The Internal Responsibility System

1. The Internal Responsibility System What Does This Mean for You? SSNS conference March 20,2013 Gary G. Ramey, CRSP

2. Internal Responsibility System • WHAT DO YOU THINK IT IS??

3. MISCONCEPTIONS • The supervisor is the ‘key (only) person’ • It’s all just worker behaviour • There’s no personal fault, it’s all the management system at root • It’s all just engineering controls and physical barriers • A good way to score on a system audit

4. MISCONCEPTIONS • A way for Supervisors, Managers and Owners to cover their butts • A paper trail exercise • A way to blame workers

5. Internal Responsibility System Ramey's version • A Philosophy of work organization which promotes a system, • to allow workplace parties to openly participate • to allow workplace parties to openly offer advice • to create a safety culture within the organization that eliminates fear of reprisal from co-workers, managers or owners

6. HOW DO YOU MAKE THAT HAPPEN?? Internal Responsibility System

7. Internal Responsibility System TRUST INVOLVEMENT

8. Internal Responsibility System • The Law • Establishes employer responsibilities • Provide information, • instruction and • supervision regarding workplace hazards

9. Internal Responsibility System • The Law • Establishes basic workers’ rights (4 r's) • To participate in workplace health & safety • To know about workplace hazards • To refuse unsafe work • To complain

10. The Four principles of IRS Foundation/Shared Principle Primary Principle Framework Principle OSH Division Principle Internal Responsibility System

11. Internal Responsibility System • Foundation/Shared Principle • employers, employees, contractors, and self-employed persons, and • owners, suppliers or an architect/engineer share the responsibility for OH&S. 1111

12. Internal Responsibility System PRIMARY RESPONSIBILITY/PRINCIPLE based on each party's authority and ability to act 1212

13. Internal Responsibility System • FRAMEWORK PRINCIPLE • Allows for worker participation, exchange of information and the right to refuse unsafe work

14. Internal Responsibility System • OSH DIVISION ROLE PRINCIPLE • to establish and clarify the roles of the parties, provide support, and intervene appropriately when responsibilities are not carried out • NOT TO MAKE YOUR WORKPLACE SAFE

15. Internal Responsibility System • So Who Is Responsible for What? • Worker • Has direct responsibility for safety( REASONABLE PRECAUTIONS) • Follow rules, use procedures, cooperate • Fix hazards that can be fixed; • report hazards that cannot be fixed

16. Internal Responsibility System • So Who Is Responsible for What? • Employer • -Take all reasonable precautions to ensure OH&S • -Train, supervise, coordinate • -Provide and maintain safe equipment, machines, materials • -Consult, cooperate with JOHSC • -Establish policy, program, procedures

17. Internal Responsibility System • So Who Is Responsible for What? • Supervisor • Assignment of work, direction, supervision • Training • Fix hazards that can be fixed; report hazards that cannot be fixed; stop work until hazard fixed • Investigate, inspect, create procedures • Ensure workers are carrying out their roles

18. Internal Responsibility System • So Who Is Responsible for What? • Manager/Superintendent • Set/interpret objectives, plan operation, write program • Obtain necessary equipment, supplies, facilities • Delegate authority • Set standards and audit compliance • Fix hazards that can be fixed; report hazards that cannot be fixed; stop work until hazard fixed • Ensure supervisors are carrying out their roles

19. Internal Responsibility System • So Who Is Responsible for What? • President/Board • Set policy, philosophy, purpose • Authorize necessary equipment, supplies, facilities • Fix hazards that can be fixed; stop work until hazard fixed Ensure managers are carrying out their roles • Report to owners/public on discharge of responsibility

20. Internal Responsibility System • So Who Is Responsible for What? • Joint OH&S Committee • “forum of consultation between those with the ability to contribute and those accountable for deciding what is to be done” • Look to policy, system performance, operations, conditions • Standards • Modifications • Training • Emergency response • Maintenance • Overseers, not “doers”

21. Specific Responsibilities in OH&S Act • JOHSC • involve employers and employees together in OH&S • co-operative identification of hazards and effective systems to respond to the hazards; • co-operative auditing of compliance • receipt, investigation and prompt disposition of complaints • participation in inspections, inquiries and investigations • advising on individual protective devices, equipment and clothing that are best adapted to the needs of the employees • advising the employer regarding a policy or program • making recommendations for the improvement of the health and safety of persons at the workplace;

22. Internal Responsibility System • So Who Is Responsible for What? • Internal OH&S Manager: • Advise on OH&S issues • Keep up to date on OH&S issues • Coordinate actions • Lead corporate initiatives • Monitor OH&S program

23. Internal Responsibility System • So Who Is Responsible for What? • OH&S Division -not to assume responsibility for creating and maintaining safe and healthy workplaces -to establish and clarify the responsibilities of the parties under the law, to support them in carrying out their responsibilities and to intervene appropriately when those responsibilities are not carried out.

24. But Everyone is Responsible!!! • OH&S Act (Section 23): • Where a provision of this Act or the regulations imposes a duty or requirement on more than one person, the duty or requirement is meant to be imposed primarily on the person with the greatest degree of control over the matters. • Where the person with the greatest degree of control fails to comply with a duty or requirement, the other persons on whom the duty or requirement lies shall, where possible, comply with the provision.

25. Internal Responsibility System What Can you do -Set standards specific to your workplace -Implementing them -Measuring/monitoring them -Correct non-conformances -Be consistent & effective

26. Internal Responsibility System • What Can You Do? • Develop specific policies, practices and procedures for hazardous activities • Provide adequate orientation and training • Ensure supervisors monitor hazardous work and communicate risks

27. Internal Responsibility System • What Can You Do? • Audit/inspect for foreseeable risks and protect workers accordingly • Ensure compliance through rules and discipline • Never assume workers know enough about the risks involved in a given task

28. Internal Responsibility System • How Can You Do It • OHS Policy • Worker training • Management training • Incident/Accident reporting/analysis • Addressing workers’ concerns formally

29. Internal Responsibility System • How You Can Do It • Emergency procedures • First aid/rescue procedures • Maintenance and repairs • Workplace inspections • Hazard recognition

30. Internal Responsibility System How You Can Do It • Personal Protective Equipment Requirements • Lockout/Tagout procedures • Confined space entry procedures • Machine guarding policies • Housekeeping procedures

31. Internal Responsibility System • How you can do it • -Integrate into production; it’s not a separate function • -Everyone has to personally take every measure reasonable to continuously work safely and improve safety • -About “responsibility” – Obligations, not rights • -Employees are responsible as well, not just management

32. Internal Responsibility System How You Can Do It -Internal responsibility is self-governing -There has to be internal regulation of the OHS in the workplace -If driven by regulations it is doomed to fail -Clear rules of procedures for your JOHSC • HOW DO YOU/WE MAKE IT WORK??

33. Internal Responsibility System • How can you do it • Act quickly on safety suggestions • Provide immediate feedback on safety related requests/suggestions • -communicate communicate communicate

34. Internal Responsibility System GET INVOLVED TRUST

35. Dr. Earl Blair “Developing a safety culture is not rocket science, it is much more complicated than that” Internal Responsibility System

36. Thank you!! Internal Responsibility System QUESTIONS??