Developing Occupational Health and Safety Policies and Programs
In May 2001, a number of amendments to the Occupational Health and Safety Act were proclaimed. One important amendment, effective January 1, 2002, requires employers with ten or more employees to establish and maintain a written health and safety program, and for employers with less than ten employees to establish and maintain a written health and safety policy. Specific regulations outlining the required elements of an occupational health and safety policy and program were approved by government in December 2001, and are reproduced below.
Safety Policy Definition
A health and safety policy is a written statement by an employer stating the company's commitment for the protection of the health and safety of employees and to the public. It is an endorsed commitment by management to its employees regarding their health and safety.
Details on the elements of an occupational health and safety policy are outlined in the attached Regulations.
Safety Program Definition
A health and safety program contains the health and safety elements of an organization, objectives which make it possible for the company to achieve its goal in the protection of its workers at the workplace.
Section 4.(1) of the Occupational Health and Safety Regulations specify the minimum requirements to be contained in a health and safety program. Some of the requirements specified in the regulation may not be applicable to every workplace. However, each employer should carry out their own health and safety risk assessment, in consultation with the occupational health and safety committee, to determine what hazards are present at the workplace. Once the hazards have been identified, controls for exposure to these hazards should be detailed in the health and safety program.
Details of the required elements of an occupational health and safety program are outlined in the attached regulations.
Reasons for Health and Safety Programs or Policies in the Workplace
There are several reasons why workplaces need a health and safety policy or program, including:
to clearly demonstrate management's full commitment to their employee's health and safety;
to show employees that safety performance and business performance are compatible;
to clearly state the company's safety beliefs, principles, objectives, strategies and processes to build buy-in through all levels of the company;
to clearly outline employer and employee accountability and responsibility for workplace health and safety;
to comply with the Occupational Health and Safety Act; and
to set out safe work practices and procedures to be followed to prevent workplace injuries and illnesses.
Rules for the Application of Health and Safety policies and Programs
The Occupational Health and Safety Act and Regulations applies to all employers, workers, and self-employed persons. Employers with less than ten employees will be required to have an occupational health and safety policy in place while employers with ten or more employees will be required to have an occupational health and safety program in place.
How to Develop a Health and Safety Policy or Program
The development of a health and safety policy or program is the responsibility of the employer. However, for such a policy or program to be accepted and successful it will need the commitment and endorsement of the workers. Therefore, it is critical to involve the workers in the early stages when developing a policy or program. This would include, but not be limited to, the workers' health and safety representative or the occupational health and safety committee.
Deadline for Compliance with the New Regulations
The requirements for the establishment of an occupational health and safety policy or programs come into effect on January 1, 2002. Occupational Health and Safety Officers will be conducting inspections to ensure such policies/programs are in place. Where the employer has not yet established a policy/program, officers will be issuing orders (directives) to ensure compliance. These orders will require the establishment of a policy within 30 days or a program within 90 days of the issuance of the order.
Requirements for Policy or Program Review and/or Revisions
The legislation stipulates that the health and safety policy is to be reviewed annually, and where required, updated in consultation with the workers' health and safety representative. The policy should also be reviewed and revised whenever there is an operational or organizational change.
The legislation stipulates that the health and safety program is to be reviewed and revised at least every three years. In addition, a review is required to be undertaken whenever there is a change of circumstances that may affect the health and safety of workers, or where an officer makes such a request. The review of the program should be done in consultation with the occupational health and safety committee.
Copying Someone Else's Health and Safety program
Section 36.1 of the Act stipulates that an employer is required to establish and maintain an occupational health and safety program at the workplace. Should you copy someone else's health and safety program, you wouldn't be in compliance with section 36.1 of the Act because you have not established a safety program that would be applicable to your workplace. A health and safety program must address the hazards that are present in your workplace, as a program developed or designed for another workplace may not accommodate the hazards present in another.
Health and Safety Policy and Program Training