Ergonomics Regulatory Requirements Bawan Saravanabawan, Labour Program, HRSDC February 4, 2008

2 Consultation with and participation of the H&S committee or representative required at ALL stages Part of Hazard Prevention Program Regulation Part XIX of the Canada Occupational Health and Safety Regulations “Hazard Prevention Program” (A program for eliminating or minimizing risk to employees in the work place) Ergonomics requirements introduced as amendments to the HPP Regulation

3 Consultation with and participation of the H&S committee or representative required at ALL stages Topics Purpose of the regulation What is a hazard prevention program? Overview of the regulation Steps for complying with the regulation Conclusion

4 Consultation with and participation of the H&S committee or representative required at ALL stages Purpose Purpose of Part II of the Canada Labour Code: “to prevent accidents and injury to health arising out of, linked with or occurring in the course of employment ” Hazard prevention programs: To eliminate or minimize risk from hazards through a program approach

5 Consultation with and participation of the H&S committee or representative required at ALL stages Scope Includes: All occupational health and safety hazards except where separate subject-specific regulations already exist. (e.g. confined spaces, hazardous substances)

6 Consultation with and participation of the H&S committee or representative required at ALL stages 19.1 HPP Regulation In consultation with and participation of the H&S Committee Develop, implement and monitor a program for the prevention of hazards (risks), including ergonomics-related hazards Program appropriate to the size of the work place

7 Consultation with and participation of the H&S committee or representative required at ALL stages 19.1 Hazard Prevention Program – Committee or representative participation required at all stages Develop Implementation Plan (19.2) Hazard Identification and Assessment Methodology (19.3) Implement Hazard Identification and Assessment (19.4) Preventive Measures (19.5) Employee Education (19.6) Monitor Program Evaluation (19.7) Reports and Records (19.8)

8 Consultation with and participation of the H&S committee or representative required at ALL stages 19.2 Implementation Plan Develop an implementation plan that : specifies the time frame for each phase of the development and implementation of the program monitors the progress of the implementation of the preventive measures review the time frame of the implementation plan regularly and, as necessary, revise it.

9 Consultation with and participation of the H&S committee or representative required at ALL stages 19.2 Implementation Plan Ergonomics-related hazards are identified, assessed and are eliminated or reduced – as much as is reasonably possible Any person assigned to identify & assess – has the necessary instruction and training. (Qualified person – because of knowledge, training and experience, is qualified to perform that duty)

10 Consultation with and participation of the H&S committee or representative required at ALL stages 19.3 Identification & Assessment Methodology Identify & assess known hazards using existing knowledge sources (19.3(1)(a) – (h)) Additional sources: Can be CCOHS, WCBs, CSA Standard (?), safety and health associations etc. Continued next page …

11 Consultation with and participation of the H&S committee or representative required at ALL stages Use a method/technique you are familiar with and which suits the nature of the work being addressed Adapt Adjust the various techniques and methods to the size and complexity of your work place(s) Record your findings 19.3 Identification & Assessment Methodology

12 Consultation with and participation of the H&S committee or representative required at ALL stages 19.3 Identification & Assessment Methodology Must include the steps and time frame for identifying and assessing hazards; the keeping of a record of the hazards; and a time frame for reviewing and, if necessary, revising the methodology

13 Consultation with and participation of the H&S committee or representative required at ALL stages 19.3 Identification & Assessment Methodology Summary The “how-to” phase, not the “doing” phase Design it to suit the work place Be sure to include the required time frames and record keeping items

14 Consultation with and participation of the H&S committee or representative required at ALL stages 19.4 Hazard Identification and Assessment Applying the methodology The “doing” phase! Much of the work may have been done during the methodology phase!

15 Consultation with and participation of the H&S committee or representative required at ALL stages Relating to ergonomics, take into account, factors such as… Physical demands of the work activities, the work environment, the work procedures, the organization of the work, the circumstances in which the work activities are performed The characteristics of materials, goods, persons, animals, things and work spaces and the features of tools and equipment

16 Consultation with and participation of the H&S committee or representative required at ALL stages 19.4 Hazard Identification and Assessment Take into account factors 19.4(a) to (f), including the key factors: Level of exposure to the hazard (how much?) Duration of exposure to the hazard (how long?) Frequency of exposure to the hazard (how often?)

17 Consultation with and participation of the H&S committee or representative required at ALL stages 19.4 Hazard Identification and Assessment Summary Committee or representative participation vital to success (and ownership) Not working? Re-visit your methodology.

18 Consultation with and participation of the H&S committee or representative required at ALL stages 19.5 Preventive Measures Hierarchy for implementation: Eliminate Reduce Personal protective equipment, clothing, devices or materials Administrative procedures (e.g. employee rotation)

19 Consultation with and participation of the H&S committee or representative required at ALL stages 19.5 Preventive Measures Engineering controls – may involve mechanical aids, equipment design or redesign that take into account physical attributes of the employee Administrative procedures, such as the management of hazard exposure and recovery periods and the management of work patterns and methods

20 Consultation with and participation of the H&S committee or representative required at ALL stages 19.5 Preventive Measures Preventive measures must not create a hazard System in place to address newly identified hazards expeditiously Address ergonomics-related hazards identified when planning implementation of change to the work environment, duties, equipment, practices or processes

21 Consultation with and participation of the H&S committee or representative required at ALL stages 19.5 Preventive Measures The employer shall ensure that any person assigned to implement ergonomics-related prevention measures has the necessary instruction and training

22 Consultation with and participation of the H&S committee or representative required at ALL stages 19.6 Employee Education H&S education, including education relating to ergonomics, to each employee, including: This program including the methodology and preventive measures Nature of the work place and associated hazards Employees’ duty to report Overview of the Act and regulations

23 Consultation with and participation of the H&S committee or representative required at ALL stages 19.6 Employee Education Education for an employee Whenever new hazard information becomes available in the work place of that employee Before an employee is assigned a new activity or exposed to a new hazard

24 Consultation with and participation of the H&S committee or representative required at ALL stages 19.6 Employee Education Education program review: at least every 3 years whenever there is a change in conditions in respect of the hazards whenever new hazard information becomes available to the employer

25 Consultation with and participation of the H&S committee or representative required at ALL stages 19.6 Employee Education Records Employee must acknowledge in writing that they received education, employer shall acknowledge in writing that they provided it. Keep paper or computerized records of the education provided to each employee for a period of two years after the employee ceases to be exposed to a hazard

26 Consultation with and participation of the H&S committee or representative required at ALL stages 19.6 Employee Education Summary In addition to other education and training required by the Code and Regulations Keeping proper, detailed records helps to demonstrate due care and diligence

27 Consultation with and participation of the H&S committee or representative required at ALL stages 19.7 Program Evaluation Evaluation, including ergonomics-related components based on: Conditions related to the work place and employee activities, inspection reports, hazardous occurrence investigation reports, safety audits, first aid records and injury statistics, observations of the policy and work place committees, or the representative, on the effectiveness of the program other relevant information.

28 Consultation with and participation of the H&S committee or representative required at ALL stages 19.7 Program Evaluation Program must be reviewed: at least every three years; whenever there is a change in conditions in respect of hazards whenever new hazard information in respect of a hazard in the work place becomes available

29 Consultation with and participation of the H&S committee or representative required at ALL stages 19.8 Reports and Records If a program evaluation has been conducted under section 19.7, prepare a program evaluation report and submit a copy of it to the Minister of Labour with the annual hazardous occurrence report Keep the program evaluation report readily available for six years after the date of the report

30 Consultation with and participation of the H&S committee or representative required at ALL stages