This is the first summer that Ontario employers have new liability and responsibility to summer students who are with them in unpaid co-op or internships. The Occupational Health and Safety Act coverage expanded to unpaid co-op students and learners in work placements, effective November 20, 2014.
For employers, this means that unpaid summer co-op students should be subject to the same training, orientation, supervision and safety requirements as paid young workers in the workplace. While some employers might see summer students as a quick fix to cover for vacations and to complete extra projects, employers who commit to the safety and supervision of all students, both paid and unpaid will have more successful short-term and long-term outcomes in their organization.
1. Safety requirements
Occupational Health and Safety basic awareness training
This is now the second summer that the mandatory basic health and safety awareness training for employees is applicable to summer students. This now applies to both paid and unpaid co-op students. Students must complete a ministry approved training that includes some form of evaluation. The health and safety awareness training is available online through the Ministry of Labour website and students are able to print of a certificate of training completion.
Workplace violence and harassment training
Students must be made aware of your organization’s policies and procedures around workplace violence and harassment. Specific hazards to your workplace should be identified, including the method of reporting.
Young workers
The Ministry of Labour highlights that young workers are more vulnerable than experienced or older workers. This means that training sessions may need to be tailored specifically to young workers who don’t have a basic level of “common sense” that might be expected from an older or experienced worker. Common sense at work, related to job specific tasks, is actually a highly transferable skill based on training and experience. Basic hazards may need to be outlined, procedures may need to be broken in to steps, reasons for wearing personal protective equipment (PPE) should be made explicit and safety rules may need to be explained and enforced.
Industry and job specific orientation
Depending on the work environment, specific safety training such as working at heights, for example may need to be addressed. It helps to have written reminders, stickers and signs on any equipment that has specific operating requirements. Having a checklist that gets signed off by both the supervisor and the student is also a best practice.
2. Supervision requirements
As an employer, you need to remind your supervisors that they are responsible for the health and safety of the young workers in their department. Each supervisor must have completed both the Occupational Health and Safety Basic awareness and the supervisor level training. Supervisors need to lead by example, by wearing PPE’s and following safety procedures. They also need to encourage questions and prompt reporting of unsafe or hazardous conditions. It also falls to supervisors to enforce the health and safety rules for the protection of the more inexperienced workers. As supervisors they have the experience to know the potentially serious consequences of a behavior a student might think is insignificant. Students should never be allowed to choose to work in a manner that is unsafe. Their choice is to follow the rules and work safely or to be disciplined or sent home. Supervisors and employers have legal responsibilities for their workers.
When providing student workers with on the job training, best practice is to pair them up with an experienced, safety conscious worker who has good communication skills. It is also a best practice to show new workers to the location of health and safety information, and hazard reporting forms and to introduce them to members or representatives of the Joint Health and Safety Committee.
Health and safety is increasingly focused on wellness, mental health and stress in the workplace. Employers need to ensure open lines of communication between the student and the supervisor, and provide an alternative contact such as human resources, for students to talk to about any concerns. Ensure that your supervisors and your hiring managers are familiar with the duty to accommodate regulations for employees contained in both the AODA and in the Human Rights Code.
3. Summer student success
A commitment to summer student supervision and safety in the workplace goes a long way to the successful development of both your own organizational safety culture and your long-term recruitment pipeline. Early work experiences are highly impactful to students – and it is the negative experiences that tend to go viral! Supporting summer students with good supervision and safe practices ensures your employment brand reputation doesn’t get smeared!
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