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Hazard Prevention Program. Canada Labour Code–Part II. HPP and Ergonomics. Section 125(1)(u) Ensure that the work place, work spaces and procedures meet prescribed ergonomic standards. BACKGROUND TO ERGONOMICS AMENDMENTS. The development involved. employers. regulators. workers.

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Hazard Prevention Program

Canada Labour Code–Part II


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HPP and Ergonomics

  • Section 125(1)(u)

    Ensure that the work place, work spaces and procedures meet prescribed ergonomic standards.


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BACKGROUND TO ERGONOMICS AMENDMENTS

  • The development involved

employers

regulators

workers

The Canada Labour Code was amended in 2000 to address the requirement to have a HPP program and ergonomics.


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Regulatory Amendments

  • Non-consensus on ergonomics regulations

  • Will be identified as a specific hazard to be addressed in Part XIX – Hazard Prevention Program Regulation


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Hazard Prevention Program Requirements

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)


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HPP

  • Implementation Plan (19.2)

    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.


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HPP

The Guide suggests:

  • Identify & assess known hazards using existing knowledge sources (19.3(1)(a) – (h))

  • Additional sources: CCOHS, WCBs, brochures, safety and health associations, the Internet

  • Use a 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


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    HPP

    This 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


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    HPP

    • Preventive Measures (19.5)

      Hierarchy for implementation:

    • Eliminate

    • Reduce

    • Personal protective equipment, clothing, devices or materials

    • Administrative procedures (e.g. employee rotation)


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    HPP

    • Employee Education (19.6)

      Must include for each employee:

    • 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


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    HPP

    Education program review:

    • at least every 3years

    • whenever there is a change in conditions in respect of the hazards

    • whenever new hazard information becomes available to the employer


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    HPP

    • Elements of HPP (hazard identification, assessment & prevention, implementation, education, evaluation and record keeping) are fundamental elements of a good work place Health and Safety Program

    • HPP regulation requires work places to have a formal program to address hazards


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    HPP

    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


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    HPP

    • Program Evaluation (19.7)

      Evaluation shall be 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.


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    HPP

    How often must a program review occur?

    • 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


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    HPP

    • Reports and Records (19.8)

    • If a program evaluation has been conducted under section 19.7, prepare a program evaluation report and a copy is to be submitted 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


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    Impact on work places

    • Minimal where there is already a formal health & safety program

      • ensure HPP elements are part of the site health & safety program

      • comply with record keeping & reporting

      • Ensure it covers ergonomic hazards

    • Places that do not already have a health & safety program

      • Implement HPP and specifically address ergonomic hazards if any


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    Reminder on HPP development

    Employers must develop, implement and monitor the HPP in consultation and participation with the appropriate committee

    Employers must ensure they include the appropriate committee (work place or policy) or representative at ALL stages of site work