Ontario’s Occupational Health and Safety Act says that employers and supervisors should “take every precaution reasonable in the circumstances for the protection of a worker.” This is known as the general duty clause, but what it means in an uncertain period such as during a pandemic is a question many employers have been asking WSPS.
WSPS Regional Community Coordinator Lori Shepherd cuts through any uncertainty with this simple approach: “It means applying the same risk management strategies to this hazard as we would to any other hazard.”
To help workplaces put this into practice, Lori offers the following eight suggestions.
Identify and assess COVID-related hazards that may be present in your workplace. “We know the risk of contracting COVID-19 through close, prolonged personal contact can be very high,” says Lori. “What processes, procedures and tasks could put employees at risk? How many people could be exposed to the virus, and how likely are they to become infected?”
Determine how best to control the hazards. Once you know the nature and extent of risk, it’s possible to explore control options. Apply the hierarchy of controls, starting with elimination. For instance, replace in-person meetings and conversations with virtual meetings and phone calls. For hazards that can’t be eliminated, determine how to control them. Can you install barriers? Can you employ signage to promote physical distancing? Increase ventilation? Is it possible to stagger shifts and breaks? If masks are appropriate, what type of masks would be suitable for the circumstances? To help workplaces control hazards, WSPS, the Ministry of Labour, Training, and Skills Development, and other prevention system partners have collaborated on over 100 sector-specific guidance documents. Each document includes a number of control options.
Develop a COVID-19 safety plan. Compile all of the steps necessary to protect workers from exposure to the coronavirus, as well as the procedures necessary to monitor worker exposure and their health. Include screening measures and steps to take in response to a suspected case of COVID-19 at work. Complement internal expertise with external expertise where needed. Involve your joint health and safety committee or health and safety representative early on. Once you have drafted a plan, discuss and share it with everyone at work.
Document everything you do – hazard assessments, controls, training, inspections, investigations, logs, checklists – so that if the need arises you can demonstrate due diligence, i.e. that you have taken every precaution reasonable in the circumstances to protect your workers from COVID-19.
Review and update your COVID-19 hazard assessment and controls. A number of factors may prompt the need for a review:
significant changes or improvements to processes or tasks
challenges introduced by these changes
evolving information on COVID-19 and related hazards
changes to public health and other government requirements
Reinforce everyone’s role under the Internal Responsibility System. We’re all in this together – employers, supervisors, and workers – and we all have a part to play
If in doubt, err on the side of caution. Focus on controlling hazards, not just on compliance. Legislation and regulations set minimum performance requirements, which cannot guarantee a safe workplace. If you focus on compliance as a minimum, and not on taking every precaution reasonable, you may not be managing hazards effectively.