Preparing for interactions with the MOL: Workplace visits
I’ll skip the opening comments from the Minister and Deputy Minister to concentrate on the meat and potatoes of the report, and what it may mean to us and how we can be prepared for interactions with the MOL. Advance warning … some stats are going to be previewed so you get a clear picture of the why’s and wherefores’ of MOL activity and how we can work together to resolve these issues.
The report highlights a compliance strategy which includes of the following activities:
- stakeholder engagement to help shape Ontario’s occupational health and safety compliance strategy.
- annual sector enforcement plans.
- blitzes and initiatives conducted by occupational health and safety inspectors in workplaces based on the annual enforcement plans.
- other proactive visits that focus on key hazards in the workplace.
- public reporting of blitz and initiative results on our website and in our annual report.
A part of the compliance strategy are proactive and reactive workplace visits
Proactive visits are unannounced inspections conducted to:
- monitor compliance with occupational health and safety legislation.
- promote the Internal Responsibility System (IRS).
- advise workplace parties of their rights, duties and responsibilities.
- discuss requirements of the occupational health and safety legislation.
Reactive visits are inspections conducted to:
- Investigate a fatality, critical injury, work refusal, complaint, occupational disease or other health and safety related event in the workplace.
In 2015-16, ministry inspectors made a total of 74,795 visits to 34,284 workplaces and issued 127,088 orders.
Procative and reactive visits resulted in the following MOL workplace activities
|Proactive Inspector Activities||Reactive Inspector Activities|
|Field Visit Activities||41,976||Orders Issued||42,987|
|Orders issued||84,101||Stop Work Orders Issued||2, 777|
|Stop Work Orders||4,319|
Each year, a series of proactive health and safety compliance and enforcement activities target certain hazards in workplaces within each sector. To identify the hazards and the workplaces to target, the ministry uses a risk-based process that takes into account: advice from stakeholders, injury and fatality rates and incidents (WSIB), the nature of the work (i.e. inherent hazards), the vulnerability of the workers and the sector’s compliance history.
The sector-specific plans identify priorities for proactive visits. They also identify the focuses for initiatives (which occur throughout the year) and blitzes (which occur over a short set period of time, usually between one to four months). The dates of all blitzes are posted in advance so employers have the opportunity to assess their own compliance and prepare before the inspectors come.
Inspectors involved in proactive compliance and enforcement activities visit workplaces, provide education, conduct inspections and issue orders. The goals are to:
- raise awareness of hazards.
- increase workplace compliance with the Occupational Health and Safety Act and its regulations.
- prevent worker injuries and illness.
In 2015-16, the MOL conducted blitzes and enforcement initiatives to support compliance strategy. These blitzes and initiatives targeted young workers, construction, industrial, chemical and health care industries.
The MOL has advised it will be focusing on the following areas during the upcoming summer months:
- Orientation, training and supervision
- Safety measures and procedures
- Minimum age
In addition, the MOL will maintain its ongoing sector specific workplace blitzes.
Preparing for a visit from a MOL inspector
Ok, so enough of the stats. How do we prepare for a visit form a MOL inspector? The easiest and best way is to be prepared for the visit. Employers can no longer simply go merrily along and not put in place plans and programs to ensure the safety of all their employees. Remember, it is not “if and Inspector will walk through the door, It is when”. It will happen!
Based on this reality there are things you can do. I hope the following suggestion will help.
|Basic. Once an employee is hired.||Complete initial orientation and training. WHMIS 2015 Generic and Site Specific Training is a must as is training related to any Personal Protective Equipment (PPE) they will use at work. Training on any tools or equipment they will use should be done before they use them.|
|Specific training||Any training required based on the work to be done. Such as Forklift Training, Hoist Training, Pneumatic powered equipment, cookers, and tools.|
|Specific procedures||This can include issues such as Confined Space Safety, Lock Out Tag Out Safety, Arc Flash Training, anything specific to the job they are expected to complete.|
|H&S representative or committee||Committee by-laws, meetings, posting of information, role and responsibility.
How to make recommendations.
Workplace Inspection schedule and reporting.
These issues may seem daunting, but they will loom larger than life and very costly should a MOL inspector find you are not providing your employees with needed safety information and training. It gets worse, if an employee is hurt and there is no safety program in place.
As an employer we have a responsibility to ensure our employees are aware of their workplace and prepared to deal with issues in the workplace.
Work safe. Your kids rely on you.
Michael Dougherty, CRSP
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