The Internal Responsibility System
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Transcript of The Internal Responsibility System
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The Internal Responsibility System
What Does This Mean for You?
SSNS conference March 20,2013Gary G. Ramey, CRSP
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Internal Responsibility System
WHAT DO YOU THINK IT IS??
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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
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MISCONCEPTIONS
• A way for Supervisors, Managers and Owners to cover their butts
• A paper trail exercise• A way to blame workers
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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
Internal Responsibility SystemRamey's version
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Internal Responsibility System
HOW DO YOU MAKE THAT HAPPEN??
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TRUST
INVOLVEMENT
Internal Responsibility System
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The Law
Establishes employer responsibilities
• Provide information,
• instruction and
• supervision regarding workplace hazards
Internal Responsibility System
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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
Internal Responsibility System
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Internal Responsibility System
The Four principles of IRS
Foundation/Shared Principle
Primary Principle
Framework Principle
OSH Division Principle
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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
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Internal Responsibility System
PRIMARY RESPONSIBILITY/PRINCIPLE
based on each party's authority and ability to act
1212
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Internal Responsibility System
FRAMEWORK PRINCIPLE Allows for worker participation,
exchange of information and the right to refuse unsafe work
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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
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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
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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
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Internal Responsibility System
So Who Is Responsible for What?SupervisorAssignment 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
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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
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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
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Internal Responsibility SystemSo 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”
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Specific Responsibilities in OH&S Act
• JOHSCinvolve 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 investigationsadvising on individual protective devices, equipment and clothing that are best adapted to the needs of the employeesadvising the employer regarding a policy or program making recommendations for the improvement of the health and safety of persons at the workplace;
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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
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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.
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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.
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Internal Responsibility System
What Can you do
-Set standards specific to your workplace
-Implementing them
-Measuring/monitoring them
-Correct non-conformances
-Be consistent & effective
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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
Internal Responsibility System
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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
Internal Responsibility System
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How Can You Do It• OHS Policy
• Worker training
• Management training
• Incident/Accident reporting/analysis
• Addressing workers’ concerns formally
Internal Responsibility System
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How You Can Do It• Emergency procedures
• First aid/rescue procedures
• Maintenance and repairs
• Workplace inspections
• Hazard recognition
Internal Responsibility System
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How You Can Do It• Personal Protective Equipment
Requirements
• Lockout/Tagout procedures
• Confined space entry procedures
• Machine guarding policies
• Housekeeping procedures
Internal Responsibility System
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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
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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??
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Internal Responsibility System
How can you do it
- Act quickly on safety suggestions
- Provide immediate feedback on safety related requests/suggestions
-communicate communicate communicate
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GET INVOLVED TRUST
Internal Responsibility System
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Internal Responsibility System
Dr. Earl Blair
“Developing a safety culture is not rocket science, it is much more complicated than
that”
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Thank you!!Internal Responsibility System
QUESTIONS??
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