Journal of Commerce | OH&S | by DAVE BASPALY | Sep 5, 2016
WorkSafeBC is proposing a Joint Health and Safety Committee evaluation tool to assist employers in evaluating their Occupational Health and Safety (OHS) committees. This tool would have to be completed every year.
Unfortunately, the proposed tool, in its current form, will get in the way of effective safety programs. The tool is currently 37 pages in length, including the focus areas.
With its overemphasis on paper evaluation, the tool will consume too much time to complete and this time will take away from the essential hands-on, practical management that results from workplace walkabouts and from interactions with workers and supervisors.
What is required instead is a common-sense approach to managing and improving the OHS committee.
The tool is far too long and complicated. It needs to be recast as a two to three page document instead of a 37 page major project.
The tool is not a regulation but it virtually has the force and intent of regulation.
The introduction to the tool states that:
“This evaluation tool includes questions to address all of the information required by section 3.26 of the OHSR. Completing all parts of this evaluation tool will result in an evaluation of the Committee that meets the regulatory requirements. Employers are not required to use this template. You may develop your own Committee evaluation template, but you must ensure that the evaluation includes all of the information required by section 3.26 of the OHSR.”
In other words, the employer is forced to either use the tool or develop an equally long and complex instrument for evaluation.
It is very unlikely that a small or medium sized company — or even a large company — will have the time to read and complete the many descriptions and questions that comprise the tool.
In one area, number three, ‘Employer support for the Committee,’ the content of the tool assumes that the proposed requirement that is going to public hearings in September 2016 will be approved.
The proposed requirement 3.27 (1) reads that:
“3.27 (1): In this section, a reference to a joint committee does not include a joint committee established and maintained under section 126 of the Workers Compensation Act, if
(a) an order under section 126 (1) of the Workers Compensation Act respecting the joint committee provides for a variation as set out in subsection (2) (b) of that section of the Act; and
(b) the variation is in regards to providing instruction and training to the members of the joint committee.
(2) The employer must ensure that each member of the employer’s joint committees who was selected on or after June 1, 2017 to be a member receives, as soon as practicable but no more than 6 months after becoming a member, a total of at least 8 hours of instruction and training, as set out in subsection (4).”
We do not think that it is appropriate to presume that a proposed requirement will be approved before the concerns of stakeholders have even been received and considered by WorkSafeBC .
The tool will generate an extraordinary amount of paper and result in a focus on paperwork instead of a concentration of resources to keep the workplace safe.
We request that WorkSafeBC rescind the tool and instead develop a much shorter, two to four page document that addresses the basic methods for evaluating a Joint Health and Safety Committee.
You can provide direct feedback and support COCA’s position by email: ohsregfeedback@worksafebc.com