Ergonomics Regulatory Requirements

Bawan Saravanabawan, Labour Program, HRSDC

February 4, 2008

Consultation with and participation of the H&S committee or representative required at ALL stages 2

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

Consultation with and participation of the H&S committee or representative required at ALL stages 3

Topics

• Purpose of the regulation

• What is a hazard prevention program?

• Overview of the regulation

• Steps for complying with the regulation

• Conclusion

Consultation with and participation of the H&S committee or representative required at ALL stages 4

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

Consultation with and participation of the H&S committee or representative required at ALL stages 5

Scope

Includes:

All occupational health and safety hazards except where separate subject-specific regulations already exist.

(e.g. confined spaces, hazardous substances)

Consultation with and participation of the H&S committee or representative required at ALL stages 6

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

Consultation with and participation of the H&S committee or representative required at ALL stages 7

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)

Consultation with and participation of the H&S committee or representative required at ALL stages 8

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.

Consultation with and participation of the H&S committee or representative required at ALL stages 9

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)

Consultation with and participation of the H&S committee or representative required at ALL stages 10

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 …

Consultation with and participation of the H&S committee or representative required at ALL stages 11

• 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

Consultation with and participation of the H&S committee or representative required at ALL stages 12

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

Consultation with and participation of the H&S committee or representative required at ALL stages 13

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

Consultation with and participation of the H&S committee or representative required at ALL stages 14

19.4 Hazard Identification and Assessment

Applying the methodology

• The “doing” phase!

• Much of the work may have been done during the methodology phase!

Consultation with and participation of the H&S committee or representative required at ALL stages 15

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

Consultation with and participation of the H&S committee or representative required at ALL stages 16

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?)

Consultation with and participation of the H&S committee or representative required at ALL stages 17

19.4 Hazard Identification and Assessment

Summary

• Committee or representative participation vital to success (and ownership)

• Not working? Re-visit your methodology.

Consultation with and participation of the H&S committee or representative required at ALL stages 18

19.5 Preventive Measures

Hierarchy for implementation:

• Eliminate

• Reduce

• Personal protective equipment, clothing, devices or materials

• Administrative procedures (e.g. employee rotation)

Consultation with and participation of the H&S committee or representative required at ALL stages 19

19.5 Preventive MeasuresEngineering 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

Consultation with and participation of the H&S committee or representative required at ALL stages 20

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

Consultation with and participation of the H&S committee or representative required at ALL stages 21

19.5 Preventive Measures

• The employer shall ensure that any person assigned to implement ergonomics-related prevention measures has the necessary instruction and training

Consultation with and participation of the H&S committee or representative required at ALL stages 22

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

Consultation with and participation of the H&S committee or representative required at ALL stages 23

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

Consultation with and participation of the H&S committee or representative required at ALL stages 24

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

Consultation with and participation of the H&S committee or representative required at ALL stages 25

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

Consultation with and participation of the H&S committee or representative required at ALL stages 26

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

Consultation with and participation of the H&S committee or representative required at ALL stages 27

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.

Consultation with and participation of the H&S committee or representative required at ALL stages 28

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

Consultation with and participation of the H&S committee or representative required at ALL stages 29

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

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