HR Q&A: Occupational Health and Safety policies and practices

Question: We are a small organization without a Human Resources department.  When is an organization required to have an Occupational Health and Safety policy and who is responsible?

Answer: An Occupational Health and Safety Policy is required for every organization that regularly employs more than five employees.

Organizations that regularly employ more than 20 employees are also required to have a Joint Health and Safety Committee (JHSC).

Question: What is involved in creating and implementing an Occupational Health and Safety policy?

Answer: An Occupational Health and Safety policy highlights the organization’s commitment, support and attitude toward the health and safety program and the protection of workers. It should be signed by the organization’s most senior leader. In addition, organizations must have a supporting Occupational Health and Safety program that might include any or all of the following:

  • worker training (e.g., Joint Health and Safety Committee members, new worker orientation, WHMIS, new job procedures etc.);
  • workplace inspections and hazard analysis;
  • analysis of the accidents and illnesses occurring at the workplace;
  • a health and safety budget;
  • a formal means of communication to promptly address the concerns of workers;
  • maintenance and repairs;
  • housekeeping;
  • fire prevention, first aid and evacuation procedures;
  • electrical safety.

The policy must be reviewed annually and revised where necessary.

Question: How do we set up a Health and Safety Program?

1.            Identify the appropriate number of members to form the JHSC (preferably volunteers), post their names alongside a WSIB Health & Safety at Work poster, a copy of the Occupational Health and Safety Act, and a copy of your Health and Safety policy.

2.            Register each of the members of the JHSC for certification training.

3.            The JHSC members should meet monthly to inspect the office, review incident reports, discuss possible concerns, and if necessary recommend health and safety improvements.

4.            All employees should receive a copy of the Health and Safety policy and acknowledge they have read and understand the policy.

5.            Provide new employees with a copy of the policy along with a short overview and tour of the workplace to point out potential hazards, evacuation procedures and emergency contact information.

6.            Once a year the JHSC should deliver a refresher of the organization’s Health and Safety policy to all staff, and could include presentation on workplace hazards and prevention as well as workplace violence. A 2009 amendment to the Occupational Health and Safety Act with respect to violence and harassment in the workplace requires all organizations requiring an Occupational Health and Safety policy to also have a Workplace Violence policy and a Workplace Harassment policy.

HR advice provided by Gerlinde Herrmann, owner of HR consultancy The Herrmann Group. 

This ongoing series of advice columns written by members of the The Human Resources Professionals Association (HRPA). If you have a general HR question you’d like answered, e-mail it We’ll pass the questions along to HRPA for consideration as the subject of a future article.

For more specific quetions, HRPA’s EZ HR small business service connects companies with human resources information experts and provides employment practices liability insurance designed to protect businesses from employment- or discrimination-related allegations.

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  • Given that the target audience of this magazine is the transportation industry, many of whom are federally regulated, I think it would be appropriate to discus identifying which jurisdiction has governance over the specific company’s operations before recommending how the create a committee. While there are many similarities, there are significant differences, in both terminology, and application, in the development of an OHS Safety Program for federally regulated companies. Some of the comments in this are definitely not applicable to a federally regulated employer.