It is widely understood that the OH&S code requires employers to conduct hazard assessments before work begins at a work site. What may not be so evident is the obligation to involve all affected workers in this process. Alberta’s legislation used to leave some wiggle room for employers to perform these assessments on their own, but not anymore. In 2009 the words “if reasonably practicable” were removed from section 8(1) of the Code. This change imposes a positive duty on employers to involve workers in both the daily hazard identification and assessment process and in the control or elimination of the identified hazards. It also ensures that information flows in both directions between employers and workers, not just from the top down.
When considered in the broader scheme – the main purpose of the legislative change to hazard assessment regulations is to protect your employees! Workers in the field are intimately familiar with the risks and hazards that arise through the course of their days. Using worker first-hand knowledge, hazard id’s, observations and experiences during the hazard identification and assessment process will undoubtedly enhance the thoroughness of what hazards an employer might have identified on its own.
In addition, section 7(4) of the Code states there is an obligation to repeat a hazard assessment when the job scope changes. So, where a work process or operation changes an employer must involve affected workers in repeating the hazard identification and assessment. A practical example of this on an oilfield lease would be when a wireline or cementing service comes out to perform a task on location during a job that is already ongoing. There must be another hazard assessment and discussion of the hazard assessment at this time; which involves all affected workers. This process increases communication between workers themselves, so that less experienced individuals benefit from the insights of their more seasoned co-workers in a truly meaningful manner.
Some important points to remember:
- The pre-job hazard assessment must be done at the start of the day, or when changes to the job occur. It is too late to complete a hazard assessment after the fact, especially if there is an incident/accident!
- Discuss prior hazard ids, observations and experiences that might affect your job during your hazard assessment and discussion to help reflect and add relevance.
- Have hazard assessment forms on hand so if your computer is down or not accessible for whatever reason you can still fill it in and have it signed.
- If the hazard assessment meeting report is not reviewed and signed, in the eyes of a Health and Safety Auditor or OH&S investigator it did not occur!
Legislation is working for you. Participate in your safety program; get involved and engaged every day.