Module 3 - How to incorporate health and safety into your management style

Supervisors of projects or in workspaces shall conduct a hazard identification and risk assessment (HIRA) at the start of a project, as well as throughout a project following significant changes to identify, evaluate, and mitigate potential hazards and risks. The assessment ensures that users conduct proper project and workspace planning and become aware of potential hazards.

A competent person or team that has good knowledge about the hazards assessed, situations that are likely to occur, and protective measures to control hazards and risks should carry out the hazard identification.

These assessments must be documented. Refer to module 4 for additional information.

You will recall that management has the greatest level of responsibility for ensuring a healthy and safe workplace, and inspections are important in order to identify hazards and observe processes. Management (especially individual supervisors) must continually look for hazards and take appropriate action to control those hazards. These inspections may be conducted by management personnel themselves or by persons acting on behalf of management, such as a facility manager or a health, safety, and risk manager. These are called “management inspections”.

During the Worker Health and Safety Awareness workshop, we introduced the idea of the Joint Health and Safety Committee (JHSC). Comprised of persons representing workers, unions, associations, and management, these committees work together to identify sources of danger inadvertently overlooked by management. Much like management personnel, the committees also conduct inspections. Under Ontario law, the physical condition of the workplace must be inspected at least once per year, with a part of the workplace inspected every month. The physical size of the University makes this a large and important task, given the diversity of operations and the hazards that exist every day. A JHSC Inspector assists the committee in meeting this goal. These are “joint health and safety committee inspections”.

These processes, while similar, are distinct and not concurrent. The JHSC inspectors are acting on behalf of the committee, not management. It is critical to understand the nuanced difference. JHSC inspectors are representing the committee, not management. The JHSC inspectors are not responsible for “approving” or “guiding” management representatives. The extent of the JHSC committee inspections – regardless of whether they are performed by the JHSC committee or the JHSC inspector – is to identify sources of danger and make a recommendation to eliminate or control the hazard. Management maintains their primary responsibility for day-to-day health and safety of the workplace.

What kind of inspection am I doing?

No matter the type of inspection, it is critical that those conducting the inspection document their findings and the action taken. Where a situation is observed that cannot be resolved by a manager or supervisor,  it is incumbent on those conducting the inspection to escalate the matter to the next level of authority.

Lastly, it is important to understand that management and those acting on management’s behalf are responsible for workplace health and safety. There are workplace safety advocates internal to the uOttawa workplace, and that includes the JHSCs, but the primary responsibility lies with management.

It is important to note that “accidents” are not random events, but rather preventable occurrences. All occurrences must be promptly and thoroughly investigated – regardless of their severity – and corrective measures must be instituted, where applicable. Despite the best efforts of everyone, sometimes things can happen that may result in an injury or an illness. This is where a manager or supervisor has the duty to investigate the incident (with support from the available resources). The purpose of an incident investigation is to address and correct situations in the workplace that have caused injury or property damage, or had the potential to do so. To be a useful exercise, the investigation must establish the root cause of the incident.

An investigation should focus on finding facts rather than finding fault. This is not to say that investigators should not assign responsibility when failure, action, or inaction has caused injury, or that individuals should not be held accountable for their actions or inactions. Rather, the incident investigation itself should be primarily concerned with finding factual information on what led to, or contributed to, the incident. If further actions are required, such as sanctions or disciplinary action, these actions should be conducted outside the incident investigation process and should be conducted in accordance with the uOttawa policies, procedures, and collective agreement(s) governing the work.

Further reasons for conducting an incident investigation include:

• Determining the underlying and root cause(s) of the incident;
• Correcting and/or preventing similar incidents in the future;
• Determining the direct and indirect cost(s) associated with the incident;
• Building a positive health and safety culture;
• Processing worker compensation claims; and
• Fulfilling legal and organizational responsibilities.

If an incident does occur, it is important to note that there is rarely a single cause that yields a single outcome. It is likely that there are multiple factors contributing to an incident, which in turn, produce multiple different outcomes. In some cases, the outcomes can be neutral or, in rare cases, even desirable. Causes may be classified into categories including material, environment, personnel, management, and task.

The direct cause of the incident needs to be identified and corrected; but why did the direct cause exist? The investigation should extend beyond the obvious and into more tangentially related causes. For example, if an investigation concludes that an incident was due to the “carelessness of a worker”, how can a supervisor correct “carelessness” in a reasonable fashion? In this case, the investigation has failed to obtain answers to subsequent questions, such as:

• Why was the worker “careless”?
• Was the worker distracted? If so, why?
• Was a safe work procedure in place? Was it being followed? If not, why?
• Were the protective devices and equipment in order and/or used? If not, why?
• Was the worker trained? If not, why?

An investigation that pursues these types of questions – i.e. those questions that remain following the identification of a direct cause – is likely to reveal conditions that are more reasonably correctable than attempts on the part of the supervisor (and by extension, uOttawa) to prevent "carelessness of a worker". As the depth of the investigation progresses, it is likely that systemic and organizational issues are at the root of the incident.

Lastly, it is critical to document the:

• Incident cause(s);
• Corrective action(s);
• New hazards and/or risks related to the modification or institution of corrective measures;
• The effectiveness of corrective action(s);
• Any management of change processes.

The deeper the investigation goes, the greater the likelihood of system issues that require fundamental action.

This documented record should be made available to those involved, including support services at uOttawa (e.g. Health, Safety and Risk Managers, Office of the Chief Risk Officer, Joint Occupational Health and Safety Committee, etc.). 

The University has established various incident management programs, including the Hazard Reporting procedure (PDF, 2.5MB) and Supervisor Incident Investigation program (PDF, 401KB). These resources provide tools to assist the University community in executing their individual responsibilities. Workers, managers, and supervisors should consult these programs as needed to reinforce the duties of all workplace parties within the internal responsibility system.

Emergency response organizations, such as the Ottawa Police Service, the Ottawa Fire Department, and the Ottawa Paramedic Service, are only a supplement to the emergency response process. To rely on these organizations exclusively is a recipe for unnecessary injury and property damage. If something goes wrong in the workplace, a procedure for de-escalation and initial action is needed well before any civil authority is able to attend the scene. Benjamin Franklin is credited with coining the phrase “if you fail to plan, you are planning to fail” and when it comes to an emergency, that failure can result in injury, illness, damage, or death.

While the Emergency Management team has general procedures for emergencies, the manager or supervisor needs to be ready with specific instructions for their workplace that users can implement before a situation spirals out of control. Early actions can greatly reduce or mitigate an emergency. For example, what does a lab or workshop group do in the event of an audible alarm from atmospheric sensors indicating the presence of a hazardous substance? The early intervention by an alert lab user will surely avoid larger consequences. A template for response to an atmospheric sensors (PDF, 2.12MB) is available online. Managers and supervisors are required to evaluate their operations and create emergency procedures. Resources are available through the faculty’s Health, Safety and Risk Manager.