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Hazard Prevention Program Guide

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3. Guide to the regulatory requirements

Section 19.5: Preventive Measures

1. The employer shall, in order to address identified and assessed hazards, including ergonomics-related hazards, take preventive measures to address the assessed hazard in the following order of priority:;
   
   1. the elimination of the hazard, including by way of engineering controls which may involve mechanical aids, equipment design or redesign that take into account the physical attributes of the employee
   2. the reduction of the hazard, including isolating it;
   3. the provision of personal protective equipment, clothing, devices or materials; and
   4. administrative procedures such as the management of hazard exposure and recovery periods and the management of work patterns and methods.
2. As part of the preventive measures, the employer shall develop and implement a preventive maintenance program in order to avoid failures that could result in a hazard to employees.
3. The employer shall ensure that any preventive measure shall not in itself create a hazard and shall take into account the effects on the work place.
4. The preventive measures shall include steps to address:
   
   1. a newly identified hazard in an expeditious manner; and
   2. ergonomics-related hazards that are identified when planning implementation of change to the work environment or to work duties, equipment, practices or processes.
5. The employer shall ensure that any person assigned to implement ergonomics-related prevention measures has the necessary instruction and training.

Explanation

Preventive measures mean all useful, practical and effective methods that make it possible to avoid the occurrence of a hazardous situation. There are multiple methods to help you find solutions to a given problem, but Part XIX of the Regulations has established a hierarchal order: elimination, reduction, protection, and administrative control.

First, try to eliminate the hazard

Of all the existing prevention techniques, the elimination of a hazard is the most effective. To achieve this, the machine, thing, condition or activity, that constitutes the hazard, is replaced by another machine, thing, condition or activity that eliminates the original hazard, and which does not create a new hazard. For example, if you prohibit everyone from walking in a warehouse, you eliminate the hazard of collision between staff and a lift truck.

If not, reduce it

If you cannot eliminate the hazard, you can attempt to reduce it through control techniques that aim to diminish the intensity of the hazard should it occur, prevent the hazardous situation from occurring, or eliminate hazardous tasks. For example, in a warehouse, you can identify corridors and areas that are safe for pedestrians by using yellow stripes painted on the floor.

If this is not possible, protect yourself

Protection techniques make it possible to counter a hazardous occurrence or diminish the scope of potential damage. There are two types of protection: group and personal. Group protection involves blocking or separating the hazard from the employee. For example, you can install buffers in strategic locations to prevent the lift truck from entering areas where people circulate. Personal protection involves providing employees with protective equipment or clothing. For example, the use of high-visibility apparel.

Other administrative measures

Part XIX of the Regulations require that administrative measures be considered only after the preceding preventive measures have been considered, not because they are without value, but because technical solutions are more effective than solutions that focus on individuals. This category encompasses all management techniques that aim to reduce the hazard.

Preventive maintenance

Regardless of the preventive measures proposed, the preventive maintenance program is mandatory. Its purpose is to prevent failure in the long term of structures, equipment, machinery and tools through routine inspections and the repair of worn parts. For example, planned inspections, mechanical maintenance and the replacement of worn brakes on a lift truck are indispensable prevention measures.

Since Part XIX of the Regulations require a preventive maintenance program, you must establish a list of the structures, machinery, equipment and tools that need to be inspected, adjusted, cleaned, lubricated, replaced, and so on. You must draw up a maintenance schedule, describe the maintenance procedures, record the work completed, verify the progress of work and assess effectiveness.

Hazard-free preventive measure

Since a preventive measure is a control of a present hazard, a current working condition or an existing activity, make sure that the measure itself is not a source of a hazard before implementing it. For example, if you install a conveyor belt to replace a lift truck, make sure it is in compliance with current safety standards.

A preventive measure must not create a new hazard. If such a hazard arises, it must be dealt with as soon as possible. For example, when indicating areas for pedestrian traffic, make sure it does not cause an unsafe congestion of lift trucks in another location, install mirrors so that the operator can see pedestrians before turning a blind corner, and so on.

Record preventive measures

Keeping a record of implemented preventive measures is important to the success of the hazard prevention program. You will need this record to complete the subsequent steps in the prevention process.

Section 19.6: Employee Education

1. The employer shall provide health and safety education, including education relating to ergonomics, to each employee which shall include the following:
   
   1. the hazard prevention program implemented in accordance with this Part to prevent hazards applicable to the employee, including the hazard identification and assessment methodology and the preventive measures taken by the employer;
   2. the nature of the work place and the hazards associated with it;
   3. the employee's duty to report under paragraphs 126(1)(g) and (h) of the Act and under section 15.3; and
   4. an overview of the Act and these Regulations.
2. The employer shall provide education to an employee:
   
   1. whenever new hazard information in respect of a hazard in the work place becomes available to the employer; and
   2. shortly before the employee is assigned a new activity or exposed to a new hazard.
3. The employer shall review the employee education program, and, if necessary, revise it:
   
   1. at least every three years;
   2. whenever there is a change in conditions in respect of the hazards; and
   3. whenever new hazard information in respect of a hazard in the work place becomes available to the employer.
4. Each time education is provided to an employee, the employee shall acknowledge in writing that they received it, and the employer shall acknowledge in writing that they provided it.
5. The employer shall keep, in paper or computerized form, records of the education provided to each employee, which shall be kept for a period of two years after the employee ceases to be exposed to a hazard.

Explanation

Content and duration of education

Although the detail of instruction and its duration may vary depending on the requirements of each work position, the requirements of 19.6(1) must be addressed.

Education schedule

As soon as the content and the duration of the education sessions have been determined, you must prepare the education schedule.

There is no requirement to educate every employee every three years, although refresher sessions in between are a good idea. However, they must be educated before performing their tasks, before being exposed to a hazard and every time you receive new information about the hazards they are exposed to. You must review your education program accordingly. If there is no change in the hazards, you must review the program every three years.

Confirmation of education

Whenever an education session is given, the employer must acknowledge in writing that the education took place, and employees must also acknowledge in writing that they have received such education. In many cases, a simple learning report such as the one presented below is all that is required.

Education record

Training Report

No.	Name	Signature	PIN	Department/Section
1	Thomas Fisher		234	Warehouse
2	Kim Hasley		40	Warehouse
3	Paul Duchesneau		119	Shop
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Education record

For each employee, you must create and regularly update a record of all occupational health and safety education you have provided. This record must be kept for two years following the date the employee ceases being exposed to a hazard. Here is an example of a education record:

Employee Education Record

Training Report

No.	From - To - Duration	Course Title	Description
1	12/04/02 - 12/04/02 - 3½ hrs	Tire repair	Work procedures on a new machine
2	15/02/03 - 16/02/03 - 14 hrs	Work procedures on a new machine	Preventive maintenance
3	05/07/03 - 05/07/03 - 1 hr	LPG	Handling of tanks, refuelling safety
4	10/04/09 - 12/04/09 - 3 days	Lift trucks	Defensive driving, maintenance and inspection
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10

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Date Modified:

2012-03-19