is that if we scrutinize each hazard through these lenses, we are given a more profound understanding of how this hazard came to be. As a result, the employer will be better able to establish controls appropriate in the circumstances. To quote my supervisor, "Good culture needs contributing factors addressed," and as much as it pains me to say he is correct, it's true. Your program as a document is just that; it is the people in your organization that interpret the words and transpose the implications into your culture. When implementing or even maintaining your program, a constant focus has to be on how it works in practice and not just on paper.
Although "people" are listed as a separate category, they play a part in every contributing factor in my experience, which should be controlled throughout your health and safety program. According to the CPO standard, people factors include elements such as untrained workers (do workers ever perform tasks their employer hasn't given specific instruction on?); indifferent attitude (is it a case of long tenures and multiple decades of experience causing complacency?); others in the area (do you have visitors, contractors, customers who are not aware, or do not care about your health and safety program?); horseplay (does your culture allow for pranks, or "the cat is away, the mice will play" to take place?); human error (do you have any mechanism to ensure mistakes are caught by some level of redundancy?); rushing (is there a healthy balance of productivity, quality, and worker safety? Or does productivity reign supreme?); and fatigue (are workers checked for fitness for duty?); physical (have you designed roles to accommodate the physical differences between workers abilities?); and mental health (how is the morale, the commitment of your workforce? What about substance abuse?).
People play into material factors as well. Materials are listed as easy or difficult (are workers lifting inappropriately due to their own perceived abilities contrary to company direction?); tipping and collapsing (do workers stack higher than instructed, or choose to place things where it is most convenient for them, posing increasing the risk?); large or bulky (have these items become part of the scenery to the point where workers, not loner respect the hazard?); vision blocked (are circumstances where workers are creating blind spots without realizing it or informing others?); received vs shipped (do your procedures for loading and unloading trailers get performed if items have shifted or broken open in transport?); and team lifts (if you do have designated items where more than one worker is required, what are the odds they actually ask for help?).
Equipment hazards are usually well represented in a health and safety program through PSR's (pre-start health and safety reviews O. Reg. 851 S.7), lifting devices, Lockout/Tag-out (LOTO), etc. Let's now consider the human factor in the breakdown from the CPO standard. Equipment contributing factors are: maintenance (you know it is required, but is it being done? If I ask a forklift driver to point out what was checked on the pre use inspection sheet will they actually be able to show me?); right tool for the job (flathead screw driver vs butter knife – need I say more?); suited to where it's to be used (are workers using pieces of equipment such as ladders and forklift in areas where they truly are not meant to be causing steep angles or caught between hazards?); owned vs rented (who is responsible for maintenance? Although most reputable rental companies respects their OHSA S.31 obligations, is there a process to double check condition of rented equipment?); performance characteristics (every piece of equipment has its own idiosyncrasies as it were; do workers recognize and understand the risk this poses?); and suited to the user (are there some pieces of equipment in your facility that cannot be adjusted to better suit the worker assigned to use it that day?).
The environment we work in is a contributing factor to hazards identified and controlled in the health and safety program. The CPO training standard gives examples of space availability or congestion (if workers find themselves with an abundance of empty space, are they misusing it? Or if space is severely limited in your organization, are controls like the 5 S's of safety (sort, set in order, shine, standardize, sustain) actually being maintained by your workers?); lighting or noise (although these seem like easy to control, workers can be doing tasks at a height where the lighting isn't adequate or performing occasional operations generating substantial amounts of noise. Are these actions planned for in your program? Are workers reporting these deviations from normal working conditions?); floor ground conditions (are housekeeping and spill response programs being carried out promptly? Are workers taking part if they are otherwise not authorized to do so?); indoor vs. outdoor (are workers taking the principles of your program covering internal conditions and applying them outside of your facility? Salting, shovelling, and sanding being done?); variability of the workplace (are workers following the set instructions working offsite? Does your program have an element for worker safety while working from home? I had to work in a Covid-19 point in eventually); and psychological atmosphere (are workers pumped and excited to be at work? Or is there an overall sense of dread being in your facility? Both play a substantial role in buy-in to the health and safety program).
Finally, the fifth contributing factor – process. Examples include: the pace of work (are workers always "go, go, go" where productivity can trump an emphasis on safety? Or is it "slow, slow, slow" where workers feel they have free time and can fill it however they choose is most entertaining? Providing they don't get caught, of course); frequency of tasks (what is the organization's competency levels? What tools are used to monitor the inevitable transition from "unconscious incompetence" to "eyes on task, mind on task" to "indifferent attitude"?); the complexity of the work (are tasks identified that take the total concentration of the worker? Are workers cognizant of how they may be unaware of what is going on around them? Are there tasks that are relatively mindless in scope? Where distractions or not paying attention can occur to the point where your workers lose situational awareness?), and workplace safety culture (how is the commitment to safety actually at your workplace? Are people there to be part of a great organization? Or simply to collect a paycheck indifferent to anything else?).
The purpose here is not to criticize anyone's employer; no workplace is perfect. The OHSA does state that "an employer shall, provide information, instruction and supervision to a worker to protect the health or safety of the worker" (S. 25(2)(a)). As mentioned initially, a solid health and safety program is an excellent foundation for setting expectations. It is, however, just a document, many pieces of paper. Its purpose is to set out how the employer recognizes hazards in the workplace, how risk and compliance has been assessed, what controls have been put in place, and what step is done to evaluate this program so safety doesn't become a flavour the month. But what about the human element? Has it been considered in the roll-out of your employer's program? Ideally, after reading this, you will see what your program does exceptionally well and where there is a little room for improvement. The end goal here is to support the internal responsibility system, and that doesn't exist without taking your workers into consideration. Ensure that the challenges and solutions that they can add are part of the conversation. I can think of no better way of ensuring this happens than utilizing your JHSC. Remember, this legally mandated entity exists so the employer can consider what will work best in your own particular environment.
Geoff Rowatt, CHRL
Industrial Safety Trainers Inc.