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Hazard Prevention Program Guide

3. Guide to the regulatory requirements

Section 19.2: Implementation Plan

  1. The employer shall:
    1. develop an implementation plan that specifies the time frame for each phase of the development and implementation of the prevention program;
    2. monitor the progress of the implementation of the preventive measures; and
    3. review the time frame of the implementation plan regularly and, as necessary, revise it.
  2. In implementing the prevention program, the employer shall ensure that ergonomics-related hazards are identified and assessed and that they are eliminated or reduced, as required by subsection 19.5(1), as much as is reasonably possible and that any person assigned to identify and asses ergonomics-related hazards has the necessary instruction and training.

Explanation

All activities planned for the hazard prevention program must be listed and given a specific time frame for completion.

One way to monitor implementation of a prevention program is to verify whether the scheduled activities took place as planned. Most of the time, the implementation process involves four steps. For each step, you should verify your progress. The four steps are:

  • describe the measure to be implemented and the work to be performed (new work, new conditions, new technical activities or new tasks)
  • approve the work to be performed
  • document new work procedures
  • provide employee training

A second way to monitor implementation of a prevention program is to verify whether the preventive measures were implemented as planned. If for any reason implementation of a scheduled measure of the prevention program is delayed, it is best to revise the work schedule immediately because other work planned to follow may have to be shifted.

Section 19.7: Program Evaluation

  1. The employer shall evaluate the effectiveness of the hazard prevention 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.
  2. The evaluation of the effectiveness of the prevention program shall be based on the following documents and information:
    1. conditions related to the work place and the activities of the employees;
    2. any work place inspection reports;
    3. any hazardous occurrence investigation reports;
    4. any safety audits;
    5. first aid records and any injury statistics, including records and statistics related to ergonomics-related first-aid and injuries;
    6. any observations of the policy and work place committees, or the health and safety representative, on the effectiveness of the prevention program; and
    7. any other relevant information.

Explanation

At least once every three years you must evaluate the overall effectiveness of your prevention program and revise it if necessary. The effectiveness evaluation may be conducted more often if hazard conditions change, for example, when you buy new machinery, fit out new offices, reorganize work, rearrange equipment or change tasks. You must also evaluate your prevention program if you discover additional information about the hazards in your business. For example, it was recently discovered that pentachlorophenol, used to treat the wood used in railway ties, telephone poles and wharves, is a carcinogen for humans; as soon as you are made aware of this development, you must re-analyse the hazard and revise your program, if required.

Consult your files first

The evaluation of the prevention program must be quantified as much as possible because Part XIX of the Regulations require an evaluation of its effectiveness. It is very difficult to evaluate effectiveness without supporting figures. Subsection 19.7(2) provides the list of documents to be consulted.

Written report

There is no standard format for the evaluation report but it should generally answer the following questions:

  • What are the main hazards in your business?
  • Which hazards did you address over the period covered by the report?
  • Do some hazardous occurrences recur on a regular basis? What have you done to control them? Are there any new ones?
  • Has there been a change in the nature of accidents, diseases and lost time?
  • Has there been a change in the frequency of the hazardous occurrences?
  • Has there been a change in the duration of the hazardous occurrences?
  • Has there been a change in the level of exposure of employees to hazards in the work place?

Section 19.8: Reports

  1. If a program evaluation has been conducted under section 19.7, the employer shall prepare a program evaluation report.
  2. The employer shall keep readily available every program evaluation report for six years after the date of the report.

Explanation

An employer is required to prepare an evaluation report at least once every three years. Also, whenever there is a change in the work place in respect of the hazards or whenever the employer becomes aware of new information about a particular hazard or hazards, the employer is required to prepare a new evaluation.

Conclusion

A good hazard prevention program can prevent work place accidents and injuries while streamlining an employer's health and safety activities. The Labour Program can also assist you in identifying resources to help you get started. Contact us at one of our district offices today.

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Date Modified:
2012-03-19