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Ergonomics Regulatory Requirements. Bawan Saravanabawan, Labour Program, HRSDC February 4, 2008. Part of Hazard Prevention Program Regulation. Part XIX of the Canada Occupational Health and Safety Regulations “Hazard Prevention Program”
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Ergonomics Regulatory Requirements Bawan Saravanabawan, Labour Program, HRSDC February 4, 2008
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
Topics • Purpose of the regulation • What is a hazard prevention program? • Overview of the regulation • Steps for complying with the regulation • Conclusion
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
Scope Includes: All occupational health and safety hazards except where separate subject-specific regulations already exist. (e.g. confined spaces, hazardous substances)
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
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)
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.
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)
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 …
19.3 Identification & Assessment Methodology • 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 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
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
19.4 Hazard Identification and Assessment Applying the methodology • The “doing” phase! • Much of the work may have been done during the methodology phase!
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
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?)
19.4 Hazard Identification and Assessment Summary • Committee or representative participation vital to success (and ownership) • Not working? Re-visit your methodology.
19.5 Preventive Measures Hierarchy for implementation: • Eliminate • Reduce • Personal protective equipment, clothing, devices or materials • Administrative procedures (e.g. employee rotation)
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
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
19.5 Preventive Measures • The employer shall ensure that any person assigned to implement ergonomics-related prevention measures has the necessary instruction and training
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
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
19.6 Employee Education 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
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
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
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.
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
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
