Regularly updating and monitoring the effectiveness of your health and safety program is the law.  It also increases the due diligence of the employer in the event of an incident causing injury or illness.


When to Complete a Review and Refresh/Update

A review and update must be completed annually, at minimum. However, completing a review and update once a year may not be sufficient. When processes change, hazards change. Other times when a review and update of your health and safety program would be required are when an incident occurs or there are Legislative or Regulatory changes that require a change to a policy or procedure. This goes towards implementing a proper health and safety management system.

The simplest and most common time to complete a review and update is at the end of the year.
New year, new health and safety program!


Legislative Requirements

There are requirements under the Occupational Health and Safety Act to update your program. The following Sections apply to this requirement:

  • Section 25(2)(j) – The 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.
  • Section 32.0.1(1) – An employer shall prepare a policy with respect to workplace violence, prepare a policy with respect to workplace harassment and review the policies as often as is necessary, but at least annually.

What’s Involved

What is involved in updating your health and safety program?

Some may say a quick update of the health and safety policy, violence and harassment policies with the current date and updating the date the manual was created would be enough. A proper update and refresh of the program involves a few different tasks:

Hazard Assessment

A hazard assessment reviews the current hazards in the workplace. Hazards and conditions change over the course of time and require a review on a regular basis.

Perhaps you have some new equipment that has been installed, you have changed the layout of your workplace or you have streamlined a process that removes some of the safety concerns found previously. There may be additional measures required due to updated legislative requirements. Completing an updated hazard assessment on an annual basis ensures any changes to tasks, conditions and the general workplace are assessed for hazards and control measures implemented.


Program

Assessing the program against the current legislative and regulatory requirements ensures policies and procedures in place are following the most up-to-date laws, regulations and standards that apply to the workplace. The laws and standards change regularly and assuming your policies and procedures comply regardless of those changes is a costly mistake.

Conditions such as new equipment, general workplace changes, employee and workforce changes (increases or decreases) and even an updated hazard assessment require changes to policies and procedures to match the current processes. If your documentation does not match your actions, then you have compliance gaps which can lead to potential liability issues.


Training

Assessing the effectiveness of your training program, as well as the contents, ensures training is provided in accordance with applicable laws, regulations and standards. This checks for gaps such as expired or missing training that may not be previously recognized.

Changes to processes, policies/requirements and equipment require updated training. You may also have new requirements due to general industry or workplace responsibilities.


Action Plan

It is important to create an action plan for any items that need to be improved upon. This shows you have reviewed the elements, will take steps to improve and will monitor and record progress. The action plan lists any gaps found, what is needed to correct the gap(s), who is responsible, a timeline for completion and a sign off area to show it has been completed. Monitoring the action plan progress ensures the gaps are corrected.

This list is not exhaustive as the actual steps can be quite detailed. This is simply a starting point. There are other areas and more in-depth reviews required. If you do not have the capability or knowledge to complete these tasks, a consultant such as myself can help ensure you review every component of your program and develop an action plan that works for your business.

If you require assistance with your workplace safety program I can assist with different steps in the process. I do this by getting to know your business and developing a proposal that meets your needs. If you would like to discuss your requirements, or obtain more information, contact me by phone or email today.

Phone: 416-984-1107
Email: doug@sooleyssafetyservices.ca

Let’s prevent any potential fines or non-compliance issues ahead of time.

Prevention is better than reaction!