Pinchin Environmental Bulletin # 8

Developing Health and Safety Programs for
Small to Medium-Sized Government Agencies

OH&S Case Study

Health and safety management can be difficult at the best of times. The magnitude of the problem is often inversely proportional to the size of the organization, as smaller entities commonly lack the internal resources needed to effectively and efficiently address OH&S issues that arise in the workplace. Such was the case at Measurement Canada.

The Challenge

Measurement Canada (MC) is a special operating agency under the umbrella of Industry Canada. MC has a mission to ensure equity and accuracy where goods and services are bought and sold on the basis of measurement, in order to contribute to a fair and competitive marketplace for Canadians. Their activities include field inspection of measuring device (e.g. gasoline pumps), approval of prototype devices, and laboratory calibration of the standards used by MC inspectors. MC employs 362 staff through a network of 17 offices located across Canada.

MC management faced numerous challenges related to OH&S. MC lacked a formal OH&S program appropriate to its personnel and their duties. The size of the agency limited their internal OH&S personnel. Their work environments were varied, including offices, workshops, various types of laboratories, vehicles, and virtually any Canadian facility or work site that contained a measuring-device intended for use in commercial trade. Due to this diversity in the type and location of work performed, the hazards were also varied. Some employees may be exposed to gasoline vapour at fuel dispensing operations, others to electrical hazards in a lab, while still others experienced potential ergonomic risks while handling weights used to inspect scales. How could such a diverse set of OH&S issues be effectively and consistently managed over the entire organization?

MC recognized that they required external guidance and assistance in developing a plan to ensure that their employees were protected on the job. However, finding one consulting firm possessing technical expertise, management experience and training capabilities, throughout Canada and in both official languages, limited the number of firms that could effectively assist them. MC chose to retain the services of Pinchin Environmental, a national environmental, health and safety consulting firm with 22 offices across Canada. Pinchin had successfully assisted MC in the past with a number of laboratory safety and occupational hygiene projects. Pinchin staff included Certified Industrial Hygienists (CIH) and Canadian Registered Safety Professionals (CRSP), some specializing in the technical aspects of OH&S, others in developing management programs, while others held expertise in training.

The project team was assembled and the challenge was clear. MC needed answers to several questions.

• What are the hazards our employees may potentially face on the job?
• How do we control these hazards?
• How do we demonstrate compliance with regulatory requirements and due diligence?
• How do we ensure on-going compliance?
• How do we make it easier for our supervisors to "manage safety"?
• How do we do all of these things efficiently and cost-effectively?

The Approach

Pinchin had successfully assisted a number of other organizations in answering these questions. Their approach was to work with MC management and the JOSH Committees to develop, implement, and maintain a formal, yet simple, OH&S Program. Here's how it was done:

Step 1: Develop a Policy Statement

The first task was to prepare an OH&S Policy Statement that clearly communicated senior management's genuine commitment to providing safe and healthy workplace conditions. A Roles and Responsibilities Program was also prepared which outlined the general responsibilities and expectations of all workplace parties. Each level of management was assigned responsibilities, so each individual would understand that they were accountable for specific actions and deliverables.

Step 2: Identify Potential Hazards and OH&S Issues

The next step was to identify the major OH&S issues or hazards that MC employees might face. Much of this part of the project was done by the various JOSH Committees that were uniquely positioned to identify these issues. To better understand the problems facing MC employees, Pinchin's consultants spent time interviewing MC employees and managers, and in some cases, spent time in the field with inspectors, observing the work and listening to the frontline concerns and recommendations.

At the end of this stage of the project, a list of hazards/issues had been developed. The next step was to determine how these issues should be managed.

Step 3: Prepare Written Programs

Comprehensive, written programs were prepared by Pinchin for each issue identified in Step 2. Programs were designed to provide very specific yet practical direction and technical information as to how an issue should be managed. The intention was to develop and implement effective programs to control recognized hazards. It was vital to ensure that these programs provided demonstrable legal compliance, but were practically field based to promote acceptance by the stakeholders. If successful, these programs would, collectively, promote and provide a safe and healthy workplace, that is, satisfy the organization's policy goal.

Each program contained several sections including Objectives, Scope and Limitations, and various program elements. These elements formed the backbone of the program, providing the "how-to" information. For example, the Respiratory Protection Program contained elements such as Selection of Respirators, Fit Testing, Facial Hair Policy, and Training. Each program provided clear guidance to the reader so that he/she could clearly understand his/her responsibilities. Various forms and procedures were included in appendices to ensure that managers had easy access to them. This, of course, was designed to facilitate conformance with programs by making it convenient for the user to find and complete the appropriate form, whether it be during new employee orientation, while conducting workplace inspections, or any other standard task.

Pinchin prepared the initial draft versions of the programs referencing and ensuring compliance with applicable codes, regulations, CSA standards, and the like. Once comments on the draft document had been received from MC managers and JOSH Committees, and appropriate revisions incorporated into the final documents, the programs were complied, translated, and bound into hardcopy OH&S Manuals. These manuals were distributed to the regional offices, and eventually provided to all MC employees during the "roll-out" training.

It was recognized that the OH&S Manual would be a "living document", undergoing periodic revisions following changes to regulatory requirements, or in response to JOSH Committee recommendations. To ensure that all MC offices had instantaneous access to the latest version of the programs, the manual was made available on the agency's intranet. Updates to the programs can only be made by appropriate MC personnel (e.g. National OH&S Co-ordinator) following approval from senior management.

Step 4: Roll-Out Training

Unless properly communicated and implemented, even a comprehensive, well-written OH&S Program Manual is doomed to failure. MC requested that Pinchin develop a training program primarily intended to ensure that all MC employees were aware of the new OH&S Policy and Programs, and their individual responsibilities under the Programs. In addition, some components of the course were to include technical training such as respiratory protection, lead handling, and confined space entry.

The four-day courses were delivered in thirteen locations across Canada, in French and English, over a period of approximately eight months. Course evaluations consistently demonstrated the importance, quality and relevance of the training. Feedback on the individual programs received during the regional sessions was communicated back to MC management in Ottawa to facilitate continuous improvement.

The Results

At the completion of the project, MC had the answers to the six questions posed earlier. They had used the knowledge and experience of their own employees and JOSH Committees, along with the technical support and management experience of Pinchin Environmental, to formally identify potential workplace hazards, and to develop effective and simple programs to provide on-going management of these issues. All in about a year!

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