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Hazard Prevention Program Guide

3. Guide to the regulatory requirements

Section 19.3: Hazard Identification and Assessment Methodology

  1. The employer shall develop a hazard identification and assessment methodology, including an identification and assessment methodology for ergonomics-related hazards, taking into account the following documents and information:
    1. any hazardous occurrence investigation reports;
    2. first aid records and minor injury records;
    3. work place health protection programs;
    4. any results of work place inspections;
    5. any employee reports made under paragraph 126(1)(g) or (h) of the Act or under section 15.3;
      6. any government or employer reports, studies and tests concerning the health and safety of employees; any reports made under the Safety and Health Committees and Representatives Regulations; the record of hazardous substances; and
      (i) any other relevant information, including ergonomics-related information.
  2. The hazard identification and assessment methodology shall include:
    1. the steps and time frame for identifying and assessing the hazards;
    2. the keeping of a record of the hazards; and
    3. a time frame for reviewing and, if necessary, revising the methodology.

Explanation

The purpose of hazard identification is to highlight the operations of critical tasks, that is, those tasks posing significant risks to the health and safety of employees, as well as highlighting those hazards pertaining to certain equipment due to energy sources, working conditions or activities performed.

Consult your files first

You already have information about the hazards in your work place. Start the identification process by carefully going over them. Paragraphs 19.3(1)(a) to (h) provide you with a list of items for this purpose.

Identification techniques

To complete your hazard identification, you can use techniques to identify hazards such as:

  • work place inspections
  • task safety analysis
  • preliminary investigations
  • potential accident factors
  • failure analysis
  • accident and incident investigations

For each of these techniques, the hazards are identified by observing tasks that are actually performed at the various work stations.

Adaptation to the size of your business

It is in your interest to adopt your own process and your own identification techniques so that they match your management procedures and the size of your business. In fact, the identification method may vary depending on the size of the work place. If your business is small, it may be to your benefit to identify hazards “per individual,” as each individual performs specific tasks. For example, in a small road transport business, Kim is a truck driver, while Paul is a truck driver who also takes care of welding and the mechanical maintenance of trucks; Yvon is a lift truck driver and repairs tires and bodywork, while Claire is a fuel pump attendant and dispatches the drivers. Therefore, the hazards for Kim, Paul, Yvon and Claire must be identified.

If your business is larger, it is more likely that several employees hold the same positions. You can then carry out the identification “per work station.” In a larger road transport business, hazards can be identified for truck drivers, lift truck drivers, welders, mechanics, body workers, body painters, fuel pump attendants and office staff.

If your business is larger still, you could proceed by “work area,” grouping individuals and work stations by similarity of tasks, hazards and management; this is a commonly used method. For example, there are specific hazards and preventive measures associated with pressure boilers. Since everyone who works in a boiler room is exposed to much the same hazards, you can identify the hazards for all boiler room workers. Another example would be in large warehouses, where a number of lift trucks are often used, doors are frequently open even in winter, heavy loads are handled, and so on. You could group together the hazards for all shipping and receiving employees in one work area.

If the areas are too large, you can divide them so that each foreman or department head would be responsible for both production and his or her prevention program. In very large businesses, the identification method might differ among facilities.

Hazard record

After having identified the hazards, you must establish and maintain an identification record, either in print or electronic format.

The identification technique used in the example is very simple. It identifies five components of work: equipment (machines and tools), materials (substances and products), environment, personnel and work organization. When the interaction among these five components is normal, the desired products and services are delivered: in this case, transporting material with a lift truck to load a truck, a railway car, a container, and so on. On occasion, the interaction among components may work in an unexpected way and result in incidents such as an accident, an occupational disease or a fire. To identify the hazards involved in driving a lift truck you must 1) identify the work components and 2) ask what may go wrong. For example, the lift truck is the equipment. There may be the potential of a breakdown of a truck part, collision or a back injury, for example. As for materials being transported, the operator may be hit by falling material, there may be a fire hazard because of flammable material, and so on.

Time frame for identification and review

You must define the steps for the identification of hazards and a time frame for this identification. The following information should be included:

  • who will be responsible for the identification: for example, it may be the work place health and safety committee, or an individual or individuals appointed by the committee
  • the way in which the identification reports are processed: for example, they may be compiled and processed by the committee, or by individuals appointed by the committee
  • the identification time frame: for example, the identification of hazards for workshop A must be completed in December, for workshop B in April and for workshop C in November
  • the date for the review of the identification: for example, the review of the identification method will be carried out every two years

These steps cannot be completed in one day. A minimum amount of time will have to be spent on them. Remember that emphasis must be placed on identification, because follow-up of the prevention program depends upon it, that is, the assessment of hazards, the implementation of preventive measures and employee education.

Section 19.4: Hazard Identification and Assessment

The employer shall identify and assess the hazards in the work place, including ergonomics-related hazards, in accordance with the methodology developed under section 19.3 taking into account:

  1. the nature of the hazard;
    (a.1) in the case of ergonomics-related hazards, all ergonomics-related factors such as:
    1. the physical demands of the work activities, the work environment, the work procedures, the organization of the work and the circumstances in which the work activities are performed, and
    2. the characteristics of materials, goods, persons, animals, things and work spaces and the features of tools and equipment;
  2. the employees' level of exposure to the hazard;
  3. the frequency and duration of employees' exposure to the hazard;
  4. the effects, real or apprehended, of the exposure on the health and safety of employees;
  5. the preventive measures in place to address the hazard;
  6. any employee reports made under paragraph 126(1)(g) or (h) of the Act or under section 15.3; and
  7. any other relevant information.

Explanation

In the identification step you inventoried all the hazards encountered in your business. It is very likely that they are numerous, which makes any single action to control all of them impossible. Therefore, you must critically examine all of the hazards in order to establish an order of priority. In this way, you can prioritize your preventive measures, without losing sight of the final objective, which is to eliminate all hazards in the work place or, if they cannot be eliminated, control them.

Consult your files

You can consult the employee reports, the first aid record, the minor injuries record, the hazardous occurrence reports and your workers' compensation statements. This will enable you to assess the level of hazard exposure to employees.

Other assessment methods

You can use any other assessment method, provided it takes into account all the factors mentioned in paragraphs 19.4(a) to (g).

Caution! For hazardous substances, you must use the assessment method described in section 10.4 of Part X of the Regulations, for noise, the one contained in section 7.3 of Part VII, and for confined spaces, the one stipulated in section 11.2 of Part XI. In each of these three instances, the assessment must be made by a qualified person, and the assessment criteria are determined by the Regulations.

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Date Modified:
2012-03-19