By Barb Szychta, Frank Cowan Company
May 2010 – As June 15th nears, and the Bill 168 amendments to the Ontario Health and Safety Act (OHSA) get ready to take effect, there are many tasks to remember. Below is a list of 26 key points that can help you with the implementation of policies and procedures, as well as the ongoing process with regard to the new legislation governing workplace violence and harassment.
Appoint a staff member to lead the implementation of Bill 168 to ensure that all of the requirements are met. Don’t assume a requirement has been met.
Be aware of your responsibilities under Ontario’s Human Rights Code and privacy legislation (ie. PIPEDA) when you are developing your violence and harassment policies and program. If in doubt, contact your lawyer.
Check in with employees that work in the field by using established periodic contact procedures. Don’t forget about your mobile workers. Their safety is your responsibility.
Develop a checklist for the requirements of Bill 168. Tick off the boxes as each one is completed.
Entrances that allow non-employees access to your workplace need to be locked from the outside. Instruct employees to keep them locked at all times. Propping open doors should not be allowed.
For compliance with the Act, your policies need to be in written form and “posted in a conspicuous place in the workplace”.
Give your employees the training they require to keep them safe. Don’t forget to include employees who work alone, work off-site, travel, etc. They may require different forms of training, i.e. staying safe in hotel rooms, airports, on client premises, etc.
How often employee training should take place depends on whether or not the risks within the workplace have changed. Train your employees as soon as new risks emerge or changes are made to your policies and program. If there are no changes, then implement a training schedule on a regular basis.
Include all workers in the development of your policies and procedures. If they have input they will take ownership.
Joint health and safety committees should be consulted in the development of workplace violence and harassment policies and programs. Remember – they have the same powers and responsibilities for violence and harassment as they do for other occupational hazards.
Keep in mind that “workplace” includes all places where your employees are directed or paid to visit.
Legal counsel should be consulted regarding the type of personal information that should and should not be disclosed to employees regarding a co-worker.
Make sure all of your workers understand your policies and procedures and their obligations under them.
Never ignore a worker’s concern. Investigate and record all complaints.
Organize or ask your employees to organize a “buddy system” – especially those employees who work after hours.
Policies for workplace violence and harassment must be reviewed annually according to Section 32.0.1 of the Act.
Question anyone that you don’t recognize in your workplace.
Recognizing the warning signs of potential violence should be included in your training program. Most employees don’t know what they are.
Security devices such as external cameras, card key access systems, panic-bar doors locked from the outside, etc. can make your premises safer.
There’s no need to reinvent the wheel when developing your policies. There are many templates out there. Use them as your starting point.
Use community resources to help educate staff, i.e. your local police.
Visibility and lighting are important environmental design considerations that can make your premises safer for your employees.
Workplace violence incident reports should be analyzed to determine patterns and emerging risks. These are valuable risk management documents.
X’amine your workplace and identify “safe areas” where workers can go if they feel threatened. Make sure these areas are accessible by all employees and have communications capabilities.
Your workplace assessment should be specific to each of your locations. Your locations have both common and unique risks. Know them and address them.
Zero tolerance for workplace violence and harassment will minimize the risks.
This article has been reprinted with permission from the May 2010 Workplace Violence Special Bulletin, and was authored by Barb Szychta, Director- Risk Management Services, Frank Cowan Company. The Workplace Violence Special Bulletin was co-created by Frank Cowan Company (www.frankcowan.com) and Cowan Insurance Group (www.cowangroup.ca), which are affiliated through common ownership.