The Internal Responsibility System

What Does This Mean for You?

SSNS conference March 20,2013Gary G. Ramey, CRSP

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

MISCONCEPTIONS

• A way for Supervisors, Managers and Owners to cover their butts

• A paper trail exercise• A way to blame workers

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

Internal Responsibility System

HOW DO YOU MAKE THAT HAPPEN??

TRUST

INVOLVEMENT

Internal Responsibility System

The Law

Establishes employer responsibilities

• Provide information,

• instruction and

• supervision regarding workplace hazards

Internal Responsibility System

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

Internal Responsibility System

The Four principles of IRS

Foundation/Shared Principle

Primary Principle

Framework Principle

OSH Division Principle

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.

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Internal Responsibility System

PRIMARY RESPONSIBILITY/PRINCIPLE

based on each party's authority and ability to act

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Internal Responsibility System

FRAMEWORK PRINCIPLE Allows for worker participation,

exchange of information and the right to refuse unsafe work

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.

Internal Responsibility System

What Can you do

-Set standards specific to your workplace

-Implementing them

-Measuring/monitoring them

-Correct non-conformances

-Be consistent & effective

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

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

How Can You Do It• OHS Policy

• Worker training

• Management training

• Incident/Accident reporting/analysis

• Addressing workers’ concerns formally

Internal Responsibility System

How You Can Do It• Emergency procedures

• First aid/rescue procedures

• Maintenance and repairs

• Workplace inspections

• Hazard recognition

Internal Responsibility System

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

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??

Internal Responsibility System

How can you do it

- Act quickly on safety suggestions

- Provide immediate feedback on safety related requests/suggestions

-communicate communicate communicate

GET INVOLVED TRUST

Internal Responsibility System

Internal Responsibility System

Dr. Earl Blair

“Developing a safety culture is not rocket science, it is much more complicated than

that”

Thank you!!Internal Responsibility System

QUESTIONS??