Accounting Finance:Occupational Health and Safety Policy Manual

Purpose Statement

uniPHARM is committed to the goal of providing, promoting, and maintaining a healthy and safe working environment, with a view to ongoing improvement. This goal is only achievable by adherence to established objectives striving to meet or exceed all obligations under applicable regulations and legislation, and by fostering a commitment to providing a safe working environment for all personnel including employees, contractors, and visitors. Occupational health and safety concerns will be incorporated into daily job duties and business decisions as appropriate.

It is acknowledged that:

• Managers and supervisors will be working in cooperation with the Safety Committee, and will strive to take all reasonable steps to reduce workplace hazards to as low as possible.
• Managers and supervisors are held accountable for the health and safety of all employees under their supervision. This includes responsibility for applicable training and instruction, appropriate follow-up on reported health and safety concerns, and implementation of recommended corrective action. This accountability is integrated into the performance appraisal system.
• Managers, supervisors, employees, and visitors are expected to perform their duties and responsibilities in a safe manner, and are accountable for the health and safety of themselves and others.
• uniPHARM is committed to providing all necessary training and instruction to ensure that appropriate work practices and safety procedures are followed on the job.
• If necessary, uniPHARM will take disciplinary action where individuals fail to work in a healthy and safe manner, or do not comply with applicable legislation or company policies and procedures.

Health, safety, and the environment of the workplace are everyone’s responsibility. uniPHARM expects that everyone will join in our efforts and dedication on a continuous day-to-day basis to succeed in providing a healthy and safe working environment.

Responsibilities

The responsibilities for workplace health and safety are specified under sections 115 to 124 of the Act. This section provides an overview of the responsibilities of the different members of the company.

Employer

uniPHARM is responsible for aspects related to hazard control and employee health and safety. In carrying out these duties, management demonstrates their commitment to health and safety in the workplace. uniPHARM is responsible for the following:

• Ensure the health and safety of uniPHARM’s employees and other employees present at the workplace.
• Provide general direction to management, supervisors, and employees about their responsibilities and roles in providing a safe and healthy workplace.
• Provide specific direction and delegate authority to those responsible for health and safety.
• Consult and cooperate with individuals carrying out occupational health and safety duties (i.e., safety committee members, first-aid attendants, etc.)
• Provide employees with the information, instruction, training, and supervision necessary to protect their health and safety.
• Provide supervisors with the support and training necessary to carry out their health and safety responsibilities.
• Provide and maintain protective equipment, devices, and clothing, and ensure that they are used.
• Identify potential hazards through regular inspections, and either eliminate or control the hazards immediately.
• Remedy any workplace conditions that are hazardous to employee health or safety.
• Encourage employees to express concerns and suggest improvements on health and safety issues.

Managers and Supervisors

Managers and supervisors should give health and safety the same priority as productivity or quality control. They must know and comply with occupational health and safety requirements. All managers and supervisors are responsible for the health and safety of the employees under their control. Managers and supervisors are responsible for the following:

• Ensure the health and safety of all employees under their direct supervision.
• Know the WorkSafeBC requirements that apply to the work being supervised and ensure that they are followed.
• Ensure that employees under their supervision are made aware of all known or reasonably foreseeable health and safety hazards where they work.
• Consult and cooperate with safety committee members or employee health and safety representatives, and cooperate with others carrying out health and safety duties (including WorkSafeBC prevention officers).
• Ensure that the appropriate personal protective equipment and clothing are available, properly worn when required, and properly inspected and maintained.
• Investigate unsafe conditions reported to them and ensure that corrective action is taken without delay.
• Be aware of all safety considerations when introducing a new process, procedure, machine, or material to the workplace.
• Conduct a safety orientation for all new employees, as well as existing employees who are learning a new role. Include the risks associated with the role. Have employees sign-off on training.
• Review all accidents and complete Incident Investigation Reports, when required, to ensure that documentation requirements are fulfilled and appropriate action is taken to prevent recurrence.
• Inspect work areas often to detect unsafe conditions and work practices. If unsafe or harmful conditions are found, remedy the issue immediately.
• Conduct monthly health and safety meetings and inspections.
• Eliminate or minimize risks to employees by implementing control measures, training and educating staff, and evaluating controls for effectiveness.
• Ensure that all employees are fit for duty. An employee must not be assigned to activities where a reported or observed impairment may create undue risk to the employee or anyone else. Consider the effects of alcohol, prescription and non-prescription drugs, and fatigue as potential sources of impairment. Substance Abuse Policy

Employees

Employees have general responsibilities for their own health and safety and that of other employees. In addition, employees have the responsibility to refuse unsafe work, and uniPHARM cannot take discriminatory action against employees for refusing to do unsafe work. Employees are responsible for the following:

• Cooperate with the safety committee or employee health and safety representative, WorkSafeBC prevention officers, and any other person carrying out occupational health and safety duties.
• Learn and follow safe work procedures, and adhere to all safety rules and regulations.
• Be alert to hazards, and report hazards or problems to the supervisor or manager.
• Perform work in a safe manner. Do not engage in horseplay or work while impaired by alcohol, drugs, or other causes.
• Refuse to do work that would create an undue hazard to the health and safety of any person.
• Never knowingly put yourself or others at risk. Encourage others to work safely and responsibly.
• Participate in inspections and investigations where applicable.
• Wear protective equipment as needed or required.
• Do not operate any machinery or equipment without receiving the proper instructions.
• Always report all injuries or symptoms immediately to your supervisor.
• Maintain equipment in good, safe working order.
• Assist in the creation of a safe work environment by recommending actions that will improve the effectiveness of the health and safety program.

Prime Contractors

In a multiple-employer workplace (where there are two or more employers working at the same time), a prime contractor should be specifically designated as a prime contractor for the purposes of the Workers Compensation Act through written agreement. If there is no written agreement, the owner is deemed to be the prime contractor. Each employer at a multi-employer workplace must designate a supervisor and inform the prime contractor of the supervisor’s name. Prime contractors are responsible for the following:

• Ensure the coordination of occupational health and safety activities of employers, employees, and other persons at the workplace.
• Establish and maintain a system or process that will ensure compliance with occupational health and safety requirements at the workplace. (Individual employers are still responsible for the health and safety of their own employees.)

Others

Suppliers of tools and equipment and directors and officers of a corporation also have responsibilities for health and safety under the Workers Compensation Act. If a person has two or more functions (i.e., employer and owner) then the person must meet the obligations of each function. For more information, see sections 120 to 124 of the Workers Compensation Act.

OHS Policy

uniPHARM’s formal OHS Policy strives to follow the Occupational Health Regulation and the Workers Compensation Act to ensure that proper work safe procedures are followed and health and safety are the top priority.

Regular Inspections

Regular inspections of the workplace are intended to:

• Identify conditions and unsafe acts with the potential to cause injury or disease
• Determine necessary corrective measures
• Prevent unsafe work conditions from developing

Three different kinds of inspections:

• Regular, planned workplace inspections: Inspect workplace, equipment, and work methods and practices for hazards that might cause injury. These inspections may be scheduled daily, weekly, or monthly to prevent unsafe conditions from developing.
• Equipment inspections: Employees should be trained to inspect their equipment regularly, following the manufacturer’s recommendations. The Occupational Health and Safety Regulation may also have specific requirements.
• Special inspections: The Occupational Health and Safety Regulation require a special inspection after a malfunction or accident to ensure that work does not resume until it is safe to do so.

Workplace Inspections

An inspection team includes employee, management, and safety committee representatives. A worksite inspection checklist must be used to ensure inspections are thorough, results are recorded, and the inspection process is standardized. The checklist assists those of the team who may be unfamiliar with the work or inspection process and is adapted to the needs of uniPHARM’s workplace.

Any unsafe or harmful conditions found during a regular inspection must be reported immediately to the supervisor or manager, and remedied without delay. Record and communicate all findings. Provide a copy for the safety committee, and post the memo on the bulletin boards to be available for all employees to see.

Safety Committee Meetings

An extensive review of health and safety activities and incident trends will be discussed during safety committee meetings. These meetings will:

• Review existing policies and procedures
• Review feedback from employees
• Consider reports and other information provided by the safety committee
• Address questions or concerns brought directly to management
• Review reports and other information about health and safety in workplaces performing similar work, as well as general information about workplace injury and disease prevention, to improve the existing OHS program

Recommendations for action from the safety committee will be considered and acted upon by:

• Developing an action plan for implementing the recommendation, or
• Suggesting an acceptable alternative

Safety committee decisions and activities on health and safety matters will be communicated to supervisors and employees.

Investigations

uniPHARM has procedures in place for investigating accidents and incidents that had the potential to cause an injury or health concerns. The purpose of an investigation is to identify the cause or causes and to recommend steps to prevent similar unsafe conditions.

What is an incident?

The Occupational Health and Safety Regulation define an incident as “an accident or other occurrence which resulted in or had the potential for causing an injury or occupational disease.” Incidents include the following:

• Accidents in which an employee is injured or killed
• Accidents in which no one is hurt but equipment or property is damaged
• Near misses (no visible injury or damage but the incident could have resulted in a serious injury, death, or property damage)
• Serious incidents you need to report to WorkSafeBC

uniPHARM has a duty to report to WorkSafeBC of any serious incidents that:

• Resulted in serious injury to an employee or the death of an employee
• Involved a major structural failure or collapse of any equipment or a hoist.
• Involved the major release of a hazardous substance
• Involved a fire or explosion that had a potential for causing serious injury to an employee

To report a serious incident, call 604-276-3100 in the Lower Mainland or 1-888-621-SAFE (7233) toll-free in B.C.

In the event of a serious incident, the scene must be secured and left undisturbed until a WorkSafeBC officer releases it (except for attending to injured employees and preventing further injuries).

Incident Investigations

uniPHARM must immediately investigate the above serious incidents as well as any incidents that:

• Resulted in injury to an employee requiring medical treatment
• Did not involve injury to an employee, or involved only minor injury not requiring medical treatment, but had a potential for causing serious injury to an employee.

Incident investigations should be carried out by persons knowledgeable about the type of work being done. Investigations will involve manager/supervisor and employee representatives and members of the safety committee. An incident investigation report will include the following information:

• The place, date, and time of the incident
• The names and job titles of persons injured in the incident
• The names of witnesses
• A brief description of the incident
• A statement of the sequence of events that led up to the incident
• Identification of any unsafe conditions, acts, or procedures that contributed to the incident
• Recommended corrective actions to prevent similar incidents
• The name of persons who investigated the incident

Sections 172 to 177 of the Workers Compensation Act outline investigation and reporting requirements.

1. If one or more employees were injured and would like to claim an injury with WorkSafeBC, please fill out:

a. Form 7: Employer's Report of Injury or Occupational Disease and send copies to WorkSafeBC or submit online.

2. Determine who will investigate the incident.

3. Conduct a preliminary investigation to identify the unsafe conditions or acts that significantly contributed to the incident, and list the recommended corrective actions.

4. Conduct a full investigation:

a. Determine the cause or causes of the incident.

b. Identify any unsafe conditions, acts, or procedures that contributed to the incident.

c. Recommend corrective action to prevent similar incidents.

5. Prepare incident investigation report.

6. Provide copy of report to the safety committee (and to WorkSafeBC if required), and post the report at the workplace.

7. Take corrective action required to prevent reoccurrence of similar incidents.

8. Prepare follow-up report on corrective action taken.

9. Provide a copy of the corrective action reports to the safety committee, and post the report in the workplace.

10. Follow up to ensure corrective action was taken and was effective at preventing the recurrence of similar incidents.

For more detailed information about the investigation process, visit: Conducting an employer investigation on WorkSafeBC.

Records

Under the Occupational Health and Safety Regulation, uniPHARM is required to keep health and safety records on file. Records will include:

• Inspections reports and records of corrective actions taken
• Incident investigation reports and records of corrective actions taken
• Employee orientation records
• Records of employee and supervisor training showing the date, names of attendees, and topics covered
• Records of meetings and crew talks at which safety issues were discussed
• Supervisors’ notes and logs of safety contacts
• Records showing use of progressive discipline to enforce safety rules and written safe work procedures
• Safety committee meeting reports showing steps taken to address health and safety issues
• Subcontractor pre-qualification documents
• Equipment logbooks and maintenance records
• First aid records, medical certificates, and hearing tests
• Forms and checklists showing requirements for safe work procedures
• Sampling and monitoring records for work around harmful substances
• Emergency response plan, record of drills, and any resulting improvements

Instruction and Supervision of Employees

uniPHARM adheres to the responsibly of ensuring that every employee receives adequate instruction to do their work safely. This is done through education and training.

The Occupational Health and Safety Regulation require orientation and training for new employees. See the resource Support for Employers: Training and Orientation for Young and New Workers for more information.

An education and training record should be maintained for each employee, listing topics covered and date of education and training. Education and training records should be reviewed periodically to ensure that training requirements have been met.

Supervisors must supervise their employees to ensure that they follow safe work procedures. Adequate supervision includes:

• Ensuring proper training of employees
• Observing employees after training to ensure that they continue to following safe work procedures
• Making informal inspections on a daily basis to ensure safe work procedures are being followed, including the proper use of protective equipment, devices, and clothing provided
• Enforcing safety rules and safe work procedures
• Conducting informal discussions with employees to discuss specific safety issues as they arise

The following are some examples of education and training topics:

Safety Committee

The safety committee is required under sections 125 to 140 of the Workers Compensation Act and is made up of manager, supervisor, and employee representatives. The main purpose of the committee is to work together to identify any health and safety issues and make recommendations to uniPHARM on how to solve them. The committee advises the company on the OHS program and any other required programs and monitors their effectiveness while complying with the Act and the Regulation. To be successful, the committee must operate in an atmosphere of cooperation and commitment to health and safety in the workplace. Committee meetings are to be held at least once a month.

Duties

The Workers Compensation Act sets out the following duties and functions of the safety committee:

• To identify situations that may be unhealthy or unsafe for employees and advise on effective systems for responding to those situations
• To consider and expeditiously deal with complaints relating to health and safety of employees
• To consult with employees and uniPHARM on issues related to occupational health and safety and occupational environment
• To make recommendations to uniPHARM and the employees for the improvement of the occupational health, safety, and environment of employees
• To make recommendations to uniPHARM on educational programs promoting the health and safety of employees and compliance with the Workers Compensation Act and the Occupational Health and Safety Regulation and to monitor their effectiveness
• To advise uniPHARM on programs and policies required and to monitor their effectiveness
• To advise uniPHARM on proposed changes to the workplace or the work processes that may affect the health or safety of employees
• To ensure that accident investigations and regular inspections are carried out as required
• To participate in inspections, investigations, and inquiries
• To carry out any other duties and functions prescribed by regulation

Membership

A safety committee must have:

• At least four members
• Both employee and employer representatives; at least half of the members must be employee representatives
• Two co-chairs, one selected by the employee representatives and the other by the employer representatives

Committee members should be chosen for their ability to get the job done, their knowledge of various work processes, and ability to work cooperatively with others. There is no specific requirement for how long members serve on a committee. The committee should consider a term that will keep up enthusiasm, encourage fresh ideas, and promote efficiency through continuity.

uniPHARM must post the names and work locations of committee members at the workplace

Employer representatives

uniPHARM must select representatives from those who exercise managerial functions for the employer at the workplace. An individual employer can act as an employer representative.

It is important that employer representatives have the authority to make commitments and to speak on behalf of the employer at committee meetings. Since the committee itself does not have the power to act on its own recommendations, the committee depends on the authority of the employer representatives to finalize matters agreed upon at a meeting.

Employee representatives

Employees must select representatives from employees who do not exercise managerial functions at the workplace. The employee representative must attend all safety meetings, participate in inspections and incident investigations, influence others to work safely, and recommend measures to correct unsafe conditions.

The employer and employee representatives selected to be co-chairs will have monthly responsibilities given to go over any health and safety concerns or issues in the workplace.

Education and Training

All new safety committee members are required to receive training and instruction from the chair person on the following topics:

• The duties and functions of a safety committee
• The rules of procedure of the safety committee
• The requirements around conducting incident investigations
• The requirements around conducting regular workplace inspections
• The requirements around responding to a refusal of unsafe work
• The requirements for annually evaluating the safety committee

Each member of a safety committee is also entitled to an annual educational leave totalling eight hours to attend OHS training courses.

In addition, it is good practice to set aside part of every meeting for education. Members with certain expertise can prepare and deliver a talk, suppliers can be invited to discuss equipment and materials, and professionals from outside organizations can also be included. Members can be sent to seminars and report findings and new knowledge back to the committee.

Committee and Program Support

The regular meeting should not be the only time when members concern themselves with the OHS program. Not all safety-related problems can wait until the next meeting for resolution.

Outside the regular meeting, members should monitor ongoing health and safety procedures. Hazards can be identified and recommendations made to employees, supervisors, and managers that will improve conditions. Committee members are in a good position to promote cooperation throughout the operation.

In addition to the regular meeting, members may be required to:

• Deal with complaints relating to health and safety
• Advise uniPHARM on programs and monitor their effectiveness
• Participate in workplace inspections
• Participate in investigations of accidents or incidents

Employee complaints

Employees should be instructed that complaints concerning health and safety should be directed to their supervisor. However, if the situation is not handled to the employee’s satisfaction, a committee member should be contacted. The member can work with the supervisor and the committee, if needed, to resolve the complaint. It is important to keep the employee informed of the disposition of the matter. The safety committee must not be used as a grievance committee.

Monitoring program effectiveness

uniPHARM has a number of health and safety programs in addition to the formal OHS program, including a WHMIS program, Good Manufacturing Practice (GMP) and an emergency evacuation plan. uniPHARM is required to consult with safety committees on the development, maintenance, and review of many of these programs. Programs will be reviewed at least annually to ensure that they are effective and to consider changes in the workplace and work activities. Furthermore, all certifications (i.e., first-aid, forklift) must be monitored and in good standing.

An Effective Committee

Section 3.26 of the Occupational Health and Safety Regulation requires safety committees to conduct an annual evaluation of their effectiveness.

The effectiveness and credibility of both the committee and uniPHARM depend on results. The committee itself is only an advisory body, making recommendations to the company. The company may accept the committee’s recommendation or may give reasons for not accepting them. The committee should communicate the results of recommendations to employees along with any explanations.

Committee members should not attempt to bypass normal channels of supervision or control. Health and safety are part of the job and should be dealt with on the job. Reporting hazardous conditions and procedures and taking corrective action is a matter for immediate attention through normal channels. Do not wait until the next meeting.

Forms and Checklists

Fire Safety Plan & Fire Drill Evaluation and Evacuation

• Fire Safety Plan
• Fire Drill Checklist
• Fire Drill Floor Plan

Emergency Checklist & Procedure

• Monthly Team Checklist
• Evacuation Procedure

Employee Training Checklist

• New Employee Orientation Checklist
• Employee Orientation Checklist

Inspection Checklists

• Monthly Department Meeting
• Annual Inspection Checklist
• Monthly Inspection Checklist
• Forklift Checklist
• Forklift Lock-up/Batter Change

Forms & Other Checklists

• WHIMIS Training Checklist
• Good Manufacturing Practice (GMP)
• First Aid Attendant List
• Inspection Report
• Supervisor Training Checklist
• Distribution Centre Inspection Checklists
• Storage Rack Checklist

Important Links

• The Occupational Health and Safety Regulation
• Workers Compensation Act
• Substance Abuse Policy
• WorkSafeBC