Archived - Audit of the INAC Occupational Health and Safety Management Control Framework
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Date: September 2009
PDF Version (403 Kb, 77 Pages)
Table of Contents
- Initialisms and Abbreviations
- Executive Summary
- 1.0 Statement of Assurance
- 2.0 Background
- 3.0 Objectives
- 4.0 Scope
- 5.0 Approach
- 6.0 Conclusion
- 7.0 Observations and Recommendations
- 8.0 Recommendations
- 9.0 Management Action Plan
- Appendix 1 - Consolidated List of Audit Criteria
- Appendix 2 - E-mailed Surveys
- Appendix 3 - Documentation Reviewed
- Appendix 4a - OHS Program Documents and Records
- Appendix 4b - Detail Findings of Compliance to Program Documents and Records
Initialisms and Abbreviations
AES | Audit and Evaluation Sector |
---|---|
CLC-II | Canada Labour Code Part II |
CSP | Contaminated Sites Program |
DG | Director General |
EHS | Environmental Health and Safety |
HRSDC | Human Resources and Skills Development Canada |
HRWSB | Human Resources and Workplace Services Branch |
HS | Health and Safety |
IIA | Institute of Internal Auditors |
INAC | Indian and Northern Affairs Canada |
NCSP | Northern Contaminated Sites Program |
OHS | Occupational Health and Safety |
PWGSC | Public Works and Government Services Canada |
RDG | Regional Director General |
SOHS | Security and Occupational Health and Safety Division |
TB | Treasury Board Secretariat |
Executive Summary
At the request of Indian and Northern Affairs Canada's ("INAC") Director of Security, Occupational Safety and Health, an audit of Occupational Health and Safety ("OHS") at INAC was conducted between January and May 2009 to provide information that would support OHS priority setting and planning processes. Upon the recommendation of the Chief Audit and Evaluation Executive, the request was considered and approved by the Audit Committee as an addition to the 2008-09 Risk-Based Audit Plan.
The audit objectives were to evaluate the adequacy of INAC's OHS Management Control Framework, assess compliance with selected OHS requirements contained in the Canada Labour Code Part II ("CLC-II") and the Treasury Board Secretariat ("TB") OHS Directive, and to identify best practices.
The scope of the audit included an assessment of (1) management and employee awareness of, and compliance with, duties specified in the INAC OHS Statement of Roles and Responsibilities; (2) the existence and sufficiency of OHS program documentation required by law or TB; (3) the sufficiency of actions taken by management for protection of employees performing specific hazardous work activities carried out in INAC; (4) the existence and functioning of OHS committees, representatives, and advisors across INAC; and (5) compliance with the program documentation and activity record keeping requirements of the Contaminated Sites Program ("CSP"), at Headquarters and in the selected Regions.
Audit criteria were derived from select requirements set out in the INAC Statement of Roles and Responsibilities, CLC-II, Canada Occupational Health and Safety Regulations, TB OHS Directives, and the EHS Management Systems Manual – Edition 2 – March 2008. Data collection was conducted via telephone interviews, a written request for documentation and e-mail surveys. Some audit criteria were assessed on a population basis while others were assessed on a sample basis.
The audit found that the OHS Management Control Framework, while sound in design, is essentially non-operational in practice. There is an overall low level of compliance with the CLC-II and TB requirements relating to OHS program documents and records, and to the functioning of Health and Safety Representatives and Workplace and Regional Health and Safety Committees. Reasons for the low level of compliance include a generalized lack of knowledge of internal OHS requirements and regulations, insufficient resources to carry out prescribed tasks, and an absence of procedures and systems to carry out OHS related activities.
The current state of affairs potentially exposes the Department to OHS charges for non-compliance, Criminal prosecutions in the event of a serious injury or death, exposes employees to potentially harmful risks in the course of their work, and other impacts that have been described in this report.
Ten recommendations are provided to address current conditions and the underlying causes of identified deficiencies.
On the basis of the audit findings, no assurance can be provided to support the fact that INAC's Occupational Health and Safety Management Control Framework is adequate. Assurances also cannot be provided to support the fact that controls either ensure compliance with the OHS Directive of the Treasury Board Secretariat ("TB"), or ensure that INAC OHS policies, procedures and responsibilities are communicated, documented and understood.
1.0 Statement of Assurance
The audit of Indian and Northern Affairs Canada's ("INAC") Occupational Health and Safety ("OHS") Management Control Framework was conducted in accordance with the auditing standards specified by the INAC Internal Audit Manual, Version 1, dated April 25, 2008 and the Treasury Board of Canada's Policy on Internal Audit.
The objectives of the audit were to (1) provide reasonable assurance on the adequacy of INAC's OHS Management Control Framework; (2) provide reasonable assurance on the adequacy and effectiveness of controls for ensuring that the OHS Directive of the Treasury Board Secretariat ("TB") is complied with, and that INAC OHS policies, procedures and responsibilities are communicated, documented and understood; and (3) identify, where possible, potential OHS best practices for implementation within the department.
The audit evaluated management and employee awareness of, and compliance with, duties specified in the INAC OHS Statement of Roles and Responsibilities, on an INAC-wide basis (i.e. across all programs, sectors and regions); the existence and sufficiency of OHS program documentation required by law or Treasury Board, on an INAC-wide basis; the sufficiency of actions taken by management for protection of employees performing specific hazardous work activities carried out in INAC; the existence and functioning of OHS committees, representatives, and advisors across INAC; and compliance with the program documentation and activity record keeping requirements of the CSP Contaminated Sites Program, at headquarters and in the relevant Regions.
The audit was conducted in accordance with INAC's Internal Audit Manual (April 2008) with an amount of rigor and due professional care necessary for the provision of a reasonable level of assurance, as envisioned in the TB Policy on Internal Audit and related directives and in the Institute of Internal Auditors (IIA) International Standards for the Professional Practice of Internal Auditing (the IIA Standards).
The audit procedures developed were sufficient to gather evidence to support the accuracy of the conclusions reached and contained in this report. The conclusions were based on the information that existed at the time of the audit and are only applicable for the areas audited.
2.0 Background
INAC and its personnel are subject to OHS requirements contained in the Canada Labour Code Part II and regulations, and the Treasury Board Secretariat OHS Directive. These OHS requirements are broad in scope, and include specific management practices, document production and record-keeping, information collection and reporting, monitoring and evaluation activities, work practices, equipment and facility requirements, organizational structures and systems, investigation and review procedures, committee structures and functions, training and instruction, ect.
Contraventions of OHS requirements can have impacts ranging from the insignificant to the catastrophic, depending primarily upon the degree of harm to persons associated with the contravention. Legal consequences can include prosecution of the Department and its personnel under the Canada Labour Code and the Criminal Code, as well as exposure to civil liability in certain circumstances.
INAC has created a documented entitled "INAC OHS Statement of Roles and Responsibilities", which assigns a large number of specific OHS responsibilities to personnel across a variety of job functions and ranks at INAC [Note 1]. The Statement gives all INAC employees in all Programs and Regions certain basic OHS responsibilities, and gives a variety of more complex responsibilities to personnel with supervisory, managerial and executive roles. There are also specific additional responsibilities assigned to health and safety committees and representatives and health and safety staff specialists. The ultimate intent of this "Statement" is to provide guidance to employees in performance of activities that will ensure compliance and protection of personnel in the performance of work.
INAC has also established a Security and OHS Directorate, located at the Gatineau corporate office, which has been assigned a variety of program development, administration and monitoring functions via the OHS Statement of Roles and Responsibilities.
INAC has established a number of Workplace Health and Safety ("HS") Committees, and a Policy HS Committee. These Committees have statutory and regulatory functions, and additional functions as defined in the INAC OHS Statement of Roles and Responsibilities.
INAC manages and delivers a variety of programs. One program that has the potential to be particularly hazardous is the Northern Contaminated Sites Program ("NCSP"), which is mandated to remediate contaminated properties in the North. This Program has established an EHS Management Manual that prescribes a variety of supplementary health and safety roles, responsibilities and actions to be taken by specific corporate and regional personnel within the NCSP to ensure protection of personnel in field work settings and at contaminated sites.
At the request of the INAC Director of Security, Occupational Safety and Health, an audit of OHS was initiated by INAC's Audit and Evaluation Sector in order to characterize current conditions in the Department and provide information for OHS priority setting and planning purposes.
3.0 Objectives
The objectives of the audit were to:
- Provide reasonable assurance on the adequacy of INAC's OHS Management Control Framework.
- At selected INAC sites, provide reasonable assurance on the adequacy and effectiveness of controls for ensuring that
- the OHS Directive of the Treasury Board Secretariat ("TB") is complied with,
- and INAC OHS policies, procedures and responsibilities are
- communicated
- documented and
- understood
- Identify, where possible, potential OHS best practices for implementation within the department.
4.0 Scope
The scope of the audit included:
(1) Management awareness of, and compliance with empirically-measurable duties specified in the INAC OHS Statement of Roles and Responsibilities, on an INAC-wide basis (i.e. across all programs, sectors and regions), with the target groups being principally Directors General, Directors, Managers and Supervisors.
(2) Existence and sufficiency of OHS program documentation required by law or Treasury Board, on an INAC-wide basis.
(3) Sufficiency of actions taken by management for protection of employees performing some of the more hazardous work activities carried out in INAC, such as: work at construction or remediation sites; work in wilderness areas; travel by small airplane, helicopter, snow mobile, or small boat; and work in isolated areas where assistance could not readily be provided in emergency situations.
(4) Existence of OHS committees, representatives, and advisors, in all INAC workplaces where required by law or the INAC OHS Statement of Roles and Responsibilities; and extent to which the activities of committees, representatives and advisors comply with legislated functions, Treasury Board directives, and the INAC OHS Statement of Roles and Responsibilities. This was assessed on an INAC-wide basis.
(5) Compliance with the program documentation and activity record keeping requirements of the Contaminated Sites Program ("CSP"), at corporate and regional offices; and for a sample of site remediation projects, compliance with project safety management requirements specified in the CSP EHS Management Systems Manual.
The following were excluded from the audit scope:
(1) Management duties specified in the INAC OHS Statement of Roles and Responsibilities that are either (i) not operationally defined, or (ii) not empirically measurable, or (iii) for which measurement would not yield unequivocal findings, or (iv) for which the execution of the duty would be "need dependant", and the extent of need could not be fairly assessed in the audit.
(2) Employee duties specified in law, Treasury Board directives, or in the INAC OHS Statement of Roles and Responsibilities. These duties are substantially limited to self-protection, compliance with employer instructions, and hazard reporting, and are not considered to be OHS "management controls".
(3) Direct assessment of compliance at workplaces with specific work practice, facility-related, and equipment-related standards (this was excluded by the audit terms of reference prepared by the Audit and Evaluation Sector).
The audit covered activities and documentation between January 1st 2008, and May 2009. Sufficient investigations and evaluations were conducted to provide a representative portrayal of conditions.
5.0 Approach
5.1 Audit Criteria
Audit criteria were derived directly from requirements specified by:
(1) The INAC OHS Statement of Roles and Responsibilities.
(2) Sections 134.1 through 137 of the Canada Labour Code Part II (pertaining to Policy HS Committees, Workplace HS Committees, and HS Representatives), the Health and Safety Committees Regulation made under the Canada Labour Code Part II, and portions of the Treasury Board OSH Directive pertaining to Policy HS Committees, Workplace HS Committees, and HS Representatives.
(3) Employer duties pertaining to preparation and maintenance of OHS program documentation, contained in the Canada Labour Code Part II, the Canada Occupational Health and Safety Regulations, and the Treasury Board OHS Directive.
(4) OHS program document and record production and maintenance duties of INAC corporate EHS staff, regional EHS staff, and contaminated sites project managers, as set out in the Contaminated Sites Program EHS Management Systems Manual – Edition 2 – March 2008.
The requirements contained in the following documents were also considered for purposes of formulating audit criteria, and were deemed suitable:
- TB Occupational Health and Safety Policy
- TB Manager's Handbook – Canada Labour Code Part II
However, these documents contained no requirements that would result in any additional criteria beyond those referenced in (1), (2) and (3) above.
The requirements contained in the following documents would require "direct assessment of compliance at workplaces", and were excluded:
- TB Smoking in the Workplace Policy 1-01
- TB Motor Vehicle Operations Directive - Chapter 2-11
- TB Occupational Health Evaluation Standard
- TB Procedures for Liaison with Private Contractors
- TB Safety Guide for Field Operations - Chapter 5-4
- TB Safety Guide for Operations Over Ice
- TB Employees Working Alone - Chapter 6-1
- TB Occupational Exposure to Sunlight - Chapter 6-5
- TB Effects of Extreme Cold - Chapter 6-3
The consolidated listing of audit criteria is presented in Appendix 1. The listing also shows sources for all criteria.
5.2 Methodology
Audit conduct consisted of data collection and analysis activities in relation to four areas:
1 - Compliance with Requirements of the INAC OHS Roles and Responsibilities Statement Pertaining to OHS Management Controls
- The "Statement" assigns approximately 100 responsibilities to 17 parties (staff, committees). Management awareness of, and compliance with empirically-measurable duties specified in the INAC OHS Statement of Roles and Responsibilities was evaluated on an INAC-wide basis (i.e. across all programs, sectors and regions), with the target groups being Directors General, Directors, Managers, Supervisors, HS Committees and Representatives, and Human Resources Advisors with labour portfolio responsibilities.
2 - Compliance with Canada Labour Code Part II ("CLC-II") and TB Requirements Respecting the Existence of Prescribed Policies, Procedures, Programs, Reports and Records pertaining to OHS Management Controls
- The Canada Labour Code Part II ("CLC-II") and the TB OHS Directive require the Department to maintain a variety of specific documents, which can be broadly characterized as OHS Program Documents and OHS Activity Records. Information used to determine compliance with these requirements was gathered via interviews with, and document submissions from, both Regional and Corporate human resources and HS personnel, HS representatives and HS committee co-chairs.
3 - Compliance with CLC-II and TB Requirements Respecting Establishment and Operation of Policy and Workplace HS Committees
- Under CLC-II, 24 INAC work locations require HS representatives, but only 14 locations were in compliance. Nine HS Representatives were selected for this audit and seven were successfully interviewed.
- CLC-II also prescribes one Workplace Health and Safety Committee for each workplace with 20 or more employees. Using this criterion, INAC should have a total of 35 Committees. Of the locations requiring Committees, seven Committees were successfully audited.
4 - Compliance with Requirements of the INAC Contaminated Sites Program – EHS Management Manual – Edition 2 – March 2008
- The audit evaluated the existence and content of all HS program documents and activity records required in the Manual, by asking the CSP Corporate EHS Section and key management personnel in the Regions to provide those documents and records.
Audit forms and checklists used for audit activities are presented in the following Appendices:
- E-mailed surveys – Appendix 2
- Documentation reviewed – Appendix 3
Some audit criteria were assessed on a population-basis (e.g. all HS Representatives, all HS Committee Co-Chairs, all OHS corporate program documents, existence of OHS committees at all workplaces where required), while others were assessed on a sample basis (e.g. compliance with responsibilities by certain groups of senior managers, adequacy of protective measures for a sample of employees performing specific high-hazard work operations, compliance with CSP EHS Management System requirements for a sample of remediation projects in the relevant regions).
Entire populations were reviewed where the size of the sample frame was small and all members of the population could be easily assessed, and sampling was used where the sample frames were too large to conduct a census of the entire population.
Audit planning and conduct was performed between February 3rd, 2009 and May 20th, 2009.
6.0 Conclusions
6.1 Objective 1: Adequacy of INAC's Occupational Health and Safety ("OHS") Management Control Framework
The design of INAC's OHS Management Control Framework is generally sound but there is a need for the preparation of additional management and operational procedures to provide specific instruction to personnel on how to perform more complex OHS functions and to incorporate explicit OHS objective setting and planning.
The degree of implementation of the OHS Management Control Framework is very low. As a result, there are many OHS statutory and regulatory requirements and TB OHS requirements that the Department has not complied with.
6.2 Objective 2: At specific INAC sites, provide reasonable assurance on the adequacy and effectiveness of controls
There are not adequate or effective controls in any Region or Program to ensure compliance with the TB OHS Directive and the level of compliance with most requirements is very low.
INAC OHS policies, procedures and responsibilities have not been effectively communicated to, and are poorly understood by, personnel at all levels of the organization, and in all Regions and Programs. Most of the requisite OHS documents and activity records are not being produced or maintained.
6.3 Objective 3: Identify, where possible, potential OHS best practices for implementation within the department
No OHS practices were identified that could be considered "best practices" for implementation throughout the Department.
6.4 Implications
Health and safety is not adequately managed or controlled in any of the Regions or Programs within the Department. This state of affairs has several potential consequences:
- It exposes the Department to the potential for orders and charges under the Canada Labour Code Part II.
- It renders it difficult for the Department to demonstrate due diligence in the event of a mishap.
- It may result in some employees being exposed to unacceptable health and safety risks in the performance of their work.
- It creates the potential for adverse publicity.
- It could expose Departmental managers to risk of Criminal Code prosecution in the event of the occurrence of any accidental workplace death or serious injury.
- It results in inefficient and ineffective deployment of staff and financial resources in relation to OHS issues.
- It presents potential for unfavourable perceptions of the Department by staff.
7.0 Observations and Recommendations
7.1 Compliance with the INAC OHS Statement of Roles and Responsibilities
- For all of the parties named in the "Statement", the levels of compliance with specified roles and responsibilities are uniformly very low. In other words, most of the required functions and activities are not being carried out most of the time.
- The "Statement" assigns approximately 100 responsibilities to 17 parties (staff, committees), and is the paramount OHS management controls document for the Department.
- The content of the "Statement", and manner in which roles and responsibilities are allocated, is basically sound. Specifically,
- The roles and responsibilities that are assigned can and should reasonably be carried out by the parties to which they are assigned and should be consistent with their broader job responsibilities and scope of organizational authority and accountability.
- The overall scheme of allocation is consistent with the OHS statutory principal that the "employer" has ultimate responsibility and accountability for compliance and protection of personnel and that this duty is fulfilled in practice by the actions of management.
- Where CLC-II assigns specific responsibilities to a party or a committee, the "Statement" appropriately re-states and assigns such responsibilities.
- In total, the responsibilities specified by the "Statement" reconcile with many of the management and control activities recommended by prevailing occupational health and safety management system standards, such as CSA Z1000. [Note 2]
- The roles and responsibilities that are assigned can and should reasonably be carried out by the parties to which they are assigned and should be consistent with their broader job responsibilities and scope of organizational authority and accountability.
- If the roles and responsibilities were performed as written in the "Statement", the level of OHS compliance across the Department would be high, OHS programs would be well-managed and effective, and management practices would be consistent with many of the requirements of CSA Z1000.
- The actual level of employee awareness and understanding of roles and responsibilities, however, is very low across the entire organization (all regions, all program areas) and at all staff levels. This is also the case for employees who have been designated as HS Representatives and for HR Advisors with labour portfolio responsibilities [Note 3] (which includes the HS roles and responsibilities assigned to HR Advisors by the "Statement") and the HS Committee Co-Chairs.
- The reasons for the low level of compliance with the requirements of the "Statement" are likely:
- There appears to have been little or no communication to Departmental personnel (verbal, e-mail, posted, or other) to explain OHS roles and responsibilities.
- While some of the responsibilities are simple for a layperson to understand and perform without special training or skill [Note 4], there are many complex responsibilities [Note 5] that a layperson could not reasonably be expected to carry out without benefit of specific procedures explaining how to perform those functions, and no such procedures exist.
- Many responsibilities cannot be carried out without devoting sufficient time [Note 6], and / or financial resources [Note 7], and / or assistance from OHS specialists (whether staff or consultants) [Note 8], and there are no formalized mechanisms to ensure that these enablers are present.
- The Department has no programs to instruct or train personnel in the OHS roles and responsibilities specified in the "Statement", nor in the procedures that need to be followed to discharge the more complex responsibilities.
- There are a variety of responsibilities that cannot be fulfilled without easy access to accurate information on OHS compliance and performance [Note 9]. The "Statement" describes a range of information collection and internal reporting activities, and makes reference to an OHS database. There is no such database, however, and there are no procedures for information collection and reporting. In fact, very little of the requisite information is being collected and reported in the manner envisioned by the "Statement". Without such information, many responsibilities cannot be fulfilled.
- There appears to have been little or no communication to Departmental personnel (verbal, e-mail, posted, or other) to explain OHS roles and responsibilities.
7.2 Compliance with CLC-II and TB Requirements Respecting the Existence of Prescribed Policies, Procedures, Programs, Reports and Records pertaining to OHS Management Controls
- The Canada Labour Code Part II ("CLC-II") and the TB OHS Directive require the Department to maintain a variety of specific documents.
- These documents fall into two categories: (a) OHS program documents (e.g. policies, procedures, standards, plans); and (b) records relating to OHS activities and events (e.g. inspection reports, hazardous occurrence reports, reports on evaluations and reviews of mandated programs).
- Some of these documents are program-specific, location-specific, or job-specific in nature, and should reasonably be produced and maintained at the Regional level. Others have department-wide application, and should reasonably be produced and maintained at the Corporate level.
- The specific OHS program documents and records that should reasonably be maintained by Corporate and each of the Regions are shown in Appendix 4A.
- The following table shows the numbers of program documents and categories of records that should be present at the Regional and Corporate levels:
- There is a very low level of compliance with requirements relating to prescribed program documents and records at both the Corporate and Regional level. Detailed findings with respect to Corporate and all regions are shown in Appendix 4B, and are summarized below:
- Of the 16 program documents required to be maintained in each of the Regions, eight were not provided by any Region. Of the 24 OHS activity records required to be maintained in the Regions, 11 did not exist in any Region.
- To help illustrate the low level of compliance, the following table shows overall regional compliance with OHS program document and OHS activity record requirements:
- Of the 16 program documents required to be maintained in each of the Regions, eight were not provided by any Region. Of the 24 OHS activity records required to be maintained in the Regions, 11 did not exist in any Region.
Regions' Document Compliance Profile | ||
---|---|---|
No. of Regions | No. OHS Program Documents/Categories Observed | No. Categories of OHS Activity Records Observed |
1 | 7/16 | 11/24 |
1 | 6/16 | 6/24 |
3 | 2/16 | 0/24 |
6 | 1/16 | 0/24 |
- Corporate was only able to provide two of the required corporate OHS program documents (a Hazard Prevention Plan per Part 19 of the Canada OHS Regulations, in draft form, and a Corporate building emergency plan), and produced none of the required OHS activity records.
- The reasons for the low level of compliance with documentation requirements are likely:
- Little understanding of the requirements by parties with responsibilities for document preparation and maintenance.
- Absence of specific instructions and procedures for creating, maintaining and reporting OHS activity records.
- Absence of OHS specialist staff resources in the Regions to prepare and maintain documents, and to assist / support other parties in doing so.
- Prior absence of OHS specialist staff resources at Corporate to prepare and maintain documents, and to assist / support other parties in doing so.
- The absence of Departmental OHS information management standards and a suitable database.
- Little understanding of the requirements by parties with responsibilities for document preparation and maintenance.
7.3 Compliance with CLC-II and TB Requirements Respecting Establishment and Functioning of HS Representatives, and Policy and Workplace Health & Safety Committees
7.3.1 HS Representatives
- There is a low level of compliance with the requirement for HS representatives and of those locations that do comply, no HS representatives were able to demonstrate full compliance with their prescribed functions.
- Under CLC-II, 24 INAC work locations require HS representatives, but only 14 locations comply with this requirement.
- All seven HS Representatives interviewed had volunteered for their positions and had not been selected or appointed in the manner prescribed by CLC-II.
- Five of the seven interviewed HS Representatives were not performing any of the 11 specific functions prescribed by CLC-II and the INAC OHS Statement of Roles and Responsibilities. The other two performed only one prescribed function each.
- The reasons for the low level of compliance with functional requirements are likely:
- Lack of awareness of, and absence of instruction and training in prescribed functions.
- Lack of procedures and systems to allow management and SOHS Directorate to monitor HS Representatives' and Workplace HS Committees' activities.
- Lack of awareness of, and absence of instruction and training in prescribed functions.
7.3.2 Workplace Health and Safety Committees
7.3.2.1 Workplace and Regional Representation Structure
- CLC-II allows for either Workplace HS Committees or Multi-site Regional Committees (where permission is granted), however, INAC is non-compliant with either type of Committee structure.
- A Workplace HS Committee is required at every workplace location where 20 or more persons are normally employed, unless consent has been granted for a multi-site regional structure from the Minister of Human Resources and Skills Development ("HRSDC") in the form of an Exemption Order or Validation Order under subsection 135(3) of CLC-II, or written approval by a Labour Program Health and Safety Officer in accordance with HRSDC Operations Program Directive 907-1. None of the co-chairs or the SOHS Directorate staff interviewed knew whether such consent had been obtained previously by the Department.
- According to the INAC employee directory [Note 12], 35 INAC work locations have 20 or more employees. Therefore, there should be 35 Workplace HS Committees.
- INAC has adopted a regional Workplace HS Committee structure, with 11 regional committees covering the following regions: Alberta, Atlantic, British Columbia, Manitoba, Nunavut, Northwest Territories, Ontario, National Capital Region, Quebec, Saskatchewan, and Yukon.
- In addition to the regional committees, there are eight site-specific committees at the following Ontario locations - Thunder Bay, Brantford, five Schools in Southwestern Ontario – and one at Prince Albert, Saskatchewan.
- While notionally, there are 19 Workplace HS Committees, there are 18 functioning ones as the co-chair of the National Capital Region Workplace HS Committee reports that it is not operating.
- According to the INAC employee directory, the following regions - Alberta, Atlantic Provinces, Yukon and Nunavut - have only one workplace location with 20 or more persons normally employed, and these regional committees all operate from those workplace locations having 20 or more persons. Therefore, in these four regions, the regional Workplace HS Committees comply with CLC-II requirements relating to the establishment of a Workplace HS Committee at every workplace with 20 or more persons.
- Since there are four regional committees that comply with the "one Workplace HS Committee per workplace of 20" requirement, and eight site-specific committees that comply with this requirement, a total of 12 INAC workplaces comply with this requirement, and 23 workplaces do not.
- The reasons for the non-compliance with committee location establishment requirements are likely:
- Little understanding of the statutory requirements within the Department, and failure to recognize that the current structure is non-compliant.
- The fact that this regional model is commonplace in other federal government Departments and agencies (but in those cases, the requisite approvals may have been obtained).
- The prior absence of Departmental OHS internal audits to recognize the problem.
- Little understanding of the statutory requirements within the Department, and failure to recognize that the current structure is non-compliant.
- While the current structure is technically non-compliant, a regional structure can work well. We see no compelling reasons to establish additional Committees, and we expect that the current structure would be acceptable to HRSDC if INAC made proper application for approval.
7.3.2.2 Selection of Co-Chairs and Members
- With the exception of one employee co-chair, all interviewed management and employee co-chairs (14 representing seven functioning Regional Workplace HS Committees) were appointed by the correct procedure.
- Workplace HS Committee composition and co-chairing practices are compliant.
7.3.2.3 Performance of Functions
- Through co-chair interviews, review of minutes and documents submitted by co-chairs in response to our requests, the seven audited Regional Workplace HS Committees are not performing a number of prescribed functions.
- Committees were compliant with regards to dealing with HS issues brought to their attention, involvement in studies and investigations, holding meetings, and retaining minutes.
- Committees were non-compliant with respect to the following prescribed functions:
- Involvement in Hazard Prevention Programs: Only two of the seven Regional Workplace HS Committees (Quebec and Yukon) were aware of the development of a national Hazard Prevention Program and none reported having been consulted thus far on program development, nor seeing any draft documents.
- Annual Reports: Only two of the seven Regional Workplace HS Committees (British Columbia and Yukon) reported having produced in the past year the annual Workplace HS Committee report required to be filed with HRSDC by March 1st of each year, but neither of these Workplace HS Committees have posted the report in their workplaces (as is required).
- HS Program Development, Implementation, Monitoring: Four of the seven Regional Workplace HS Committees reported some manner of work relating to Regional HS program development, implementation and monitoring, and this was reflected in the minutes.
- Personal Protective Equipment Program Development, Implementation, Monitoring: Only two of seven Regional Workplace HS Committees reported activities relating to implementation of personal protective equipment programs.
- Workplace HS Inspections: Four Regional Workplace HS Committees have been performing monthly inspections while the remaining reviewed inspections done by others or were not performing/reviewing inspections at all. None of the Committees have formally assigned inspection duties in the manner prescribed. Where Committees were performing inspections, these inspections were not explicitly performed to evaluate compliance with prescribed requirements in CLC-II, the Canada Occupational Health and Safety Regulations, or TB OHS Directives and Standards. Consequently these Committee HS inspections provide no assurance that compliance deficiencies are recognized and addressed.
- Involvement in Hazard Prevention Programs: Only two of the seven Regional Workplace HS Committees (Quebec and Yukon) were aware of the development of a national Hazard Prevention Program and none reported having been consulted thus far on program development, nor seeing any draft documents.
- The reasons for the non-compliance with requisite Committee functions are likely:
- Little understanding of the statutory requirements by Committee members and within the Department.
- Absence of training to render Committee members competent to perform their functions.
- Lack of standardized procedures and checklists to guide workplace HS inspection activities.
- Absence of procedures and mechanisms to monitor, track and report on Committee activities and to intervene where necessary in order to address functional deficiencies when recognized.
- Absence of understanding by local managers of their responsibilities to perform Committee functions when the Committee itself fails to do so.
- Little understanding of the statutory requirements by Committee members and within the Department.
7.3.3 Policy Health and Safety Committee
- While the membership of the Policy HS Committee is properly constituted as prescribed and he Committee met the requisite four times in 2008, and produces and distributes minutes of its meetings, the Committee does not appear to have a proactive long-range agenda dealing with "strategic departmental health and safety matters".
- Co-chairs and the minutes indicate that a variety of issues have been placed on the agenda of the Policy HS Committee for information and discussion, including:
- The possibility of arranging on-line OHS training for INAC personnel
- Safety issues in delivery of treaty payments
- Potable water
- Field safety issues (contaminated sites, laboratories, firearms warehouse, travel by small plane or helicopter)
- Workplace violence issues
- Review of the draft Chapter 2 (hazard prevention program)
- A proposed corporate OHS manual
- The possibility of arranging on-line OHS training for INAC personnel
- While these matters have come before the Policy HS Committee, it does not appear that the Committee has played an active role in developing, implementing or monitoring related programs. The Policy HS Committee's involvement appears to be limited to receiving information and providing commentary.
- While the issues listed above are Department-wide in character, the minutes of 2008 also reflect considerable focus on Region-specific issues.
- The Policy HS Committee's agenda appears to be formed primarily by "reactive" issues that are presented to the Committee. This is likely due to the absence of Departmental processes for OHS needs assessment, enterprise objective setting, and long-range planning relating to OHS conditions, performance and compliance.
7.4 Compliance with Requirements of the INAC Contaminated Sites Program – Environmental Health and Safety ("EHS") Management Manual – Edition 2 – March 2008
7.4.1 Adequacy of the EHS Management Manual
- The contents of this Management Manual apply to employees and operations of INAC's Northern Contaminated Sites Program ("NCSP") and addresses both environmental and OHS requirements associated with the Program's operations.
- The contents of the Manual are consistent with recommendations of two standards – ISO 14001, and BSI OHSAS 18001 [Note 13]. These are voluntary standards that have received wide acceptance internationally amongst employers as guidelines for development of environmental and OHS management systems.
7.4.2 Corporate and Regional Compliance with OHS Documentation Requirements
- Corporate and Northern Regions were unable to demonstrate full compliance with OHS documentation requirements of the NCSP.
- Neither the CSP Corporate EHS Section, nor two of the three NCSP Regions (Northwest Territories and Nunavut) were able to supply us with any of the required OHS activity records. Yukon supplied us with two OHS activity records, both of which were OHS audit reports (but neither audit was conducted in accordance with the NCSP EHS Audit Program Guide).
- CSP Corporate EHS Section provided only two of the required Departmental CSP program documents – an EHS Audit Program Guide, and an EHS Management System Standard Operating Procedures Manual. Neither Northwest Territories nor Nunavut provided any of the required Regional NCSP program documents. Yukon Region supplied us with several additional documents that appear to be Departmental CSP program documents.
- None of the NCSP Regions reviewed had a comprehensive set of OHS instructions and procedures applicable to their field operations. A coordinated effort led by Corporate EHS specialists, involving consultation with all Regions, to develop such documents would assist the Regions in attaining compliance with the NCSP.
- The reasons for the low level of compliance with NCSP OHS Management documentation requirements are likely:
- Failure to perform the requisite activities that are to be recorded and documented.
- Little understanding of the requirements by parties with responsibilities for document preparation and maintenance.
- Absence of specific instructions and procedures for creating, maintaining and reporting OHS activity records.
- Insufficient OHS specialist staff resources in the NCSP Regions to prepare and maintain documents and to assist / support other parties in doing so.
- The absence of Departmental OHS information management standards and a suitable NCSP OHS database.
- Failure to perform the requisite activities that are to be recorded and documented.
7.4.3 NCSP Project Manager Compliance with OHS Documentation Requirements
- NCSP Project Managers were unable to demonstrate full compliance with OHS documentation requirements of the CSP.
- The Manual requires NCSP Project Managers to prepare, or ensure the production of, the following documents for each contaminated sites project:
- Specifications containing relevant OHS terms and conditions (to be prepared by PWGSC)
- A project specific safety plan (to be prepared by the contractor / consultant)
- Project-level programs to achieve the annual EHS objectives and targets.
- Project start-up meeting minutes
- Documents describing site-specific EHS reporting, inspections and auditing requirements
- Documents describing how the CSP EHS Policy is communicated to all persons involved in a project.
- Pre-project hazard assessments
- Project EHS inspection records - prepared by any party
- Project-specific EHS plan reviews performed by third party professionals
- Procedures developed by any of NCSP Project Managers, consultants or contractors that describe the way their processes and work activities are monitored and controlled, including workplace and project inspections.
- Root causes analysis reports for any identified instances of non-compliance or non-conformance.
- Quarterly non-conformance and non-compliance reports of Project Managers
- Project-level detailed work plans that contain annual EHS objectives and targets for the project
- Written warnings on record
- Training records for all EHS training sessions and site orientations delivered by INAC personnel for the project
- Specifications containing relevant OHS terms and conditions (to be prepared by PWGSC)
- A review of requisite project-specific OHS documents for four of the five projects completed between January 2008 and 2009 revealed:
- In the case of one project, no OHS documents were available, and the responsible NCSP project manager indicated that no such documents were produced for the project.
- In the case of three projects, the only OHS documents provided were the specifications prepared by PWGSC (which included the requisite OHS terms and conditions), and the project-specific safety plans prepared by the contractors. None of the OHS documents required to be produced and / or collected by the NCSP Project Managers during the course of the project were supplied, and were reported not to exist.
- In the case of one project, no OHS documents were available, and the responsible NCSP project manager indicated that no such documents were produced for the project.
- The reasons for the low level of compliance with project-specific OHS documentation requirements are likely to be as follows:
- Failure to perform the requisite activities that are to be recorded and documented.
- Little understanding of the requirements by parties with responsibilities for document preparation and maintenance.
- Absence of specific instructions and procedures for creating, maintaining and reporting OHS activity records.
- Absence of training for project managers to explain and develop skills in the requirements.
- Absence of procedures and systems to track performance of OHS project safety activities, and to intervene where appropriate.
- Failure to perform the requisite activities that are to be recorded and documented.
8.0 Recommendations
- OHS knowledge and competency requirements for all categories of managers and employees should be defined. Appropriately detailed instructional procedures should be developed. Training and instruction standards and programs should be established and implemented using a risk-based approach (i.e. higher hazard program areas and occupations) to ensure that personnel understand and can discharge their OHS roles and responsibilities.
- Specific OHS governance requirements and procedures, applicable to Corporate and the Regions should be established for: (1) OHS objective setting, (2) development of formal plans to achieve objectives; (3) OHS auditing and evaluation; (4) HS opinion surveys of the workforce; (5) internal reporting on the foregoing; and (6) senior management review of findings and recommendations arising therefrom. These requirements should be incorporated into the existing INAC OHS Statement of Roles and Responsibilities.
- The scope of support to be provided to internal departmental clients by SOHS Directorate and other departmental HS resources, as well as the performance standards, mechanisms for delivering such support, resource requirements for success, and procedures for monitoring delivery and impacts should be developed.
- A blueprint for future corporate OHS program development (policies, standards, procedures), determining resource requirements, obtaining senior management approval should be developed and implemented in consultation with the Policy HS Committee.
- An enterprise information management system requirements and procedures to support department-wide HS management and record keeping should be assessed, specified and implemented.
- Department-wide OHS programs, guidelines and procedures required for the higher risk operations carried out by departmental personnel should be identified, developed and implemented.
- Procedures to ensure proper flow of information between SOHS Directorate, HR / HS Advisors, HS Representatives, and HS Committees should be established and implemented.
- The selection and appointment of health and safety representatives at those additional locations where required should be conducted.
- The need for additional HS specialist staff, and optimal organizational placement, to adequately support the organization should be assessed.
- HRSDC approval of the existing HS committee structure, to avoid the need for creation of additional HS committees, should be obtained.
9.0 Management Action Plan
Recommendations | Actions | Responsible Manager (Title) | Planned Implementation and Completion Dates |
---|---|---|---|
1. OHS knowledge and competency requirements for all categories of managers and employees should be defined. Appropriately detailed instructional procedures should be developed. Training and instruction standards and programs should be established and implemented using a risk-based approach (i.e. higher hazard program areas and occupations) to ensure that personnel understand and can discharge their OHS roles and responsibilities. | Development of a national OHS training program is underway with specific modules for: a) managers (4-5 hours), b) local committees (4-5 hours) and c) employees (60-90 minutes) All modules will meet legislative and Treasury Board requirements. Training delivery will be prioritized in high-risk areas – expected to start in October 2009. All 3 modules can be delivered in a given Region during a 4-5 day span. Committed to provide ongoing training to new employees and refreshers to employees who have already received training sessions. |
DG, HRWSB | Delivery of training for high risk area in February 2010 and, depending on available financial and human resources, will be virtually completed by March 2012. It should be noted that training will be ongoing beyond March 2012 to train new committee members, new managers, new employees, and to retrain according to new hazards or legislative changes. Training will be an ongoing activity. |
2. Specific OHS governance requirements and procedures, applicable to Corporate and the Regions should be established for: (1) OHS objective setting, (2) development of formal plans to achieve objectives; (3) OHS auditing and evaluation; (4) HS opinion surveys of the workforce; (5) internal reporting on the foregoing; and (6) senior management review of findings and recommendations arising therefrom. These requirements should be incorporated into the existing INAC OHS Statement of Roles and Responsibilities. | A 3-year OHS Strategic Plan is being developed and will address five major areas:
|
DG, HRWSB | The strategic plan implementation date is February 2010, as reported to the Audit Committee on September 25, 2009. |
Inspections, audits and evaluations will be part of regular cycle and will be defined in guidelines (Chapter 7). | Inspections, audits and evaluations will be ongoing activities. | ||
A tracking system is being developed and will be used to report back to the National Policy Health and Safety Committee. The strategic plan will rely heavily on active regional participation through monthly exchanges with OHS Coordinators. A first face-to-face meeting is planned for November 2009 at which clear objectives and timelines will be established for monitoring, reporting and evaluation of the OHS Program. |
Once in place in the first quarter of 2010-11, reporting will be done on a quarterly basis. | ||
3. The scope of support to be provided to internal departmental clients by SOHS Directorate and other departmental HS resources, as well as the performance standards, mechanisms for delivering such support, resource requirements for success, and procedures for monitoring delivery and impacts should be developed. | The 8 Chapters of INAC's National OHS Program clearly identify all these elements, under different headings. The last 5 Chapters were reviewed and approved by the National Policy H&S Committee on June 15, 2009 and are currently being reviewed by the local committees in the regions. Presentation to senior management is scheduled for early December 2009. |
DG, HRWSB | December 2009 |
4. A blueprint for future corporate OHS program development (policies, standards, and procedures), determining resource requirements, and obtaining senior management approval should be developed and implemented in consultation with the Policy HS Committee. | The OHS Strategic Plan will outline ongoing OHS activities and requirements for the next 3 years (2012). It is based on legislative and Treasury Board requirements with a focus on INAC's particular activities and programs. All new policies, standards and/or procedures will be developed in consultation with the National Policy H&S Committee. |
DG, HRWSB | At the Nov. 2009 conference with Regional OHS Coordinators, priorities for development of policies, standards and procedures were identified. To review policies and guidelines on a periodic basis |
5. An enterprise information management system requirements and procedures to support department-wide HS management and record keeping should be assessed, specified and implemented. | A tracking system is currently being developed to capture all OHS reporting requirements, by law or by TB Directive. The system will allow for quarterly reporting on the status of the Departmental OHS Program for internal and external stakeholders. The system will be introduced at the November 2009 meeting with the Regional OHS Coordinators. Data collection is expected to begin in the first quarter of 2010-11. |
DG, HRWSB | The system was discussed at the November 2009 conference with the Regional OHS Coordinators who are in agreement with the proposal. The spreadsheet-type report is currently being customized for every site controlled by INAC. It should be ready for testing in the 4th quarter of 2009-10, and for full use in the first quarter of 2010-11. |
6. Department-wide OHS programs, guidelines and procedures required for the higher risk operations carried out by departmental personnel should be identified, developed and implemented. | National policies and guidelines are completed and have been vetted at the National Policy Health and Safety Committee on June 15, 2009. Once reviewed by the Regions by August 21, they will be submitted to senior management. | DG, HRWSB | December 2009 (National Policies) |
Working groups of Regional OHS Coordinators will be formed at the November meeting to identify and develop, or review existing procedures for high-risk operations, such as site decontamination. | November 2009 (working groups) |
||
7. Procedures to ensure proper flow of information between SOHS Directorate, HR / HS Advisors, HS Representatives, and HS Committees should be established and implemented. | Theses procedures are included in the national policies and guidelines (8 Chapters). The OHS training sessions will include many references to the procedures to ensure a constant and consistent approach in the flow of information. |
DG, HRWSB | Starting December 2009 |
8. The selection and appointment of health and safety representatives at those additional locations where required should be conducted. | We have requested a list of all local committee members and health and safety representatives, at all sites controlled by INAC. We are advising Regional Management on the requirement to nominate H&S representatives. All H&S representatives and local committee members will be prioritized for training in the fall of 2009. The Regional OHS Coordinators will be tasked with the monitoring and will report back to Corporate OHS. |
DG, HRWSB in collaboration with RDGs and the Responsible Senior Manager (for satellite offices). | One training session for OHS Committee members and representatives will take place in the NCR December 4, 2009. Training at the national level should be completed by February 2010. The Regional OHS Coordinators have received training November 23 to 27 and will now be in a better position to schedule training for OHS Committees and representatives in their regions. |
9. The need for additional HS specialist staff, and optimal organizational placement, to adequately support the organization should be assessed. | Regional OHS Coordinators have been identified in every region. A 3 to 4 day training session is planned for November 2009. The session will outline clear objectives and provide them with tools to support the delivery of the OHS Program in the regions. We will monitor the activities related to the delivery of the OHS Program and assess the need for additional H&S staff on an annual basis. |
DG, HRWSB | A 5-day training session took place November 23 to 27 for Regional OHS Coordinators, as planned. |
10. HRSDC approval of the existing HS committee structure, to avoid the need for creation of additional HS committees, should be obtained. | Regions have been advised at a June 2009 teleconference of the requirement to obtain exemptions to form committees – some regions only have one regional committee. Assistance was offered and provided, in obtaining exemptions. We are still gathering information on regional and local committee structures and we will seek updates at the next teleconferences. All committees should be legally structured and operational by December 31, 2009. |
DG, HRWSB in collaboration with RDGs | February 2010. Regional OHS Coordinators have confirmed active committees in their regions and the need for either representatives or regional committees. |
Appendix 1
Key :
CLCII = Canada Labour Code Part II
COHSR = Canadian Occupational Health and Safety Regulations
EHSCSM = National Contaminated Sites Program EHS Management Systems Manual
HSCRR = Health and Safety Committees and Representatives Regulation
OHSSRR = INAC OHS Statement of Roles and Responsibilities
TBOHSD = Treasury Board OHS Directive
DESIGNATED RESPONSIBLE PARTY (X), PARTY OF INQUIRY (HIGHLIGHT) | |||||||||||
---|---|---|---|---|---|---|---|---|---|---|---|
Audit Area | Source | Responsabilities | Departments (TBD) | Deputy Minister (INAC) | Assistant Deputy Ministers (INAC) | Chief Financial Officer (INAC) | Director General - Human Resources and Workplace Services (INAC) | Director General - Communications (INAC) | Chief Audit and Evaluation Executive (INAC) | Executive Director - Inuit Relations Secretariat and Corporate Secretary (INAC) | |
1 | OHSSRR | Provides overall accountability in developing and maintaining a healthy and safe work environment. | x | ||||||||
1 | OHSSRR | Provide advice, guidance and support regarding OHS matters to managers, employees, workplace health and safety committees and health and safety representatives in their respective regions or their area of responsibility. | |||||||||
1 | OHSSRR | Provides functional direction, information and advice on legislative, administrative and technical health and safety matters to management, employees, Health and Safety Advisors and Human Resource Officers. | |||||||||
1 | OHSSRR | Provides subject matter expertise to the Policy Health and Safety Committee. | |||||||||
1 | OHSSRR | Appointing a Co-Chairperson, at the Director General level or above, to the Policy Health and Safety Committee. | x | ||||||||
1 | OHSSRR | Employee health and safety representatives are appointed to address OHS issues for each workplace controlled by INAC where there are less than 20 employees. | |||||||||
1 | OHSSRR | Identify senior representatives to serve on the Policy Health and Safety Committee. | x | x | x | x | x | x | |||
1 | OHSSRR | Policy Health and Safety Committee shall include employee representatives and senior management representatives. | |||||||||
1 | OHSSRR | Committees shall include employee and management representatives. | |||||||||
1 | OHSSRR | Committees shall (be established) in a workplace of 20 or more employees. | |||||||||
1 | OHSSRR | Where applicable, designate regional Health and Safety Advisors. | x | x | x | x | x | x | |||
1 | OHSSRR | Assign departmental OHS personnel according to the size, complexity and operating risks of the department. | x | ||||||||
1 | OHSSRR | Communicates the commitment of senior management in developing and maintaining a healthy and safe work environment. | x | ||||||||
1 | OHSSRR | Inform the Security and Occupational Health and Safety Directorate of regional OHS strategic plans, initiatives and emerging issues | |||||||||
1 | OHSSRR | Keep employees informed of applicable OHS matters. | |||||||||
1 | OHSSRR | Liaise with the Security and Occupational Health and Safety Directorate. | |||||||||
1 | OHSSRR | Liaises with central agencies by representing INAC's interests and needs, and reports back on issues affecting the Department. | |||||||||
1 | OHSSRR | Participates with central agencies and departments on OHS issues of national importance such as SARS, Avian Flu, Pandemics, etc.. | |||||||||
1 | OHSSRR | Provide all regulatory and statistical data as requested by the Security and Occupational Health and Safety Directorate. | |||||||||
1 | OHSSRR | Refer matters and issues that cannot be resolved, and that have been referred to them by workplace committees and representatives, to the Policy Health and Safety Committee for their consideration. | |||||||||
1 | OHSSRR | Make recommendations and report its activities to the Deputy Minister through the National Union Management Consultation Committee. | |||||||||
1 | OHSSRR | Committees shall report to the most senior officer responsible for that workplace, or to their delegate. | |||||||||
1 | OHSSRR | Undertake or assume the role of the person in authority to whom workplace health and safety committees report, when they are the most senior officer of the physical location. | x | x | x | x | x | x | |||
1 | OHSSRR | Ensure accessibility to operational OHS training in consultation with the Security and Occupational Health and Safety Directorate. | |||||||||
1 | OHSSRR | Facilitates and co-ordinates cross-group/cross-region consultations on OHS matters and responses. | |||||||||
1 | OHSSRR | Facilitates the implementation of necessary OHS measures. | x | ||||||||
1 | OHSSRR | Employees have a responsibility to take all reasonable and necessary precautions to ensure their health and safety and that of anyone else who may be affected by their work or activities. | |||||||||
1 | OHSSRR | Take reasonable precautions to protect themselves and other employees (TBD). | |||||||||
1 | OHSSRR | Ensure that the Internal Complaint Resolution Process is followed to address any OHS concerns that an employee may have. | |||||||||
1 | OHSSRR | Follow prescribed procedures with respect to health and safety. | |||||||||
1 | OHSSRR | Use the OHS equipment and devices provided (TBD). | |||||||||
1 | OHSSRR | Implement corporate OHS policies, directives, procedures and guidelines in a timely manner. | |||||||||
1 | OHSSRR | Comply with Health Canada directives on the occupational safety and health of employees. | x | ||||||||
1 | OHSSRR | Ensure compliance with all applicable OHS legislation, regulations, policies and directives. | |||||||||
1 | OHSSRR | Ensure that employees comply with the OHS requirements such as legislation, policies, directives and guidelines associated with their individual employment. | |||||||||
1 | OHSSRR | Ensure that periodic health evaluations are carried out for employees within their areas of responsibility for identified positions in accordance with the Occupational Health Assessment Guide (OHAG). | |||||||||
1 | OHSSRR | Ensure implementation of this document at all departmental workplaces. | x | ||||||||
1 | OHSSRR | Establish and maintain effective occupational safety and health (OSH) programs consistent with Treasury Board policies, standards and procedures. | x | ||||||||
1 | OHSSRR | Implement all applicable OHS legislation, regulations, policies and directives. | |||||||||
1 | OHSSRR | Perform the functions of the committee when no employee representatives have been nominated to participate on a workplace health and safety committee, and until such time as one is selected. | |||||||||
1 | OHSSRR | Provide employee assistance services. | |||||||||
1 | OHSSRR | Provide leadership in the effective implementation of OHS initiatives within their respective areas of responsibility. | x | x | x | x | x | x | |||
1 | OHSSRR | Committees shall address health and safety matters in the workplace. | |||||||||
1 | OHSSRR | Ensure that all employees under their supervision are adequately informed, instructed, trained (in) the OHS hazards associated with their employment. | |||||||||
1 | OHSSRR | Ensure that all employees under their supervision are knowledgeable of the OHS hazards associated with their employment. | |||||||||
1 | OHSSRR | Ensure that employees have adequate training to meet OHS requirements. | x | x | x | x | x | x | |||
1 | OHSSRR | Ensure that employees within their area of responsibility are aware and understand their responsibilities. | x | x | x | x | x | x | |||
1 | OHSSRR | Ensure that managers have adequate training to meet OHS requirements. | x | x | x | x | x | x | |||
1 | OHSSRR | Ensure that managers within their area of responsibility are aware and understand their responsibilities. | x | x | x | x | x | x | |||
1 | OHSSRR | Ensures that a general departmental OHS training and awareness program is in place. | |||||||||
1 | OHSSRR | Learn and follow the OSH provisions of the workplace (TBD) | |||||||||
1 | OHSSRR | Provide OSH training and information to employees. | x | ||||||||
1 | OHSSRR | Provides corporate leadership on OHS issues that affect the entire Department. | x | ||||||||
1 | OHSSRR | Provides overall leadership in developing and maintaining a healthy and safe work environment. | x | ||||||||
1 | OHSSRR | Policy Health and Safety Committee includes shall address strategic departmental health and safety matters. | |||||||||
1 | OHSSRR | Co-ordinate and monitor, in their respective regions, the implementation of the OHS training and awareness requirements, in consultation with the Security and Occupational Health and Safety Directorate. | |||||||||
1 | OHSSRR | Ensure managers are providing employees with an overview of OHS. | |||||||||
1 | OHSSRR | Ensure the monitoring of this document at all departmental workplaces. | x | ||||||||
1 | OHSSRR | Monitor corporate OHS policies, directives, procedures and guidelines in a timely manner. | |||||||||
1 | OHSSRR | Monitor regional OHS reporting through the departmental or regional OHS databases. | |||||||||
1 | OHSSRR | Monitors and reports on the effectiveness of the program and on the Employer's Annual Hazardous Occurrence Report. | x | ||||||||
1 | OHSSRR | Monitors the departmental Occupational Health and Safety program through investigations, inspections, surveys and audits. | |||||||||
1 | OHSSRR | Monitors the performance of workplace health and safety committees. | |||||||||
1 | OHSSRR | Oversee and monitor the implementation of the OHS program within their area of responsibility. | |||||||||
1 | OHSSRR | The Security and Occupational Health and Safety Directorate shall monitor the implementation of this document. | |||||||||
1 | OHSSRR | Develop programs, guidelines and procedures in consultation with the Security and Occupational Health and Safety Directorate to meet specific requirements in their area of responsibility. | |||||||||
1 | OHSSRR | Develops policies, directives, standards and procedures in consultation with the OHS policy committee. | |||||||||
1 | OHSSRR | Ensure development of this document at all departmental workplaces. | x | ||||||||
1 | OHSSRR | Signing off on departmental OHS policies. | x | ||||||||
1 | OHSSRR | Issue and approve regional, directorate, OHS guidelines, directives or procedures in accordance with this document to meet specific operational needs. | x | x | x | x | x | x | |||
1 | OHSSRR | Issues internal departmental OHS policies, directives and guidelines in consultation with the Policy Health and Safety Committee. | x | ||||||||
1 | OHSSRR | Post a copy of a general policy statement worded this way: "A high priority in the Public Service of Canada is providing working conditions conducive to the safety and health of employees. This department is committed to promoting occupational safety and. | x | ||||||||
1 | OHSSRR | Post a copy of the Canada Labour Code, Part II. | x | ||||||||
1 | OHSSRR | Post any printed notices or other material prescribed by Human Resources Development Canada - Labour Program or the Treasury Board Secretariat. | x | ||||||||
1 | OHSSRR | Keep and maintain health and safety records for their area of responsibility. | |||||||||
1 | OHSSRR | Maintains program records. | |||||||||
1 | OHSSRR | Manages the departmental OHS database. | |||||||||
1 | OHSSRR | Ensure that employees have adequate resources to meet OHS requirements. | x | x | x | x | x | x | |||
1 | OHSSRR | Ensure that managers have adequate resources to meet OHS requirements. | x | x | x | x | x | x | |||
1 | OHSSRR | Plan and budget for OHS initiatives within their organizations. | x | x | x | x | x | x | |||
1 | OHSSRR | Plans and budgets for essential OHS resources, including training. | x | ||||||||
1 | OHSSRR | Ensure that all known OHS incidents, accidents and occupational illnesses are reported to the INAC Health and Safety Advisors. | |||||||||
1 | OHSSRR | Ensure timely and effective hazardous occurrence investigation, recording and reporting and use this as a monitoring tool. | |||||||||
1 | OHSSRR | Investigate, record and report all accidents, occupational illnesses and other hazardous occurrences known. | |||||||||
1 | OHSSRR | Report internally and externally on INAC's OHS program performance, including the analysis of accident trends. | |||||||||
1 | OHSSRR | Submits an annual written report on the 1st of March of each year to the HRSDC Labour Program, outlining the number of accidents, occupational diseases and other hazardous occurrences for each identified workplace of which management is aware. | |||||||||
2 | TBOHSD | Part 1, General | Procedure for resolution of "qualified person" dispute | x | |||||||
2 | TBOHSD | 5.4 | Procedure for Halon system non-destructive testing and inspection | x | |||||||
2 | TBOHSD | 7.1 | Report of any noise exposure investigation | x | |||||||
2 | TBOHSD | 9.2.7 | Contingency procedures for cases in which there is a temporary interruption in the supply of drinking water and water for the removal of water-borne waste | x | |||||||
2 | TBOHSD | 10.1 | Record of all hazardous substances that, in the work place, are used, produced, handled, or stored | x | |||||||
2 | TBOHSD | 10.5 | Record of each air sample test related to exposure to hazardous substance | x | |||||||
2 | TBOHSD | 10.6 | Asbestos management program | x | |||||||
2 | TBOHSD | 12.15 | Storage, maintenance, inspection, and testing of personal protective equipment | x | |||||||
2 | TBOHSD | 15.11 | Hazardous occurrence investigation procedures and methodology | x | |||||||
2 | TBOHSD | 16.1.2 | Procedures respecting the availability of first-aid services | x | |||||||
2 | TBOHSD | 16.2.2 | Procedures respecting the availability of first-aid services | x | |||||||
2 | TBOHSD | 18.7 | Rules of procedure for Policy Committees | x | |||||||
2 | TBOHSD | 18.9 | Policy Committee Minutes | x | |||||||
2 | TBOHSD | 18.10 | Regional policy HS committee terms of reference | x | |||||||
2 | TBOHSD | 18.14 | Workplace HS committee rules of procedure | x | |||||||
2 | TBOHSD | 18.16 | Records of all matters brought before workplace committee | x | |||||||
2 | TBOHSD | 1.0 | Copy of a general policy statement | x | |||||||
2 | CLCII | 125(1)d)(2) | Health and Safety policy | x | |||||||
2 | CLCII | 125(1)z.03) | Program for the prevention of hazards in the work place | x | |||||||
2 | CLCII | 125(1)z.13) | Program for the provision of personal protective equipment, clothing, devices or materials | x | |||||||
2 | CLCII | 125(1)z.10) | Written response to recommendations made by work place and policy committee | x | |||||||
2 | CLCII | 125(1)z.17) | Name, work telephone numbers and work locations of work place committee members / HS representative | x | |||||||
2 | CLCII | 135.1(9) | Meeting minutes | x | |||||||
2 | CLCII | 135.1(9) | Records of complaints, investigations | x | |||||||
2 | CLCII | 135.2g) | Annual record report of activities | x | |||||||
2 | HSCRR | 9 | Minutes of safety and health committee meetings | x | |||||||
2 | HSCRR | 10 | Report of the safety and health committee's activities | x | |||||||
2 | COHSR | 2.27(1) | Procedure for investigating situations in which the health or safety of an employee in the work place is or may be endangered by the air quality | x | |||||||
2 | COHSR | 2.27(7) | Records of every indoor air quality complaint and investigation for at least five years | x | |||||||
2 | COHSR | 7.3(5) | Report of noise exposure investigation | x | |||||||
2 | COHSR | 7.7(2)a) | Procedures for hearing protection fit, care and use of hearing protector | x | |||||||
2 | COHSR | 10.3 | Record of all hazardous substances that, in the work place, are used, produced, handled, or stored | x | |||||||
2 | COHSR | 10.5 | Written reports of investigation into exposure to hazardous substance | x | |||||||
2 | COHSR | 10.5b) | Written procedure for the control of the concentration or level of the hazardous substance in the work place | x | |||||||
2 | COHSR | 10.15 | Employee education program | x | |||||||
2 | COHSR | 10.15 | Record of instruction and training for hazardous substances | x | |||||||
2 | COHSR | 10.49d) | Maintenance and operating procedures to prevent the escape of flammable liquids and combustible liquids | x | |||||||
2 | COHSR | 12.14(1) | Record of all protection equipment provided by the employer | x | |||||||
2 | COHSR | 12.15(1) | Written instructions in the use, operation and maintenance of the equipment | x | |||||||
2 | COHSR | Written emergency procedures | x | ||||||||
2 | COHSR | 14.20 | Record of maintenance, use and testing before initial use | x | |||||||
2 | COHSR | 14.23(4) | Record of training for operators | x | |||||||
2 | COHSR | 14.29(4) | Record of any repair or modification work and of any restriction on use imposed | x | |||||||
2 | COHSR | 15.4 | Records of any motor vehicle accident | x | |||||||
2 | COHSR | 15.7(1) | Record of each minor injury | x | |||||||
2 | COHSR | 15.8 | Record describing the hazardous occurrence (incl. time, date and location), the cause of the occurrence and corrective measures taken? | x | |||||||
2 | COHSR | 15.10 | Written yearly summary to Minister | x | |||||||
2 | COHSR | 16.2(1) | Written first aid instructions that provide for the prompt rendering of first aid to an employee for an injury, an occupational disease or an illness | x | |||||||
2 | COHSR | 16.13 | On-site first aid-records | x | |||||||
2 | COHSR | 16.13(2) | Off-site first aid-records | x | |||||||
2 | COHSR | 16.13(6) | Record of the expiry dates of the first aid certificates of the first aid attendants | ||||||||
2 | COHSR | 17.4(1) | Emergency procedures re: spilll,leak, failure of lighting, fire | x | |||||||
2 | COHSR | 17.8(2) | Record of all instruction and training provided to every emergency warden, deputy emergency warden and monitor | x | |||||||
2 | COHSR | 17.5(2) | Emergency evacuation plan, where applicable, or a plan for evacuating employees who require special assistance to be implemented in the event of a fire | x | |||||||
2 | COHSR | 17.9 | Record of inspection of all fire escapes, exits, stairways and fire protection equipment in a building | x | |||||||
2 | COHSR | 17.10(2) | Record of each Emergency Warden meeting and emergency evacuation drill | x | |||||||
2 | COHSR | 19.1 | Hazard Prevention Program | x | |||||||
2 | COHSR | 19.5(2) | Preventive Maintenance Program | x | |||||||
2 | COHSR | 19.6(5) | Records of health and safety education, including education relating to ergonomics | x | |||||||
2 | COHSR | 19.8 | Hazard prevention program evaluation report | x | |||||||
2 | COHSR | 20.9 | Records of investigation of employee reports | x | |||||||
2 | COHSR | 20.5 | Assessment of potential for work place violence | x | |||||||
2 | COHSR | 20.6(3) | Procedures for appropriate follow-up maintenance and corrective measures | x | |||||||
2 | COHSR | 20.7 | Record of review of the effectiveness of the work place violence prevention measures | x | |||||||
2 | COHSR | 20.10 | Records on the information, instruction and training provided to each employee exposed to work place violence or a risk of work place violence | x | |||||||
3 | CLCII | 136(5)b) | Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints; | ||||||||
3 | CLCII | 136(5)d) | Shall participate in the implementation and monitoring of the program referred to in paragraph 134.1(4)(c); | ||||||||
3 | CLCII | 136(5)e) | Where the program referred to in paragraph 134.1(4)(c) does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in health and safety matters related to those hazards; | ||||||||
3 | CLCII | 136(5)g) | Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the representative on those matters; | ||||||||
3 | CLCII | 136(5)i) | Shall participate in the implementation of changes that may affect occupational health and safety, including work processes and procedures and, where there is no policy committee, shall participate in the planning of the implementation of those changes; | ||||||||
3 | CLCII | 136(5)j) | Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; | ||||||||
3 | CLCII | 136(5)k) | Shall participate in the development of health and safety policies and programs; | ||||||||
3 | CLCII | 136(5)l) | Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; and | ||||||||
3 | CLCII | 136(5)m) | Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program. | ||||||||
3 | CLCII | 136(1) | Every employer shall, for each work place controlled by the employer at which fewer than twenty employees are normally employed or for which an employer is not required to establish a work place committee, appoint the person selected in accordance with subsection (2) as the health and safety representative for that work place. | ||||||||
3 | CLCII | 136(2) | The employer shall perform the functions of the health and safety representative until a person is selected under subsection (2). | ||||||||
3 | CLCII | 136(2) | The health and safety representative for a work place shall be selected as follows: (a) the employees at the work place who do not exercise managerial functions shall select from among those employees the person to be appointed; or (b) if those employees are represented by a trade union, the trade union shall select the person to be appointed, in consultation with any employees who are not so represented, and subject to any regulations made under subsection (11). | ||||||||
3 | CLCII | 134.1(1) | Every employer who normally employs directly three hundred or more employees shall establish a policy health and safety committee and, subject to section 135.1, select and appoint its members. | ||||||||
3 | CLCII | 134.1(4)i) | Shall meet during regular working hours at least quarterly and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours. | ||||||||
3 | CLCII | 134.1(4)g) | Shall monitor data on work accidents, injuries and health hazards; and | ||||||||
3 | CLCII | 134.1(4)c) | Shall participate in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters; | ||||||||
3 | CLCII | 134.1(4)e) | Shall participate in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials; | ||||||||
3 | CLCII | 134.1(4)a) | Shall participate in the development of health and safety policies and programs; | ||||||||
3 | CLCII | 134.1(4)h) | Shall participate in the planning of the implementation and in the implementation of changes that might affect occupational health and safety, including work processes and procedures. | ||||||||
3 | CLCII | 134.1(4)d) | Shall participate to the extent that it considers necessary in inquiries, investigations, studies and inspections pertaining to occupational health and safety; | ||||||||
3 | CLCII | 135.1(8) | The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member. | ||||||||
3 | CLCII | 135.1(6) | The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b). | ||||||||
3 | CLCII | 135.1(9) | A committee shall ensure that accurate records are kept of all of the matters that come before it and that minutes are kept of its meetings. The committee shall make the minutes and records available to a health and safety officer at the officer's request. | ||||||||
3 | CLCII | 135.1(7) | A committee shall have two chairpersons selected from among the committee members. One of the chairpersons shall be selected by the employee members and the other shall be selected by the employer members. | ||||||||
3 | CLCII | 135.1(1) | A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have been selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented. | ||||||||
3 | CLCII | 135.1 | Every employer shall, for each work place controlled by the employer at which twenty or more employees are normally employed, establish a work place health and safety committee and, subject to section 135.1, select and appoint its members. | ||||||||
3 | CLCII | 135.1(5) | If (there is no committee), the employer shall perform the functions of the committee until a person is selected and the committee is established. | ||||||||
3 | CLCII | 137 | If an employer controls more than one work place referred to in section 135 or 136 or the size or nature of the operations of the employer or those of the work place precludes the effective functioning of a single work place committee or health and safety representative, as the case may be, for those work places, the employer shall, subject to the approval or in accordance with the direction of a health and safety officer, establish or appoint in accordance with section 135 or 136, as the case may require, a work place committee or health and safety representative for the work places that are specified in the approval or direction. | ||||||||
3 | CLCII | 135.1(7)j) | Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; | ||||||||
3 | CLCII | 135.1(7)a) | Shall consider and expeditiously dispose of matters concerning health and safety raised by members of the committee or referred to it by a work place committee or a health and safety representative; | ||||||||
3 | CLCII | 135.1(7)h) | Shall cooperate with health and safety officers; | ||||||||
3 | CLCII | 135.1(7)g) | Shall ensure that adequate records are maintained on work accidents, injuries and health hazards relating to the health and safety of employees and regularly monitor data relating to those accidents, injuries and hazards; | ||||||||
3 | CLCII | 135.1(7)k) | Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; and | ||||||||
3 | CLCII | 135.1(7)e) | Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the committee on those matters; | ||||||||
3 | CLCII | 135.1(7)c) | Shall participate in the development, implementation and monitoring of a program for the prevention of those hazards (not covered by the hazard prevention program) that also provides for the education of employees in health and safety matters related to those hazards; | ||||||||
3 | CLCII | 135.1(7)f) | Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program; | ||||||||
3 | CLCII | 135.1(7)b) | Shall participate in the implementation and monitoring of the program referred to in paragraph 134.1(4)c) | ||||||||
3 | CLCII | 135.1(7)i) | Shall participate in the implementation of changes that might affect occupational health and safety, including work processes and procedures and, where there is no policy committee, shall participate in the planning of the implementation of those changes; | ||||||||
3 | CLCII | 135.1(8) | The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member. | ||||||||
3 | CLCII | 135.1(6) | The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b). | ||||||||
3 | CLCII | 135.1(10) | Work place committee shall meet during regular working hours at least nine times a year at regular intervals and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours. | ||||||||
3 | HSCRR | 8 | Quorum of a safety and health committee shall consist of the majority of the members of the committee, of which at least half are representatives of the employees and at least one is a representative of the employer. | ||||||||
3 | HSCRR | 9(4) | A copy of the minutes referred to in subsection (1) shall be kept by the employer at the work place to which it applies or at the head office of the employer for a period of two years from the day on which the safety and health committee meeting is held in such a manner that it is readily available for examination by a safety officer. | ||||||||
3 | HSCRR | 5(1) | A safety and health committee shall have two chairmen selected from among the members of the committee, one being selected by the representatives of the employees and the other by the representatives of the employer. | ||||||||
3 | HSCRR | 10 | The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen referred to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report referred to in paragraph (a), post a copy of the report in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months. | ||||||||
3 | HSCRR | 9(2) | The chairman selected by the representatives of the employer shall provide, as soon as possible after each safety and health committee meeting, a copy of the minutes referred to in subsection (1) to the employer and to each member of the safety and health committee. | ||||||||
3 | HSCRR | 5(2) | The chairmen referred to in subsection (1) shall act alternately for such period of time as the safety and health committee specifies in its rules of procedure. | ||||||||
3 | HSCRR | 3 | The employer shall select the member or members of a safety and health committee to represent him from among persons who exercise managerial functions. | ||||||||
3 | HSCRR | 9(3) | The employer shall, as soon as possible after receiving a copy of the minutes referred to in subsection (2), post a copy of the minutes in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for one month. | ||||||||
3 | HSCRR | 9(1) | The minutes of each safety and health committee meeting shall be signed by the two chairmen referred to in subsection 5(1). | ||||||||
3 | HSCRR | 7 | Where a member of a safety and health committee resigns or ceases to be a member for any other reason, the vacancy shall be filled within 30 days after the next regular meeting of the committee. | ||||||||
3 | HSCRR | 4 | Where any employees at a work place are not represented by a trade union, those employees shall select, by majority vote, the member or members of the safety and health committee to represent them. |
DESIGNATED RESPONSIBLE PARTY (X), PARTY OF INQUIRY (HIGHLIGHT) | |||||||||||
---|---|---|---|---|---|---|---|---|---|---|---|
Audit Area | Source | Responsabilities | Directors General (INAC) | Directors (INAC) | Managers (INAC) | Supervisors (INAC) | Employees (INAC) | Security and Occupational Health and Safety Directorate (INAC) | Health and Safety Advisors and/or Human Resources Officers (INAC) | Health and Safety Representatives (INAC) | |
1 | OHSSRR | Provides overall accountability in developing and maintaining a healthy and safe work environment. | |||||||||
1 | OHSSRR | Provide advice, guidance and support regarding OHS matters to managers, employees, workplace health and safety committees and health and safety representatives in their respective regions or their area of responsibility. | x | ||||||||
1 | OHSSRR | Provides functional direction, information and advice on legislative, administrative and technical health and safety matters to management, employees, Health and Safety Advisors and Human Resource Officers. | x | ||||||||
1 | OHSSRR | Provides subject matter expertise to the Policy Health and Safety Committee. | x | ||||||||
1 | OHSSRR | Appointing a Co-Chairperson, at the Director General level or above, to the Policy Health and Safety Committee. | |||||||||
1 | OHSSRR | Employee health and safety representatives are appointed to address OHS issues for each workplace controlled by INAC where there are less than 20 employees. | x | ||||||||
1 | OHSSRR | Identify senior representatives to serve on the Policy Health and Safety Committee. | |||||||||
1 | OHSSRR | Policy Health and Safety Committee shall include employee representatives and senior management representatives. | |||||||||
1 | OHSSRR | Committees shall include employee and management representatives. | |||||||||
1 | OHSSRR | Committees shall (be established) in a workplace of 20 or more employees. | |||||||||
1 | OHSSRR | Where applicable, designate regional Health and Safety Advisors. | |||||||||
1 | OHSSRR | Assign departmental OHS personnel according to the size, complexity and operating risks of the department. | |||||||||
1 | OHSSRR | Communicates the commitment of senior management in developing and maintaining a healthy and safe work environment. | |||||||||
1 | OHSSRR | Inform the Security and Occupational Health and Safety Directorate of regional OHS strategic plans, initiatives and emerging issues | x | ||||||||
1 | OHSSRR | Keep employees informed of applicable OHS matters. | x | x | x | x | |||||
1 | OHSSRR | Liaise with the Security and Occupational Health and Safety Directorate. | x | ||||||||
1 | OHSSRR | Liaises with central agencies by representing INAC's interests and needs, and reports back on issues affecting the Department. | x | ||||||||
1 | OHSSRR | Participates with central agencies and departments on OHS issues of national importance such as SARS, Avian Flu, Pandemics, etc.. | x | ||||||||
1 | OHSSRR | Provide all regulatory and statistical data as requested by the Security and Occupational Health and Safety Directorate. | x | ||||||||
1 | OHSSRR | Refer matters and issues that cannot be resolved, and that have been referred to them by workplace committees and representatives, to the Policy Health and Safety Committee for their consideration. | x | ||||||||
1 | OHSSRR | Make recommendations and report its activities to the Deputy Minister through the National Union Management Consultation Committee. | |||||||||
1 | OHSSRR | Committees shall report to the most senior officer responsible for that workplace, or to their delegate. | |||||||||
1 | OHSSRR | Undertake or assume the role of the person in authority to whom workplace health and safety committees report, when they are the most senior officer of the physical location. | x | x | x | x | |||||
1 | OHSSRR | Ensure accessibility to operational OHS training in consultation with the Security and Occupational Health and Safety Directorate. | x | ||||||||
1 | OHSSRR | Facilitates and co-ordinates cross-group/cross-region consultations on OHS matters and responses. | x | ||||||||
1 | OHSSRR | Facilitates the implementation of necessary OHS measures. | |||||||||
1 | OHSSRR | Employees have a responsibility to take all reasonable and necessary precautions to ensure their health and safety and that of anyone else who may be affected by their work or activities. | x | ||||||||
1 | OHSSRR | Take reasonable precautions to protect themselves and other employees (TBD). | x | ||||||||
1 | OHSSRR | Ensure that the Internal Complaint Resolution Process is followed to address any OHS concerns that an employee may have. | x | x | x | x | |||||
1 | OHSSRR | Follow prescribed procedures with respect to health and safety. | x | ||||||||
1 | OHSSRR | Use the OHS equipment and devices provided (TBD). | x | ||||||||
1 | OHSSRR | Implement corporate OHS policies, directives, procedures and guidelines in a timely manner. | x | x | x | x | |||||
1 | OHSSRR | Comply with Health Canada directives on the occupational safety and health of employees. | |||||||||
1 | OHSSRR | Ensure compliance with all applicable OHS legislation, regulations, policies and directives. | x | x | x | x | |||||
1 | OHSSRR | Ensure that employees comply with the OHS requirements such as legislation, policies, directives and guidelines associated with their individual employment. | x | x | x | x | |||||
1 | OHSSRR | Ensure that periodic health evaluations are carried out for employees within their areas of responsibility for identified positions in accordance with the Occupational Health Assessment Guide (OHAG). | x | x | x | x | |||||
1 | OHSSRR | Ensure implementation of this document at all departmental workplaces. | |||||||||
1 | OHSSRR | Establish and maintain effective occupational safety and health (OSH) programs consistent with Treasury Board policies, standards and procedures. | |||||||||
1 | OHSSRR | Implement all applicable OHS legislation, regulations, policies and directives. | x | x | x | x | |||||
1 | OHSSRR | Perform the functions of the committee when no employee representatives have been nominated to participate on a workplace health and safety committee, and until such time as one is selected. | x | x | x | x | |||||
1 | OHSSRR | Provide employee assistance services. | |||||||||
1 | OHSSRR | Provide leadership in the effective implementation of OHS initiatives within their respective areas of responsibility. | |||||||||
1 | OHSSRR | Committees shall address health and safety matters in the workplace. | |||||||||
1 | OHSSRR | Ensure that all employees under their supervision are adequately informed, instructed, trained (in) the OHS hazards associated with their employment. | x | x | x | x | |||||
1 | OHSSRR | Ensure that all employees under their supervision are knowledgeable of the OHS hazards associated with their employment. | x | x | x | x | |||||
1 | OHSSRR | Ensure that employees have adequate training to meet OHS requirements. | |||||||||
1 | OHSSRR | Ensure that employees within their area of responsibility are aware and understand their responsibilities. | |||||||||
1 | OHSSRR | Ensure that managers have adequate training to meet OHS requirements. | |||||||||
1 | OHSSRR | Ensure that managers within their area of responsibility are aware and understand their responsibilities. | |||||||||
1 | OHSSRR | Ensures that a general departmental OHS training and awareness program is in place. | x | ||||||||
1 | OHSSRR | Learn and follow the OSH provisions of the workplace (TBD) | x | ||||||||
1 | OHSSRR | Provide OSH training and information to employees. | |||||||||
1 | OHSSRR | Provides corporate leadership on OHS issues that affect the entire Department. | |||||||||
1 | OHSSRR | Provides overall leadership in developing and maintaining a healthy and safe work environment. | |||||||||
1 | OHSSRR | Policy Health and Safety Committee includes shall address strategic departmental health and safety matters. | |||||||||
1 | OHSSRR | Co-ordinate and monitor, in their respective regions, the implementation of the OHS training and awareness requirements, in consultation with the Security and Occupational Health and Safety Directorate. | x | ||||||||
1 | OHSSRR | Ensure managers are providing employees with an overview of OHS. | x | ||||||||
1 | OHSSRR | Ensure the monitoring of this document at all departmental workplaces. | |||||||||
1 | OHSSRR | Monitor corporate OHS policies, directives, procedures and guidelines in a timely manner. | x | x | x | x | |||||
1 | OHSSRR | Monitor regional OHS reporting through the departmental or regional OHS databases. | x | ||||||||
1 | OHSSRR | Monitors and reports on the effectiveness of the program and on the Employer's Annual Hazardous Occurrence Report. | |||||||||
1 | OHSSRR | Monitors the departmental Occupational Health and Safety program through investigations, inspections, surveys and audits. | x | ||||||||
1 | OHSSRR | Monitors the performance of workplace health and safety committees. | x | ||||||||
1 | OHSSRR | Oversee and monitor the implementation of the OHS program within their area of responsibility. | x | ||||||||
1 | OHSSRR | The Security and Occupational Health and Safety Directorate shall monitor the implementation of this document. | x | ||||||||
1 | OHSSRR | Develop programs, guidelines and procedures in consultation with the Security and Occupational Health and Safety Directorate to meet specific requirements in their area of responsibility. | x | ||||||||
1 | OHSSRR | Develops policies, directives, standards and procedures in consultation with the OHS policy committee. | x | ||||||||
1 | OHSSRR | Ensure development of this document at all departmental workplaces. | |||||||||
1 | OHSSRR | Signing off on departmental OHS policies. | |||||||||
1 | OHSSRR | Issue and approve regional, directorate, OHS guidelines, directives or procedures in accordance with this document to meet specific operational needs. | |||||||||
1 | OHSSRR | Issues internal departmental OHS policies, directives and guidelines in consultation with the Policy Health and Safety Committee. | |||||||||
1 | OHSSRR | Post a copy of a general policy statement worded this way: "A high priority in the Public Service of Canada is providing working conditions conducive to the safety and health of employees. This department is committed to promoting occupational safety and. | |||||||||
1 | OHSSRR | Post a copy of the Canada Labour Code, Part II. | |||||||||
1 | OHSSRR | Post any printed notices or other material prescribed by Human Resources Development Canada - Labour Program or the Treasury Board Secretariat. | x | x | x | x | |||||
1 | OHSSRR | Keep and maintain health and safety records for their area of responsibility. | x | x | x | x | |||||
1 | OHSSRR | Maintains program records. | x | ||||||||
1 | OHSSRR | Manages the departmental OHS database. | x | ||||||||
1 | OHSSRR | Ensure that employees have adequate resources to meet OHS requirements. | |||||||||
1 | OHSSRR | Ensure that managers have adequate resources to meet OHS requirements. | |||||||||
1 | OHSSRR | Plan and budget for OHS initiatives within their organizations. | |||||||||
1 | OHSSRR | Plans and budgets for essential OHS resources, including training. | |||||||||
1 | OHSSRR | Ensure that all known OHS incidents, accidents and occupational illnesses are reported to the INAC Health and Safety Advisors. | x | x | x | x | |||||
1 | OHSSRR | Ensure timely and effective hazardous occurrence investigation, recording and reporting and use this as a monitoring tool. | x | x | x | x | |||||
1 | OHSSRR | Investigate, record and report all accidents, occupational illnesses and other hazardous occurrences known. | x | x | x | x | |||||
1 | OHSSRR | Report internally and externally on INAC's OHS program performance, including the analysis of accident trends. | x | ||||||||
1 | OHSSRR | Submits an annual written report on the 1st of March of each year to the HRSDC Labour Program, outlining the number of accidents, occupational diseases and other hazardous occurrences for each identified workplace of which management is aware. | x | ||||||||
2 | TBOHSD | Part 1, General | Procedure for resolution of "qualified person" dispute | ||||||||
2 | TBOHSD | 5.4 | Procedure for Halon system non-destructive testing and inspection | ||||||||
2 | TBOHSD | 7.1 | Report of any noise exposure investigation | ||||||||
2 | TBOHSD | 9.2.7 | Contingency procedures for cases in which there is a temporary interruption in the supply of drinking water and water for the removal of water-borne waste | ||||||||
2 | TBOHSD | 10.1 | Record of all hazardous substances that, in the work place, are used, produced, handled, or stored | ||||||||
2 | TBOHSD | 10.5 | Record of each air sample test related to exposure to hazardous substance | ||||||||
2 | TBOHSD | 10.6 | Asbestos management program | ||||||||
2 | TBOHSD | 12.15 | Storage, maintenance, inspection, and testing of personal protective equipment | ||||||||
2 | TBOHSD | 15.11 | Hazardous occurrence investigation procedures and methodology | ||||||||
2 | TBOHSD | 16.1.2 | Procedures respecting the availability of first-aid services | ||||||||
2 | TBOHSD | 16.2.2 | Procedures respecting the availability of first-aid services | ||||||||
2 | TBOHSD | 18.7 | Rules of procedure for Policy Committees | ||||||||
2 | TBOHSD | 18.9 | Policy Committee Minutes | ||||||||
2 | TBOHSD | 18.10 | Regional policy HS committee terms of reference | ||||||||
2 | TBOHSD | 18.14 | Workplace HS committee rules of procedure | ||||||||
2 | TBOHSD | 18.16 | Records of all matters brought before workplace committee | ||||||||
2 | TBOHSD | 1.0 | Copy of a general policy statement | ||||||||
2 | CLCII | 125(1)d)(2) | Health and Safety policy | ||||||||
2 | CLCII | 125(1)z.03) | Program for the prevention of hazards in the work place | ||||||||
2 | CLCII | 125(1)z.13) | Program for the provision of personal protective equipment, clothing, devices or materials | ||||||||
2 | CLCII | 125(1)z.10) | Written response to recommendations made by work place and policy committee | ||||||||
2 | CLCII | 125(1)z.17) | Name, work telephone numbers and work locations of work place committee members / HS representative | ||||||||
2 | CLCII | 135.1(9) | Meeting minutes | ||||||||
2 | CLCII | 135.1(9) | Records of complaints, investigations | ||||||||
2 | CLCII | 135.2g) | Annual record report of activities | ||||||||
2 | HSCRR | 9 | Minutes of safety and health committee meetings | ||||||||
2 | HSCRR | 10 | Report of the safety and health committee's activities | ||||||||
2 | COHSR | 2.27(1) | Procedure for investigating situations in which the health or safety of an employee in the work place is or may be endangered by the air quality | ||||||||
2 | COHSR | 2.27(7) | Records of every indoor air quality complaint and investigation for at least five years | ||||||||
2 | COHSR | 7.3(5) | Report of noise exposure investigation | ||||||||
2 | COHSR | 7.7(2)a) | Procedures for hearing protection fit, care and use of hearing protector | ||||||||
2 | COHSR | 10.3 | Record of all hazardous substances that, in the work place, are used, produced, handled, or stored | ||||||||
2 | COHSR | 10.5 | Written reports of investigation into exposure to hazardous substance | ||||||||
2 | COHSR | 10.5b) | Written procedure for the control of the concentration or level of the hazardous substance in the work place | ||||||||
2 | COHSR | 10.15 | Employee education program | ||||||||
2 | COHSR | 10.15 | Record of instruction and training for hazardous substances | ||||||||
2 | COHSR | 10.49d) | Maintenance and operating procedures to prevent the escape of flammable liquids and combustible liquids | ||||||||
2 | COHSR | 12.14(1) | Record of all protection equipment provided by the employer | ||||||||
2 | COHSR | 12.15(1) | Written instructions in the use, operation and maintenance of the equipment | ||||||||
2 | COHSR | Written emergency procedures | |||||||||
2 | COHSR | 14.20 | Record of maintenance, use and testing before initial use | ||||||||
2 | COHSR | 14.23(4) | Record of training for operators | ||||||||
2 | COHSR | 14.29(4) | Record of any repair or modification work and of any restriction on use imposed | ||||||||
2 | COHSR | 15.4 | Records of any motor vehicle accident | ||||||||
2 | COHSR | 15.7(1) | Record of each minor injury | ||||||||
2 | COHSR | 15.8 | Record describing the hazardous occurrence (incl. time, date and location), the cause of the occurrence and corrective measures taken? | ||||||||
2 | COHSR | 15.10 | Written yearly summary to Minister | ||||||||
2 | COHSR | 16.2(1) | Written first aid instructions that provide for the prompt rendering of first aid to an employee for an injury, an occupational disease or an illness | ||||||||
2 | COHSR | 16.13 | On-site first aid-records | ||||||||
2 | COHSR | 16.13(2) | Off-site first aid-records | ||||||||
2 | COHSR | 16.13(6) | Record of the expiry dates of the first aid certificates of the first aid attendants | ||||||||
2 | COHSR | 17.4(1) | Emergency procedures re: spilll,leak, failure of lighting, fire | ||||||||
2 | COHSR | 17.8(2) | Record of all instruction and training provided to every emergency warden, deputy emergency warden and monitor | ||||||||
2 | COHSR | 17.5(2) | Emergency evacuation plan, where applicable, or a plan for evacuating employees who require special assistance to be implemented in the event of a fire | ||||||||
2 | COHSR | 17.9 | Record of inspection of all fire escapes, exits, stairways and fire protection equipment in a building | ||||||||
2 | COHSR | 17.10(2) | Record of each Emergency Warden meeting and emergency evacuation drill | ||||||||
2 | COHSR | 19.1 | Hazard Prevention Program | ||||||||
2 | COHSR | 19.5(2) | Preventive Maintenance Program | ||||||||
2 | COHSR | 19.6(5) | Records of health and safety education, including education relating to ergonomics | ||||||||
2 | COHSR | 19.8 | Hazard prevention program evaluation report | ||||||||
2 | COHSR | 20.9 | Records of investigation of employee reports | ||||||||
2 | COHSR | 20.5 | Assessment of potential for work place violence | ||||||||
2 | COHSR | 20.6(3) | Procedures for appropriate follow-up maintenance and corrective measures | ||||||||
2 | COHSR | 20.7 | Record of review of the effectiveness of the work place violence prevention measures | ||||||||
2 | COHSR | 20.10 | Records on the information, instruction and training provided to each employee exposed to work place violence or a risk of work place violence | ||||||||
3 | CLCII | 136(5)b) | Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints; | x | |||||||
3 | CLCII | 136(5)d) | Shall participate in the implementation and monitoring of the program referred to in paragraph 134.1(4)(c); | x | |||||||
3 | CLCII | 136(5)e) | Where the program referred to in paragraph 134.1(4)(c) does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in health and safety matters related to those hazards; | x | |||||||
3 | CLCII | 136(5)g) | Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the representative on those matters; | x | |||||||
3 | CLCII | 136(5)i) | Shall participate in the implementation of changes that may affect occupational health and safety, including work processes and procedures and, where there is no policy committee, shall participate in the planning of the implementation of those changes; | x | |||||||
3 | CLCII | 136(5)j) | Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; | x | |||||||
3 | CLCII | 136(5)k) | Shall participate in the development of health and safety policies and programs; | x | |||||||
3 | CLCII | 136(5)l) | Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; and | x | |||||||
3 | CLCII | 136(5)m) | Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program. | x | |||||||
3 | CLCII | 136(1) | Every employer shall, for each work place controlled by the employer at which fewer than twenty employees are normally employed or for which an employer is not required to establish a work place committee, appoint the person selected in accordance with subsection (2) as the health and safety representative for that work place. | x | |||||||
3 | CLCII | 136(2) | The employer shall perform the functions of the health and safety representative until a person is selected under subsection (2). | x | |||||||
3 | CLCII | 136(2) | The health and safety representative for a work place shall be selected as follows: (a) the employees at the work place who do not exercise managerial functions shall select from among those employees the person to be appointed; or (b) if those employees are represented by a trade union, the trade union shall select the person to be appointed, in consultation with any employees who are not so represented, and subject to any regulations made under subsection (11). | x | |||||||
3 | CLCII | 134.1(1) | Every employer who normally employs directly three hundred or more employees shall establish a policy health and safety committee and, subject to section 135.1, select and appoint its members. | ||||||||
3 | CLCII | 134.1(4)i) | Shall meet during regular working hours at least quarterly and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours. | ||||||||
3 | CLCII | 134.1(4)g) | Shall monitor data on work accidents, injuries and health hazards; and | ||||||||
3 | CLCII | 134.1(4)c) | Shall participate in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters; | ||||||||
3 | CLCII | 134.1(4)e) | Shall participate in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials; | ||||||||
3 | CLCII | 134.1(4)a) | Shall participate in the development of health and safety policies and programs; | ||||||||
3 | CLCII | 134.1(4)h) | Shall participate in the planning of the implementation and in the implementation of changes that might affect occupational health and safety, including work processes and procedures. | ||||||||
3 | CLCII | 134.1(4)d) | Shall participate to the extent that it considers necessary in inquiries, investigations, studies and inspections pertaining to occupational health and safety; | ||||||||
3 | CLCII | 135.1(8) | The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member. | ||||||||
3 | CLCII | 135.1(6) | The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b). | ||||||||
3 | CLCII | 135.1(9) | A committee shall ensure that accurate records are kept of all of the matters that come before it and that minutes are kept of its meetings. The committee shall make the minutes and records available to a health and safety officer at the officer's request. | ||||||||
3 | CLCII | 135.1(7) | A committee shall have two chairpersons selected from among the committee members. One of the chairpersons shall be selected by the employee members and the other shall be selected by the employer members. | ||||||||
3 | CLCII | 135.1(1) | A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have been selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented. | ||||||||
3 | CLCII | 135.1 | Every employer shall, for each work place controlled by the employer at which twenty or more employees are normally employed, establish a work place health and safety committee and, subject to section 135.1, select and appoint its members. | ||||||||
3 | CLCII | 135.1(5) | If (there is no committee), the employer shall perform the functions of the committee until a person is selected and the committee is established. | ||||||||
3 | CLCII | 137 | If an employer controls more than one work place referred to in section 135 or 136 or the size or nature of the operations of the employer or those of the work place precludes the effective functioning of a single work place committee or health and safety representative, as the case may be, for those work places, the employer shall, subject to the approval or in accordance with the direction of a health and safety officer, establish or appoint in accordance with section 135 or 136, as the case may require, a work place committee or health and safety representative for the work places that are specified in the approval or direction. | ||||||||
3 | CLCII | 135.1(7)j) | Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; | ||||||||
3 | CLCII | 135.1(7)a) | Shall consider and expeditiously dispose of matters concerning health and safety raised by members of the committee or referred to it by a work place committee or a health and safety representative; | ||||||||
3 | CLCII | 135.1(7)h) | Shall cooperate with health and safety officers; | ||||||||
3 | CLCII | 135.1(7)g) | Shall ensure that adequate records are maintained on work accidents, injuries and health hazards relating to the health and safety of employees and regularly monitor data relating to those accidents, injuries and hazards; | ||||||||
3 | CLCII | 135.1(7)k) | Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; and | ||||||||
3 | CLCII | 135.1(7)e) | Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the committee on those matters; | ||||||||
3 | CLCII | 135.1(7)c) | Shall participate in the development, implementation and monitoring of a program for the prevention of those hazards (not covered by the hazard prevention program) that also provides for the education of employees in health and safety matters related to those hazards; | ||||||||
3 | CLCII | 135.1(7)f) | Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program; | ||||||||
3 | CLCII | 135.1(7)b) | Shall participate in the implementation and monitoring of the program referred to in paragraph 134.1(4)c) | ||||||||
3 | CLCII | 135.1(7)i) | Shall participate in the implementation of changes that might affect occupational health and safety, including work processes and procedures and, where there is no policy committee, shall participate in the planning of the implementation of those changes; | ||||||||
3 | CLCII | 135.1(8) | The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member. | ||||||||
3 | CLCII | 135.1(6) | The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b). | ||||||||
3 | CLCII | 135.1(10) | Work place committee shall meet during regular working hours at least nine times a year at regular intervals and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours. | ||||||||
3 | HSCRR | 8 | Quorum of a safety and health committee shall consist of the majority of the members of the committee, of which at least half are representatives of the employees and at least one is a representative of the employer. | ||||||||
3 | HSCRR | 9(4) | A copy of the minutes referred to in subsection (1) shall be kept by the employer at the work place to which it applies or at the head office of the employer for a period of two years from the day on which the safety and health committee meeting is held in such a manner that it is readily available for examination by a safety officer. | ||||||||
3 | HSCRR | 5(1) | A safety and health committee shall have two chairmen selected from among the members of the committee, one being selected by the representatives of the employees and the other by the representatives of the employer. | ||||||||
3 | HSCRR | 10 | The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen referred to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report referred to in paragraph (a), post a copy of the report in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months. | ||||||||
3 | HSCRR | 9(2) | The chairman selected by the representatives of the employer shall provide, as soon as possible after each safety and health committee meeting, a copy of the minutes referred to in subsection (1) to the employer and to each member of the safety and health committee. | ||||||||
3 | HSCRR | 5(2) | The chairmen referred to in subsection (1) shall act alternately for such period of time as the safety and health committee specifies in its rules of procedure. | ||||||||
3 | HSCRR | 3 | The employer shall select the member or members of a safety and health committee to represent him from among persons who exercise managerial functions. | ||||||||
3 | HSCRR | 9(3) | The employer shall, as soon as possible after receiving a copy of the minutes referred to in subsection (2), post a copy of the minutes in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for one month. | ||||||||
3 | HSCRR | 9(1) | The minutes of each safety and health committee meeting shall be signed by the two chairmen referred to in subsection 5(1). | ||||||||
3 | HSCRR | 7 | Where a member of a safety and health committee resigns or ceases to be a member for any other reason, the vacancy shall be filled within 30 days after the next regular meeting of the committee. | ||||||||
4 | EHSCSM | A.2.3 | PWGSC will review and consolidate EHS requirements in specifications | ||||||||
4 | EHSCSM | A.2.3 | At start-up meetings:
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4 | EHSCSM | A.2.3 | Crown to review the Prime's EHS Plan
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4 | EHSCSM | A.2.3 | INAC and PWGSC parties will determine and implement site-specific reporting, inspections and auditing requirements | ||||||||
4 | EHSCSM | A.2.4 | Identify and assess the significance of EHS aspects (risk factors and hazards) and potential impacts associated with their plans, activities and operations; | ||||||||
4 | EHSCSM | A.2.4 | Identify and keep up to date with legal and other requirements; | ||||||||
4 | EHSCSM | A.2.4 | Focus management priorities by setting EHS objectives and targets; | ||||||||
4 | EHSCSM | A.2.4 | Establish management programs to achieve EHS objectives and targets; | ||||||||
4 | EHSCSM | A.2.4 | Establish roles, responsibilities and requirements to meet EHS objectives and targets; | ||||||||
4 | EHSCSM | A.2.4 | Establish effective internal and external communication methods regarding EHS management; | ||||||||
4 | EHSCSM | A.2.4 | Develop EHS documentation, document control and records management practices; | ||||||||
4 | EHSCSM | A.2.4 | Ensure compliance with EHS requirements through monitoring and measurement, internal and external audits, non-conformance investigations and effective corrective actions; and | ||||||||
4 | EHSCSM | A.2.4 | Conduct regular management review to assess EHS performance and performance of the MS. | ||||||||
4 | EHSCSM | Policy Statement | Senior managers are responsible for ensuring that all the requirements of this EHS Policy are fully implemented. | ||||||||
4 | EHSCSM | Policy Statement | All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations. | ||||||||
4 | EHSCSM | Policy Statement | All personnel are required to support and comply with the EHS program, making safety, health and protection of the environment a part of their daily routine, and ensuring that they follow safe work methods and relevant regulations. | ||||||||
4 | EHSCSM | Policy Statement | All personnel will be held accountable for implementing, and adhering to, the requirements of the EHS program. | ||||||||
4 | EHSCSM | Policy Statement | All personnel are accountable for reporting to their immediate supervisor any unsafe practices or areas in need of improvement. Personnel are further accountable for bringing such reports to the attention of higher levels in the organization, without fear of reprisal, if the situation is not addressed appropriately. | ||||||||
4 | EHSCSM | Policy Statement | All relevant Territorial and Federal laws, regulations and policies, including the requirements of INAC's NAO Northern Contaminated Sites Program Management Framework, are incorporated into our program as minimum standards. | ||||||||
4 | EHSCSM | Policy Statement | Pollution prevention practices and programs to achieve continuous improvement will be implemented as an ongoing requirement of the program. | ||||||||
4 | EHSCSM | Policy Statement | Where a conflict arises due to different standards or requirements between different regulations or standards, the more stringent of the two will apply. | ||||||||
4 | EHSCSM | Policy Statement | Each Region shall establish EHS Procedures consistent with the ISO 14001 and OHSAS 18001 requirements, appropriate to the nature, scale and EHS impacts of all Northern Contaminated Sites Program activities. These Procedures shall be documented in a Regional EHS Manual and shall include a commitment to:
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4 | EHSCSM | Policy Statement | Project and Site Level EHS Procedures shall be developed and implemented where:
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4 | EHSCSM | Policy Statement | Overall responsibility for the EHS Policy rests with the Assistant Deputy Minister (ADM). | ||||||||
4 | EHSCSM | ||||||||||
4 | EHSCSM | Policy Statement | Senior Management (Director General, and Program Directors) | ||||||||
4 | EHSCSM | Policy Statement | Approve EHS policies and programs, | ||||||||
4 | EHSCSM | Policy Statement | Ensure regional and project level EHS programs are in place, and | ||||||||
4 | EHSCSM | Policy Statement | Ensure the EHS Policy is being implemented as intended. | ||||||||
4 | EHSCSM | Policy Statement | |||||||||
4 | EHSCSM | Policy Statement | Project and Program Managers | ||||||||
4 | EHSCSM | Policy Statement | Develop project level EHS procedures as required for all EHS risks, | ||||||||
4 | EHSCSM | Policy Statement | Ensure all individuals involved with a project (i.e., including Site Operator and INAC employees, consultants and contractors, and visitors) are aware of and comply with the EHS policy, | ||||||||
4 | EHSCSM | Policy Statement | Maintain original copies of the EHS policy and revisions, signed by Senior Management, and | ||||||||
4 | EHSCSM | Policy Statement | Coordinate the communication of the EHS policy internally and externally. | ||||||||
4 | EHSCSM | Policy Statement | |||||||||
4 | EHSCSM | Policy Statement | Site Manager, Line Supervisors, and Task Leaders | ||||||||
4 | EHSCSM | Policy Statement | Are aware of and understand the EHS Policy and Procedures, and | ||||||||
4 | EHSCSM | Policy Statement | Ensure work activities are performed consistent with the EHS Policy and Procedures. | ||||||||
4 | EHSCSM | Policy Statement | |||||||||
4 | EHSCSM | Policy Statement | Workers | ||||||||
4 | EHSCSM | Policy Statement | Are aware of and understand the EHS Policy and Procedures, and | ||||||||
4 | EHSCSM | Policy Statement | Perform work activities consistent with the EHS Policy and Procedures. | ||||||||
4 | EHSCSM | Policy Statement | |||||||||
4 | EHSCSM | Policy Statement | Site Visitors | ||||||||
4 | EHSCSM | Policy Statement | Are aware of and understand the EHS Policy and Procedures. | ||||||||
4 | EHSCSM | 2.1.3.1 | The EHS HQ Coordinator shall prepare a composite list of EHS aspects and hazards from the INAC NCSP Risk Register and review this list at least annually, based on the risk assessments done at the project-level as part of the annual detailed work planning process, and other relevant information. The list shall be based primarily on the following risk categories: human health and safety, environmental impact, and legal obligations. All EHS aspects and hazards ranked as 'Moderate Risk' or higher shall be considered significant for the purposes of the EHS MS. | ||||||||
4 | EHSCSM | 2.1.3.2 | The EHS HQ Coordinator shall document and maintain the EHS aspects and hazards in the EHS Aspects and Hazards Register (Appendix B, Register of EHS Aspects). | ||||||||
4 | EHSCSM | 2.1.3.3 | The EHS HQ Coordinator shall prepare a summary analysis of the EHS Aspects and Hazards Register in January of each year and provide recommendations related to the management of program-level aspects and hazards to the Director - NCSP HQ, which will be considered in annual work planning. | ||||||||
4 | EHSCSM | 2.1.3.4 | Regional Directors, with support from the EHS Regional Coordinator shall analyse EHS risks, assign actions related to the management of regional aspects and hazards to appropriate individuals, provide these individuals with the necessary resources and monitor progress as part of the general operation of this EHS MS. Project Managers will analyse EHS risks, assign actions related to the management of project aspects and hazards to appropriate individuals, provide these individuals with the necessary resources and monitor progress as part of the general operation of this EHS MS. Project staff are required to communicate to their supervisors any EHS risks that are not covered by the EHS MS. | ||||||||
4 | EHSCSM | 2.1.3.5 | A hazard assessment is required before commencing any project. Project specific job / task hazards will be identified by the site supervisor (or the Project Manager if no supervisor is assigned for a site) and addressed using the job safety analysis procedure found in the Standard Operating Procedures (SOP) Manual. Results of the hazard assessment are to be communicated to the appropriate staff. | ||||||||
4 | EHSCSM | 2.1.3.6 | Known hazards at non-active sites (i.e., those awaiting assessment, remediation or monitoring) shall be included in the Regional EHS aspects and hazards register to ensure such hazards are managed. | ||||||||
4 | EHSCSM | 2.2.3.1 | The EHS HQ Coordinator shall maintain an up-to-date register of federal laws, regulations, policies and other requirements that apply to the NCSP in the Regulatory Summary (Appendix C - Applicable Acts, Regulations and Guidelines). | ||||||||
4 | EHSCSM | 2.2.3.2 | Regional Directors, with support from the Regional EHS Coordinator and Project Managers, shall maintain an up-to-date register of applicable territorial laws, regulations, licences, policies and other requirements as applicable in the Regulatory Summary (Appendix C - Applicable Acts, Regulations and Guidelines). | ||||||||
4 | EHSCSM | 2.2.3.3 | Applicable territorial laws and regulations, licences, policies and other requirements vary between sites and within sites, depending on type of site and the phase and nature of the work (e.g., assessment and monitoring vs. active remediation). The regions shall classify sites into two categories - assessment and remediation - and follow the sections of regulations applicable to sites of these two types (e.g., Part XV "Exploration" of the NWT Mine Health and Safety Act and Regulations could be followed in the case of assessment projects; other sections to remediation projects). | ||||||||
4 | EHSCSM | 2.3.3.1 | The EHS HQ Coordinator shall develop and recommend annual EHS objectives and targets for the NAO NCSP. The Director NCSP, as Chair of the Directors' Committee, is responsible for approving these objectives and targets. NCSP EHS objectives and targets shall be documented in the Performance Measurement Strategy of the program RMAF. | ||||||||
4 | EHSCSM | 2.3.3.2 | The EHS Regional Coordinator shall develop and recommend annual EHS objectives and targets for their region. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in regional-level work plans. | ||||||||
4 | EHSCSM | 2.3.3.3 | Project Managers shall develop and recommend annual EHS objectives and targets for their project. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in project-level detailed work plans. | ||||||||
4 | EHSCSM | 2.3.3.4 | Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning processes and EHS Management Review. | ||||||||
4 | EHSCSM | 3.1.3.2 |
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4 | EHSCSM | 3.1.3.2 |
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4 | EHSCSM | 3.1.3.2 |
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4 | EHSCSM | 3.1.3.3 | HQ CSP Director is responsible for: | ||||||||
4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.4 | The EHS HQ Coordinator is responsible for: | ||||||||
4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.5 | Regional Directors are responsible for: | ||||||||
4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.6 | INAC Project Managers / Contaminated Sites Specialists shall be responsible for: | ||||||||
4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.7 | PWGSC (includes PM and EHS staff for PWGSC-managed project sites) shall: | ||||||||
4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.2.3 | The EHS HQ Coordinator shall develop an EHS MS awareness training package to communicate, as a minimum, the following: the EHS Policy, the process required to identify EHS aspects and hazards of contaminated work sites; the EHS objectives, targets, and performance measures of the NCSP; roles, responsibilities, and authorities of everyone involved with NCSP sites; legal compliance requirements and the consequences of non-compliance; the Internal Responsibility System (IRS); and due diligence. | ||||||||
4 | EHSCSM | 3.2.3 | The EHS HQ Coordinator shall ensure the EHS MS awareness-training package is delivered to all employees, and to new employees, students, consultants and contractors as part of a new job / site orientation, and afterwards as circumstances require. Everyone must be aware of: | ||||||||
4 | EHSCSM | 3.2.3 |
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4 | EHSCSM | 3.2.3 |
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4 | EHSCSM | 3.2.3 |
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4 | EHSCSM | 3.2.3 |
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4 | EHSCSM | 3.2.3 | The EHS HQ Coordinator shall develop a training package on the Standard Operating Procedures Manual to support EHS programs and provide NCSP personnel with the knowledge required to mitigate EHS risks, hazards, and impacts. This training will be provided to INAC staff involved in operational activities and will be refreshed on a regular basis and whenever circumstances require retraining. Regional Directors are responsible to ensure that training is delivered as required. | ||||||||
4 | EHSCSM | 3.2.3 | The EHS HQ Coordinator and the EHS Regional Coordinator shall annually assess the effectiveness and delivery of the EHS MS training package and specific training programs. They shall ensure these programs are modified as required to meet specific training needs. Individual employee responsibilities, abilities, and risk factors of the work sites shall be used as criteria to assess training needs. | ||||||||
4 | EHSCSM | 3.2.3 | The EHS Regional Coordinator shall review the job descriptions or other suitable vehicles for INAC project managers, field supervisors and field workers as new positions are created or before existing ones are posted for existence of EHS requirements, and shall recommend modifications where necessary to assure the appropriate EHS qualification. | ||||||||
4 | EHSCSM | 3.2.3 | Project Managers shall ensure that SSA and contract documents contain specifications regarding EHS competencies of key site personnel (e.g., site manager, EHS site supervisor) and that contractors are selected with due regard for the EHS competencies of the proposed teams. | ||||||||
4 | EHSCSM | 3.2.3 | Training records for all EHS training sessions and site orientations delivered by INAC personnel shall be maintained on file at the appropriate location (i.e., project site, regional office, or HQ) for a minimum of five years. The party responsible for overseeing delivery of the program (i.e., EHS HQ Coordinator, EHS Regional Coordinator or Project Manager) is responsible for ensuring training records is maintained. | ||||||||
4 | EHSCSM | 3.3.3 | NCSP Directors and Managers shall add EHS items to the standing agenda of existing monthly (or more frequent) staff meetings to: | ||||||||
4 | EHSCSM | 3.3.3 |
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4 | EHSCSM | 3.3.3 |
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4 | EHSCSM | 3.3.3 |
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4 | EHSCSM | 3.3.3 | Significant changes to the EHS MS including objectives and targets, programs, procedures and responsibilities shall be communicated internally to appropriate personnel. Methods for communication include e-mails, postings on an intranet site and bulletin boards, awareness training sessions and staff meetings. | ||||||||
4 | EHSCSM | 3.3.3 | Required changes to SOPs identified by regional staff shall be communicated to the Regional Director for review and approval and acted upon by the HQ EHS Coordinator. | ||||||||
4 | EHSCSM | 3.3.3 | Required changes to regional amplification of SOPs identified by regional staff shall be communicated to the Regional Director and acted upon by the regional EHS Coordinator. | ||||||||
4 | EHSCSM | 3.3.3 | The Project Manager shall ensure that contractor and consultant EHS requirements are documented in the contract documents. The Project Manager will ensure that start-up meetings are held with contractors and consultants to review the work requirements, including health & safety and environmental protection requirements, prior to starting work. In addition, contractors and consultants will issue progress reports that include an EHS reporting component, via e-mail, progress meetings and/or conference calls. Communication will take place within an appropriate timeframe, which may be weekly, monthly, or as required. | ||||||||
4 | EHSCSM | 3.3.3 | Concerns or issues related to sites where the site operator is a PWGSC contractor shall be communicated between the EHS HQ Coordinator and the RD, OGGO PWGSC. | ||||||||
4 | EHSCSM | 3.3.3 | Anyone who becomes aware of an unsafe situation shall take immediate action to manage the risk in the case of serious situations. In all other cases, the risk shall be communicated and documented in writing to the immediate supervisor, with copy to PWGSC (if the site operator is a PWGSC contractor) and to the Regional EHS Coordinator. | ||||||||
4 | EHSCSM | 3.3.3 | The EHS HQ Coordinator working with INAC Communications and others shall produce and distribute as appropriate: brochures, fact sheets, videos, reports, web page and other materials that describe the EHS MS. The HQ EHS Coordinator, regional health and safety personnel, and project managers will ensure the EHS Policy is publicly available. | ||||||||
4 | EHSCSM | 3.5.3 | All EHS MS documents shall contain standard identification on each page (i.e., header or footer with title, revision number, date, and page number and total) and be provided with a file number. | ||||||||
4 | EHSCSM | 3.5.3 | Document control is divided into two areas: | ||||||||
4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | 3.5.3 | EHS MS Documentation: | ||||||||
4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | ||||||||||
4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | 3.6.3 | The EHS HQ Coordinator shall develop the EHS MS SOP Manual, in consultation with the EHS Regional Coordinator and Program/Project Managers. The SOPs shall be designed to establish suitable controls for the significant aspects and hazards identified for the NCSP, and control situations where their absence could lead to the deviation from the EHS Policy, objectives and targets. | ||||||||
4 | EHSCSM | 3.6.3 | The EHS Regional Coordinator shall develop additional regional EHS SOPs where the regional risk assessment identifies significant aspects or hazards not covered by the EHS SOP Manual, or where procedures need to be customized to reflect regional circumstances. These regional procedures form an important component of the Regional EHS MS Manual. | ||||||||
4 | EHSCSM | 3.6.3 | All sites/projects require a site specific EHS Plan. The Project Manager shall ensure that a site specific EHS Plan has been developed that meets or exceeds all regulatory requirements, as well as meets or exceeds all of the requirements in the EHS Policy. When two or more regulatory requirements apply, the most stringent will be followed. Where the project level risk assessment identifies significant aspects or hazards not covered by the Corporate or Regional EHS SOPs, site specific SOPs must be developed. These regional procedures form an important component of the Site EHS Plan. Where the site operator is a PWGSC contractor, the PWGSC project manager makes sure that this requirement is met through the contractors' site specific EHS plan. | ||||||||
4 | EHSCSM | 3.6.3 | Any new activity on site shall undergo a risk assessment/job hazard analysis to ensure that mitigation measures appropriate to the hazard are developed and implemented. The Project Manager is responsible for ensuring the risk assessment/job hazard analysis is completed in advance of commencing any new activity. | ||||||||
4 | EHSCSM | 3.6.4 | The Project Manager shall ensure specific emergency preparedness and response procedures are developed for all sites/projects. | ||||||||
4 | EHSCSM | 3.6.4 | Each Project Manager shall ensure that health and safety and spill contingency emergency procedures for their sites are tested at least annually through either mock incidents or drills, or tabletop exercises. The results of these exercises shall be documented and maintained on file as an EHS MS record. | ||||||||
4 | EHSCSM | 3.6.4 | After the occurrence of accidents and emergency situations, the Project Manager shall ensure that emergency procedures are reviewed and revised, where necessary. A record of the critical review of each situation, and the identified corrective and preventive action, shall be maintained on file as an EHS MS record. | ||||||||
4 | EHSCSM | 4.1.3 | The EHS MS performance shall be monitored and measured through: | ||||||||
4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 | Project Managers shall be responsible for preparing quarterly project reports that provide the required information to assess progress towards the EHS objectives and targets at the project and Program level. Information required for this report shall be collected, compiled and reported by the Project Managers and the regional health and safety personnel, including: | ||||||||
4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | ||||||||||
4 | EHSCSM | 4.1.3 | The EHS HQ Coordinator shall be responsible for quarterly reporting on program EHS performance to Regional Directors and the Director HQ. | ||||||||
4 | EHSCSM | 4.1.3 | The EHS HQ Coordinator, in cooperation with the RD OGGO PWGSC, shall develop and oversee implementation of the EHS MS audit program (described in Section 4.4), the purpose of which will be to determine conformance and compliance with EHS MS requirements, the EHS Policy and relevant legislation. | ||||||||
4 | EHSCSM | 4.1.3 | The EHS HQ Coordinator, in cooperation with the Regional EHS Coordinator and the RD OGGO PWGSC, shall organize and oversee site inspections on an as needed basis. | ||||||||
4 | EHSCSM | 4.1.3 | NCSP Project Managers, consultants and contractors shall develop procedures that describe the way their processes and work activities are monitored and controlled, including workplace and project inspections. These procedures shall include the required time intervals for tracking performance against EHS objectives and targets. | ||||||||
4 | EHSCSM | 4.1.3 | Project Managers, consultants and contractors shall develop procedures for the calibration and maintenance of monitoring equipment, which will include record maintenance and retention times. | ||||||||
4 | EHSCSM | 4.2.3 | At the Program level, non-conformance and non-compliance will be identified during: | ||||||||
4 | EHSCSM | 4.2.3 |
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4 | EHSCSM | 4.2.3 |
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4 | EHSCSM | 4.2.3 |
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4 | EHSCSM | 4.2.3 |
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4 | EHSCSM | 4.2.3 | For non-conformance and non-compliance events identified in 4.2.3.1, a root cause analysis should be conducted to determine the direct cause of the non-conformance / non-compliance. Corrective and Preventive Action Plans shall be developed for all identified non-conformances / non-compliances using the Corrective and Preventive Action Plan template found in the EHS Audit Program Guide. | ||||||||
4 | EHSCSM | 4.2.3 | EHS Policy and SOPs Manual infractions by personnel will be dealt with through a system of verbal and written warnings with review. | ||||||||
4 | EHSCSM | 4.2.3 | Project Managers shall report results quarterly (as part of regular project quarterly reporting) and the reports will be used for assessing the effectiveness of the EHS MS. | ||||||||
4 | EHSCSM | 4.2.3 | The audit process, quarterly reporting, and the EHS MS management review will determine the effectiveness of the corrective and preventive actions. | ||||||||
4 | EHSCSM | 4.4.3 | The EHS HQ Coordinator, in cooperation with Regional Directors and the RD OGGO PWGSC when necessary, shall develop and coordinate an annual EHS MS audit plan according to the requirements of the NCSP EHS Audit Program Guide. The audit plan shall, at a minimum, detail the frequency of audits and the sites subject to upcoming audits. | ||||||||
4 | EHSCSM | 4.4.3 | Audits shall be conducted to assess compliance with regulatory requirements and to ensure the EHS MS is implemented in accordance with the requirements of the EHS MS Manual (this document), the EHS SOP Manual, ISO 14001 and OHSAS 18001. Where feasible, joint INAC/PWGSC audits may be conducted. | ||||||||
4 | EHSCSM | 4.4.3 | Among other things, the EHS MS audit shall determine whether or not the: | ||||||||
4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | ||||||||||
4 | EHSCSM | 4.4.3 | The frequency of audits may be based on: | ||||||||
4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 | Certified professional auditors shall conduct the audits in accordance with generally accepted audit principles and practices specified in the Guidelines for Quality and/or Environmental Management System Auditing, ISO 19011 and as outlined in the NCSP EHS Audit Program Guide. | ||||||||
4 | EHSCSM | 4.4.3 | The audit findings shall be documented and considered in EHS MS management reviews (described in Section 5.1.3). | ||||||||
4 | EHSCSM | 4.4.3 | The person responsible for an activity or area that has been audited shall prepare Corrective and Preventive Action Plans to address the deficiencies found by the audit, following the requirements provided in the NCSP EHS Audit Program Guide. | ||||||||
4 | EHSCSM | 5.1.3 | The EHS HQ Coordinator shall prepare and present the EHS MS assessment report to the Steering Committee and/or the Directors Committee annually. The review may include items such as: | ||||||||
4 | EHSCSM | 5.1.3 |
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4 | EHSCSM | 5.1.3 |
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4 | EHSCSM | 5.1.3 |
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4 | EHSCSM | 5.1.3 |
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4 | EHSCSM | 5.1.3 |
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4 | EHSCSM | 5.1.3 |
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4 | EHSCSM | 5.1.3 |
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4 | EHSCSM | 5.1.3 | The results of the review, including any changes to be made to the EHS MS and new EHS objectives and targets, shall be communicated to the HQ EHS Coordinator, Program Directors, regional health and safety personnel, and Project Managers. The results of the review shall be documented by the HQ EHS Coordinator and maintained on file as an EHS MS record. | ||||||||
4 | EHSCSM | A.2.3 | PWGSC will review and consolidate EHS requirements in specifications | ||||||||
4 | EHSCSM | A.2.3 | At start-up meetings:
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4 | EHSCSM | A.2.3 | Crown to review the Prime's EHS Plan
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4 | EHSCSM | A.2.3 | INAC and PWGSC parties will determine and implement site-specific reporting, inspections and auditing requirements | ||||||||
4 | EHSCSM | A.2.4 | Identify and assess the significance of EHS aspects (risk factors and hazards) and potential impacts associated with their plans, activities and operations; | ||||||||
4 | EHSCSM | A.2.4 | Identify and keep up to date with legal and other requirements; | ||||||||
4 | EHSCSM | A.2.4 | Focus management priorities by setting EHS objectives and targets; | ||||||||
4 | EHSCSM | A.2.4 | Establish management programs to achieve EHS objectives and targets; | ||||||||
4 | EHSCSM | A.2.4 | Establish roles, responsibilities and requirements to meet EHS objectives and targets; | ||||||||
4 | EHSCSM | A.2.4 | Establish effective internal and external communication methods regarding EHS management; | ||||||||
4 | EHSCSM | A.2.4 | Develop EHS documentation, document control and records management practices; | ||||||||
4 | EHSCSM | A.2.4 | Ensure compliance with EHS requirements through monitoring and measurement, internal and external audits, non-conformance investigations and effective corrective actions; and | ||||||||
4 | EHSCSM | A.2.4 | Conduct regular management review to assess EHS performance and performance of the MS. | ||||||||
4 | EHSCSM | Policy Statement | Senior managers are responsible for ensuring that all the requirements of this EHS Policy are fully implemented. | ||||||||
4 | EHSCSM | Policy Statement | All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations. | ||||||||
4 | EHSCSM | Policy Statement | All personnel are required to support and comply with the EHS program, making safety, health and protection of the environment a part of their daily routine, and ensuring that they follow safe work methods and relevant regulations. | ||||||||
4 | EHSCSM | Policy Statement | All personnel will be held accountable for implementing, and adhering to, the requirements of the EHS program. | ||||||||
4 | EHSCSM | Policy Statement | All personnel are accountable for reporting to their immediate supervisor any unsafe practices or areas in need of improvement. Personnel are further accountable for bringing such reports to the attention of higher levels in the organization, without fear of reprisal, if the situation is not addressed appropriately. | ||||||||
4 | EHSCSM | Policy Statement | All relevant Territorial and Federal laws, regulations and policies, including the requirements of INAC's NAO Northern Contaminated Sites Program Management Framework, are incorporated into our program as minimum standards. | ||||||||
4 | EHSCSM | Policy Statement | Pollution prevention practices and programs to achieve continuous improvement will be implemented as an ongoing requirement of the program. | ||||||||
4 | EHSCSM | Policy Statement | Where a conflict arises due to different standards or requirements between different regulations or standards, the more stringent of the two will apply. | ||||||||
4 | EHSCSM | Policy Statement | Each Region shall establish EHS Procedures consistent with the ISO 14001 and OHSAS 18001 requirements, appropriate to the nature, scale and EHS impacts of all Northern Contaminated Sites Program activities. These Procedures shall be documented in a Regional EHS Manual and shall include a commitment to:
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4 | EHSCSM | Policy Statement | Project and Site Level EHS Procedures shall be developed and implemented where:
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4 | EHSCSM | Policy Statement | Overall responsibility for the EHS Policy rests with the Assistant Deputy Minister (ADM). | ||||||||
4 | EHSCSM | ||||||||||
4 | EHSCSM | Policy Statement | Senior Management (Director General, and Program Directors) | ||||||||
4 | EHSCSM | Policy Statement | Approve EHS policies and programs, | ||||||||
4 | EHSCSM | Policy Statement | Ensure regional and project level EHS programs are in place, and | ||||||||
4 | EHSCSM | Policy Statement | Ensure the EHS Policy is being implemented as intended. | ||||||||
4 | EHSCSM | Policy Statement | |||||||||
4 | EHSCSM | Policy Statement | Project and Program Managers | ||||||||
4 | EHSCSM | Policy Statement | Develop project level EHS procedures as required for all EHS risks, | ||||||||
4 | EHSCSM | Policy Statement | Ensure all individuals involved with a project (i.e., including Site Operator and INAC employees, consultants and contractors, and visitors) are aware of and comply with the EHS policy, | ||||||||
4 | EHSCSM | Policy Statement | Maintain original copies of the EHS policy and revisions, signed by Senior Management, and | ||||||||
4 | EHSCSM | Policy Statement | Coordinate the communication of the EHS policy internally and externally. | ||||||||
4 | EHSCSM | Policy Statement | |||||||||
4 | EHSCSM | Policy Statement | Site Manager, Line Supervisors, and Task Leaders | ||||||||
4 | EHSCSM | Policy Statement | Are aware of and understand the EHS Policy and Procedures, and | ||||||||
4 | EHSCSM | Policy Statement | Ensure work activities are performed consistent with the EHS Policy and Procedures. | ||||||||
4 | EHSCSM | Policy Statement | |||||||||
4 | EHSCSM | Policy Statement | Workers | ||||||||
4 | EHSCSM | Policy Statement | Are aware of and understand the EHS Policy and Procedures, and | ||||||||
4 | EHSCSM | Policy Statement | Perform work activities consistent with the EHS Policy and Procedures. | ||||||||
4 | EHSCSM | Policy Statement | |||||||||
4 | EHSCSM | Policy Statement | Site Visitors | ||||||||
4 | EHSCSM | Policy Statement | Are aware of and understand the EHS Policy and Procedures. | ||||||||
4 | EHSCSM | 2.1.3.1 | The EHS HQ Coordinator shall prepare a composite list of EHS aspects and hazards from the INAC NCSP Risk Register and review this list at least annually, based on the risk assessments done at the project-level as part of the annual detailed work planning process, and other relevant information. The list shall be based primarily on the following risk categories: human health and safety, environmental impact, and legal obligations. All EHS aspects and hazards ranked as 'Moderate Risk' or higher shall be considered significant for the purposes of the EHS MS. | ||||||||
4 | EHSCSM | 2.1.3.2 | The EHS HQ Coordinator shall document and maintain the EHS aspects and hazards in the EHS Aspects and Hazards Register (Appendix B, Register of EHS Aspects). | ||||||||
4 | EHSCSM | 2.1.3.3 | The EHS HQ Coordinator shall prepare a summary analysis of the EHS Aspects and Hazards Register in January of each year and provide recommendations related to the management of program-level aspects and hazards to the Director - NCSP HQ, which will be considered in annual work planning. | ||||||||
4 | EHSCSM | 2.1.3.4 | Regional Directors, with support from the EHS Regional Coordinator shall analyse EHS risks, assign actions related to the management of regional aspects and hazards to appropriate individuals, provide these individuals with the necessary resources and monitor progress as part of the general operation of this EHS MS. Project Managers will analyse EHS risks, assign actions related to the management of project aspects and hazards to appropriate individuals, provide these individuals with the necessary resources and monitor progress as part of the general operation of this EHS MS. Project staff are required to communicate to their supervisors any EHS risks that are not covered by the EHS MS. | ||||||||
4 | EHSCSM | 2.1.3.5 | A hazard assessment is required before commencing any project. Project specific job / task hazards will be identified by the site supervisor (or the Project Manager if no supervisor is assigned for a site) and addressed using the job safety analysis procedure found in the Standard Operating Procedures (SOP) Manual. Results of the hazard assessment are to be communicated to the appropriate staff. | ||||||||
4 | EHSCSM | 2.1.3.6 | Known hazards at non-active sites (i.e., those awaiting assessment, remediation or monitoring) shall be included in the Regional EHS aspects and hazards register to ensure such hazards are managed. | ||||||||
4 | EHSCSM | 2.2.3.1 | The EHS HQ Coordinator shall maintain an up-to-date register of federal laws, regulations, policies and other requirements that apply to the NCSP in the Regulatory Summary (Appendix C - Applicable Acts, Regulations and Guidelines). | ||||||||
4 | EHSCSM | 2.2.3.2 | Regional Directors, with support from the Regional EHS Coordinator and Project Managers, shall maintain an up-to-date register of applicable territorial laws, regulations, licences, policies and other requirements as applicable in the Regulatory Summary (Appendix C - Applicable Acts, Regulations and Guidelines). | ||||||||
4 | EHSCSM | 2.2.3.3 | Applicable territorial laws and regulations, licences, policies and other requirements vary between sites and within sites, depending on type of site and the phase and nature of the work (e.g., assessment and monitoring vs. active remediation). The regions shall classify sites into two categories - assessment and remediation - and follow the sections of regulations applicable to sites of these two types (e.g., Part XV "Exploration" of the NWT Mine Health and Safety Act and Regulations could be followed in the case of assessment projects; other sections to remediation projects). | ||||||||
4 | EHSCSM | 2.3.3.1 | The EHS HQ Coordinator shall develop and recommend annual EHS objectives and targets for the NAO NCSP. The Director NCSP, as Chair of the Directors' Committee, is responsible for approving these objectives and targets. NCSP EHS objectives and targets shall be documented in the Performance Measurement Strategy of the program RMAF. | ||||||||
4 | EHSCSM | 2.3.3.2 | The EHS Regional Coordinator shall develop and recommend annual EHS objectives and targets for their region. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in regional-level work plans. | ||||||||
4 | EHSCSM | 2.3.3.3 | Project Managers shall develop and recommend annual EHS objectives and targets for their project. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in project-level detailed work plans. | ||||||||
4 | EHSCSM | 2.3.3.4 | Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning processes and EHS Management Review. | ||||||||
4 | EHSCSM | 3.1.3.2 |
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4 | EHSCSM | 3.1.3.2 |
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4 | EHSCSM | 3.1.3.2 |
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4 | EHSCSM | 3.1.3.3 | HQ CSP Director is responsible for: | ||||||||
4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.3 |
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4 | EHSCSM | 3.1.3.4 | The EHS HQ Coordinator is responsible for: | ||||||||
4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.4 |
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4 | EHSCSM | 3.1.3.5 | Regional Directors are responsible for: | ||||||||
4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.5 |
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4 | EHSCSM | 3.1.3.6 | INAC Project Managers / Contaminated Sites Specialists shall be responsible for: | ||||||||
4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.6 |
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4 | EHSCSM | 3.1.3.7 | PWGSC (includes PM and EHS staff for PWGSC-managed project sites) shall: | ||||||||
4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.1.3.7 |
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4 | EHSCSM | 3.2.3 | The EHS HQ Coordinator shall develop an EHS MS awareness training package to communicate, as a minimum, the following: the EHS Policy, the process required to identify EHS aspects and hazards of contaminated work sites; the EHS objectives, targets, and performance measures of the NCSP; roles, responsibilities, and authorities of everyone involved with NCSP sites; legal compliance requirements and the consequences of non-compliance; the Internal Responsibility System (IRS); and due diligence. | ||||||||
4 | EHSCSM | 3.2.3 | The EHS HQ Coordinator shall ensure the EHS MS awareness-training package is delivered to all employees, and to new employees, students, consultants and contractors as part of a new job / site orientation, and afterwards as circumstances require. Everyone must be aware of: | ||||||||
4 | EHSCSM | 3.2.3 |
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4 | EHSCSM | 3.2.3 |
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4 | EHSCSM | 3.2.3 |
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4 | EHSCSM | 3.2.3 |
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4 | EHSCSM | 3.2.3 | The EHS HQ Coordinator shall develop a training package on the Standard Operating Procedures Manual to support EHS programs and provide NCSP personnel with the knowledge required to mitigate EHS risks, hazards, and impacts. This training will be provided to INAC staff involved in operational activities and will be refreshed on a regular basis and whenever circumstances require retraining. Regional Directors are responsible to ensure that training is delivered as required. | ||||||||
4 | EHSCSM | 3.2.3 | The EHS HQ Coordinator and the EHS Regional Coordinator shall annually assess the effectiveness and delivery of the EHS MS training package and specific training programs. They shall ensure these programs are modified as required to meet specific training needs. Individual employee responsibilities, abilities, and risk factors of the work sites shall be used as criteria to assess training needs. | ||||||||
4 | EHSCSM | 3.2.3 | The EHS Regional Coordinator shall review the job descriptions or other suitable vehicles for INAC project managers, field supervisors and field workers as new positions are created or before existing ones are posted for existence of EHS requirements, and shall recommend modifications where necessary to assure the appropriate EHS qualification. | ||||||||
4 | EHSCSM | 3.2.3 | Project Managers shall ensure that SSA and contract documents contain specifications regarding EHS competencies of key site personnel (e.g., site manager, EHS site supervisor) and that contractors are selected with due regard for the EHS competencies of the proposed teams. | ||||||||
4 | EHSCSM | 3.2.3 | Training records for all EHS training sessions and site orientations delivered by INAC personnel shall be maintained on file at the appropriate location (i.e., project site, regional office, or HQ) for a minimum of five years. The party responsible for overseeing delivery of the program (i.e., EHS HQ Coordinator, EHS Regional Coordinator or Project Manager) is responsible for ensuring training records is maintained. | ||||||||
4 | EHSCSM | 3.3.3 | NCSP Directors and Managers shall add EHS items to the standing agenda of existing monthly (or more frequent) staff meetings to: | ||||||||
4 | EHSCSM | 3.3.3 |
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4 | EHSCSM | 3.3.3 |
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4 | EHSCSM | 3.3.3 |
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4 | EHSCSM | 3.3.3 | Significant changes to the EHS MS including objectives and targets, programs, procedures and responsibilities shall be communicated internally to appropriate personnel. Methods for communication include e-mails, postings on an intranet site and bulletin boards, awareness training sessions and staff meetings. | ||||||||
4 | EHSCSM | 3.3.3 | Required changes to SOPs identified by regional staff shall be communicated to the Regional Director for review and approval and acted upon by the HQ EHS Coordinator. | ||||||||
4 | EHSCSM | 3.3.3 | Required changes to regional amplification of SOPs identified by regional staff shall be communicated to the Regional Director and acted upon by the regional EHS Coordinator. | ||||||||
4 | EHSCSM | 3.3.3 | The Project Manager shall ensure that contractor and consultant EHS requirements are documented in the contract documents. The Project Manager will ensure that start-up meetings are held with contractors and consultants to review the work requirements, including health & safety and environmental protection requirements, prior to starting work. In addition, contractors and consultants will issue progress reports that include an EHS reporting component, via e-mail, progress meetings and/or conference calls. Communication will take place within an appropriate timeframe, which may be weekly, monthly, or as required. | ||||||||
4 | EHSCSM | 3.3.3 | Concerns or issues related to sites where the site operator is a PWGSC contractor shall be communicated between the EHS HQ Coordinator and the RD, OGGO PWGSC. | ||||||||
4 | EHSCSM | 3.3.3 | Anyone who becomes aware of an unsafe situation shall take immediate action to manage the risk in the case of serious situations. In all other cases, the risk shall be communicated and documented in writing to the immediate supervisor, with copy to PWGSC (if the site operator is a PWGSC contractor) and to the Regional EHS Coordinator. | ||||||||
4 | EHSCSM | 3.3.3 | The EHS HQ Coordinator working with INAC Communications and others shall produce and distribute as appropriate: brochures, fact sheets, videos, reports, web page and other materials that describe the EHS MS. The HQ EHS Coordinator, regional health and safety personnel, and project managers will ensure the EHS Policy is publicly available. | ||||||||
4 | EHSCSM | 3.5.3 | All EHS MS documents shall contain standard identification on each page (i.e., header or footer with title, revision number, date, and page number and total) and be provided with a file number. | ||||||||
4 | EHSCSM | 3.5.3 | Document control is divided into two areas: | ||||||||
4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | 3.5.3 | EHS MS Documentation: | ||||||||
4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | ||||||||||
4 | EHSCSM | 3.5.3 |
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4 | EHSCSM | 3.6.3 | The EHS HQ Coordinator shall develop the EHS MS SOP Manual, in consultation with the EHS Regional Coordinator and Program/Project Managers. The SOPs shall be designed to establish suitable controls for the significant aspects and hazards identified for the NCSP, and control situations where their absence could lead to the deviation from the EHS Policy, objectives and targets. | ||||||||
4 | EHSCSM | 3.6.3 | The EHS Regional Coordinator shall develop additional regional EHS SOPs where the regional risk assessment identifies significant aspects or hazards not covered by the EHS SOP Manual, or where procedures need to be customized to reflect regional circumstances. These regional procedures form an important component of the Regional EHS MS Manual. | ||||||||
4 | EHSCSM | 3.6.3 | All sites/projects require a site specific EHS Plan. The Project Manager shall ensure that a site specific EHS Plan has been developed that meets or exceeds all regulatory requirements, as well as meets or exceeds all of the requirements in the EHS Policy. When two or more regulatory requirements apply, the most stringent will be followed. Where the project level risk assessment identifies significant aspects or hazards not covered by the Corporate or Regional EHS SOPs, site specific SOPs must be developed. These regional procedures form an important component of the Site EHS Plan. Where the site operator is a PWGSC contractor, the PWGSC project manager makes sure that this requirement is met through the contractors' site specific EHS plan. | ||||||||
4 | EHSCSM | 3.6.3 | Any new activity on site shall undergo a risk assessment/job hazard analysis to ensure that mitigation measures appropriate to the hazard are developed and implemented. The Project Manager is responsible for ensuring the risk assessment/job hazard analysis is completed in advance of commencing any new activity. | ||||||||
4 | EHSCSM | 3.6.4 | The Project Manager shall ensure specific emergency preparedness and response procedures are developed for all sites/projects. | ||||||||
4 | EHSCSM | 3.6.4 | Each Project Manager shall ensure that health and safety and spill contingency emergency procedures for their sites are tested at least annually through either mock incidents or drills, or tabletop exercises. The results of these exercises shall be documented and maintained on file as an EHS MS record. | ||||||||
4 | EHSCSM | 3.6.4 | After the occurrence of accidents and emergency situations, the Project Manager shall ensure that emergency procedures are reviewed and revised, where necessary. A record of the critical review of each situation, and the identified corrective and preventive action, shall be maintained on file as an EHS MS record. | ||||||||
4 | EHSCSM | 4.1.3 | The EHS MS performance shall be monitored and measured through: | ||||||||
4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 | Project Managers shall be responsible for preparing quarterly project reports that provide the required information to assess progress towards the EHS objectives and targets at the project and Program level. Information required for this report shall be collected, compiled and reported by the Project Managers and the regional health and safety personnel, including: | ||||||||
4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | 4.1.3 |
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4 | EHSCSM | ||||||||||
4 | EHSCSM | 4.1.3 | The EHS HQ Coordinator shall be responsible for quarterly reporting on program EHS performance to Regional Directors and the Director HQ. | ||||||||
4 | EHSCSM | 4.1.3 | The EHS HQ Coordinator, in cooperation with the RD OGGO PWGSC, shall develop and oversee implementation of the EHS MS audit program (described in Section 4.4), the purpose of which will be to determine conformance and compliance with EHS MS requirements, the EHS Policy and relevant legislation. | ||||||||
4 | EHSCSM | 4.1.3 | The EHS HQ Coordinator, in cooperation with the Regional EHS Coordinator and the RD OGGO PWGSC, shall organize and oversee site inspections on an as needed basis. | ||||||||
4 | EHSCSM | 4.1.3 | NCSP Project Managers, consultants and contractors shall develop procedures that describe the way their processes and work activities are monitored and controlled, including workplace and project inspections. These procedures shall include the required time intervals for tracking performance against EHS objectives and targets. | ||||||||
4 | EHSCSM | 4.1.3 | Project Managers, consultants and contractors shall develop procedures for the calibration and maintenance of monitoring equipment, which will include record maintenance and retention times. | ||||||||
4 | EHSCSM | 4.2.3 | At the Program level, non-conformance and non-compliance will be identified during: | ||||||||
4 | EHSCSM | 4.2.3 |
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4 | EHSCSM | 4.2.3 |
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4 | EHSCSM | 4.2.3 |
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4 | EHSCSM | 4.2.3 |
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4 | EHSCSM | 4.2.3 | For non-conformance and non-compliance events identified in 4.2.3.1, a root cause analysis should be conducted to determine the direct cause of the non-conformance / non-compliance. Corrective and Preventive Action Plans shall be developed for all identified non-conformances / non-compliances using the Corrective and Preventive Action Plan template found in the EHS Audit Program Guide. | ||||||||
4 | EHSCSM | 4.2.3 | EHS Policy and SOPs Manual infractions by personnel will be dealt with through a system of verbal and written warnings with review. | ||||||||
4 | EHSCSM | 4.2.3 | Project Managers shall report results quarterly (as part of regular project quarterly reporting) and the reports will be used for assessing the effectiveness of the EHS MS. | ||||||||
4 | EHSCSM | 4.2.3 | The audit process, quarterly reporting, and the EHS MS management review will determine the effectiveness of the corrective and preventive actions. | ||||||||
4 | EHSCSM | 4.4.3 | The EHS HQ Coordinator, in cooperation with Regional Directors and the RD OGGO PWGSC when necessary, shall develop and coordinate an annual EHS MS audit plan according to the requirements of the NCSP EHS Audit Program Guide. The audit plan shall, at a minimum, detail the frequency of audits and the sites subject to upcoming audits. | ||||||||
4 | EHSCSM | 4.4.3 | Audits shall be conducted to assess compliance with regulatory requirements and to ensure the EHS MS is implemented in accordance with the requirements of the EHS MS Manual (this document), the EHS SOP Manual, ISO 14001 and OHSAS 18001. Where feasible, joint INAC/PWGSC audits may be conducted. | ||||||||
4 | EHSCSM | 4.4.3 | Among other things, the EHS MS audit shall determine whether or not the: | ||||||||
4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
|
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4 | EHSCSM | ||||||||||
4 | EHSCSM | 4.4.3 | The frequency of audits may be based on: | ||||||||
4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
|
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
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4 | EHSCSM | 4.4.3 |
|
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4 | EHSCSM | 4.4.3 | Certified professional auditors shall conduct the audits in accordance with generally accepted audit principles and practices specified in the Guidelines for Quality and/or Environmental Management System Auditing, ISO 19011 and as outlined in the NCSP EHS Audit Program Guide. | ||||||||
4 | EHSCSM | 4.4.3 | The audit findings shall be documented and considered in EHS MS management reviews (described in Section 5.1.3). | ||||||||
4 | EHSCSM | 4.4.3 | The person responsible for an activity or area that has been audited shall prepare Corrective and Preventive Action Plans to address the deficiencies found by the audit, following the requirements provided in the NCSP EHS Audit Program Guide. | ||||||||
4 | EHSCSM | 5.1.3 | The EHS HQ Coordinator shall prepare and present the EHS MS assessment report to the Steering Committee and/or the Directors Committee annually. The review may include items such as: | ||||||||
4 | EHSCSM | 5.1.3 |
|
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4 | EHSCSM | 5.1.3 |
|
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4 | EHSCSM | 5.1.3 |
|
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4 | EHSCSM | 5.1.3 |
|
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4 | EHSCSM | 5.1.3 |
|
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4 | EHSCSM | 5.1.3 |
|
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4 | EHSCSM | 5.1.3 |
|
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4 | EHSCSM | 5.1.3 | The results of the review, including any changes to be made to the EHS MS and new EHS objectives and targets, shall be communicated to the HQ EHS Coordinator, Program Directors, regional health and safety personnel, and Project Managers. The results of the review shall be documented by the HQ EHS Coordinator and maintained on file as an EHS MS record. |
Appendix 2
Appendix 2A –E-mail Survey – Employees
Survey Name: Audit Questionnaire 1-2
1 | Name the Sector you work in: |
2 | Name the Region/HQ you work in: |
3 | How long have you been in the Department? |
4 | As part of your job do you visit project sites where construction or remediation work is being performed? |
5 | Have you received training from INAC in the hazards associated with construction / remediation sites? |
6 | Does INAC provide you with any of the following types of personal protective equipment: |
7 | Have you received training from INAC in the use, wearing and care of any of this equipment? |
8 | As part of your job do you travel to remote isolated locations? |
9 | Do you travel to these locations exclusively by car, truck or SUV? |
10 | Is it equipped with any of the following emergency equipment: |
11 | Have you received training from INAC in the use, wearing and care of any of this equipment? |
12 | Do you ever travel to these locations by all-terrain vehicle? |
13 | Is it equipped with a roll-over protection bar or canopy? |
14 | Is it equipped with any of the following emergency equipment: |
15 | Have you received training from INAC in the use, wearing and care of any of this equipment? |
16 | Do you travel to these locations by snowmobile? |
17 | Is it equipped with any of the following emergency equipment: |
18 | Have you received training from INAC in the use, wearing and care of any of this equipment? |
19 | Do you ever travel to these locations by small airplane? |
20 | Have you received training in safety around small airplanes? |
21 | Do you ever travel to these locations by helicopter? |
22 | Have you received training in safety around helicopter? |
23 | Do you ever travel to these locations by boat? |
24 | Have you received training in safe operation and travel on boats? |
25 | Is it equipped with any of the following emergency equipment: |
26 | Before traveling, is a travel plan prepared and filed with someone in INAC or an external agency? |
27 | Does the travel plan require you to periodically check-in? |
28 | Does the travel plan identify how emergency search and rescue would occur if necessary? |
29 | Have you received wilderness survival training? |
30 | As part of your job do you periodically encounter situations where you experience or perceive threats to your personal security? If yes, please describe some examples of those situations. |
31 | Have you received training in any of the following: |
32 | What measures are in place or available to you for your protection against persons who may pose a threat of harm to you: |
Appendix 2B – E-mail Survey - Managers & Supervisors
Survey Name: Audit Questionnaire 1-1
1 | Name the Sector you work in: |
2 | Name the Region/HQ you work in: |
3 | How long have you been in the Department? |
4 | Does your program / sector / region have a Health and Safety Advisor? |
5 | If so, has the Health and Safety Advisor been helpful to you in any of the following: |
6 | Do you believe that your program / sector / region / organizational unit has: |
7 | Do you believe that you have an adequate understanding of the OHS hazards faced by the personnel for whom you are responsible? |
8 | What OHS training have you been provided by INAC? |
9 | Do you believe that you have adequate OHS policies, procedures, and guidelines for the work performed by your personnel? |
10 | Do you believe that your personnel have had sufficient OHS training to enable them to work safely? |
11 | Have you ever been unable to address an OHS need to your personnel because of insufficient budget / funding? |
12 | Do you or your personnel have any other specific OHS needs that you feel are not being met? If so, what are they? |
13 | Are you aware of an incident investigation procedure? |
14 | Have you been trained in incident investigation? |
15 | What are the reporting requirements? |
16 | How do you ensure incidents get reported and investigated? |
17 | Have you received instruction to identify the kinds of health and safety records that are to be kept? |
18 | Do you keep such health and safety records? |
19 | List the health and safety records INAC requires you to keep. |
20 | Are there any examples of OHS initiatives that you specifically planned and budgeted for from 2007 to present? If so, what were those OHS initatives? |
21 | How much money did you budget for those OHS initiatives? |
22 | What do you consider to be examples of "essential OHS resources" for your area of responsibility (e.g. personal protective equipment, training services, ect.)? |
23 | Do you formally plan and budget for these essential OHS resources? |
24 | Approximately how much do you expect to spend on each of these essential OHS resources in 2008? |
25 | How much do you expect to spend on each of these essential OHS resources in 2009? |
Appendix 2C – E-mail Survey - Director & Director Generals
Survey Name: Audit Questionnaire 1-1
1 | Name the Sector you work in: |
2 | Name the Region/HQ you work in: |
3 | How long have you been in the Department? |
4 | Are there any examples of OHS initiatives that you specifically planned and budgeted for from 2007 to present? If so, what were those OHS initiatives? |
5 | How much money did you budget for those OHS initiatives? |
6 | What do you consider to be examples of "essential OHS resources" for your area of responsibility (e.g. personal protective equipment, training services, ect.)? |
7 | Do you formally plan and budget for these essential OHS resources? |
8 | Approximately how much was spent on each of these essential OHS resources in 2008? |
9 | How much do you expect to spend on each of these essential OHS resources in 2009? |
10 | Are you aware of an incident investigation procedure? |
11 | Have you been trained in incident investigation? |
12 | What are the reporting requirements? |
13 | How do you ensure incidents get reported and investigated? |
14 | Have you received instruction to identify the kinds of health and safety records that are to be kept? |
15 | Do you keep such health and safety records? |
16 | List the health and safety records INAC requires you to keep. |
Appendix 3
Appendix 3A - Document Request List for Corporate and Regional HS Staff / Advisors
Audit Checklist 2-1 (Documents Required by CLC-II or Treasury Board)
Audit Subjects: Corporate and Regional Health and Safety Staff / Advisors
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:
ITEM | SOURCE | MANDATORY DOCUMENTS / DOCUMENT REQUEST LIST | PROVIDED | NOT LOCATED | |
---|---|---|---|---|---|
1 | TBOHSD | Part 1, General | Procedure for resolution of "qualified person" dispute | ||
2 | TBOHSD | 7.1 | Report of any noise exposure investigation | ||
COHSR | 7.3(5) | ||||
3 | TBOHSD | 9.2.7 | Contingency procedures for cases in which there is a temporary interruption in the supply of drinking water and water for the removal of water-borne waste | ||
4 | TBOHSD | 10.1 | Record of all hazardous substances that, in the work place, are used, produced, handled, or stored | ||
COHSR | 10.3 | ||||
5 | TBOHSD | 10.5 | Written reports of any investigation or testing of exposure to hazardous substance | ||
COHSR | 10.5 | ||||
6 | COHSR | 10.5(b) | Written procedure for the control of the concentration or level of a hazardous substance in the work place | ||
7 | COHSR | 10.15 | Records of instruction and training for hazardous substances | ||
8 | TBOHSD | 10.6 | Asbestos management program | ||
9 | CLCII | 125.1(z.13) | Program for the provision of personal protective equipment, clothing, devices or materials | ||
10 | COHSR | 12.14(1) | Record of all protective equipment provided by the employer | ||
11 | TBOHSD | 15.1.1 | Hazardous occurrence investigation procedures and methodology | ||
12 | COHSR | 15.7(1) | Record of each minor injury | ||
13 | COHSR | 15.8 | Hazardous occurrence reports | ||
14 | TBOHSD | 16.1.2 | Procedures respecting the availability of first-aid services | ||
15 | TBOHSD | 16.2.2 | Written record of every injury or illness that requires first-aid treatment | ||
16 | COHSR | 16.2(1) | Written first aid instructions that provide for the prompt rendering of first aid to an employee for an injury, an occupational disease or an illness | ||
17 | COHSR | 16.13 | On-site first aid-records | ||
18 | COHSR | 16.13(2) | Off-site first aid-records | ||
19 | COHSR | 16.13(6) | Record of the expiry dates of the first aid certificates of the first aid attendants | ||
20 | TBOHSD | 1.0 | Health and Safety policy statement | ||
CLCII | 125.1(d)(2) | ||||
21 | CLCII | 125.1(z.03) | Hazard prevention program document | ||
COHSR | 19.1 | ||||
22 | COHSR | 19.8 | Hazard prevention program evaluation report | ||
23 | COHSR | 20.7 | Record of review of the effectiveness of work place violence prevention measures | ||
24 | COHSR | 20.10 | Records of information, instruction and training provided to each employee exposed to work place violence or a risk of work place violence | ||
25 | CLCII | 125.1(z.17) | Name, work telephone numbers and work locations of work place committee members and HS representatives | ||
26 | COHSR | 2.27(1) | Procedure for investigating situations in which the health or safety of an employee in the work place is or may be endangered by the air quality | ||
27 | COHSR | 2.27(7) | Records of every indoor air quality complaint and investigation for the past five years | ||
28 | COHSR | 7.7(2)(a) | Procedures for hearing protection fit, care and use | ||
29 | COHSR | 10.15 | Employee education program for hazardous substances (e.g. WHMIS training) | ||
30 | COHSR | 19.6(5) | Records of health and safety education, including education relating to ergonomics | ||
31 | COHSR | 10.49(d) | Maintenance and operating procedures to prevent the escape of flammable liquids and combustible liquids | ||
32 | COHSR | 12.15(1) | Written instructions in the use, operation and maintenance of the equipment | ||
33 | COHSR | Written emergency procedures | |||
34 | COHSR | 17.4(1) | Emergency procedures for spills, leaks, failure of lighting, fires | ||
35 | COHSR | 17.8(2) | Record of all instruction and training provided to every emergency warden, deputy emergency warden and monitor | ||
36 | COHSR | 17.5(2) | Emergency evacuation plan, where applicable, or a plan for evacuating employees who require special assistance in the event of a fire | ||
37 | COHSR | 17.10(2) | Record of each Emergency Warden meeting | ||
38 | COHSR | 17.10(2) | Record of each emergency evacuation drill | ||
39 | COHSR | 14.20 | Record of maintenance, use and testing of material handling equipment before initial use | ||
40 | COHSR | 14.23(4) | Record of training for operators of material handling equipment | ||
41 | COHSR | 14.29(4) | Record of any repair or modification work and of any restriction on use imposed on material handling equipment | ||
42 | COHSR | 15.4 | Records of any motor vehicle accident | ||
43 | COHSR | 15.10 | Annual report to HRSDC Labour Program, outlining the number of accidents, occupational diseases and other hazardous occurrences for each identified workplace of which management is aware | ||
44 | COHSR | 17.9 | Record of inspection of all fire escapes, exits, stairways and fire protection equipment in a building | ||
45 | COHSR | 20.9 | Records of investigation of employee reports of violence | ||
46 | COHSR | 20.5 | Assessment of potential for work place violence | ||
47 | COHSR | 20.6(3) | Procedures for appropriate follow-up maintenance and corrective measures for violence control measures that have been established | ||
48 | COHSR | 19.5(2) | Preventive maintenance program in respect of equipment or systems where failures could harm employees |
Appendix 3B - Document Request List for Committees, HS Representatives and Designated Managers
Audit Checklist 3-1 (Functions of PHSC, WHSC, HSRs)
Audit Subjects:
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:
ITEM | SOURCE | APPLI-CATION | AUDIT CRITERIA | AUDIT QUESTIONS | RESPONSE AFF/NEG | REQUIRED SUPPORTING EVIDENCE FOR AFFIRMATIVES | |
---|---|---|---|---|---|---|---|
1 | CLCII | 136(2) | HSR | The health and safety representative for a work place shall be selected as follows: (a) the employees at the work place who do not exercise managerial functions shall select from among those employees the person to be appointed; or (b) if those employees are represented by a trade union, the trade union shall select the person to be appointed, in consultation with any employees who are not so represented, and subject to any regulations made under subsection (11). | How were you selected or appointed the HSR? | ||
2 | CLCII | 136(5)(b) | HSR | Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints. | Who maintains records for work accidents, injuries, and any health and safety complaints for this workplace? | Hazardous occurrence / injury / accident reports. | |
3 | CLCII | 136(5)(b) | HSR | Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints. | Do you periodically review monitor data relating to those accidents, injuries, hazards and complaints? | ||
4 | CLCII | 136(5)(b) | HSR | Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints. | How many accidents, injuries, hazards and complaints have there been in this workplace in the past 12 months? | ||
5 | CLCII | 136(5)(d) | HSR | Shall participate in the implementation and monitoring of the hazard prevention program. | Is there a hazard prevention program for your workplace? | Copy of program document. | |
6 | CLCII | 136(5)(d) | HSR | Shall participate in the implementation and monitoring of the hazard prevention program. | What role do you play in implementation and monitoring the hazard prevention program? | ||
7 | CLCII | 136(5)(e) | HSR | Where the hazard prevention program does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in healt and safety matters related to those hazards. | What information, instruction or training have employees received in this workplace on those additional hazards? | Copy of relevant information, instruction or training materials. Records of training delivery / attendance. | |
8 | CLCII | 136(5)(e) | HSR | Where the hazard prevention program does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in healt and safety matters related to those hazards. | What additional hazards do employees in this workplace encounter that are not included in the hazard prevention program? | Copy of program document. | |
9 | CLCII | 136(5)(e) | HSR | Where the hazard prevention program does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in healt and safety matters related to those hazards. | What role have you played in developing any programs for these additional hazards? | ||
10 | CLCII | 136(5)(g) | HSR | Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise to advise the representative on those matters. | What health and safety inquiries, investigations, studies and inspections have you participated in? | Copies of any such studies or inspection records. | |
11 | CLCII | 136(5)(i) | HSR | Shall participate in the implementation of changes that may affect occupational health and safety, including work processes and procedures. | Have you been involved in planning or implementing changes in the workplace that may affect employee health or safety - for example, renovations, introduction of new equipment or materials, significant changes in work procedures or practices? | ||
12 | CLCII | 136(5)(j) | HSR | Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; | Do you inspect each month all or part of the work place, and is the entire workplace covered over the course of a year? | Inspection records. | |
13 | CLCII | 136(5)(k) | HSR | Shall participate in the development of health and safety policies and programs; | Have you been involved in planning or implementing health and safety policies or programs at the workplace? | Referenced health and safety policy and program documents. | |
14 | CLCII | 136(5)(l) | HSR | Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; and | Have you participated in any investigations of exposure of employees to hazardous substances? | Exposure assessment reports. | |
15 | CLCII | 136(5)(m) | HSR | Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials. | Have you participated in the implementation and monitoring any personal protective clothing use programs? | Program documents. | |
16 | OHSSRR | HSR | Oversee and monitor the implementation of the OHS program within their area of responsibility. | Do you ever conduct observations or reviews to determine if requirements of health and safety programs are being adhered to by personnel? | |||
17 | OHSSRR | HSR | Oversee and monitor the implementation of the OHS program within their area of responsibility. | What kinds of observations or reviews have you performed (e.g. inspections, review of records, etc.)? | |||
18 | OHSSRR | HSR | Oversee and monitor the implementation of the OHS program within their area of responsibility. | What have you observed / found? | |||
19 | CLCII | 134.1(4)(a) | PHSC | Shall participate in the development of health and safety policies and programs; | Has PHSC participated in the development of health and safety policies and programs? | Minutes reflecting these activities. | |
20 | CLCII | 134.1(4)(c) | PHSC | Shall participate in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters; | Has PHSC participated in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters? | Minutes reflecting these activities, and the referenced hazard prevention program document. | |
21 | CLCII | 134.1(4)(d) | PHSC | Shall participate to the extent that it considers necessary in inquiries, investigations, studies and inspections pertaining to occupational health and safety; | Has PHSC participated to the extent that it considers necessary in inquiries, investigations, studies and inspections pertaining to occupational health and safety? | Minutes reflecting these activities, and the referenced investigation / inspection reports and studies. | |
22 | CLCII | 134.1(4)(e) | PHSC | Shall participate in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials; | Has PHSC participated in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials? | Minutes reflecting these activities, and the referenced personal protective equipment program document. | |
23 | CLCII | 134.1(4)(g) | PHSC | Shall monitor data on work accidents, injuries and health hazards; and | Does PHSC monitor data on work accidents, injuries and health hazards? | Minutes reflecting this activity, and the data records. | |
24 | CLCII | 134.1(4)(h) | PHSC | Shall participate in the planning of the implementation and in the implementation of changes that might affect occupational health and safety, including work processes and procedures. | Does PHSC participate in the planning of the implementation and in the implementation of changes that might affect occupational health and safety, including work processes and procedures? | Minutes reflecting this activity. | |
25 | CLCII | 134.1(4)(i) | PHSC | Shall meet during regular working hours at least quarterly and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours. | How many meetings has the PHSC held in 2008/2009? | Minutes of the meeting. | |
26 | CLCII | 135.1(1) | PHSC | A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have been selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented. | Is the PHSC comprised of at least 2 members? | Minutes, and / or records of appointment. | |
27 | CLCII | 135.1(1) | PHSC | A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have been selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented. | Are 50% or more of the PHSC members non-managerial personnel? | Job titles of personnel from INAC employee directory, with confirmation from INAC HR Directorate of the status of any positions where managerial / non-managerial status is uncertain. | |
28 | CLCII | 135.1(6) | PHSC | The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b). | Does the PHSC have alternate members? | Minutes or records of appointment. | |
29 | CLCII | 135.1(7) | PHSC | A committee shall have two chairpersons selected from among the committee members. One of the chairpersons shall be selected by the employee members and the other shall be selected by the employer members. | Who are the management and non-management co-chairs? | Minutes or records of appointment. | |
30 | CLCII | 135.1(8) | PHSC | The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member us designated, the member shall be an employee member. | Have committee members been formally assigned responsibilities (e.g. inspections)? | Minutes evidencing same. | |
31 | CLCII | 135.1(8) | PHSC | The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member us designated, the member shall be an employee member. | Are at least half of the members assigned specific functions non-management members? | Minutes. | |
32 | CLCII | 135.1(9) | PHSC | A committee shall ensure that accurate records are kept of all of the matters that come before it and that minutes are kept of its meetings. The committee shall make the minutes and records available to a health and safety officer at the officer's request | Has the committee maintained minutes? | Minutes. | |
33 | OHSSRR | PHSC | Make recommendations and report its activities to the Deputy Minister through the National Union Management Consultation Committee. | Does the PHSC make recommendations and report on its activities to the National Union Management Consultation Committee? | Any written recommendations or reports to the National Union Management Consultation Committee, or Minutes of the NUMCC evidencing same. | ||
34 | OHSSRR | PHSC | Policy Health and Safety Committee shall address strategic departmental health and safety matters. | Do you believe that the PHSC deals primarily with OHS matters that are important and effect all or most of INAC, or employees facing the highest risks? | Minutes. | ||
35 | HSCRR | 3 | WHSC | The employer shall select the member or members of a safety and health committee to represent him from among persons who exercise managerial functions. | How were the management members selected or appointed? | Minutes or records of appointment. | |
36 | HSCRR | 4 | WHSC | Where any employees at a work place are not represented by a trade union, those employees shall select, by majority vote, the member or members of the safety and health committee to represent them. | How were the non-management members selected or appointed? | Minutes or records of appointment. | |
37 | HSCRR | 7 | WHSC | Where a member of a safety and health committee resigns or ceases to be a member for any other reason, the vacancy shall be filled within 30 days after the next regular meeting of the committee. | Have vacancies been filled within 30 days? | Minutes. | |
38 | HSCRR | 8 | WHSC | Quorum of a safety and health committee shall consist of the majority of the members of the committee, of which at least half are representatives of the employees and at least one is a representative of the employer. | Do all meetings comply with quorum requirements? | Minutes. | |
39 | HSCRR | 10 | WHSC | The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen reffered to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report reffered to in paragraph (a), post a copy of the report in the conspicious place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months. | Has the committee prepared the annual report? | Copies of past annual reports. | |
40 | HSCRR | 10 | WHSC | The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen reffered to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report reffered to in paragraph (a), post a copy of the report in the conspicious place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months. | Have these annual reports been submitted to HRSDC? | Evidence of submittal. | |
41 | HSCRR | 10 | WHSC | The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen reffered to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report reffered to in paragraph (a), post a copy of the report in the conspicious place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months. | Have these annual reports been posted? | Evidence of posting. | |
42 | CLCII | 135.1(1) | WHSC | A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have be selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented. | Is the WHSC comprised of at least 2 members? | Procès-verbaux et/ou dossiers des nominations | |
43 | CLCII | 135.1(10) | WHSC | Work place committee shall meet during regular working hours at least nine times a year at regular intervals and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours. | Are 50% or more of the WHSC members non-managerial personnel? | Job titles of personnel from INAC employee directory, with confirmation from INAC HR Directorate of the status of any positions where managerial / non-managerial status is uncertain. | |
44 | CLCII | 135.1(6) | WHSC | The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b). | Does the WHSC have alternate members? | Minutes or records of appointment. | |
45 | CLCII | 135.1(7) | WHSC | A committee shall have two chairpersons selected from among the committee members. One of the chairpersons shall be selected by the employee members and the other shall be selected by the employer members. | Who are the management and non-management co-chairs? | Minutes or records of appointment. | |
46 | CLCII | 135.1(7)(a) | WHSC | Shall consider and expeditiously dispose of matters concerning health and safety raised by members of the committee or referred to it by a work place committee or a health and safety representative; | Does the WHSC receive and discuss OHS concerns or complaints raised by employees? | Minutes evidencing same. | |
47 | CLCII | 135.1(7)(b) | WHSC | Shall participate in the implementation and monitoring of the hazard prevention program. | Is there a hazard prevention program for your workplace? | Copy of program document. | |
48 | CLCII | 135.1(7)(b) | WHSC | Shall participate in the implementation and monitoring of the hazard prevention program. | What role does the WHSC play in implementation and monitoring the hazard prevention program? | Minutes evidencing same. | |
49 | CLCII | 135.1(7)(c) | WHSC | Shall participate in the development, implementation and monitoring of a program for the prevention of those hazards (not covered by the hazard prevention program) that also provides for the education of employees in health and safety matters related to those hazards; | Has the WHSC participated in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters? | Minutes reflecting these activities, and the referenced hazard prevention program document. | |
50 | CLCII | 135.1(7)(e) | WHSC | Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the committee on those matters; | What health and safety inquiries, investigations, studies and inspections has the WHSC participated in? | Minutes evidencing same. | |
51 | CLCII | 135.1(7)(f) | WHSC | Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program; | Has the WHSC participated in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials? | Minutes reflecting these activities, and the referenced personal protective equipment program document. | |
52 | CLCII | 135.1(7)(g) | WHSC | Shall ensure that adequate records are maintained on work accidents, injuries and health hazards relating to the health and safety of employees and regularly monitor data relating to those accidents, injuries and hazards; | Who maintains records for work accidents, injuries, and any health and safety complaints for this workplace? | Hazardous occurrence / injury / accident reports. | |
53 | CLCII | 135.1(7)(g) | WHSC | Shall ensure that adequate records are maintained on work accidents, injuries and health hazards relating to the health and safety of employees and regularly monitor data relating to those accidents, injuries and hazards; | Does the WHSC periodically review monitor data relating to those accidents, injuries, hazards and complaints? | Minutes evidencing same | |
54 | CLCII | 135.1(7)(i) | WHSC | Shall participate in the implementation of changes that might affect occupational health and safety, including work processes and procedures. | Has the WHSC been involved in planning or implementing changes in the workplace that may affect employee health or safety - for example, renovations, introduction of new equipment or materials, significant changes in work procedures or practices? | Minutes evidencing same | |
55 | CLCII | 135.1(7)(j) | WHSC | Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; | Has the WHSC participated in any investigations of exposure of employees to hazardous substances? | Exposure assessment reports. | |
56 | CLCII | 135.1(7)(k) | WHSC | Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; and | Does the WHSC inspect each month all or part of the work place, and is the entire workplace covered over the course of a year? | Inspection records. | |
57 | CLCII | 135.1(8) | WHSC | The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member. | Have committee members been formally assigned responsibilities (e.g. inspections)? | Minutes evidencing same | |
58 | CLCII | 135.1(8) | WHSC | The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member. | Are at least half of the members assigned specific functions non-management members? | Minutes | |
59 | CLCII | 135.1(9) | WHSC | A committee shall ensure that accurate records are kept of all of the matters that come before it and that minutes are kept of its meetings. The committee shall make the minutes and records available to a health and safety officer at the officer's request. | Has the committee maintained minutes? | Minutes | |
60 | HSCRR | 5(1) | WHSC | A safety and health committee shall have two chairmen selected from among the members of the committee, one being selected by the representatives of the employees and the other by the representatives of the employer. | Are there management and non-management co-chairs for the WHSC? | Minutes | |
61 | HSCRR | 5(2) | WHSC | The chairmen referred to in subsection (1) shall act alternately for such period of time as the safety and health committee specifies in its rules of procedure. | How has the WHSC decided on which co-chair will chair which meetings? | Minutes or terms of reference explaining same. | |
62 | HSCRR | 9(1) | WHSC | The minutes of each safety and health committee meeting shall be signed by the two chairmen referred to in subsection 5(1). | Are minutes signed by the co-chairs? | Minutes | |
63 | HSCRR | 9(2) | WHSC | The chairman selected by the representatives of the employer shall provide, as soon as possible after each safety and health committee meeting, a copy of the minutes referred to in subsection (1) to the employer and to each member of the safety and health committee. | Are minutes distributed within a month of each meeting? | For minutes, check meeting dates against minutes issuance dates (if indicated). | |
64 | HSCRR | 9(3) | WHSC | The employer shall, as soon as possible after receiving a copy of the minutes referred to in subsection (2), post a copy of the minutes in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for a month. | Are minutes posted in a conspicuous place? | ||
65 | HSCRR | 9(4) | WHSC | A copy of the minutes referred to in subsection (1) shall be kept by the employer at the work place to which it applies or at the head office of the employer for a period of two years from the day on which the safety and health committee meeting is held in such a manner that it is readily available for examination by a safety officer. | Are minutes retained for at least two years? | ||
66 | OHSSR | WHSC | Committees shall report to the most senior officer responsible for that workplace, or to their delegate. | What senior officer does the WHSC report to? |
Appendix 3C - Document Request List for Corporate (HQ) and Regional CSMP EHS Coordinators
Audit Checklist 4-1 (Documents Required by EHS Contaminated Sites Manual - EHS Coordinators)
Audit Subjects:
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:
AUDIT AREA | SOURCE | APPLI-CATION | AUDIT CRITERIA | DOCUMENT REQUEST LIST | PROVIDED? | PROPER STD IDENTIFIERS? | CONTENT MEETS SPECS? | |
---|---|---|---|---|---|---|---|---|
4 | EHSCSM | 3.3.3 | HQ EHSC | Significant changes to the EHS MS including objectives and targets, programs, procedures and responsibilities shall be communicated internally to appropriate personnel. Methods for communication include e-mails, postings on an intranet site and bulletin boards, awareness training sessions and staff meetings. | Any e-mails, internet postings or other internal communications advising of significant changes to the Contaminated Sites EHS Management System, in 2007 to date. | |||
4 | EHSCSM | 3.3.3 | HQ EHSC | Concerns or issues related to sites where the site operator is a PWGSC contractor shall be communicated between the EHS HQ Coordinator and the RD, OGGO PWGSC. | Any e-mails to PWGSC respecting contractor EHS activities, EHS non-compliance, or EHS poor performance, 2007 to date. | |||
4 | EHSCSM | 4.1.3 | HQ EHSC | The EHS HQ Coordinator, in cooperation with the Regional EHS Coordinator and the RD OGGO PWGSC, shall organize and oversee site inspections on an as needed basis. | Project Site inspection records. | |||
4 | EHSCSM | 2.1.3.3 | HQ EHSC | The EHS HQ Coordinator shall prepare a summary analysis of the EHS Aspects and Hazards Register in January of each year and provide recommendations related to the management of program-level aspects and hazards to the Director – NCSP HQ. | Annual summary analysis of the EHS Aspects and Hazards Register, and recommendations. | |||
4 | EHSCSM | 2.3.3.1 | HQ EHSC | The EHS HQ Coordinator shall develop and recommend annual EHS objectives and targets for the NAO NCSP. The Director NCSP, as Chair of the Directors' Committee, is responsible for approving these objectives and targets. NCSP EHS objectives and targets shall be documented in the Performance Measurement Strategy of the program RMAF. | The Performance Measurement Strategy of the Results-Based Management and Accountability Framework. | |||
4 | EHSCSM | 2.3.3.1 | HQ EHSC | The EHS HQ Coordinator shall develop and recommend annual EHS objectives and targets for the NAO NCSP. The Director NCSP, as Chair of the Directors' Committee, is responsible for approving these objectives and targets. NCSP EHS objectives and targets shall be documented in the Performance Measurement Strategy of the program RMAF. | The 2007 and 2008 annual EHS objectives and targets provided to the Director - NCSP. | |||
4 | EHSCSM | 2.3.3.4 | HQ EHSC | Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning. | Programs to achieve the annual EHS objectives and targets. | |||
4 | EHSCSM | 3.6.3 | HQ EHSC | The EHS HQ Coordinator shall develop the EHS MS SOP Manual, in consultation with the EHS Regional Coordinator and Program/Project Managers. The SOPs shall be designed to establish suitable controls for the significant aspects and hazards identified for the NCSP, and control situations where their absence could lead to the deviation from the EHS Policy, objectives and targets. | EHS Management System Standard Operating Procedures Manual. | |||
4 | EHSCSM | 4.1.3 | HQ EHSC | The EHS HQ Coordinator shall be responsible for quarterly reporting on program EHS performance to Regional Directors and the Director HQ. | Quarterly reports on program EHS performance to Regional Directors and the Director HQ, for 2007 to date. | |||
4 | EHSCSM | 4.4.3 | HQ EHSC | The person responsible for an activity or area that has been audited shall prepare Corrective and Preventive Action Plans to address the deficiencies found by the audit, following the requirements provided in the NCSP EHS Audit Program Guide. | Corrective and Preventive Action Plans prepared as part of NCSP EHS Audits. | |||
4 | EHSCSM | 2.4 | HQ EHSC | There shall be an EHS Audit Program Guide. | The NCSP EHS Audit Program Guide. | |||
4 | EHSCSM | 5.1.3 | HQ EHSC | The EHS HQ Coordinator shall prepare and present the EHS MS assessment report to the Steering Committee and/or the Directors Committee annually. The review may include items such as:
|
Annual EHS Management System assessment reports for 2007 and 2008. | |||
4 | EHSCSM | 5.1.3 | HQ EHSC | The results of the review, including any changes to be made to the EHS MS and new EHS objectives and targets, shall be communicated to the HQ EHS Coordinator, Program Directors, regional health and safety personnel, and Project Managers. The results of the review shall be documented by the HQ EHS Coordinator and maintained on file as an EHS MS record. | Documents describing the results of senior management reviews of the EHS Management System. | |||
4 | EHSCSM | 3.3.3 | HQ EHSC | Required changes to SOPs identified by regional staff shall be communicated to the Regional Director for review and approval and acted upon by the HQ EHS Coordinator. | Changes made to SOPs in response to requests of Regional Directors. | |||
4 | EHSCSM | 4.4.3 | HQ EHSC | The EHS HQ Coordinator, in cooperation with Regional Directors and the RD OGGO PWGSC when necessary, shall develop and coordinate an annual EHS MS audit plan according to the requirements of the NCSP EHS Audit Program Guide. The audit plan shall, at a minimum, detail the frequency of audits and the sites subject to upcoming audits. | The annual EHS Management System audit plans for 2008, 2009 and 2010. | |||
4 | EHSCSM | 4.4.3 | HQ EHSC | Among other things, the EHS MS audit shall determine whether or not the: | Reports of EHS Management System audits, 2007 to date. | |||
4 | EHSCSM | 4.4.3 | HQ EHSC |
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4 | EHSCSM | 4.4.3 | HQ EHSC |
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4 | EHSCSM | 4.4.3 | HQ EHSC | The frequency of audits may be based on: | ||||
4 | EHSCSM | 4.4.3 | HQ EHSC |
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4 | EHSCSM | 4.4.3 | HQ EHSC |
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4 | EHSCSM | 4.4.3 | HQ EHSC |
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4 | EHSCSM | 4.4.3 | HQ EHSC | Certified professional auditors shall conduct the audits in accordance with generally accepted audit principles and practices specified in the Guidelines for Quality and/or Environmental Management System Auditing, ISO 19011 and as outlined in the NCSP EHS Audit Program Guide. | Names and qualifications of auditors. | |||
4 | EHSCSM | Policy Statement | HQ EHSC | All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations. | Roster of EHS training programs offered and provided to NCSP employees. | |||
4 | EHSCSM | 3.2.3 | HQ EHSC | The EHS HQ Coordinator shall develop an EHS MS awareness training package to communicate, as a minimum, the following: the EHS Policy, the process required to identify EHS aspects and hazards of contaminated work sites; the EHS objectives, targets, and performance measures of the NCSP sites; legal compliance requirements and the consequences of non-compliance; the Internal Responsibility System (IRS); and due diligence. | The EHS MS Awareness Training Package. | |||
4 | EHSCSM | 3.2.3 | HQ EHSC | The EHS HQ Coordinator shall ensure the EHS MS awareness-training package is delivered to all employees, and to new employees, students, consultants and contractors as part of a new job / site orientation, and afterwards as circumstances require. | Records of training of NCSP employees in the EHS MS Awareness Training Package. | |||
4 | EHSCSM | 3.2.3 | HQ EHSC | The EHS HQ Coordinator shall develop a training package on the Standard Operating Procedures Manual to support EHS programs and provide NCSP personnel with the knowledge required to mitigate EHS risks, hazards, and impacts. This training will be provided to INAC staff involved in operational activities and will be refreshed on a regular basis and whenever circumstances require retraining. Regional Directors are responsible to ensure that training is delivered as required. | The training package on the EHS MS Standard Operating Procedures Manual. | |||
4 | EHSCSM | 3.2.3 | HQ EHSC | The EHS HQ Coordinator shall develop a training package on the Standard Operating Procedures Manual to support EHS programs and provide NCSP personnel with the knowledge required to mitigate EHS risks, hazards, and impacts. This training will be provided to INAC staff involved in operational activities and will be refreshed on a regular basis and whenever circumstances require retraining. Regional Directors are responsible to ensure that training is delivered as required. | Records of employee training in the EHS MS Standard Operating Procedures Manual. | |||
4 | EHSCSM | 3.2.3 | HQ EHSC | The EHS HQ Coordinator and the EHS Regional Coordinator shall annually assess the effectiveness and delivery of the EHS MS training package and specific training programs. They shall ensure these programs are modified as required to meet specific training needs. Individual employee responsibilities, abilites, and risk factors of the work sites shall be used as criteria to assess training needs. | Records of assessments of the effectiveness and delivery of the EHS Management System Training Package, and the delivery of specific EHS training programs. | |||
4 | EHSCSM | Policy Statement | REG EHSC | All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations. | Roster of EHS training programs offered and provided to NCSP employees. | |||
4 | EHSCSM | Policy Statement | REG EHSC | All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations. | Records of EHS training of NCSP employees. | |||
4 | EHSCSM | Policy Statement | REG EHSC | Each Region shall establish EHS Procedures consistent with the ISO 14001 and OHSAS 18001 requirements, appropriate to the nature, scale and EHS impacts of all Northern Contaminated Sites Program activities. These Procedures shall be documented in a Regional EHS Manual and shall include a commitment to:
|
Regional EHS Procedures. | |||
4 | EHSCSM | 2.1.3.6 | REG EHSC | Known hazards at non-active sites (i.e., those awaiting assessment, remediation or monitoring) shall be included in the Regional EHS aspects and hazards register to ensure such hazards are managed. | Regional EHS Aspects and Hazard Register. | |||
4 | EHSCSM | 2.3.3.2 | REG EHSC | The EHS Regional Coordinator shall develop and recommend annual EHS objectives and targets for their region. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in regional-level work plans. | Regional-level workplans for 2007 to 2009 showing EHS Annual Objectives and Targets. | |||
4 | EHSCSM | 3.6.3 | REG EHSC | The EHS Regional Coordinator shall develop additional regional EHS SOPs where the regional risk assessment identifies significant aspects or hazards not covered by the EHS SOP Manual, or where procedures need to be customized to reflect regional circumstances. These regional procedures form an important component of the Regional EHS MS Manual. | Regional EHS Standard Operating Procedures. | |||
4 | EHSCSM | 3.3.3 | REG EHSC | Required changes to regional amplification of SOPs identified by regional staff shall be communicated to the Regional Director and acted upon by the regional EHS Coordinator. | Examples of Regional EHS SOPs amended in response to requests of the Regional Director. | |||
4 | EHSCSM | 3.2.3 | REG EHSC | The EHS Regional Coordinator shall review the job descriptions or other suitable vehicles for INAC project managers, field supervisors and field workers as new positions are created or before existing ones are posted for existence of EHS requirements, and shall recommend modifications where necessary to assure the appropriate EHS qualification. | Examples of job descriptions amended on the advice of the EHS Regional Coordinator to incorporate EHS qualifications requirements. | |||
4 | EHSCSM | 3.2.3 | REG EHSC | Training records for all EHS training sessions and site orientations delivered by INAC personnel shall be maintained on file at the appropriate location (i.e., project site, regional office, or HQ) for a minimum of five years. | Records of EHS training (list of courses and dates, lists of attendees) that has been provided in the region. | |||
4 | EHSCSM | 2.3.3.4 | REG EHSC | Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning. | Regional-level Programs to achieve EHS annual objectives and targets. |
Appendix 3D - Document Request List for CSMP Project Managers
Audit Checklist 4-2 (Documents Required by EHS Contaminated Sites Manual - Project Managers)
Audit Subjects:
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:
AUDIT AREA | SOURCE | APPLI-CATION | AUDIT CRITERIA | DOCUMENT REQUEST LIST | PROVIDED? | PROPER STD IDENTIFIERS? | CONTENT MEETS SPECS? | |
---|---|---|---|---|---|---|---|---|
4 | EHSCSM | 2.3.3.4 | PROJ MGR | Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning. | Project-level programs to achieve the annual EHS objectives and targets. | |||
4 | EHSCSM | A.2.3 | PROJ MGR | PWGSC will review and consolidate EHS requirements in specifications. | Project specifications (sample size to be determined). | |||
4 | EHSCSM | A.2.3 | PROJ MGR | At start-up meetings:
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Project start-up meeting minutes (sample size to be deteremined). | |||
4 | EHSCSM | A.2.3 | PROJ MGR | Crown to review the Prime's EHS Plan
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Prime Contractors EHS Plans for projects (sample size to be determined). | |||
4 | EHSCSM | A.2.3 | PROJ MGR | INAC and PWGSC parties will determine and implement site-specific reporting, inspections and auditing requirements. | Documents describing site-specific EHS reporting, inspections and auditing requirements (sample size to be determined). | |||
4 | EHSCSM | Policy Statement | PROJ MGR | Ensure all individuals involved with a project (i.e., including Site Operator and INAC employees, consultants and contractors, and visitors) are aware of and comply with the EHS policy. | Documents describing how the NCSP EHS Policy is communicated to all persons involved in a project. | |||
4 | EHSCSM | 2.1.3.5 | PROJ MGR | A hazard assessment is required before commencing any project. Project specific job / task hazards will be identified by the site supervisor (or the Project Manager if no supervisor is assigned for a site) and addressed using the job safety analysis procedure found in the Standard Operating Procedures (SOP) Manual. Results of the hazard assessment are to be communicated to the appropriate staff. | Pre-project hazard assessments (sample size to be determined). | |||
4 | EHSCSM | 3.1.3.6 | PROJ MGR | Identify project EHS aspects and hazards and develop project-level procedures and programs for all EHS aspects and hazards not covered by corporate or regional procedures, as required (i.e., amplifying the SOP Manual); | Project-level EHS procedures (sample size to be determined, will overlap with projects for which hazard assessments are requested). | |||
4 | EHSCSM | 3.1.3.6 | PROJ MGR | Ensure the requirements of the EHS Policy, EHS MS Manual and SOP Manual are transferred to non-INAC project participants (e.g., PWGSC, contractors and consultants) as minimum requirements, through SSAs or contracts; | Project contracts (sample size to be determined). | |||
4 | EHSCSM | 3.1.3.6 | PROJ MGR | Ensure the requirements of the EHS Policy, EHS MS Manual and SOP Manual are transferred to non-INAC project participants (e.g., PWGSC, contractors and consultants) as minimum requirements, through SSAs or contracts; | Project staff service agreements with PWGSC. | |||
4 | EHSCSM | 3.1.3.6 | PROJ MGR | Request and review site specific EHS Plans to ensure EHS requirements are documented, and inspecting project activities and operations to ensure site activities conform to requirements; | Project site specific EHS plans (sample size to be determined, will overlap with projects for which hazard assessments are requested). | |||
4 | EHSCSM | 3.1.3.6 | PROJ MGR | Request and review site specific EHS Plans to ensure EHS requirements are documented, and inspecting project activities and operations to ensure site activities conform to requirements; | Project EHS inspection records - prepared by any party (sample size to be determined, will overlap with projects for which hazard assessments are requested). | |||
4 | EHSCSM | 3.1.3.7 | PROJ MGR | Forward project-specific EHS plan submittals to qualified professional for review; | Project-specific EHS plan reviews performed by third party professionals (sample size to be determined, will overlap with projects for which hazard assessments are requested). | |||
4 | EHSCSM | 4.1.3 | PROJ MGR | NCSP Project Managers, consultants and contractors shall develop procedures that describe the way their processes and work activities are monitored and controlled, including workplace and project inspections. These procedures shall include the required time intervals for tracking performance against EHS objectives and targets. | Procedures developed by any of NCSP Project Managers, consultants or contractors that describe the way their processes and work activities are monitored and controlled, including workplace and project inspections. | |||
4 | EHSCSM | 4.2.3 | PROJ MGR | or non-conformance and non-compliance events identified in 4.2.3.1, a root cause analysis should be conducted to determine the direct cause of the non-conformance / non-compliance. Corrective and Preventive Action Plans shall be developed for all identified non-conformances / non-compliances using the Corrective and Preventive Action Plan template found in the EHS Audit Program Guide. | Root causes analysis reports for any identified instances of non-compliance or non-comformance. | |||
4 | EHSCSM | 4.2.3 | PROJ MGR | Project Managers shall report (non-conformance and non-compliance) results quarterly (as part of regular project quarterly reporting) and the reports will be used for assessing the effectiveness of the EHS MS. | Quarterly non-conformance and non-compliance reports of Project Managers (sample size to be determined). | |||
4 | EHSCSM | 2.3.3.3 | PROJ MGR | Project Managers shall develop and recommend annual EHS objectives and targets for their project. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in project-level detailed work plans. | Project-level detailed work plans that contain annual EHS objectives and targets for the project (sample size to be determined). | |||
4 | EHSCSM | 4.2.3 | PROJ MGR | EHS Policy and SOPs Manual infractions by personnel will be dealt with through a system of verbal and written warnings with review. | Written warnings on record (sample size of projects to be determined). | |||
4 | EHSCSM | 4.2.3 | PROJ MGR | Training records for all EHS training sessions and site orientations delivered by INAC personnel shall be maintained on file at the appropriate location (i.e., project site, regional office, or HQ) for a minimum of five years. | Training records for all EHS training sessions and site orientations delivered by INAC personnel for the project (sample size of projects to be determined). |
Appendix 4a
Appendix 4A – OHS Program Documents and Records
Appendix 4A - Document Request List for Corporate and Regional HS Staff / Advisors
Audit Checklist 2-1 (Documents Required by CLCII or Treasury Board)
Audit Subjects: Corporate and Regional Health and Safety Staff / Advisors
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:
Item | Source | Mandatory Documents / Document Request List |
Regional Program Document | Regional Activity Record | Corporate Program Document | Corporate Activity Record | |
---|---|---|---|---|---|---|---|
1 | TBOHSD | Part 1, General | Procedure for resolution of "qualified person" dispute | x | |||
2 | TBOHSD | 7.1 | Report of any noise exposure investigation | x | |||
COHSR | 7.3(5) | ||||||
3 | TBOHSD | 9.2.7 | Contingency procedures for cases in which there is a temporary interruption in the supply of drinking water and water for the removal of water-borne waste | x | x | ||
4 | TBOHSD | 10.1 | Record of all hazardous substances that, in the work place, are used, produced, handled, or stored | x | |||
COHSR | 10.3 | ||||||
5 | TBOHSD | 10.5 | Written reports of any investigation or testing of exposure to hazardous substance | x | |||
COHSR | 10.5 | ||||||
6 | COHSR | 10.5(b) | Written procedure for the control of the concentration or level of a hazardous substance in the work place | x | |||
7 | COHSR | 10.15 | Records of instruction and training for hazardous substances | x | |||
8 | TBOHSD | 10.6 | Asbestos management program | x | |||
9 | CLCII | 125.1z.13) | Program for the provision of personal protective equipment, clothing, devices or materials | x | |||
10 | COHSR | 12.14(1) | Record of all protective equipment provided by the employer | x | |||
11 | TBOHSD | 15.1.1 | Hazardous occurrence investigation procedures and methodology | x | x | ||
12 | COHSR | 15.7(1) | Record of each minor injury | x | |||
13 | COHSR | 15.8 | Hazardous occurrence reports | x | |||
14 | TBOHSD | 16.1.2 | Procedures respecting the availability of first-aid services | x | x | ||
15 | TBOHSD | 16.2.2 | Written record of every injury or illness that requires first-aid treatment | x | |||
16 | COHSR | 16.2(1) | Written first aid instructions that provide for the prompt rendering of first aid to an employee for an injury, an occupational disease or an illness | x | |||
17 | COHSR | 16.13 | On-site first aid-records | x | |||
18 | COHSR | 16.13(2) | Off-site first aid-records | x | |||
19 | COHSR | 16.13(6) | Record of the expiry dates of the first aid certificates of the first aid attendants | x | |||
20 | TBOHSD | 1.0 | Health and Safety policy statement | x | |||
CLCII | 125.1(d)(2) | ||||||
21 | CLCII | 125.1(z.03) | Hazard prevention program document | x | |||
COHSR | 19.1 | ||||||
22 | COHSR | 19.8 | Hazard prevention program evaluation report | x | |||
23 | COHSR | 20.7 | Record of review of the effectiveness of work place violence prevention measures | x | x | ||
24 | COHSR | 20.10 | Records of information, instruction and training provided to each employee exposed to work place violence or a risk of work place violence | x | |||
25 | CLCII | 125.1(z.17) | Name, work telephone numbers and work locations of work place committee members and HS representatives | x | |||
26 | COHSR | 2.27(1) | Procedure for investigating situations in which the health or safety of an employee in the work place is or may be endangered by the air quality | x | x | ||
27 | COHSR | 2.27(7) | Records of every indoor air quality complaint and investigation for the past five years | x | |||
28 | COHSR | 7.7(2)(a) | Procedures for hearing protection fit, care and use | x | |||
29 | COHSR | 10.15 | Employee education program for hazardous substances (e.g. WHMIS training) | x | |||
30 | COHSR | 19.6(5) | Records of health and safety education, including education relating to ergonomics | x | x | ||
31 | COHSR | 10.49(d) | Maintenance and operating procedures to prevent the escape of flammable liquids and combustible liquids | x | |||
32 | COHSR | 12.15(1) | Written instructions in the use, operation and maintenance of the equipment | x | |||
33 | COHSR | Written emergency procedures | x | x | |||
34 | COHSR | 17.4(1) | Emergency procedures for spills, leaks, failure of lighting, fires | x | x | ||
35 | COHSR | 17.8(2) | Record of all instruction and training provided to every emergency warden, deputy emergency warden and monitor | x | x | ||
36 | COHSR | 17.5(2) | Emergency evacuation plan, where applicable, or a plan for evacuating employees who require special assistance in the event of a fire | x | x | ||
37 | COHSR | 17.10(2) | Record of each Emergency Warden meeting | x | |||
38 | COHSR | 17.10(2) | Record of each emergency evacuation drill | x | |||
39 | COHSR | 14.20 | Record of maintenance, use and testing of material handling equipment before initial use | x | |||
40 | COHSR | 14.23(4) | Record of training for operators of material handling equipment | x | |||
41 | COHSR | 14.29(4) | Record of any repair or modification work and of any restriction on use imposed on material handling equipment | x | |||
42 | COHSR | 15.4 | Records of any motor vehicle accident | x | |||
43 | COHSR | 15.10 | Annual report to HRSDC Labour Program, outlining the number of accidents, occupational diseases and other hazardous occurrences for each identified workplace of which management is aware. | x | |||
44 | COHSR | 17.9 | Record of inspection of all fire escapes, exits, stairways and fire protection equipment in a building | x | x | ||
45 | COHSR | 20.9 | Records of investigation of employee reports of violence | x | |||
46 | COHSR | 20.5 | Assessment of potential for work place violence | x | x | ||
47 | COHSR | 20.6(3) | Procedures for appropriate follow-up maintenance and corrective measures for violence control measures that have been established | x | |||
48 | COHSR | 19.5(2) | Preventive maintenance program in respect of equipment or systems where failures could harm employees | x |
Appendix 4B – Detail Findings of Compliance to Program Documents and Records
Appendix 4B - Document Request List for Corporate and Regional HS Staff / Advisors
Audit Checklist 2-1 (Documents Required by CLCII or Treasury Board)
Audit Subjects: Corporate and Regional Health and Safety Staff / Advisors
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:
Item | Source | Mandatory Documents / Document Request List | Regional Program Document Received by: | Regional Activity Record Recieved by: | Corporate Program Document Received? | Corporate Activity Record Received? | |
---|---|---|---|---|---|---|---|
1 | TBOHSD | Part 1, General | Procedure for resolution of "qualified person" dispute | No | |||
2 | TBOHSD | 7.1 | Report of any noise exposure investigation | No | |||
COHSR | 7.3(5) | ||||||
3 | TBOHSD | 9.2.7 | Contingency procedures for cases in which there is a temporary interruption in the supply of drinking water and water for the removal of water-borne waste | None | No | ||
4 | TBOHSD | 10.1 | Record of all hazardous substances that, in the work place, are used, produced, handled, or stored | MB | |||
COHSR | 10.3 | ||||||
5 | TBOHSD | 10.5 | Written reports of any investigation or testing of exposure to hazardous substance | MB | |||
COHSR | 10.5 | ||||||
6 | COHSR | 10.5(b) | Written procedure for the control of the concentration or level of a hazardous substance in the work place | None | |||
7 | COHSR | 10.15 | Records of instruction and training for hazardous substances | None | |||
8 | TBOHSD | 10.6 | Asbestos management program | None | |||
9 | CLCII | 125.1(z.13) | Program for the provision of personal protective equipment, clothing, devices or materials | ON | |||
10 | COHSR | 12.14(1) | Record of all protective equipment provided by the employer | MB | |||
11 | TBOHSD | 15.1.1 | Hazardous occurrence investigation procedures and methodology | ON | No | ||
12 | COHSR | 15.7(1) | Record of each minor injury | MB | |||
13 | COHSR | 15.8 | Hazardous occurrence reports | MB, ON, NWT, NU | |||
14 | TBOHSD | 16.1.2 | Procedures respecting the availability of first-aid services | MB | No | ||
15 | TBOHSD | 16.2.2 | Written record of every injury or illness that requires first-aid treatment | MB | MB | ||
16 | COHSR | 16.2(1) | Written first aid instructions that provide for the prompt rendering of first aid to an employee for an injury, an occupational disease or an illness | MB | |||
17 | COHSR | 16.13 | On-site first aid-records | MB | No | ||
18 | COHSR | 16.13(2) | Off-site first aid-records | ||||
19 | COHSR | 16.13(6) | Record of the expiry dates of the first aid certificates of the first aid attendants | ON | |||
20 | TBOHSD | 1.0 | Health and Safety policy statement | No | |||
CLCII | 125.1(d)(2) | ||||||
21 | CLCII | 125.1(z.03) | Hazard prevention program document | Yes | No | ||
COHSR | 19.1 | ||||||
22 | COHSR | 19.8 | Hazard prevention program evaluation report | No | |||
23 | COHSR | 20.7 | Record of review of the effectiveness of work place violence prevention measures | None | |||
24 | COHSR | 20.10 | Records of information, instruction and training provided to each employee exposed to work place violence or a risk of work place violence | None | |||
25 | CLCII | 125.1(z.17) | Name, work telephone numbers and work locations of work place committee members and HS representatives | 10 Regions | |||
26 | COHSR | 2.27(1) | Procedure for investigating situations in which the health or safety of an employee in the work place is or may be endangered by the air quality | None | No | ||
27 | COHSR | 2.27(7) | Records of every indoor air quality complaint and investigation for the past five years | MB | |||
28 | COHSR | 7.7(2)(a) | Procedures for hearing protection fit, care and use | No | |||
29 | COHSR | 10.15 | Employee education program for hazardous substances (e.g. WHMIS training) | No | |||
30 | COHSR | 19.6(5) | Records of health and safety education, including education relating to ergonomics | ON | No | ||
31 | COHSR | 10.49(d) | Maintenance and operating procedures to prevent the escape of flammable liquids and combustible liquids. | None | |||
32 | COHSR | 12.15(1) | Written instructions in the use, operation and maintenance of the equipment. | None | |||
33 | COHSR | Written emergency procedures | MB, ON | Yes | |||
34 | COHSR | 17.4(1) | Emergency procedures for spills,leaks, failure of lighting, fires | No | |||
35 | COHSR | 17.8(2) | Record of all instruction and training provided to every emergency warden, deputy emergency warden and monitor | None | No | ||
36 | COHSR | 17.5(2) | Emergency evacuation plan, where applicable, or a plan for evacuating employees who require special assistance in the event of a fire | MB, ON | No | ||
37 | COHSR | 17.10(2) | Record of each Emergency Warden meeting | None | |||
38 | COHSR | 17.10(2) | Record of each emergency evacuation drill | MB, ON | |||
39 | COHSR | 14.20 | Record of maintenance, use and testing of material handling equipment before initial use | None | |||
40 | COHSR | 14.23(4) | Record of training for operators of material handling equipment | None | |||
41 | COHSR | 14.29(4) | Record of any repair or modification work and of any restriction on use imposed on material handling equipment | None | |||
42 | COHSR | 15.4 | Records of any motor vehicle accident | None | |||
43 | COHSR | 15.10 | Annual report to HRSDC Labour Program, outlining the number of accidents, occupational diseases and other hazardous occurrences for each identified workplace of which management is aware. | No | |||
44 | COHSR | 17.9 | Record of inspection of all fire escapes, exits, stairways and fire protection equipment in a building | MB, ON | No | ||
45 | COHSR | 20.9 | Records of investigation of employee reports of violence | None | |||
46 | COHSR | 20.5 | Assessment of potential for work place violence | None | No | ||
47 | COHSR | 20.6(3) | Procedures for appropriate follow-up maintenance and corrective measures for violence control measures that have been established | None | |||
48 | COHSR | 19.5(2) | Preventive maintenance program in respect of equipment or systems where failures could harm employees | None |
Footnotes
- The INAC OHS Statement of Roles and Responsibilities specifies approximately 100 duties and functions, allocated to 14 different occupational ranks of INAC personnel, plus health and safety representatives, workplace health and safety committees, and the INAC Policy Health and Safety Committee. (return to source paragraph)
- Canadian Standards Association standard number CSA Z1000 - Occupational Health and Safety Management Systems. (return to source paragraph)
- Labour portfolio responsibilities includes providing advice, guidance and support regarding OHS matters; participating in the development of departmental policies, directives, guidelines and procedures; co-ordinating and monitoring the implementation of OHS training and awareness requirements; providing advice on workers compensation matters; monitoring regional OHS reporting; and other responsibilities outlined in the "Statement". (return to source paragraph)
- Examples include promoting and supporting departmental OHS initiatives, designating regional Health and Safety Advisors and keeping employees informed of applicable OHS matters. (return to source paragraph)
- Examples include overseeing and monitoring the implementation of the OHS program, ensuring employees are adequately informed, instructed, trained and knowledgeable of applicable OHS hazards, and monitoring the departmental Occupational Health and Safety program. (return to source paragraph)
- Examples include ensuring that employees are adequately informed, instructed, trained and knowledgeable of applicable OHS hazards, keeping and maintaining health and safety records. (return to source paragraph)
- Examples include implementing a general departmental OHS training and awareness program, monitoring regional OHS reporting through departmental or regional OHS databases. (return to source paragraph)
- Examples include ensuring that corporate OHS policies, directives, procedures and guidelines are implemented and monitored, periodic health evaluations are carried out. (return to source paragraph)
- Examples include planning and budgeting for OHS initiatives, monitoring regional OHS reporting. (return to source paragraph)
- Examples of program documents include a Hazard Prevention Program, and Emergency Procedures. A full listing is provided in Appendix 6A. (return to source paragraph)
- Examples of activity records include noise exposure investigations, health and safety training records, and emergency evacuation drills. A full listing is provided in Appendix 6A. (return to source paragraph)
- As provided by INAC Audit and Evaluation Sector, February 2009. (return to source paragraph)
- ISO 14001 - Environmental Management Systems & BSI OHSAS 18001 Occupational Health and Safety. (return to source paragraph)