A Roadmap to Successful Implementation

1
Hazard Prevention Program Regulations
A Roadmap to Successful Implementation
Gina Gnassi B.A. CRSP 12 September 2006
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Introduction

• Overview of the Hazard Prevention Program under
  the amended COHS Regulations
• What is a gap analysis and how can it help?
• Developing your action plan for compliance and
  implementation as it relates to the regulation

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Purpose HazardPrevention Program Regulations

• The Hazard Prevention Program Regulations include
  requirements relating to hazard identification,
  assessment and control as well as the education
• of employees
• The Regulations also introduce a requirement for
  employers to submit, annually, an evaluation
  report of the effectiveness to the Minister of
  Labour. This will be part of the employers
  annual hazardous occurrence investigation report
  required under Part XV of the COHS Regulations

4
Canada Labour Code Part II

• Section 125.(1) (z 03)
• Develop, implement and monitor, in consultation
  with the policy committee or, if there is no
  policy committee, with the workplace health
  committee or the health and safety
  representative, a prescribed program for the
  prevention of hazards in the workplace
  appropriate to its size and the nature of the
  hazards in it that also provides for the
  education of employees in health and safety
  matters.

The proposed Hazard Prevention Program is the
prescribed program!
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Canada Labour Code Part II

• Section 125.(1) (z 04)
• Where the program referred to in subparagraph (z
  03) does not cover certain hazards unique to a
  workplace, develop, implement and monitor, in
  consultation with the workplace committee or the
  health and safety representative, a prescribed
  program for the prevention of those hazards that
  also provides for the education of employees in
  health and safety matters related to those
  hazards

Specific programs are to be developed that meet
the unique needs of the workplace.
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Part XIX HazardPrevention Program Regulations

• Section 19.1(1)
• The employer shall, in consultation with and with
  the participation of the policy committee or, if
  there is no policy committee, the workplace
  committee or the health and safety representative
  develop, implement and monitor a program for the
  prevention of hazards in the workplace that is
  appropriate to the size of the workplace and the
  nature of the hazards and that includes the
  following components

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Part XIX Hazard Prevention Program Regulations
Section 19.1(1) (contd)

• (a) An Implementation Plan
• (b) Hazard Identification and Assessment
  Methodology
• (c) Hazard Identification and Assessment
• (d) Preventive Measures
• (e) Employee Education
• (f) Program Evaluation/Reports and Records

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Part XIX Hazard Prevention Program Regulations
Application

• Section 19.1(2)
• Subsection (1) applies in respect of every
  workplace controlled by the employer and, in
  respect of every work activity carried out by an
  employee in the workplace that is not controlled
  by the employer, to the extent that employer
  controls the activity

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Employer Duty

• Employers will need to develop a hazard
  prevention program that includes the following
  elements

• (a) An Implementation Plan
• (b) Hazard Identification and Assessment
  Methodology
• (c) Hazard Identification and Assessment
• (d) Preventive Measures
• (e) Employee Education
• (f) Program Evaluation/Reports and Records

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Where to Begin?

• Gap Analysis
• Needs Determination
• Risk Assessment
• Set Priorities
• Action Plan

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Scope of Gap Analysis
Current OHS Program
HPP Regulation
Recommendations and Action Plan
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Gap Analysis

• Intent of a legislative gap analysis is to
  provide a concise, objective assessment of the
  current state of your health and safety program
  in relation to a specific legislative standard.
• Analysis will determine whether an organization
  is effectively meeting the legislative
  requirements or if gaps are present and need to
  be addressed.

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Part XIX HazardPrevention Program Regulations

• Hazard Prevention Program Components
• (a) An Implementation Plan
• (b) Hazard Identification and Assessment
  Methodology
• (c) Hazard Identification and Assessment
• (d) Preventive Measures
• (e) Employee Education
• (f) Program Evaluation/Reports and Records

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Implementation Plan
Section 19.2 The employer shall

• (a) develop an implementation plan that
  specifies the time frame for each developmental
  and implementation phase of the prevention
  program
• (b) monitor the progress of the implementation
  of preventive measures, and
• (c) review the time frame of the implementation
  program regularly and, as necessary, revise it

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What Does This Mean to You?
Implementation Plan

• Implementation is the process that takes
  leadership initiatives, goals and objectives and
  transforms them to a structured plan of
  activities
• The plan must match determined needs and set
  objectives that translate these needs to
  actionable items

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Implementation Plan
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Part XIX HazardPrevention Program Regulations

• Hazard Prevention Program Components
• (a) An Implementation Plan
• (b) Hazard Identification and Assessment
  Methodology
• (c) Hazard Identification and Assessment
• (d) Preventive Measures
• (e) Employee Education
• (f) Program Evaluation/Reports and Records

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Hazard Identification and Assessment Methodology

• Section 19.3(1)
• The employer shall develop a hazard
  identification and assessment methodology taking
  into account the following documents and
  information

• (a) Reports of hazardous occurrences
• (b) First aid and minor injury records
• (c) Workplace health protection programs
• (d) Workplace inspection results

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Hazard Identification and Assessment Methodology
Section 19.3(1) (contd)

• (e) Any employee reports made under paragraph
  126(1)(g) or (h) of the Act or under section 15.3
• (f) Any government or employer reports, studies
  and tests concerning the health and safety of
  employees
• (g) Any reports made under the Safety and
  Health Committees and Representatives Regulations
• (h) The record of hazardous substances
• (i) Any other relevant information

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Hazard Identification and Assessment Methodology

• Section 19.3(2)
• The hazard identification and assessment
  methodology shall include

• (a) the steps and time frame for identifying and
  assessing the hazards
• (b) the keeping of a record of the hazards and
• (c) a time frame for reviewing and, if necessary
  revising the methodology

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Hazard Identification and Assessment Methodology

• Workplace Inspections
• General planned
• Informal/ unplanned
• Critical parts
• Housekeeping
• Legislated/ regulatory

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Hazard Identification and Assessment Methodology

• Dont take on new methodologies
• Ensure that each program meets the requirements
  of a well managed system Plan Do Check Act
• Continual improvement opportunities

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Part XIX Hazard Prevention Program Regulation

• Hazard Prevention Program Components
• (a) An Implementation Plan
• (b) Hazard Identification and Assessment
  Methodology
• (c) Hazard Identification and Assessment
• (d) Preventive Measures
• (e) Employee Education
• (f) Program Evaluation/Reports and Records

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Hazard Identification and Assessment
Section 19.4 The employer shall identify and
assess the hazards in the workplace in accordance
with the methodology under section 19.3 taking
into account

• (a) the nature of the hazards
• (b) the employees level of exposure to the
  hazard
• (c) the frequency and duration of employees
  exposure to the hazard
• (d) the effects, real or apprehended, of the
  exposure on the health and safety of employees

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Hazard Identification and Assessment
Section 19.4 (contd)

• the preventive measures in place to address
• the hazard
• (f) any employee reports, made under paragraph
  126(1)(g) or (h) of the Act or under section
  15.3 and
• (g) any other relevant information

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Nature of Hazards and Level of Exposure
Hazard Identification and Assessment

• Physical
• Mechanical
• Chemical
• Biological
• Ergonomic
• Psychosocial

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Building a Hazard Inventory
Hazard Identification and Assessment Methodology

• Legislation and regulations
• National Codes Fire Code, Building Code, Safety
  Code 6
• Canadian Standards Association (CSA)
• Federal department policy, standards,
  procedures,safe use guidelines
• Equipment manufacturer specifications and
  instructions
• Industry best practices (CCOHS)(IRSST)

• Past work place inspection reports
• Past claims/injury records
• Past accident investigation reports
• Past work place committee minutes/records
• Job/task analyses and standard safe operating
  procedures
• Inspecting Physical Conditions IAPA Guide

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Qualitative Analysis

• Qualitative analysis deals with the descriptive
  scales to measure the magnitude of potential
  consequences and the likelihood that these
  consequences will occur
• Qualitative analysis is used in the initial
  stages as a filtering or screening device to
  identify risks that might require more time,
  money and effort for a fuller and detailed
  analysis
• Risk Probability x Severity

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Quantitative Analysis

• In quantitative analysis, numerical values are
  given to probability, severity and frequency to
  produce a more detailed prioritization than is
  usually achieved in the qualitative analysis
• Data is obtained from a variety of sources
• Criticality Probability Severity Frequency

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A Tool for Qualitative Risk Assessment

• Risk Probability X Severity

Probability Unlikely, possible, likely, highly
likely Severity Minimal, serious, severe,
critical Risk Level A, B, C, D
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Probability

• The chance that a given event will occur
• Probability is determined by
• Reviewing historical data
• Evaluating existing controls (engineering,
  administrative, Personal)
• Determining the extent of the exposure ( people
  affected, frequency of exposure, duration of
  exposure, etc.)

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Probability examples

• Highly Likely
• Expected to occur more than once a year
• Has happened several times before
• Likely to occur tomorrow
• Likely
• Likely to occur several times this year
• Dual instrument failure
• No training

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Probability examples (cont)

• Possible
• Expected to occur at least once during
  facility/system lifetime
• Likely to occur in the next several years
• Trained but failure to follow procedure
• Unlikely
• Not expected to occur during facility/system
  lifetime
• Never happened before (here or at other facility)
• Multiple reliable and unrelated instrument
  failures and unusual human error

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Severity

• The extent of the worst credible loss
• Severity is determined by
• Reviewing historical data
• Predicting potential outcomes
• A determination of severity includes the entire
  business, not just the health and safety losses

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Severity examples

• Critical
• Fatality or disabling injury
• Heat Stroke
• Plant shut down gt1day
• Loss gt1M
• Fire involving major systems
• Severe
• WSIB lost time injury
• Stage 3 RSI
• Single line shut down gt1day
• Loss between 100K and 1M
• Fire involving minor subsystem

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Severity examples (cont)

• Serious
• WSIB Medical Aid case
• Stage 2 RSI
• Single tool shutdown gt1day
• Productivity affected (I.e. 20 drop)
• Loss 10K to 100K
• Minimal
• First Aid
• Stage 1 RSI
• Heat Rash
• Loss lt10K

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Hazard Identification and Assessment
Probability
Severity
38
Part XIX Hazard Prevention Program Regulations

• Hazard Prevention Program Components
• (a) An Implementation Plan
• (b) Hazard Identification and Assessment
  Methodology
• (c) Hazard Identification and Assessment
• (d) Preventive Measures
• (e) Employee Education
• (f) Program Evaluation/Reports and Records

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Preventive Measures
Section 19.5(1) The employer shall, in order to
address identified and assessed hazards, take
preventive measures to address the assessed
hazard in the following order of priority

• (a) the elimination of the hazard
• (b) the reduction of the hazard, including
  isolating it
• (c) the provision of PPE, clothing devices or
  materials
• (d) administrative procedures

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Preventive Measures

• Section 19.5(2)
• As part of the preventive measures, the employer
  shall develop and implement a preventive
  maintenance
• program in order to avoid failures that could
  result in
• a hazard to the employees
• Section 19.5(3)
• The employer shall ensure that any preventive
  measure shall not in itself create a hazard and
  shall take into account the effects on the
  workplace
• Section 19.5(4)
• The preventive measures shall include steps to
  address newly identified hazards in an
  expeditious manner

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Preventive Measures
Strategies
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Hazard Control Types
ENGINEERING

• ELIMINATION
• Engineering out the hazards by designing hazards
  out
• SUBSTITUTION Substituting the hazard with less
  or non-hazardous options
  
• REDUCTION
• Reducing the level of or the exposure to the
  hazard
• ISOLATION
• Isolating the hazard to eliminate the level of
  exposure

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Hazard Control Types

• ADMINISTRATIVE
• Controlling the hazard with specific procedures,
  practices or guidelines that control the hazard
  or exposure to the hazard
  
• PERSONAL PROTECTIVE EQUIPMENT CLOTHING
  Providing the employee with adequate protection
  to control the exposure
• EMERGENCY RESPONSE
• Having effective pre-planned emergency response

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Points for Controls

• AT THE SOURCE OF THE HAZARD Engineering
  controls are the first choice for best
  protection
• ALONG THE PATH THE HAZARD TAKES
• When the hazard is not completely controlled at
  the source
• AT THE EMPLOYEE THE HAZARD REACHES
• The last line of defense to contain the hazard

45
Part XIX Hazard Prevention Program Regulations

• Hazard Prevention Program Components
• (a) An Implementation Plan
• (b) Hazard Identification and Assessment
  Methodology
• (c) Hazard Identification and Assessment
• (d) Preventive Measures
• (e) Employee Education
• (f) Program Evaluation/Reports and Records

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Employee Education
Section 19.6(1) The employer shall provide health
and safety education to each employee which shall
include the following

• (a) the hazard prevention program implemented in
  accordance with this part to prevent hazards
  applicable to the employee, including the hazard
  identification and assessment methodology and the
  preventive measures taken by the employer
• (b) the nature of the workplace and the hazards
  associated with it

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Employee Education
Section 19.6(1) (contd)

• (c) the employees duty to report under
  paragraphs 126(1)(g) and (h) of the Code and
  under section 15.3 and
• (d) an overview of the Code and these regulations

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Employee Education
Section 19.6(2) The employer shall provide
education to an employee

• (a) whenever new hazard information in respect of
  a hazard in the workplace becomes available to
  the employer, and
• (b) shortly before the employee is assigned to
  new activity or exposed to a new hazard

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Employee Education
Section 19.6(3) The employer shall review the
employee education program, and, if necessary,
revise it

• (a) at least every three years
• (b) whenever there is a change in condition in
  respect of the hazards and
• whenever new hazard information in respect of a
  hazard in the workplace becomes available to
• the employer

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Employee Education
Section 19.6(4)

• Each time education is provided to an employee,
  the employee shall acknowledge in writing that
  they received it, and the employer shall
  acknowledge in writing that they provided it

Section 19.6(5)

• The employer shall keep in paper or computerized
  form, records of the education provided to each
  employee, which shall be kept for a period of two
  years after the employee ceases to be exposed to
  a hazard

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Training Program Steps
Employee Education

• Identify training needs (based on task analysis,
  accident/incident reports, review of system
  components, etc.)
• Develop training (appropriate for the level of
  knowledge and skills required, legislative
  requirements, etc.)
• Deliver training (in-class, in plant, one on one,
  etc.)
• Evaluate training (training objectives met, level
  of attendance, appropriate subject matter, etc.)
• Continual improvement opportunities!

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Employee Education
53
Part XIX Hazard Prevention Program Regulations

• Hazard Prevention Program Components
• (a) An Implementation Plan
• (b) Hazard Identification and Assessment
  Methodology
• (c) Hazard Identification and Assessment
• (d) Preventive Measures
• (e) Employee Education

(f) Program Evaluation/Reports and Records
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Program Evaluation

• Section 19.7(1)
• The employer shall evaluate the effectiveness of
  the hazard prevention program, and, if necessary
  revise it

• (a) at least every three years
• (b) whenever there is a change in conditions in
  respect of the hazards and
• (c) whenever new hazard information in respect of
  a hazard in the workplace becomes available to
• the employer

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Program Evaluation
Section 19.7(2) The evaluation of the
effectiveness of the prevention program shall be
based on the following documents and information

• (a) Conditions related to the workplace and the
  activities of the employees
• (b) Any workplace inspection reports
• (c) Any hazardous occurrence investigation
  reports
• (d) Any safety audits

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Program Evaluation
Section 19.7(2) (contd)

• (e) First aid records and any injury statistics
• Any observations of the policy and
• workplace committees
• (g) Any other relevant information

(f)
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Types of Evaluation
Program Evaluation

• Compliance conforming to requirements, rules or
  procedures. Examples of data that provide
  evidence of compliance number of meetings held,
  number of
• inspections conducted
• Quality a measure of excellence or merit. A
  measurement data example is adequacy of
  recommendations
• Outcomes pertain to results and/or
  consequences. Examples of measurement data
  include injury frequency and severity rates and
  numbers of accidents

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Measurement
Program Evaluation

• You cant manage what you cant measure
• - Tom Peters
• Measurement is used to monitor performance
  against standards
• This allows data to be generated to be used to
  measure accountabilities, responsibilities and
  performance

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Recognition, Improvement and Correction
Program Evaluation

• This is the essence of continual improvement
• Recognize achievement
• Mentor and counsel for improved performance
• Correct and coach substandard performance,
  activities and behaviour

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Reports and Records
Section 19.8(1)

• If a program evaluation has been conducted under
  section 19.7, the employer shall prepare a
  program evaluation report and submit a copy of it
  to the Minister as part of the employers annual
  hazardous occurrence report referred to in
  subsection 15.10(1)
• Section 19.8(2)
• The employer shall keep readily available every
  program evaluation report for six years after the
  date of the report

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Part XIX Hazard Prevention Program Regulations

• Hazard Prevention Program Components
• (a) An Implementation Plan
• (b) Hazard Identification and Assessment
  Methodology
• (c) Hazard Identification and Assessment
• (d) Preventive Measures
• (e) Employee Education
• (f) Program Evaluation/Reports and Records

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Action Plan

• Provides a series of activities, processes and
  controls that an organization must put in place
  to implement the needs that have been identified
  as priorities
• Specifies who will assume ownership of the
  objectives
• Includes milestones and timelines which must be
  respected
• Identifies criteria for monitoring, measurement
  and evaluation
• Opportunities for improvement

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Action Plan
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A Continual Improvement Management System
Approach to HPP Compliance
Hazard Prevention Program Regulations
Compliance Briefing CUST162740601 Slide 63
65
Summary
Gap analysis
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Summary
General Recommendations

• Short Term (lt 3 months)
• Medium (3-6 months)
• Long-Term (6 months to 1 year)

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Summary

• What are the potential barriers in your
  organization to implementing the recommendations?
• Cultural?
  Process?
• Political? Structural?
• Resources? Other?

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Summary
Create an Action Plan!
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Thank You!

• For further assistance, please contact the IAPA
  Synergration Division Office
• 1-800-406-4272
• www.iapa.ca