ARCHIVED - Audit of the INAC Occupational Health and Safety Management Control Framework

Notice

This website will change as a result of the dissolution of Indigenous and Northern Affairs Canada, and the creation of Indigenous Services Canada and the eventual creation of Crown-Indigenous Relations and Northern Affairs Canada. During this transformation, you may also wish to consult the updated Indigenous and Northern Affairs home page.

Archived information

This Web page has been archived on the Web. Archived information is provided for reference, research or record keeping purposes. It is not subject to the Government of Canada Web Standards and has not been altered or updated since it was archived. Please contact us to request a format other than those available.

Date: September 2009

PDF Version (403 Kb, 77 Pages)

 

 

Table of Contents




Initialisms and Abbreviations

AES Audit and Evaluation Sector
CLC-II Canada Labour Code Part II
CSP Contaminated Sites Program
DG Director General
EHS Environmental Health and Safety
HRSDC Human Resources and Skills Development Canada
HRWSB Human Resources and Workplace Services Branch
HS Health and Safety
IIA Institute of Internal Auditors
INAC Indian and Northern Affairs Canada
NCSP Northern Contaminated Sites Program
OHS Occupational Health and Safety
PWGSC Public Works and Government Services Canada
RDG Regional Director General
SOHS Security and Occupational Health and Safety Division
TB Treasury Board Secretariat
 
Return to Table of Contents





Executive Summary

At the request of Indian and Northern Affairs Canada's ("INAC") Director of Security, Occupational Safety and Health, an audit of Occupational Health and Safety ("OHS") at INAC was conducted between January and May 2009 to provide information that would support OHS priority setting and planning processes. Upon the recommendation of the Chief Audit and Evaluation Executive, the request was considered and approved by the Audit Committee as an addition to the 2008-09 Risk-Based Audit Plan.

The audit objectives were to evaluate the adequacy of INAC's OHS Management Control Framework, assess compliance with selected OHS requirements contained in the Canada Labour Code Part II ("CLC-II") and the Treasury Board Secretariat ("TB") OHS Directive, and to identify best practices.

The scope of the audit included an assessment of (1) management and employee awareness of, and compliance with, duties specified in the INAC OHS Statement of Roles and Responsibilities; (2) the existence and sufficiency of OHS program documentation required by law or TB; (3) the sufficiency of actions taken by management for protection of employees performing specific hazardous work activities carried out in INAC; (4) the existence and functioning of OHS committees, representatives, and advisors across INAC; and (5) compliance with the program documentation and activity record keeping requirements of the Contaminated Sites Program ("CSP"), at Headquarters and in the selected Regions.

Audit criteria were derived from select requirements set out in the INAC Statement of Roles and Responsibilities, CLC-II, Canada Occupational Health and Safety Regulations, TB OHS Directives, and the EHS Management Systems Manual – Edition 2 – March 2008. Data collection was conducted via telephone interviews, a written request for documentation and e-mail surveys. Some audit criteria were assessed on a population basis while others were assessed on a sample basis.

The audit found that the OHS Management Control Framework, while sound in design, is essentially non-operational in practice. There is an overall low level of compliance with the CLC-II and TB requirements relating to OHS program documents and records, and to the functioning of Health and Safety Representatives and Workplace and Regional Health and Safety Committees. Reasons for the low level of compliance include a generalized lack of knowledge of internal OHS requirements and regulations, insufficient resources to carry out prescribed tasks, and an absence of procedures and systems to carry out OHS related activities.

The current state of affairs potentially exposes the Department to OHS charges for non-compliance, Criminal prosecutions in the event of a serious injury or death, exposes employees to potentially harmful risks in the course of their work, and other impacts that have been described in this report.

Ten recommendations are provided to address current conditions and the underlying causes of identified deficiencies.

On the basis of the audit findings, no assurance can be provided to support the fact that INAC's Occupational Health and Safety Management Control Framework is adequate. Assurances also cannot be provided to support the fact that controls either ensure compliance with the OHS Directive of the Treasury Board Secretariat ("TB"), or ensure that INAC OHS policies, procedures and responsibilities are communicated, documented and understood.

Return to Table of Contents





1.0 Statement of Assurance

The audit of Indian and Northern Affairs Canada's ("INAC") Occupational Health and Safety ("OHS") Management Control Framework was conducted in accordance with the auditing standards specified by the INAC Internal Audit Manual, Version 1, dated April 25, 2008 and the Treasury Board of Canada's Policy on Internal Audit.

The objectives of the audit were to (1) provide reasonable assurance on the adequacy of INAC's OHS Management Control Framework; (2) provide reasonable assurance on the adequacy and effectiveness of controls for ensuring that the OHS Directive of the Treasury Board Secretariat ("TB") is complied with, and that INAC OHS policies, procedures and responsibilities are communicated, documented and understood; and (3) identify, where possible, potential OHS best practices for implementation within the department.

The audit evaluated management and employee awareness of, and compliance with, duties specified in the INAC OHS Statement of Roles and Responsibilities, on an INAC-wide basis (i.e. across all programs, sectors and regions); the existence and sufficiency of OHS program documentation required by law or Treasury Board, on an INAC-wide basis; the sufficiency of actions taken by management for protection of employees performing specific hazardous work activities carried out in INAC; the existence and functioning of OHS committees, representatives, and advisors across INAC; and compliance with the program documentation and activity record keeping requirements of the CSP Contaminated Sites Program, at headquarters and in the relevant Regions.

The audit was conducted in accordance with INAC's Internal Audit Manual (April 2008) with an amount of rigor and due professional care necessary for the provision of a reasonable level of assurance, as envisioned in the TB Policy on Internal Audit and related directives and in the Institute of Internal Auditors (IIA) International Standards for the Professional Practice of Internal Auditing (the IIA Standards).

The audit procedures developed were sufficient to gather evidence to support the accuracy of the conclusions reached and contained in this report. The conclusions were based on the information that existed at the time of the audit and are only applicable for the areas audited.

2.0 Background

INAC and its personnel are subject to OHS requirements contained in the Canada Labour Code Part II and regulations, and the Treasury Board Secretariat OHS Directive. These OHS requirements are broad in scope, and include specific management practices, document production and record-keeping, information collection and reporting, monitoring and evaluation activities, work practices, equipment and facility requirements, organizational structures and systems, investigation and review procedures, committee structures and functions, training and instruction, ect.

Contraventions of OHS requirements can have impacts ranging from the insignificant to the catastrophic, depending primarily upon the degree of harm to persons associated with the contravention. Legal consequences can include prosecution of the Department and its personnel under the Canada Labour Code and the Criminal Code, as well as exposure to civil liability in certain circumstances.

INAC has created a documented entitled "INAC OHS Statement of Roles and Responsibilities", which assigns a large number of specific OHS responsibilities to personnel across a variety of job functions and ranks at INAC [Note 1]. The Statement gives all INAC employees in all Programs and Regions certain basic OHS responsibilities, and gives a variety of more complex responsibilities to personnel with supervisory, managerial and executive roles. There are also specific additional responsibilities assigned to health and safety committees and representatives and health and safety staff specialists. The ultimate intent of this "Statement" is to provide guidance to employees in performance of activities that will ensure compliance and protection of personnel in the performance of work.

INAC has also established a Security and OHS Directorate, located at the Gatineau corporate office, which has been assigned a variety of program development, administration and monitoring functions via the OHS Statement of Roles and Responsibilities.

INAC has established a number of Workplace Health and Safety ("HS") Committees, and a Policy HS Committee. These Committees have statutory and regulatory functions, and additional functions as defined in the INAC OHS Statement of Roles and Responsibilities.

INAC manages and delivers a variety of programs. One program that has the potential to be particularly hazardous is the Northern Contaminated Sites Program ("NCSP"), which is mandated to remediate contaminated properties in the North. This Program has established an EHS Management Manual that prescribes a variety of supplementary health and safety roles, responsibilities and actions to be taken by specific corporate and regional personnel within the NCSP to ensure protection of personnel in field work settings and at contaminated sites.

At the request of the INAC Director of Security, Occupational Safety and Health, an audit of OHS was initiated by INAC's Audit and Evaluation Sector in order to characterize current conditions in the Department and provide information for OHS priority setting and planning purposes.

Return to Table of Contents





3.0 Objectives

The objectives of the audit were to:

  1. Provide reasonable assurance on the adequacy of INAC's OHS Management Control Framework.
  2. At selected INAC sites, provide reasonable assurance on the adequacy and effectiveness of controls for ensuring that
    1. the OHS Directive of the Treasury Board Secretariat ("TB") is complied with,
    2. and INAC OHS policies, procedures and responsibilities are
      1. communicated
      2. documented and
      3. understood
  3. Identify, where possible, potential OHS best practices for implementation within the department.
Return to Table of Contents





4.0 Scope

The scope of the audit included:

(1) Management awareness of, and compliance with empirically-measurable duties specified in the INAC OHS Statement of Roles and Responsibilities, on an INAC-wide basis (i.e. across all programs, sectors and regions), with the target groups being principally Directors General, Directors, Managers and Supervisors.

(2) Existence and sufficiency of OHS program documentation required by law or Treasury Board, on an INAC-wide basis.

(3) Sufficiency of actions taken by management for protection of employees performing some of the more hazardous work activities carried out in INAC, such as: work at construction or remediation sites; work in wilderness areas; travel by small airplane, helicopter, snow mobile, or small boat; and work in isolated areas where assistance could not readily be provided in emergency situations.

(4) Existence of OHS committees, representatives, and advisors, in all INAC workplaces where required by law or the INAC OHS Statement of Roles and Responsibilities; and extent to which the activities of committees, representatives and advisors comply with legislated functions, Treasury Board directives, and the INAC OHS Statement of Roles and Responsibilities. This was assessed on an INAC-wide basis.

(5) Compliance with the program documentation and activity record keeping requirements of the Contaminated Sites Program ("CSP"), at corporate and regional offices; and for a sample of site remediation projects, compliance with project safety management requirements specified in the CSP EHS Management Systems Manual.

The following were excluded from the audit scope:

(1) Management duties specified in the INAC OHS Statement of Roles and Responsibilities that are either (i) not operationally defined, or (ii) not empirically measurable, or (iii) for which measurement would not yield unequivocal findings, or (iv) for which the execution of the duty would be "need dependant", and the extent of need could not be fairly assessed in the audit.

(2) Employee duties specified in law, Treasury Board directives, or in the INAC OHS Statement of Roles and Responsibilities.  These duties are substantially limited to self-protection, compliance with employer instructions, and hazard reporting, and are not considered to be OHS "management controls".

(3) Direct assessment of compliance at workplaces with specific work practice, facility-related, and equipment-related standards (this was excluded by the audit terms of reference prepared by the Audit and Evaluation Sector).

The audit covered activities and documentation between January 1st 2008, and May 2009. Sufficient investigations and evaluations were conducted to provide a representative portrayal of conditions.

Return to Table of Contents





5.0 Approach

5.1 Audit Criteria

Audit criteria were derived directly from requirements specified by:

(1) The INAC OHS Statement of Roles and Responsibilities.

(2) Sections 134.1 through 137 of the Canada Labour Code Part II (pertaining to Policy HS Committees, Workplace HS Committees, and HS Representatives), the Health and Safety Committees Regulation made under the Canada Labour Code Part II, and portions of the Treasury Board OSH Directive pertaining to Policy HS Committees, Workplace HS Committees, and HS Representatives.

(3) Employer duties pertaining to preparation and maintenance of OHS program documentation, contained in the Canada Labour Code Part II, the Canada Occupational Health and Safety Regulations, and the Treasury Board OHS Directive.

(4) OHS program document and record production and maintenance duties of INAC corporate EHS staff, regional EHS staff, and contaminated sites project managers, as set out in the Contaminated Sites Program EHS Management Systems Manual – Edition 2 – March 2008.

The requirements contained in the following documents were also considered for purposes of formulating audit criteria, and were deemed suitable:

However, these documents contained no requirements that would result in any additional criteria beyond those referenced in (1), (2) and (3) above.

The requirements contained in the following documents would require "direct assessment of compliance at workplaces", and were excluded:

The consolidated listing of audit criteria is presented in Appendix 1. The listing also shows sources for all criteria.

5.2 Methodology

Audit conduct consisted of data collection and analysis activities in relation to four areas:

1 - Compliance with Requirements of the INAC OHS Roles and Responsibilities Statement Pertaining to OHS Management Controls

2 - Compliance with Canada Labour Code Part II ("CLC-II") and TB Requirements Respecting the Existence of Prescribed Policies, Procedures, Programs, Reports and Records pertaining to OHS Management Controls

3 - Compliance with CLC-II and TB Requirements Respecting Establishment and Operation of Policy and Workplace HS Committees

4 - Compliance with Requirements of the INAC Contaminated Sites Program – EHS Management Manual – Edition 2 – March 2008

Audit forms and checklists used for audit activities are presented in the following Appendices:

Some audit criteria were assessed on a population-basis (e.g. all HS Representatives, all HS Committee Co-Chairs, all OHS corporate program documents, existence of OHS committees at all workplaces where required), while others were assessed on a sample basis (e.g. compliance with responsibilities by certain groups of senior managers, adequacy of protective measures for a sample of employees performing specific high-hazard work operations, compliance with CSP EHS Management System requirements for a sample of remediation projects in the relevant regions).

Entire populations were reviewed where the size of the sample frame was small and all members of the population could be easily assessed, and sampling was used where the sample frames were too large to conduct a census of the entire population.

Audit planning and conduct was performed between February 3rd, 2009 and May 20th, 2009.

Return to Table of Contents





6.0 Conclusions

6.1 Objective 1: Adequacy of INAC's Occupational Health and Safety ("OHS") Management Control Framework

The design of INAC's OHS Management Control Framework is generally sound but there is a need for the preparation of additional management and operational procedures to provide specific instruction to personnel on how to perform more complex OHS functions and to incorporate explicit OHS objective setting and planning.

The degree of implementation of the OHS Management Control Framework is very low. As a result, there are many OHS statutory and regulatory requirements and TB OHS requirements that the Department has not complied with.

6.2 Objective 2: At specific INAC sites, provide reasonable assurance on the adequacy and effectiveness of controls

There are not adequate or effective controls in any Region or Program to ensure compliance with the TB OHS Directive and the level of compliance with most requirements is very low.

INAC OHS policies, procedures and responsibilities have not been effectively communicated to, and are poorly understood by, personnel at all levels of the organization, and in all Regions and Programs. Most of the requisite OHS documents and activity records are not being produced or maintained.

6.3 Objective 3: Identify, where possible, potential OHS best practices for implementation within the department

No OHS practices were identified that could be considered "best practices" for implementation throughout the Department.

6.4 Implications

Health and safety is not adequately managed or controlled in any of the Regions or Programs within the Department. This state of affairs has several potential consequences:

  1. It exposes the Department to the potential for orders and charges under the Canada Labour Code Part II.

  2. It renders it difficult for the Department to demonstrate due diligence in the event of a mishap.

  3. It may result in some employees being exposed to unacceptable health and safety risks in the performance of their work.

  4. It creates the potential for adverse publicity.

  5. It could expose Departmental managers to risk of Criminal Code prosecution in the event of the occurrence of any accidental workplace death or serious injury.

  6. It results in inefficient and ineffective deployment of staff and financial resources in relation to OHS issues.

  7. It presents potential for unfavourable perceptions of the Department by staff.
Return to Table of Contents





7.0 Observations and Recommendations

7.1 Compliance with the INAC OHS Statement of Roles and Responsibilities

7.2 Compliance with CLC-II and TB Requirements Respecting the Existence of Prescribed Policies, Procedures, Programs, Reports and Records pertaining to OHS Management Controls

Party No. OHS Program Documents [Note 10] No. Categories of OHS Activity Records [Note 11]
Each Region 16 24
Corporate 12 9
 
Regions' Document Compliance Profile
No. of Regions No. OHS Program Documents/Categories Observed No. Categories of OHS Activity Records Observed
1 7/16 11/24
1 6/16 6/24
3 2/16 0/24
6 1/16 0/24
 

7.3 Compliance with CLC-II and TB Requirements Respecting Establishment and Functioning of HS Representatives, and Policy and Workplace Health & Safety Committees

7.3.1 HS Representatives

7.3.2 Workplace Health and Safety Committees

7.3.2.1 Workplace and Regional Representation Structure
7.3.2.2 Selection of Co-Chairs and Members
7.3.2.3 Performance of Functions

7.3.3 Policy Health and Safety Committee

7.4 Compliance with Requirements of the INAC Contaminated Sites Program – Environmental Health and Safety ("EHS") Management Manual – Edition 2 – March 2008

7.4.1 Adequacy of the EHS Management Manual

7.4.2 Corporate and Regional Compliance with OHS Documentation Requirements

7.4.3 NCSP Project Manager Compliance with OHS Documentation Requirements

Return to Table of Contents





8.0 Recommendations

  1. OHS knowledge and competency requirements for all categories of managers and employees should be defined. Appropriately detailed instructional procedures should be developed. Training and instruction standards and programs should be established and implemented using a risk-based approach (i.e. higher hazard program areas and occupations) to ensure that personnel understand and can discharge their OHS roles and responsibilities.

  2. Specific OHS governance requirements and procedures, applicable to Corporate and the Regions should be established for: (1) OHS objective setting, (2) development of formal plans to achieve objectives; (3) OHS auditing and evaluation; (4) HS opinion surveys of the workforce; (5) internal reporting on the foregoing; and (6) senior management review of findings and recommendations arising therefrom. These requirements should be incorporated into the existing INAC OHS Statement of Roles and Responsibilities.

  3. The scope of support to be provided to internal departmental clients by SOHS Directorate and other departmental HS resources, as well as the performance standards, mechanisms for delivering such support, resource requirements for success, and procedures for monitoring delivery and impacts should be developed.

  4. A blueprint for future corporate OHS program development (policies, standards, procedures), determining resource requirements, obtaining senior management approval should be developed and implemented in consultation with the Policy HS Committee.

  5. An enterprise information management system requirements and procedures to support department-wide HS management and record keeping should be assessed, specified and implemented.

  6. Department-wide OHS programs, guidelines and procedures required for the higher risk operations carried out by departmental personnel should be identified, developed and implemented.

  7. Procedures to ensure proper flow of information between SOHS Directorate, HR / HS Advisors, HS Representatives, and HS Committees should be established and implemented.

  8. The selection and appointment of health and safety representatives at those additional locations where required should be conducted.

  9. The need for additional HS specialist staff, and optimal organizational placement, to adequately support the organization should be assessed.

  10. HRSDC approval of the existing HS committee structure, to avoid the need for creation of additional HS committees, should be obtained.
Return to Table of Contents





9.0 Management Action Plan

Recommendations Actions Responsible Manager (Title) Planned Implementation and Completion Dates
1. OHS knowledge and competency requirements for all categories of managers and employees should be defined. Appropriately detailed instructional procedures should be developed. Training and instruction standards and programs should be established and implemented using a risk-based approach (i.e. higher hazard program areas and occupations) to ensure that personnel understand and can discharge their OHS roles and responsibilities. Development of a national OHS training program is underway with specific modules for:

a) managers (4-5 hours),
b) local committees (4-5 hours) and
c) employees (60-90 minutes)

All modules will meet legislative and Treasury Board requirements.

Training delivery will be prioritized in high-risk areas – expected to start in October 2009.

All 3 modules can be delivered in a given Region during a 4-5 day span.

Committed to provide ongoing training to new employees and refreshers to employees who have already received training sessions.
DG, HRWSB Delivery of training for high risk area in February 2010 and, depending on available financial and human resources, will be virtually completed by March 2012. It should be noted that training will be ongoing beyond March 2012 to train new committee members, new managers, new employees, and to retrain according to new hazards or legislative changes.

Training will be an ongoing activity.
2. Specific OHS governance requirements and procedures, applicable to Corporate and the Regions should be established for: (1) OHS objective setting, (2) development of formal plans to achieve objectives; (3) OHS auditing and evaluation; (4) HS opinion surveys of the workforce; (5) internal reporting on the foregoing; and (6) senior management review of findings and recommendations arising therefrom. These requirements should be incorporated into the existing INAC OHS Statement of Roles and Responsibilities. A 3-year OHS Strategic Plan is being developed and will address five major areas:
  • Policies / guidelines / procedures

  • Training

  • Committees and representatives

  • Reporting

  • Communications
All policies, guidelines and/or procedures will include statements of roles and responsibilities.
DG, HRWSB The strategic plan implementation date is February 2010, as reported to the Audit Committee on September 25, 2009.
Inspections, audits and evaluations will be part of regular cycle and will be defined in guidelines (Chapter 7). Inspections, audits and evaluations will be ongoing activities.
A tracking system is being developed and will be used to report back to the National Policy Health and Safety Committee.

The strategic plan will rely heavily on active regional participation through monthly exchanges with OHS Coordinators.

A first face-to-face meeting is planned for November 2009 at which clear objectives and timelines will be established for monitoring, reporting and evaluation of the OHS Program.
Once in place in the first quarter of 2010-11, reporting will be done on a quarterly basis.
3. The scope of support to be provided to internal departmental clients by SOHS Directorate and other departmental HS resources, as well as the performance standards, mechanisms for delivering such support, resource requirements for success, and procedures for monitoring delivery and impacts should be developed. The 8 Chapters of INAC's National OHS Program clearly identify all these elements, under different headings. The last 5 Chapters were reviewed and approved by the National Policy H&S Committee on June 15, 2009 and are currently being reviewed by the local committees in the regions.

Presentation to senior management is scheduled for early December 2009.
DG, HRWSB December 2009
4. A blueprint for future corporate OHS program development (policies, standards, and procedures), determining resource requirements, and obtaining senior management approval should be developed and implemented in consultation with the Policy HS Committee. The OHS Strategic Plan will outline ongoing OHS activities and requirements for the next 3 years (2012). It is based on legislative and Treasury Board requirements with a focus on INAC's particular activities and programs.

All new policies, standards and/or procedures will be developed in consultation with the National Policy H&S Committee.
DG, HRWSB At the Nov. 2009 conference with Regional OHS Coordinators, priorities for development of policies, standards and procedures were identified.

To review policies and guidelines on a periodic basis
5. An enterprise information management system requirements and procedures to support department-wide HS management and record keeping should be assessed, specified and implemented. A tracking system is currently being developed to capture all OHS reporting requirements, by law or by TB Directive. The system will allow for quarterly reporting on the status of the Departmental OHS Program for internal and external stakeholders.

The system will be introduced at the November 2009 meeting with the Regional OHS Coordinators. Data collection is expected to begin in the first quarter of 2010-11.
DG, HRWSB The system was discussed at the November 2009 conference with the Regional OHS Coordinators who are in agreement with the proposal. The spreadsheet-type report is currently being customized for every site controlled by INAC. It should be ready for testing in the 4th quarter of 2009-10, and for full use in the first quarter of 2010-11.
6. Department-wide OHS programs, guidelines and procedures required for the higher risk operations carried out by departmental personnel should be identified, developed and implemented. National policies and guidelines are completed and have been vetted at the National Policy Health and Safety Committee on June 15, 2009. Once reviewed by the Regions by August 21, they will be submitted to senior management. DG, HRWSB December 2009

(National Policies)
Working groups of Regional OHS Coordinators will be formed at the November meeting to identify and develop, or review existing procedures for high-risk operations, such as site decontamination. November 2009

(working groups)
7. Procedures to ensure proper flow of information between SOHS Directorate, HR / HS Advisors, HS Representatives, and HS Committees should be established and implemented. Theses procedures are included in the national policies and guidelines (8 Chapters).

The OHS training sessions will include many references to the procedures to ensure a constant and consistent approach in the flow of information.
DG, HRWSB Starting December 2009
8. The selection and appointment of health and safety representatives at those additional locations where required should be conducted. We have requested a list of all local committee members and health and safety representatives, at all sites controlled by INAC.

We are advising Regional Management on the requirement to nominate H&S representatives. All H&S representatives and local committee members will be prioritized for training in the fall of 2009.

The Regional OHS Coordinators will be tasked with the monitoring and will report back to Corporate OHS.
DG, HRWSB in collaboration with RDGs and the Responsible Senior Manager (for satellite offices). One training session for OHS Committee members and representatives will take place in the NCR December 4, 2009. Training at the national level should be completed by February 2010.

The Regional OHS Coordinators have received training November 23 to 27 and will now be in a better position to schedule training for OHS Committees and representatives in their regions.
9. The need for additional HS specialist staff, and optimal organizational placement, to adequately support the organization should be assessed. Regional OHS Coordinators have been identified in every region. A 3 to 4 day training session is planned for November 2009.

The session will outline clear objectives and provide them with tools to support the delivery of the OHS Program in the regions.

We will monitor the activities related to the delivery of the OHS Program and assess the need for additional H&S staff on an annual basis.
DG, HRWSB A 5-day training session took place November 23 to 27 for Regional OHS Coordinators, as planned.
10. HRSDC approval of the existing HS committee structure, to avoid the need for creation of additional HS committees, should be obtained. Regions have been advised at a June 2009 teleconference of the requirement to obtain exemptions to form committees – some regions only have one regional committee.

Assistance was offered and provided, in obtaining exemptions. We are still gathering information on regional and local committee structures and we will seek updates at the next teleconferences. All committees should be legally structured and operational by December 31, 2009.
DG, HRWSB in collaboration with RDGs February 2010.

Regional OHS Coordinators have confirmed active committees in their regions and the need for either representatives or regional committees.
 

 

Appendix 1

Key :

CLCII = Canada Labour Code Part II
COHSR = Canadian Occupational Health and Safety Regulations
EHSCSM = National Contaminated Sites Program EHS Management Systems Manual
HSCRR = Health and Safety Committees and Representatives Regulation
OHSSRR = INAC OHS Statement of Roles and Responsibilities
TBOHSD = Treasury Board OHS Directive

      DESIGNATED RESPONSIBLE PARTY (X), PARTY OF INQUIRY (HIGHLIGHT)
Audit Area Source Responsabilities Departments (TBD) Deputy Minister (INAC) Assistant Deputy Ministers (INAC) Chief Financial Officer (INAC) Director General - Human Resources and Workplace Services (INAC) Director General - Communications (INAC) Chief Audit and Evaluation Executive (INAC) Executive Director - Inuit Relations Secretariat and Corporate Secretary (INAC)
1 OHSSRR   Provides overall accountability in developing and maintaining a healthy and safe work environment.   x            
1 OHSSRR   Provide advice, guidance and support regarding OHS matters to managers, employees, workplace health and safety committees and health and safety representatives in their respective regions or their area of responsibility.                
1 OHSSRR   Provides functional direction, information and advice on legislative, administrative and technical health and safety matters to management, employees, Health and Safety Advisors and Human Resource Officers.                
1 OHSSRR   Provides subject matter expertise to the Policy Health and Safety Committee.                
1 OHSSRR   Appointing a Co-Chairperson, at the Director General level or above, to the Policy Health and Safety Committee.   x            
1 OHSSRR   Employee health and safety representatives are appointed to address OHS issues for each workplace controlled by INAC where there are less than 20 employees.                
1 OHSSRR   Identify senior representatives to serve on the Policy Health and Safety Committee.     x x x x x x
1 OHSSRR   Policy Health and Safety Committee shall include employee representatives and senior management representatives.                
1 OHSSRR   Committees shall include employee and management representatives.                
1 OHSSRR   Committees shall (be established) in a workplace of 20 or more employees.                
1 OHSSRR   Where applicable, designate regional Health and Safety Advisors.     x x x x x x
1 OHSSRR   Assign departmental OHS personnel according to the size, complexity and operating risks of the department. x              
1 OHSSRR   Communicates the commitment of senior management in developing and maintaining a healthy and safe work environment.   x            
1 OHSSRR   Inform the Security and Occupational Health and Safety Directorate of regional OHS strategic plans, initiatives and emerging issues                
1 OHSSRR   Keep employees informed of applicable OHS matters.                
1 OHSSRR   Liaise with the Security and Occupational Health and Safety Directorate.                
1 OHSSRR   Liaises with central agencies by representing INAC's interests and needs, and reports back on issues affecting the Department.                
1 OHSSRR   Participates with central agencies and departments on OHS issues of national importance such as SARS, Avian Flu, Pandemics, etc..                
1 OHSSRR   Provide all regulatory and statistical data as requested by the Security and Occupational Health and Safety Directorate.                
1 OHSSRR   Refer matters and issues that cannot be resolved, and that have been referred to them by workplace committees and representatives, to the Policy Health and Safety Committee for their consideration.                
1 OHSSRR   Make recommendations and report its activities to the Deputy Minister through the National Union Management Consultation Committee.                
1 OHSSRR   Committees shall report to the most senior officer responsible for that workplace, or to their delegate.                
1 OHSSRR   Undertake or assume the role of the person in authority to whom workplace health and safety committees report, when they are the most senior officer of the physical location.     x x x x x x
1 OHSSRR   Ensure accessibility to operational OHS training in consultation with the Security and Occupational Health and Safety Directorate.                
1 OHSSRR   Facilitates and co-ordinates cross-group/cross-region consultations on OHS matters and responses.                
1 OHSSRR   Facilitates the implementation of necessary OHS measures.         x      
1 OHSSRR   Employees have a responsibility to take all reasonable and necessary precautions to ensure their health and safety and that of anyone else who may be affected by their work or activities.                
1 OHSSRR   Take reasonable precautions to protect themselves and other employees (TBD).                
1 OHSSRR   Ensure that the Internal Complaint Resolution Process is followed to address any OHS concerns that an employee may have.                
1 OHSSRR   Follow prescribed procedures with respect to health and safety.                
1 OHSSRR   Use the OHS equipment and devices provided (TBD).                
1 OHSSRR   Implement corporate OHS policies, directives, procedures and guidelines in a timely manner.                
1 OHSSRR   Comply with Health Canada directives on the occupational safety and health of employees. x              
1 OHSSRR   Ensure compliance with all applicable OHS legislation, regulations, policies and directives.                
1 OHSSRR   Ensure that employees comply with the OHS requirements such as legislation, policies, directives and guidelines associated with their individual employment.                
1 OHSSRR   Ensure that periodic health evaluations are carried out for employees within their areas of responsibility for identified positions in accordance with the Occupational Health Assessment Guide (OHAG).                
1 OHSSRR   Ensure implementation of this document at all departmental workplaces.   x            
1 OHSSRR   Establish and maintain effective occupational safety and health (OSH) programs consistent with Treasury Board policies, standards and procedures. x              
1 OHSSRR   Implement all applicable OHS legislation, regulations, policies and directives.                
1 OHSSRR   Perform the functions of the committee when no employee representatives have been nominated to participate on a workplace health and safety committee, and until such time as one is selected.                
1 OHSSRR   Provide employee assistance services.                
1 OHSSRR   Provide leadership in the effective implementation of OHS initiatives within their respective areas of responsibility.     x x x x x x
1 OHSSRR   Committees shall address health and safety matters in the workplace.                
1 OHSSRR   Ensure that all employees under their supervision are adequately informed, instructed, trained (in) the OHS hazards associated with their employment.                
1 OHSSRR   Ensure that all employees under their supervision are knowledgeable of the OHS hazards associated with their employment.                
1 OHSSRR   Ensure that employees have adequate training to meet OHS requirements.     x x x x x x
1 OHSSRR   Ensure that employees within their area of responsibility are aware and understand their responsibilities.     x x x x x x
1 OHSSRR   Ensure that managers have adequate training to meet OHS requirements.     x x x x x x
1 OHSSRR   Ensure that managers within their area of responsibility are aware and understand their responsibilities.     x x x x x x
1 OHSSRR   Ensures that a general departmental OHS training and awareness program is in place.                
1 OHSSRR   Learn and follow the OSH provisions of the workplace (TBD)                
1 OHSSRR   Provide OSH training and information to employees. x              
1 OHSSRR   Provides corporate leadership on OHS issues that affect the entire Department.         x      
1 OHSSRR   Provides overall leadership in developing and maintaining a healthy and safe work environment.   x            
1 OHSSRR   Policy Health and Safety Committee includes shall address strategic departmental health and safety matters.                
1 OHSSRR   Co-ordinate and monitor, in their respective regions, the implementation of the OHS training and awareness requirements, in consultation with the Security and Occupational Health and Safety Directorate.                
1 OHSSRR   Ensure managers are providing employees with an overview of OHS.                
1 OHSSRR   Ensure the monitoring of this document at all departmental workplaces.   x            
1 OHSSRR   Monitor corporate OHS policies, directives, procedures and guidelines in a timely manner.                
1 OHSSRR   Monitor regional OHS reporting through the departmental or regional OHS databases.                
1 OHSSRR   Monitors and reports on the effectiveness of the program and on the Employer's Annual Hazardous Occurrence Report.         x      
1 OHSSRR   Monitors the departmental Occupational Health and Safety program through investigations, inspections, surveys and audits.                
1 OHSSRR   Monitors the performance of workplace health and safety committees.                
1 OHSSRR   Oversee and monitor the implementation of the OHS program within their area of responsibility.                
1 OHSSRR   The Security and Occupational Health and Safety Directorate shall monitor the implementation of this document.                
1 OHSSRR   Develop programs, guidelines and procedures in consultation with the Security and Occupational Health and Safety Directorate to meet specific requirements in their area of responsibility.                
1 OHSSRR   Develops policies, directives, standards and procedures in consultation with the OHS policy committee.                
1 OHSSRR   Ensure development of this document at all departmental workplaces.   x            
1 OHSSRR   Signing off on departmental OHS policies.   x            
1 OHSSRR   Issue and approve regional, directorate, OHS guidelines, directives or procedures in accordance with this document to meet specific operational needs.     x x x x x x
1 OHSSRR   Issues internal departmental OHS policies, directives and guidelines in consultation with the Policy Health and Safety Committee.         x      
1 OHSSRR   Post a copy of a general policy statement worded this way: "A high priority in the Public Service of Canada is providing working conditions conducive to the safety and health of employees. This department is committed to promoting occupational safety and. x              
1 OHSSRR   Post a copy of the Canada Labour Code, Part II. x              
1 OHSSRR   Post any printed notices or other material prescribed by Human Resources Development Canada - Labour Program or the Treasury Board Secretariat. x              
1 OHSSRR   Keep and maintain health and safety records for their area of responsibility.                
1 OHSSRR   Maintains program records.                
1 OHSSRR   Manages the departmental OHS database.                
1 OHSSRR   Ensure that employees have adequate resources to meet OHS requirements.     x x x x x x
1 OHSSRR   Ensure that managers have adequate resources to meet OHS requirements.     x x x x x x
1 OHSSRR   Plan and budget for OHS initiatives within their organizations.     x x x x x x
1 OHSSRR   Plans and budgets for essential OHS resources, including training.         x      
1 OHSSRR   Ensure that all known OHS incidents, accidents and occupational illnesses are reported to the INAC Health and Safety Advisors.                
1 OHSSRR   Ensure timely and effective hazardous occurrence investigation, recording and reporting and use this as a monitoring tool.                
1 OHSSRR   Investigate, record and report all accidents, occupational illnesses and other hazardous occurrences known.                
1 OHSSRR   Report internally and externally on INAC's OHS program performance, including the analysis of accident trends.                
1 OHSSRR   Submits an annual written report on the 1st of March of each year to the HRSDC Labour Program, outlining the number of accidents, occupational diseases and other hazardous occurrences for each identified workplace of which management is aware.                
2 TBOHSD Part 1, General Procedure for resolution of "qualified person" dispute x              
2 TBOHSD 5.4 Procedure for Halon system non-destructive testing and inspection x              
2 TBOHSD 7.1 Report of any noise exposure investigation x              
2 TBOHSD 9.2.7 Contingency procedures for cases in which there is a temporary interruption in the supply of drinking water and water for the removal of water-borne waste x              
2 TBOHSD 10.1 Record of all hazardous substances that, in the work place, are used, produced, handled, or stored x              
2 TBOHSD 10.5 Record of each air sample test related to exposure to hazardous substance x              
2 TBOHSD 10.6 Asbestos management program x              
2 TBOHSD 12.15 Storage, maintenance, inspection, and testing of personal protective equipment x              
2 TBOHSD 15.11 Hazardous occurrence investigation procedures and methodology x              
2 TBOHSD 16.1.2 Procedures respecting the availability of first-aid services x              
2 TBOHSD 16.2.2 Procedures respecting the availability of first-aid services x              
2 TBOHSD 18.7 Rules of procedure for Policy Committees x              
2 TBOHSD 18.9 Policy Committee Minutes x              
2 TBOHSD 18.10 Regional policy HS committee terms of reference x              
2 TBOHSD 18.14 Workplace HS committee rules of procedure x              
2 TBOHSD 18.16 Records of all matters brought before workplace committee x              
2 TBOHSD 1.0 Copy of a general policy statement x              
2 CLCII 125(1)d)(2) Health and Safety policy x              
2 CLCII 125(1)z.03) Program for the prevention of hazards in the work place x              
2 CLCII 125(1)z.13) Program for the provision of personal protective equipment, clothing, devices or materials x              
2 CLCII 125(1)z.10) Written response to recommendations made by work place and policy committee x              
2 CLCII 125(1)z.17) Name, work telephone numbers and work locations of work place committee members / HS representative x              
2 CLCII 135.1(9) Meeting minutes x              
2 CLCII 135.1(9) Records of complaints, investigations x              
2 CLCII 135.2g) Annual record report of activities x              
2 HSCRR 9 Minutes of safety and health committee meetings x              
2 HSCRR 10 Report of the safety and health committee's activities x              
2 COHSR 2.27(1) Procedure for investigating situations in which the health or safety of an employee in the work place is or may be endangered by the air quality x              
2 COHSR 2.27(7) Records of every indoor air quality complaint and investigation for at least five years x              
2 COHSR 7.3(5) Report of noise exposure investigation x              
2 COHSR 7.7(2)a) Procedures for hearing protection fit, care and use of hearing protector x              
2 COHSR 10.3 Record of all hazardous substances that, in the work place, are used, produced, handled, or stored x              
2 COHSR 10.5 Written reports of investigation into exposure to hazardous substance x              
2 COHSR 10.5b) Written procedure for the control of the concentration or level of the hazardous substance in the work place x              
2 COHSR 10.15 Employee education program x              
2 COHSR 10.15 Record of instruction and training for hazardous substances x              
2 COHSR 10.49d) Maintenance and operating procedures to prevent the escape of flammable liquids and combustible liquids x              
2 COHSR 12.14(1) Record of all protection equipment provided by the employer x              
2 COHSR 12.15(1) Written instructions in the use, operation and maintenance of the equipment x              
2 COHSR   Written emergency procedures x              
2 COHSR 14.20 Record of maintenance, use and testing before initial use x              
2 COHSR 14.23(4) Record of training for operators x              
2 COHSR 14.29(4) Record of any repair or modification work and of any restriction on use imposed x              
2 COHSR 15.4 Records of any motor vehicle accident x              
2 COHSR 15.7(1) Record of each minor injury x              
2 COHSR 15.8 Record describing the hazardous occurrence (incl. time, date and location), the cause of the occurrence and corrective measures taken? x              
2 COHSR 15.10 Written yearly summary to Minister x              
2 COHSR 16.2(1) Written first aid instructions that provide for the prompt rendering of first aid to an employee for an injury, an occupational disease or an illness x              
2 COHSR 16.13 On-site first aid-records x              
2 COHSR 16.13(2) Off-site first aid-records x              
2 COHSR 16.13(6) Record of the expiry dates of the first aid certificates of the first aid attendants                
2 COHSR 17.4(1) Emergency procedures re: spilll,leak, failure of lighting, fire x              
2 COHSR 17.8(2) Record of all instruction and training provided to every emergency warden, deputy emergency warden and monitor x              
2 COHSR 17.5(2) Emergency evacuation plan, where applicable, or a plan for evacuating employees who require special assistance to be implemented in the event of a fire x              
2 COHSR 17.9 Record of inspection of all fire escapes, exits, stairways and fire protection equipment in a building x              
2 COHSR 17.10(2) Record of each Emergency Warden meeting and emergency evacuation drill x              
2 COHSR 19.1 Hazard Prevention Program x              
2 COHSR 19.5(2) Preventive Maintenance Program x              
2 COHSR 19.6(5) Records of health and safety education, including education relating to ergonomics x              
2 COHSR 19.8 Hazard prevention program evaluation report x              
2 COHSR 20.9 Records of investigation of employee reports x              
2 COHSR 20.5 Assessment of potential for work place violence x              
2 COHSR 20.6(3) Procedures for appropriate follow-up maintenance and corrective measures x              
2 COHSR 20.7 Record of review of the effectiveness of the work place violence prevention measures x              
2 COHSR 20.10 Records on the information, instruction and training provided to each employee exposed to work place violence or a risk of work place violence x              
3 CLCII 136(5)b) Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints;                
3 CLCII 136(5)d) Shall participate in the implementation and monitoring of the program referred to in paragraph 134.1(4)(c);                
3 CLCII 136(5)e) Where the program referred to in paragraph 134.1(4)(c) does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in health and safety matters related to those hazards;                
3 CLCII 136(5)g) Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the representative on those matters;                
3 CLCII 136(5)i) Shall participate in the implementation of changes that may affect occupational health and safety, including work processes and procedures and, where there is no policy committee, shall participate in the planning of the implementation of those changes;                
3 CLCII 136(5)j) Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year;                
3 CLCII 136(5)k) Shall participate in the development of health and safety policies and programs;                
3 CLCII 136(5)l) Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; and                
3 CLCII 136(5)m) Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program.                
3 CLCII 136(1) Every employer shall, for each work place controlled by the employer at which fewer than twenty employees are normally employed or for which an employer is not required to establish a work place committee, appoint the person selected in accordance with subsection (2) as the health and safety representative for that work place.                
3 CLCII 136(2) The employer shall perform the functions of the health and safety representative until a person is selected under subsection (2).                
3 CLCII 136(2) The health and safety representative for a work place shall be selected as follows: (a) the employees at the work place who do not exercise managerial functions shall select from among those employees the person to be appointed; or (b) if those employees are represented by a trade union, the trade union shall select the person to be appointed, in consultation with any employees who are not so represented, and subject to any regulations made under subsection (11).                
3 CLCII 134.1(1) Every employer who normally employs directly three hundred or more employees shall establish a policy health and safety committee and, subject to section 135.1, select and appoint its members.                
3 CLCII 134.1(4)i) Shall meet during regular working hours at least quarterly and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours.                
3 CLCII 134.1(4)g) Shall monitor data on work accidents, injuries and health hazards; and                
3 CLCII 134.1(4)c) Shall participate in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters;                
3 CLCII 134.1(4)e) Shall participate in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials;                
3 CLCII 134.1(4)a) Shall participate in the development of health and safety policies and programs;                
3 CLCII 134.1(4)h) Shall participate in the planning of the implementation and in the implementation of changes that might affect occupational health and safety, including work processes and procedures.                
3 CLCII 134.1(4)d) Shall participate to the extent that it considers necessary in inquiries, investigations, studies and inspections pertaining to occupational health and safety;                
3 CLCII 135.1(8) The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member.                
3 CLCII 135.1(6) The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b).                
3 CLCII 135.1(9) A committee shall ensure that accurate records are kept of all of the matters that come before it and that minutes are kept of its meetings. The committee shall make the minutes and records available to a health and safety officer at the officer's request.                
3 CLCII 135.1(7) A committee shall have two chairpersons selected from among the committee members. One of the chairpersons shall be selected by the employee members and the other shall be selected by the employer members.                
3 CLCII 135.1(1) A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have been selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented.                
3 CLCII 135.1 Every employer shall, for each work place controlled by the employer at which twenty or more employees are normally employed, establish a work place health and safety committee and, subject to section 135.1, select and appoint its members.                
3 CLCII 135.1(5) If (there is no committee), the employer shall perform the functions of the committee until a person is selected and the committee is established.                
3 CLCII 137 If an employer controls more than one work place referred to in section 135 or 136 or the size or nature of the operations of the employer or those of the work place precludes the effective functioning of a single work place committee or health and safety representative, as the case may be, for those work places, the employer shall, subject to the approval or in accordance with the direction of a health and safety officer, establish or appoint in accordance with section 135 or 136, as the case may require, a work place committee or health and safety representative for the work places that are specified in the approval or direction.                
3 CLCII 135.1(7)j) Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances;                
3 CLCII 135.1(7)a) Shall consider and expeditiously dispose of matters concerning health and safety raised by members of the committee or referred to it by a work place committee or a health and safety representative;                
3 CLCII 135.1(7)h) Shall cooperate with health and safety officers;                
3 CLCII 135.1(7)g) Shall ensure that adequate records are maintained on work accidents, injuries and health hazards relating to the health and safety of employees and regularly monitor data relating to those accidents, injuries and hazards;                
3 CLCII 135.1(7)k) Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; and                
3 CLCII 135.1(7)e) Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the committee on those matters;                
3 CLCII 135.1(7)c) Shall participate in the development, implementation and monitoring of a program for the prevention of those hazards (not covered by the hazard prevention program) that also provides for the education of employees in health and safety matters related to those hazards;                
3 CLCII 135.1(7)f) Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program;                
3 CLCII 135.1(7)b) Shall participate in the implementation and monitoring of the program referred to in paragraph 134.1(4)c)                
3 CLCII 135.1(7)i) Shall participate in the implementation of changes that might affect occupational health and safety, including work processes and procedures and, where there is no policy committee, shall participate in the planning of the implementation of those changes;                
3 CLCII 135.1(8) The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member.                
3 CLCII 135.1(6) The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b).                
3 CLCII 135.1(10) Work place committee shall meet during regular working hours at least nine times a year at regular intervals and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours.                
3 HSCRR 8 Quorum of a safety and health committee shall consist of the majority of the members of the committee, of which at least half are representatives of the employees and at least one is a representative of the employer.                
3 HSCRR 9(4) A copy of the minutes referred to in subsection (1) shall be kept by the employer at the work place to which it applies or at the head office of the employer for a period of two years from the day on which the safety and health committee meeting is held in such a manner that it is readily available for examination by a safety officer.                
3 HSCRR 5(1) A safety and health committee shall have two chairmen selected from among the members of the committee, one being selected by the representatives of the employees and the other by the representatives of the employer.                
3 HSCRR 10 The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen referred to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report referred to in paragraph (a), post a copy of the report in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months.                
3 HSCRR 9(2) The chairman selected by the representatives of the employer shall provide, as soon as possible after each safety and health committee meeting, a copy of the minutes referred to in subsection (1) to the employer and to each member of the safety and health committee.                
3 HSCRR 5(2) The chairmen referred to in subsection (1) shall act alternately for such period of time as the safety and health committee specifies in its rules of procedure.                
3 HSCRR 3 The employer shall select the member or members of a safety and health committee to represent him from among persons who exercise managerial functions.                
3 HSCRR 9(3) The employer shall, as soon as possible after receiving a copy of the minutes referred to in subsection (2), post a copy of the minutes in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for one month.                
3 HSCRR 9(1) The minutes of each safety and health committee meeting shall be signed by the two chairmen referred to in subsection 5(1).                
3 HSCRR 7 Where a member of a safety and health committee resigns or ceases to be a member for any other reason, the vacancy shall be filled within 30 days after the next regular meeting of the committee.                
3 HSCRR 4 Where any employees at a work place are not represented by a trade union, those employees shall select, by majority vote, the member or members of the safety and health committee to represent them.                
 
      DESIGNATED RESPONSIBLE PARTY (X), PARTY OF INQUIRY (HIGHLIGHT)
Audit Area Source Responsabilities Directors General (INAC) Directors (INAC) Managers (INAC) Supervisors (INAC) Employees (INAC) Security and Occupational Health and Safety Directorate (INAC) Health and Safety Advisors and/or Human Resources Officers (INAC) Health and Safety Representatives (INAC)
1 OHSSRR   Provides overall accountability in developing and maintaining a healthy and safe work environment.                
1 OHSSRR   Provide advice, guidance and support regarding OHS matters to managers, employees, workplace health and safety committees and health and safety representatives in their respective regions or their area of responsibility.             x  
1 OHSSRR   Provides functional direction, information and advice on legislative, administrative and technical health and safety matters to management, employees, Health and Safety Advisors and Human Resource Officers.           x    
1 OHSSRR   Provides subject matter expertise to the Policy Health and Safety Committee.           x    
1 OHSSRR   Appointing a Co-Chairperson, at the Director General level or above, to the Policy Health and Safety Committee.                
1 OHSSRR   Employee health and safety representatives are appointed to address OHS issues for each workplace controlled by INAC where there are less than 20 employees.               x
1 OHSSRR   Identify senior representatives to serve on the Policy Health and Safety Committee.                
1 OHSSRR   Policy Health and Safety Committee shall include employee representatives and senior management representatives.                
1 OHSSRR   Committees shall include employee and management representatives.                
1 OHSSRR   Committees shall (be established) in a workplace of 20 or more employees.                
1 OHSSRR   Where applicable, designate regional Health and Safety Advisors.                
1 OHSSRR   Assign departmental OHS personnel according to the size, complexity and operating risks of the department.                
1 OHSSRR   Communicates the commitment of senior management in developing and maintaining a healthy and safe work environment.                
1 OHSSRR   Inform the Security and Occupational Health and Safety Directorate of regional OHS strategic plans, initiatives and emerging issues             x  
1 OHSSRR   Keep employees informed of applicable OHS matters. x x x x        
1 OHSSRR   Liaise with the Security and Occupational Health and Safety Directorate.             x  
1 OHSSRR   Liaises with central agencies by representing INAC's interests and needs, and reports back on issues affecting the Department.           x    
1 OHSSRR   Participates with central agencies and departments on OHS issues of national importance such as SARS, Avian Flu, Pandemics, etc..           x    
1 OHSSRR   Provide all regulatory and statistical data as requested by the Security and Occupational Health and Safety Directorate.             x  
1 OHSSRR   Refer matters and issues that cannot be resolved, and that have been referred to them by workplace committees and representatives, to the Policy Health and Safety Committee for their consideration.             x  
1 OHSSRR   Make recommendations and report its activities to the Deputy Minister through the National Union Management Consultation Committee.                
1 OHSSRR   Committees shall report to the most senior officer responsible for that workplace, or to their delegate.                
1 OHSSRR   Undertake or assume the role of the person in authority to whom workplace health and safety committees report, when they are the most senior officer of the physical location. x x x x        
1 OHSSRR   Ensure accessibility to operational OHS training in consultation with the Security and Occupational Health and Safety Directorate.             x  
1 OHSSRR   Facilitates and co-ordinates cross-group/cross-region consultations on OHS matters and responses.           x    
1 OHSSRR   Facilitates the implementation of necessary OHS measures.                
1 OHSSRR   Employees have a responsibility to take all reasonable and necessary precautions to ensure their health and safety and that of anyone else who may be affected by their work or activities.         x      
1 OHSSRR   Take reasonable precautions to protect themselves and other employees (TBD).         x      
1 OHSSRR   Ensure that the Internal Complaint Resolution Process is followed to address any OHS concerns that an employee may have. x x x x        
1 OHSSRR   Follow prescribed procedures with respect to health and safety.         x      
1 OHSSRR   Use the OHS equipment and devices provided (TBD).         x      
1 OHSSRR   Implement corporate OHS policies, directives, procedures and guidelines in a timely manner. x x x x        
1 OHSSRR   Comply with Health Canada directives on the occupational safety and health of employees.                
1 OHSSRR   Ensure compliance with all applicable OHS legislation, regulations, policies and directives. x x x x        
1 OHSSRR   Ensure that employees comply with the OHS requirements such as legislation, policies, directives and guidelines associated with their individual employment. x x x x        
1 OHSSRR   Ensure that periodic health evaluations are carried out for employees within their areas of responsibility for identified positions in accordance with the Occupational Health Assessment Guide (OHAG). x x x x        
1 OHSSRR   Ensure implementation of this document at all departmental workplaces.                
1 OHSSRR   Establish and maintain effective occupational safety and health (OSH) programs consistent with Treasury Board policies, standards and procedures.                
1 OHSSRR   Implement all applicable OHS legislation, regulations, policies and directives. x x x x        
1 OHSSRR   Perform the functions of the committee when no employee representatives have been nominated to participate on a workplace health and safety committee, and until such time as one is selected. x x x x        
1 OHSSRR   Provide employee assistance services.                
1 OHSSRR   Provide leadership in the effective implementation of OHS initiatives within their respective areas of responsibility.                
1 OHSSRR   Committees shall address health and safety matters in the workplace.                
1 OHSSRR   Ensure that all employees under their supervision are adequately informed, instructed, trained (in) the OHS hazards associated with their employment. x x x x        
1 OHSSRR   Ensure that all employees under their supervision are knowledgeable of the OHS hazards associated with their employment. x x x x        
1 OHSSRR   Ensure that employees have adequate training to meet OHS requirements.                
1 OHSSRR   Ensure that employees within their area of responsibility are aware and understand their responsibilities.                
1 OHSSRR   Ensure that managers have adequate training to meet OHS requirements.                
1 OHSSRR   Ensure that managers within their area of responsibility are aware and understand their responsibilities.                
1 OHSSRR   Ensures that a general departmental OHS training and awareness program is in place.           x    
1 OHSSRR   Learn and follow the OSH provisions of the workplace (TBD)         x      
1 OHSSRR   Provide OSH training and information to employees.                
1 OHSSRR   Provides corporate leadership on OHS issues that affect the entire Department.                
1 OHSSRR   Provides overall leadership in developing and maintaining a healthy and safe work environment.                
1 OHSSRR   Policy Health and Safety Committee includes shall address strategic departmental health and safety matters.                
1 OHSSRR   Co-ordinate and monitor, in their respective regions, the implementation of the OHS training and awareness requirements, in consultation with the Security and Occupational Health and Safety Directorate.             x  
1 OHSSRR   Ensure managers are providing employees with an overview of OHS.             x  
1 OHSSRR   Ensure the monitoring of this document at all departmental workplaces.                
1 OHSSRR   Monitor corporate OHS policies, directives, procedures and guidelines in a timely manner. x x x x        
1 OHSSRR   Monitor regional OHS reporting through the departmental or regional OHS databases.             x  
1 OHSSRR   Monitors and reports on the effectiveness of the program and on the Employer's Annual Hazardous Occurrence Report.                
1 OHSSRR   Monitors the departmental Occupational Health and Safety program through investigations, inspections, surveys and audits.           x    
1 OHSSRR   Monitors the performance of workplace health and safety committees.           x    
1 OHSSRR   Oversee and monitor the implementation of the OHS program within their area of responsibility.               x
1 OHSSRR   The Security and Occupational Health and Safety Directorate shall monitor the implementation of this document.           x    
1 OHSSRR   Develop programs, guidelines and procedures in consultation with the Security and Occupational Health and Safety Directorate to meet specific requirements in their area of responsibility.             x  
1 OHSSRR   Develops policies, directives, standards and procedures in consultation with the OHS policy committee.           x    
1 OHSSRR   Ensure development of this document at all departmental workplaces.                
1 OHSSRR   Signing off on departmental OHS policies.                
1 OHSSRR   Issue and approve regional, directorate, OHS guidelines, directives or procedures in accordance with this document to meet specific operational needs.                
1 OHSSRR   Issues internal departmental OHS policies, directives and guidelines in consultation with the Policy Health and Safety Committee.                
1 OHSSRR   Post a copy of a general policy statement worded this way: "A high priority in the Public Service of Canada is providing working conditions conducive to the safety and health of employees. This department is committed to promoting occupational safety and.                
1 OHSSRR   Post a copy of the Canada Labour Code, Part II.                
1 OHSSRR   Post any printed notices or other material prescribed by Human Resources Development Canada - Labour Program or the Treasury Board Secretariat. x x x x        
1 OHSSRR   Keep and maintain health and safety records for their area of responsibility. x x x x        
1 OHSSRR   Maintains program records.           x    
1 OHSSRR   Manages the departmental OHS database.           x    
1 OHSSRR   Ensure that employees have adequate resources to meet OHS requirements.                
1 OHSSRR   Ensure that managers have adequate resources to meet OHS requirements.                
1 OHSSRR   Plan and budget for OHS initiatives within their organizations.                
1 OHSSRR   Plans and budgets for essential OHS resources, including training.                
1 OHSSRR   Ensure that all known OHS incidents, accidents and occupational illnesses are reported to the INAC Health and Safety Advisors. x x x x        
1 OHSSRR   Ensure timely and effective hazardous occurrence investigation, recording and reporting and use this as a monitoring tool. x x x x        
1 OHSSRR   Investigate, record and report all accidents, occupational illnesses and other hazardous occurrences known. x x x x        
1 OHSSRR   Report internally and externally on INAC's OHS program performance, including the analysis of accident trends.           x    
1 OHSSRR   Submits an annual written report on the 1st of March of each year to the HRSDC Labour Program, outlining the number of accidents, occupational diseases and other hazardous occurrences for each identified workplace of which management is aware.           x    
2 TBOHSD Part 1, General Procedure for resolution of "qualified person" dispute                
2 TBOHSD 5.4 Procedure for Halon system non-destructive testing and inspection                
2 TBOHSD 7.1 Report of any noise exposure investigation                
2 TBOHSD 9.2.7 Contingency procedures for cases in which there is a temporary interruption in the supply of drinking water and water for the removal of water-borne waste                
2 TBOHSD 10.1 Record of all hazardous substances that, in the work place, are used, produced, handled, or stored                
2 TBOHSD 10.5 Record of each air sample test related to exposure to hazardous substance                
2 TBOHSD 10.6 Asbestos management program                
2 TBOHSD 12.15 Storage, maintenance, inspection, and testing of personal protective equipment                
2 TBOHSD 15.11 Hazardous occurrence investigation procedures and methodology                
2 TBOHSD 16.1.2 Procedures respecting the availability of first-aid services                
2 TBOHSD 16.2.2 Procedures respecting the availability of first-aid services                
2 TBOHSD 18.7 Rules of procedure for Policy Committees                
2 TBOHSD 18.9 Policy Committee Minutes                
2 TBOHSD 18.10 Regional policy HS committee terms of reference                
2 TBOHSD 18.14 Workplace HS committee rules of procedure                
2 TBOHSD 18.16 Records of all matters brought before workplace committee                
2 TBOHSD 1.0 Copy of a general policy statement                
2 CLCII 125(1)d)(2) Health and Safety policy                
2 CLCII 125(1)z.03) Program for the prevention of hazards in the work place                
2 CLCII 125(1)z.13) Program for the provision of personal protective equipment, clothing, devices or materials                
2 CLCII 125(1)z.10) Written response to recommendations made by work place and policy committee                
2 CLCII 125(1)z.17) Name, work telephone numbers and work locations of work place committee members / HS representative                
2 CLCII 135.1(9) Meeting minutes                
2 CLCII 135.1(9) Records of complaints, investigations                
2 CLCII 135.2g) Annual record report of activities                
2 HSCRR 9 Minutes of safety and health committee meetings                
2 HSCRR 10 Report of the safety and health committee's activities                
2 COHSR 2.27(1) Procedure for investigating situations in which the health or safety of an employee in the work place is or may be endangered by the air quality                
2 COHSR 2.27(7) Records of every indoor air quality complaint and investigation for at least five years                
2 COHSR 7.3(5) Report of noise exposure investigation                
2 COHSR 7.7(2)a) Procedures for hearing protection fit, care and use of hearing protector                
2 COHSR 10.3 Record of all hazardous substances that, in the work place, are used, produced, handled, or stored                
2 COHSR 10.5 Written reports of investigation into exposure to hazardous substance                
2 COHSR 10.5b) Written procedure for the control of the concentration or level of the hazardous substance in the work place                
2 COHSR 10.15 Employee education program                
2 COHSR 10.15 Record of instruction and training for hazardous substances                
2 COHSR 10.49d) Maintenance and operating procedures to prevent the escape of flammable liquids and combustible liquids                
2 COHSR 12.14(1) Record of all protection equipment provided by the employer                
2 COHSR 12.15(1) Written instructions in the use, operation and maintenance of the equipment                
2 COHSR   Written emergency procedures                
2 COHSR 14.20 Record of maintenance, use and testing before initial use                
2 COHSR 14.23(4) Record of training for operators                
2 COHSR 14.29(4) Record of any repair or modification work and of any restriction on use imposed                
2 COHSR 15.4 Records of any motor vehicle accident                
2 COHSR 15.7(1) Record of each minor injury                
2 COHSR 15.8 Record describing the hazardous occurrence (incl. time, date and location), the cause of the occurrence and corrective measures taken?                
2 COHSR 15.10 Written yearly summary to Minister                
2 COHSR 16.2(1) Written first aid instructions that provide for the prompt rendering of first aid to an employee for an injury, an occupational disease or an illness                
2 COHSR 16.13 On-site first aid-records                
2 COHSR 16.13(2) Off-site first aid-records                
2 COHSR 16.13(6) Record of the expiry dates of the first aid certificates of the first aid attendants                
2 COHSR 17.4(1) Emergency procedures re: spilll,leak, failure of lighting, fire                
2 COHSR 17.8(2) Record of all instruction and training provided to every emergency warden, deputy emergency warden and monitor                
2 COHSR 17.5(2) Emergency evacuation plan, where applicable, or a plan for evacuating employees who require special assistance to be implemented in the event of a fire                
2 COHSR 17.9 Record of inspection of all fire escapes, exits, stairways and fire protection equipment in a building                
2 COHSR 17.10(2) Record of each Emergency Warden meeting and emergency evacuation drill                
2 COHSR 19.1 Hazard Prevention Program                
2 COHSR 19.5(2) Preventive Maintenance Program                
2 COHSR 19.6(5) Records of health and safety education, including education relating to ergonomics                
2 COHSR 19.8 Hazard prevention program evaluation report                
2 COHSR 20.9 Records of investigation of employee reports                
2 COHSR 20.5 Assessment of potential for work place violence                
2 COHSR 20.6(3) Procedures for appropriate follow-up maintenance and corrective measures                
2 COHSR 20.7 Record of review of the effectiveness of the work place violence prevention measures                
2 COHSR 20.10 Records on the information, instruction and training provided to each employee exposed to work place violence or a risk of work place violence                
3 CLCII 136(5)b) Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints;               x
3 CLCII 136(5)d) Shall participate in the implementation and monitoring of the program referred to in paragraph 134.1(4)(c);               x
3 CLCII 136(5)e) Where the program referred to in paragraph 134.1(4)(c) does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in health and safety matters related to those hazards;               x
3 CLCII 136(5)g) Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the representative on those matters;               x
3 CLCII 136(5)i) Shall participate in the implementation of changes that may affect occupational health and safety, including work processes and procedures and, where there is no policy committee, shall participate in the planning of the implementation of those changes;               x
3 CLCII 136(5)j) Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year;               x
3 CLCII 136(5)k) Shall participate in the development of health and safety policies and programs;               x
3 CLCII 136(5)l) Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; and               x
3 CLCII 136(5)m) Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program.               x
3 CLCII 136(1) Every employer shall, for each work place controlled by the employer at which fewer than twenty employees are normally employed or for which an employer is not required to establish a work place committee, appoint the person selected in accordance with subsection (2) as the health and safety representative for that work place.               x
3 CLCII 136(2) The employer shall perform the functions of the health and safety representative until a person is selected under subsection (2).               x
3 CLCII 136(2) The health and safety representative for a work place shall be selected as follows: (a) the employees at the work place who do not exercise managerial functions shall select from among those employees the person to be appointed; or (b) if those employees are represented by a trade union, the trade union shall select the person to be appointed, in consultation with any employees who are not so represented, and subject to any regulations made under subsection (11).               x
3 CLCII 134.1(1) Every employer who normally employs directly three hundred or more employees shall establish a policy health and safety committee and, subject to section 135.1, select and appoint its members.                
3 CLCII 134.1(4)i) Shall meet during regular working hours at least quarterly and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours.                
3 CLCII 134.1(4)g) Shall monitor data on work accidents, injuries and health hazards; and                
3 CLCII 134.1(4)c) Shall participate in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters;                
3 CLCII 134.1(4)e) Shall participate in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials;                
3 CLCII 134.1(4)a) Shall participate in the development of health and safety policies and programs;                
3 CLCII 134.1(4)h) Shall participate in the planning of the implementation and in the implementation of changes that might affect occupational health and safety, including work processes and procedures.                
3 CLCII 134.1(4)d) Shall participate to the extent that it considers necessary in inquiries, investigations, studies and inspections pertaining to occupational health and safety;                
3 CLCII 135.1(8) The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member.                
3 CLCII 135.1(6) The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b).                
3 CLCII 135.1(9) A committee shall ensure that accurate records are kept of all of the matters that come before it and that minutes are kept of its meetings. The committee shall make the minutes and records available to a health and safety officer at the officer's request.                
3 CLCII 135.1(7) A committee shall have two chairpersons selected from among the committee members. One of the chairpersons shall be selected by the employee members and the other shall be selected by the employer members.                
3 CLCII 135.1(1) A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have been selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented.                
3 CLCII 135.1 Every employer shall, for each work place controlled by the employer at which twenty or more employees are normally employed, establish a work place health and safety committee and, subject to section 135.1, select and appoint its members.                
3 CLCII 135.1(5) If (there is no committee), the employer shall perform the functions of the committee until a person is selected and the committee is established.                
3 CLCII 137 If an employer controls more than one work place referred to in section 135 or 136 or the size or nature of the operations of the employer or those of the work place precludes the effective functioning of a single work place committee or health and safety representative, as the case may be, for those work places, the employer shall, subject to the approval or in accordance with the direction of a health and safety officer, establish or appoint in accordance with section 135 or 136, as the case may require, a work place committee or health and safety representative for the work places that are specified in the approval or direction.                
3 CLCII 135.1(7)j) Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances;                
3 CLCII 135.1(7)a) Shall consider and expeditiously dispose of matters concerning health and safety raised by members of the committee or referred to it by a work place committee or a health and safety representative;                
3 CLCII 135.1(7)h) Shall cooperate with health and safety officers;                
3 CLCII 135.1(7)g) Shall ensure that adequate records are maintained on work accidents, injuries and health hazards relating to the health and safety of employees and regularly monitor data relating to those accidents, injuries and hazards;                
3 CLCII 135.1(7)k) Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; and                
3 CLCII 135.1(7)e) Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the committee on those matters;                
3 CLCII 135.1(7)c) Shall participate in the development, implementation and monitoring of a program for the prevention of those hazards (not covered by the hazard prevention program) that also provides for the education of employees in health and safety matters related to those hazards;                
3 CLCII 135.1(7)f) Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program;                
3 CLCII 135.1(7)b) Shall participate in the implementation and monitoring of the program referred to in paragraph 134.1(4)c)                
3 CLCII 135.1(7)i) Shall participate in the implementation of changes that might affect occupational health and safety, including work processes and procedures and, where there is no policy committee, shall participate in the planning of the implementation of those changes;                
3 CLCII 135.1(8) The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member.                
3 CLCII 135.1(6) The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b).                
3 CLCII 135.1(10) Work place committee shall meet during regular working hours at least nine times a year at regular intervals and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours.                
3 HSCRR 8 Quorum of a safety and health committee shall consist of the majority of the members of the committee, of which at least half are representatives of the employees and at least one is a representative of the employer.                
3 HSCRR 9(4) A copy of the minutes referred to in subsection (1) shall be kept by the employer at the work place to which it applies or at the head office of the employer for a period of two years from the day on which the safety and health committee meeting is held in such a manner that it is readily available for examination by a safety officer.                
3 HSCRR 5(1) A safety and health committee shall have two chairmen selected from among the members of the committee, one being selected by the representatives of the employees and the other by the representatives of the employer.                
3 HSCRR 10 The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen referred to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report referred to in paragraph (a), post a copy of the report in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months.                
3 HSCRR 9(2) The chairman selected by the representatives of the employer shall provide, as soon as possible after each safety and health committee meeting, a copy of the minutes referred to in subsection (1) to the employer and to each member of the safety and health committee.                
3 HSCRR 5(2) The chairmen referred to in subsection (1) shall act alternately for such period of time as the safety and health committee specifies in its rules of procedure.                
3 HSCRR 3 The employer shall select the member or members of a safety and health committee to represent him from among persons who exercise managerial functions.                
3 HSCRR 9(3) The employer shall, as soon as possible after receiving a copy of the minutes referred to in subsection (2), post a copy of the minutes in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for one month.                
3 HSCRR 9(1) The minutes of each safety and health committee meeting shall be signed by the two chairmen referred to in subsection 5(1).                
3 HSCRR 7 Where a member of a safety and health committee resigns or ceases to be a member for any other reason, the vacancy shall be filled within 30 days after the next regular meeting of the committee.                
4 EHSCSM A.2.3 PWGSC will review and consolidate EHS requirements in specifications                
4 EHSCSM A.2.3 At start-up meetings:
  • It is the Crown's duty to communicate known risks
  • The Crown will provide its EHS MS as an example
  • PWGSC and INAC NCSP will review EHS requirements in contract documents
               
4 EHSCSM A.2.3 Crown to review the Prime's EHS Plan
  • If issues are identified, work shall be done to resolve the issues
  • If the Crown's issues are not addressed, the authorities having jurisdiction will be informed
               
4 EHSCSM A.2.3 INAC and PWGSC parties will determine and implement site-specific reporting, inspections and auditing requirements                
4 EHSCSM A.2.4 Identify and assess the significance of EHS aspects (risk factors and hazards) and potential impacts associated with their plans, activities and operations;                
4 EHSCSM A.2.4 Identify and keep up to date with legal and other requirements;                
4 EHSCSM A.2.4 Focus management priorities by setting EHS objectives and targets;                
4 EHSCSM A.2.4 Establish management programs to achieve EHS objectives and targets;                
4 EHSCSM A.2.4 Establish roles, responsibilities and requirements to meet EHS objectives and targets;                
4 EHSCSM A.2.4 Establish effective internal and external communication methods regarding EHS management;                
4 EHSCSM A.2.4 Develop EHS documentation, document control and records management practices;                
4 EHSCSM A.2.4 Ensure compliance with EHS requirements through monitoring and measurement, internal and external audits, non-conformance investigations and effective corrective actions; and                
4 EHSCSM A.2.4 Conduct regular management review to assess EHS performance and performance of the MS.                
4 EHSCSM Policy Statement Senior managers are responsible for ensuring that all the requirements of this EHS Policy are fully implemented.                
4 EHSCSM Policy Statement All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations.                
4 EHSCSM Policy Statement All personnel are required to support and comply with the EHS program, making safety, health and protection of the environment a part of their daily routine, and ensuring that they follow safe work methods and relevant regulations.                
4 EHSCSM Policy Statement All personnel will be held accountable for implementing, and adhering to, the requirements of the EHS program.                
4 EHSCSM Policy Statement All personnel are accountable for reporting to their immediate supervisor any unsafe practices or areas in need of improvement. Personnel are further accountable for bringing such reports to the attention of higher levels in the organization, without fear of reprisal, if the situation is not addressed appropriately.                
4 EHSCSM Policy Statement All relevant Territorial and Federal laws, regulations and policies, including the requirements of INAC's NAO Northern Contaminated Sites Program Management Framework, are incorporated into our program as minimum standards.                
4 EHSCSM Policy Statement Pollution prevention practices and programs to achieve continuous improvement will be implemented as an ongoing requirement of the program.                
4 EHSCSM Policy Statement Where a conflict arises due to different standards or requirements between different regulations or standards, the more stringent of the two will apply.                
4 EHSCSM Policy Statement Each Region shall establish EHS Procedures consistent with the ISO 14001 and OHSAS 18001 requirements, appropriate to the nature, scale and EHS impacts of all Northern Contaminated Sites Program activities. These Procedures shall be documented in a Regional EHS Manual and shall include a commitment to:
  • Continual improvement of the EHS program;
  • Prevention of pollution or other adverse environmental impacts;
  • Prevention of accidents and lost-time injuries;
  • Compliance with all relevant EHS legislation, regulations and other applicable federal policies and requirements;
  • Development of objectives and targets approved by senior management, to ensure the requirements of the EHS management system are met; and
  • Regular monitoring and reporting of the performance against EHS objectives and targets to senior management.
               
4 EHSCSM Policy Statement Project and Site Level EHS Procedures shall be developed and implemented where:
  • Required to ensure full implementation of this EHS Policy, and/or
  • Where the project level risk assessment identifies significant risks not covered by the NAO Corporate EHS Manual or Regional Procedures.
               
4 EHSCSM Policy Statement Overall responsibility for the EHS Policy rests with the Assistant Deputy Minister (ADM).                
4 EHSCSM                    
4 EHSCSM Policy Statement Senior Management (Director General, and Program Directors)                
4 EHSCSM Policy Statement Approve EHS policies and programs,                
4 EHSCSM Policy Statement Ensure regional and project level EHS programs are in place, and                
4 EHSCSM Policy Statement Ensure the EHS Policy is being implemented as intended.                
4 EHSCSM Policy Statement                  
4 EHSCSM Policy Statement Project and Program Managers                
4 EHSCSM Policy Statement Develop project level EHS procedures as required for all EHS risks,                
4 EHSCSM Policy Statement Ensure all individuals involved with a project (i.e., including Site Operator and INAC employees, consultants and contractors, and visitors) are aware of and comply with the EHS policy,                
4 EHSCSM Policy Statement Maintain original copies of the EHS policy and revisions, signed by Senior Management, and                
4 EHSCSM Policy Statement Coordinate the communication of the EHS policy internally and externally.                
4 EHSCSM Policy Statement                  
4 EHSCSM Policy Statement Site Manager, Line Supervisors, and Task Leaders                
4 EHSCSM Policy Statement Are aware of and understand the EHS Policy and Procedures, and                
4 EHSCSM Policy Statement Ensure work activities are performed consistent with the EHS Policy and Procedures.                
4 EHSCSM Policy Statement                  
4 EHSCSM Policy Statement Workers                
4 EHSCSM Policy Statement Are aware of and understand the EHS Policy and Procedures, and                
4 EHSCSM Policy Statement Perform work activities consistent with the EHS Policy and Procedures.                
4 EHSCSM Policy Statement                  
4 EHSCSM Policy Statement Site Visitors                
4 EHSCSM Policy Statement Are aware of and understand the EHS Policy and Procedures.                
4 EHSCSM 2.1.3.1 The EHS HQ Coordinator shall prepare a composite list of EHS aspects and hazards from the INAC NCSP Risk Register and review this list at least annually, based on the risk assessments done at the project-level as part of the annual detailed work planning process, and other relevant information. The list shall be based primarily on the following risk categories: human health and safety, environmental impact, and legal obligations. All EHS aspects and hazards ranked as 'Moderate Risk' or higher shall be considered significant for the purposes of the EHS MS.                
4 EHSCSM 2.1.3.2 The EHS HQ Coordinator shall document and maintain the EHS aspects and hazards in the EHS Aspects and Hazards Register (Appendix B, Register of EHS Aspects).                
4 EHSCSM 2.1.3.3 The EHS HQ Coordinator shall prepare a summary analysis of the EHS Aspects and Hazards Register in January of each year and provide recommendations related to the management of program-level aspects and hazards to the Director - NCSP HQ, which will be considered in annual work planning.                
4 EHSCSM 2.1.3.4 Regional Directors, with support from the EHS Regional Coordinator shall analyse EHS risks, assign actions related to the management of regional aspects and hazards to appropriate individuals, provide these individuals with the necessary resources and monitor progress as part of the general operation of this EHS MS. Project Managers will analyse EHS risks, assign actions related to the management of project aspects and hazards to appropriate individuals, provide these individuals with the necessary resources and monitor progress as part of the general operation of this EHS MS. Project staff are required to communicate to their supervisors any EHS risks that are not covered by the EHS MS.                
4 EHSCSM 2.1.3.5 A hazard assessment is required before commencing any project. Project specific job / task hazards will be identified by the site supervisor (or the Project Manager if no supervisor is assigned for a site) and addressed using the job safety analysis procedure found in the Standard Operating Procedures (SOP) Manual. Results of the hazard assessment are to be communicated to the appropriate staff.                
4 EHSCSM 2.1.3.6 Known hazards at non-active sites (i.e., those awaiting assessment, remediation or monitoring) shall be included in the Regional EHS aspects and hazards register to ensure such hazards are managed.                
4 EHSCSM 2.2.3.1 The EHS HQ Coordinator shall maintain an up-to-date register of federal laws, regulations, policies and other requirements that apply to the NCSP in the Regulatory Summary (Appendix C - Applicable Acts, Regulations and Guidelines).                
4 EHSCSM 2.2.3.2 Regional Directors, with support from the Regional EHS Coordinator and Project Managers, shall maintain an up-to-date register of applicable territorial laws, regulations, licences, policies and other requirements as applicable in the Regulatory Summary (Appendix C - Applicable Acts, Regulations and Guidelines).                
4 EHSCSM 2.2.3.3 Applicable territorial laws and regulations, licences, policies and other requirements vary between sites and within sites, depending on type of site and the phase and nature of the work (e.g., assessment and monitoring vs. active remediation). The regions shall classify sites into two categories - assessment and remediation - and follow the sections of regulations applicable to sites of these two types (e.g., Part XV "Exploration" of the NWT Mine Health and Safety Act and Regulations could be followed in the case of assessment projects; other sections to remediation projects).                
4 EHSCSM 2.3.3.1 The EHS HQ Coordinator shall develop and recommend annual EHS objectives and targets for the NAO NCSP. The Director NCSP, as Chair of the Directors' Committee, is responsible for approving these objectives and targets. NCSP EHS objectives and targets shall be documented in the Performance Measurement Strategy of the program RMAF.                
4 EHSCSM 2.3.3.2 The EHS Regional Coordinator shall develop and recommend annual EHS objectives and targets for their region. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in regional-level work plans.                
4 EHSCSM 2.3.3.3 Project Managers shall develop and recommend annual EHS objectives and targets for their project. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in project-level detailed work plans.                
4 EHSCSM 2.3.3.4 Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning processes and EHS Management Review.                
4 EHSCSM 3.1.3.2
  • Headquarters: has the lead responsibility for monitoring implementation of the EHS Policy, monitoring implementation of the EHS MS, and high-level oversight in monitoring compliance with EHS legislative and contractual requirements.
               
4 EHSCSM 3.1.3.2
  • Regions: have responsibility for monitoring implementation of the EHS Policy, with an emphasis on implementation and monitoring of the EHS MS, and have a significant oversight role in monitoring compliance with EHS legislative and contractual requirements.
               
4 EHSCSM 3.1.3.2
  • Projects: have responsibility for on-site legislative, contractual and project-specific controls and adherence to EHS MS minimum requirements.
               
4 EHSCSM 3.1.3.3 HQ CSP Director is responsible for:                
4 EHSCSM 3.1.3.3
  • Approving EHS sub-policies, objectives, targets, programs and procedures;
               
4 EHSCSM 3.1.3.3
  • Ensuring clear roles and responsibilities for achieving EHS performance;
               
4 EHSCSM 3.1.3.3
  • Ensuring regional- and project-level EHS systems are in place and functioning as intended by receiving regular reports on performance and taking appropriate action;
               
4 EHSCSM 3.1.3.3
  • Participating in the annual Management Review of the EHS Policy and EHS MS to ensure they are implemented as intended and taking appropriate action as required;
               
4 EHSCSM 3.1.3.3
  • Reviewing quarterly reports; and
               
4 EHSCSM 3.1.3.3
  • Participating and reviewing the annual management review of the EHS MS.
               
4 EHSCSM 3.1.3.4 The EHS HQ Coordinator is responsible for:                
4 EHSCSM 3.1.3.4
  • Ensuring the EHS MS is developed, implemented and maintained;
               
4 EHSCSM 3.1.3.4
  • Reporting to Senior Management on the performance of the EHS MS including recommendations for improvement, on a regular basis and at least annually as part of the Management Review;
               
4 EHSCSM 3.1.3.4
  • Maintaining original copies of the EHS Policy and revisions;
               
4 EHSCSM 3.1.3.4
  • Maintaining the Registers of EHS Aspects and Hazards (Appendix B) and Regulatory Requirements (Appendix C);
               
4 EHSCSM 3.1.3.4
  • Controlling all EHS MS documents and data;
               
4 EHSCSM 3.1.3.4
  • Developing and implementing processes for identifying, reporting and following-up on non-conformance with the EHS MS;
               
4 EHSCSM 3.1.3.4
  • Reviewing the EHS components of quarterly reports;
               
4 EHSCSM 3.1.3.5
  • Conducting the annual Management Review of the EHS MS;
               
4 EHSCSM 3.1.3.4
  • Planning and conducting EHS MS audits to monitor implementation of the EHS MS and identify any need for corrective action;
               
4 EHSCSM 3.1.3.4
  • Reporting on implementation of Corrective and Preventive Action Plans for audit findings related to HQ responsibilities;
               
4 EHSCSM 3.1.3.4
  • Monitoring the implementation of Corrective and Preventive Action Plans; and
               
4 EHSCSM 3.1.3.4
  • Preparing an annual status report on the EHS audit program.
               
4 EHSCSM 3.1.3.5 Regional Directors are responsible for:                
4 EHSCSM 3.1.3.5
  • Ensuring appropriate amplification of the EHS MS at the regional-level (including but not limited to the identification of legal and other requirements; objectives, targets and management programs; roles and responsibilities; training requirements; EHS communications; Standard Operating Procedures; environmental emergency response; and regional MS review);
               
4 EHSCSM 3.1.3.5
  • Providing resources for regional EHS MS training and awareness;
               
4 EHSCSM 3.1.3.5
  • Conducting the annual Management Review of the EHS MS;
               
4 EHSCSM 3.1.3.5
  • Providing input into the annual audit plan (e.g., selection of sites, scheduling);
               
4 EHSCSM 3.1.3.5
  • Reviewing the EHS audit report for audits in their region;
               
4 EHSCSM 3.1.3.5
  • Approving and monitoring implementation of Corrective and Preventive Action Plans;
               
4 EHSCSM 3.1.3.5
  • Reviewing Corrective and Preventive Action Plans implementation and/or close-out; and
               
4 EHSCSM 3.1.3.5
  • Reviewing the EHS component of quarterly reports.<
/td>
               
4 EHSCSM 3.1.3.6 INAC Project Managers / Contaminated Sites Specialists shall be responsible for:                
4 EHSCSM 3.1.3.6
  • Ensuring all individuals involved with a project (i.e., including INAC employees, PWGSC, site operators, consultants, contractors, and visitors) are aware of and comply with the EHS Policy and associated MS requirements;
               
4 EHSCSM 3.1.3.6
  • Identifying project EHS aspects and hazards and developing project-level procedures and programs for all EHS aspects and hazards not covered by corporate or regional procedures, as required (i.e., amplifying the SOP Manual);
               
4 EHSCSM 3.1.3.6
  • Coordinating the communication of the EHS Policy to project staff;
               
4 EHSCSM 3.1.3.6
  • Ensuring all INAC employees involved in the project understand the EHS MS Manual and SOP Manual and conduct their activities to ensure compliance with these requirements;
               
4 EHSCSM 3.1.3.6
  • Ensuring the requirements of the EHS Policy, EHS MS Manual and SOP Manual are transferred to non-INAC project participants (e.g., PWGSC, contractors and consultants) as minimum requirements, through SSAs or contracts;
               
4 EHSCSM 3.1.3.6
  • Requesting and reviewing site specific EHS Plans to ensure EHS requirements are documented, and inspecting project activities and operations to ensure site activities conform to requirements;
               
4 EHSCSM 3.1.3.6
  • Communicating known site EHS aspects and hazards to PWGSC project managers;
               
4 EHSCSM 3.1.3.6
  • Participating with PWGSC project managers in start-up meetings that discuss EHS requirements prior to initiation of site work; and
               
4 EHSCSM 3.1.3.6
  • Reviewing EHS practices of PWGSC and contractors during each site visit.
               
4 EHSCSM 3.1.3.7 PWGSC (includes PM and EHS staff for PWGSC-managed project sites) shall:                
4 EHSCSM 3.1.3.7
  • Prepare specification and incorporate all relevant EHS requirements;
               
4 EHSCSM 3.1.3.7
  • Highlight EHS requirements at contractor bidders' conferences;
               
4 EHSCSM 3.1.3.7
  • Provide the SOP Manual to the contractors for guidance and as minimum requirements;
               
4 EHSCSM 3.1.3.7
  • Forward project-specific EHS plan submittals to qualified professional for review;
               
4 EHSCSM 3.1.3.7
  • Communicate known site hazards to contractor;
               
4 EHSCSM 3.1.3.7
  • Participating in start-up meetings prior to initiation of site work that explicitly address EHS requirements;
               
4 EHSCSM 3.1.3.7
  • Reviewing EHS practices relative to specification during each site visit;
               
4 EHSCSM 3.1.3.7
  • Reviewing contractor's and Crown representative's inspection reports;
               
4 EHSCSM 3.1.3.7
  • Reviewing incident reports;
               
4 EHSCSM 3.1.3.7
  • Managing and implementing the EHS audit program for INAC NCSP sites;
               
4 EHSCSM 3.1.3.7
  • Approving Corrective and Preventive Action Plans to respond to EHS audits;
               
4 EHSCSM 3.1.3.7
  • Monitoring Corrective and Preventive Action Plan implementation and/or close-out; and
               
4 EHSCSM 3.1.3.7
  • Providing monthly reports that include EHS data, summary of inspection results and incident reports, and Corrective and Preventive Action Plan status to INAC PM.
               
4 EHSCSM 3.2.3 The EHS HQ Coordinator shall develop an EHS MS awareness training package to communicate, as a minimum, the following: the EHS Policy, the process required to identify EHS aspects and hazards of contaminated work sites; the EHS objectives, targets, and performance measures of the NCSP; roles, responsibilities, and authorities of everyone involved with NCSP sites; legal compliance requirements and the consequences of non-compliance; the Internal Responsibility System (IRS); and due diligence.                
4 EHSCSM 3.2.3 The EHS HQ Coordinator shall ensure the EHS MS awareness-training package is delivered to all employees, and to new employees, students, consultants and contractors as part of a new job / site orientation, and afterwards as circumstances require. Everyone must be aware of:                
4 EHSCSM 3.2.3
  • The importance of conforming to the EHS Policy;
               
4 EHSCSM 3.2.3
  • The significant aspects and hazards of their work at the site;
               
4 EHSCSM 3.2.3
  • Their roles and responsibilities for achieving compliance with the EHS MS within the IRS framework; and
               
4 EHSCSM 3.2.3
  • The potential impacts of non-conformance with EHS Policy and procedures as described in 4.2 Non-Conformance and Corrective and Preventive Action.
               
4 EHSCSM 3.2.3 The EHS HQ Coordinator shall develop a training package on the Standard Operating Procedures Manual to support EHS programs and provide NCSP personnel with the knowledge required to mitigate EHS risks, hazards, and impacts. This training will be provided to INAC staff involved in operational activities and will be refreshed on a regular basis and whenever circumstances require retraining. Regional Directors are responsible to ensure that training is delivered as required.                
4 EHSCSM 3.2.3 The EHS HQ Coordinator and the EHS Regional Coordinator shall annually assess the effectiveness and delivery of the EHS MS training package and specific training programs. They shall ensure these programs are modified as required to meet specific training needs. Individual employee responsibilities, abilities, and risk factors of the work sites shall be used as criteria to assess training needs.                
4 EHSCSM 3.2.3 The EHS Regional Coordinator shall review the job descriptions or other suitable vehicles for INAC project managers, field supervisors and field workers as new positions are created or before existing ones are posted for existence of EHS requirements, and shall recommend modifications where necessary to assure the appropriate EHS qualification.                
4 EHSCSM 3.2.3 Project Managers shall ensure that SSA and contract documents contain specifications regarding EHS competencies of key site personnel (e.g., site manager, EHS site supervisor) and that contractors are selected with due regard for the EHS competencies of the proposed teams.                
4 EHSCSM 3.2.3 Training records for all EHS training sessions and site orientations delivered by INAC personnel shall be maintained on file at the appropriate location (i.e., project site, regional office, or HQ) for a minimum of five years. The party responsible for overseeing delivery of the program (i.e., EHS HQ Coordinator, EHS Regional Coordinator or Project Manager) is responsible for ensuring training records is maintained.                
4 EHSCSM 3.3.3 NCSP Directors and Managers shall add EHS items to the standing agenda of existing monthly (or more frequent) staff meetings to:                
4 EHSCSM 3.3.3
  • Share information on the performance of the EHS MS (e.g., performance against EHS objectives and targets), non-conformances, EHS incidents, remediation actions, lessons learned, and other EHS concerns;
               
4 EHSCSM 3.3.3
  • Receive and discuss progress reports on EHS programs; and
               
4 EHSCSM 3.3.3
  • Report on EHS audits and management review.
               
4 EHSCSM 3.3.3 Significant changes to the EHS MS including objectives and targets, programs, procedures and responsibilities shall be communicated internally to appropriate personnel. Methods for communication include e-mails, postings on an intranet site and bulletin boards, awareness training sessions and staff meetings.                
4 EHSCSM 3.3.3 Required changes to SOPs identified by regional staff shall be communicated to the Regional Director for review and approval and acted upon by the HQ EHS Coordinator.                
4 EHSCSM 3.3.3 Required changes to regional amplification of SOPs identified by regional staff shall be communicated to the Regional Director and acted upon by the regional EHS Coordinator.                
4 EHSCSM 3.3.3 The Project Manager shall ensure that contractor and consultant EHS requirements are documented in the contract documents. The Project Manager will ensure that start-up meetings are held with contractors and consultants to review the work requirements, including health & safety and environmental protection requirements, prior to starting work. In addition, contractors and consultants will issue progress reports that include an EHS reporting component, via e-mail, progress meetings and/or conference calls. Communication will take place within an appropriate timeframe, which may be weekly, monthly, or as required.                
4 EHSCSM 3.3.3 Concerns or issues related to sites where the site operator is a PWGSC contractor shall be communicated between the EHS HQ Coordinator and the RD, OGGO PWGSC.                
4 EHSCSM 3.3.3 Anyone who becomes aware of an unsafe situation shall take immediate action to manage the risk in the case of serious situations. In all other cases, the risk shall be communicated and documented in writing to the immediate supervisor, with copy to PWGSC (if the site operator is a PWGSC contractor) and to the Regional EHS Coordinator.                
4 EHSCSM 3.3.3 The EHS HQ Coordinator working with INAC Communications and others shall produce and distribute as appropriate: brochures, fact sheets, videos, reports, web page and other materials that describe the EHS MS. The HQ EHS Coordinator, regional health and safety personnel, and project managers will ensure the EHS Policy is publicly available.                
4 EHSCSM 3.5.3 All EHS MS documents shall contain standard identification on each page (i.e., header or footer with title, revision number, date, and page number and total) and be provided with a file number.                
4 EHSCSM 3.5.3 Document control is divided into two areas:                
4 EHSCSM 3.5.3
  • EHS MS Documentation; and
               
4 EHSCSM 3.5.3
  • Records.
               
4 EHSCSM 3.5.3 EHS MS Documentation:                
4 EHSCSM 3.5.3
  • Only controlled copies of EHS MS documents shall be used for guidance by NCSP staff.
               
4 EHSCSM 3.5.3
  • Uncontrolled copies of EHS MS documents, clearly identified as uncontrolled, are available from the EHS HQ Coordinator to individuals not on the distribution list (including the general public) if requested. These individuals are responsible for obtaining updates.
               
4 EHSCSM                    
4 EHSCSM 3.5.3
  • All records shall be maintained for a period of seven years before destruction, unless a longer period is required.
               
4 EHSCSM 3.6.3 The EHS HQ Coordinator shall develop the EHS MS SOP Manual, in consultation with the EHS Regional Coordinator and Program/Project Managers. The SOPs shall be designed to establish suitable controls for the significant aspects and hazards identified for the NCSP, and control situations where their absence could lead to the deviation from the EHS Policy, objectives and targets.                
4 EHSCSM 3.6.3 The EHS Regional Coordinator shall develop additional regional EHS SOPs where the regional risk assessment identifies significant aspects or hazards not covered by the EHS SOP Manual, or where procedures need to be customized to reflect regional circumstances. These regional procedures form an important component of the Regional EHS MS Manual.                
4 EHSCSM 3.6.3 All sites/projects require a site specific EHS Plan. The Project Manager shall ensure that a site specific EHS Plan has been developed that meets or exceeds all regulatory requirements, as well as meets or exceeds all of the requirements in the EHS Policy. When two or more regulatory requirements apply, the most stringent will be followed. Where the project level risk assessment identifies significant aspects or hazards not covered by the Corporate or Regional EHS SOPs, site specific SOPs must be developed. These regional procedures form an important component of the Site EHS Plan. Where the site operator is a PWGSC contractor, the PWGSC project manager makes sure that this requirement is met through the contractors' site specific EHS plan.                
4 EHSCSM 3.6.3 Any new activity on site shall undergo a risk assessment/job hazard analysis to ensure that mitigation measures appropriate to the hazard are developed and implemented. The Project Manager is responsible for ensuring the risk assessment/job hazard analysis is completed in advance of commencing any new activity.                
4 EHSCSM 3.6.4 The Project Manager shall ensure specific emergency preparedness and response procedures are developed for all sites/projects.                
4 EHSCSM 3.6.4 Each Project Manager shall ensure that health and safety and spill contingency emergency procedures for their sites are tested at least annually through either mock incidents or drills, or tabletop exercises. The results of these exercises shall be documented and maintained on file as an EHS MS record.                
4 EHSCSM 3.6.4 After the occurrence of accidents and emergency situations, the Project Manager shall ensure that emergency procedures are reviewed and revised, where necessary. A record of the critical review of each situation, and the identified corrective and preventive action, shall be maintained on file as an EHS MS record.                
4 EHSCSM 4.1.3 The EHS MS performance shall be monitored and measured through:                
4 EHSCSM 4.1.3
  • Regular monitoring and reporting;
               
4 EHSCSM 4.1.3
  • Audits and inspections; and
               
4 EHSCSM 4.1.3
  • Management review.
               
4 EHSCSM 4.1.3 Project Managers shall be responsible for preparing quarterly project reports that provide the required information to assess progress towards the EHS objectives and targets at the project and Program level. Information required for this report shall be collected, compiled and reported by the Project Managers and the regional health and safety personnel, including:                
4 EHSCSM 4.1.3
  • Lost-time accidents;
               
4 EHSCSM 4.1.3
  • Days since last time-lost accident;
               
4 EHSCSM 4.1.3
  • Total hours worked in quarter;
               
4 EHSCSM 4.1.3
  • Near misses;
               
4 EHSCSM 4.1.3
  • Significant environmental incidents;
               
4 EHSCSM 4.1.3
  • Outstanding compliance issues;
               
4 EHSCSM 4.1.3
  • Inspections;
               
4 EHSCSM 4.1.3
  • Audits;
               
4 EHSCSM 4.1.3
  • Awareness training;
               
4 EHSCSM 4.1.3
  • Health and safety training;
               
4 EHSCSM 4.1.3
  • Environmental training; and
               
4 EHSCSM 4.1.3
  • Other corrective actions.
               
4 EHSCSM                    
4 EHSCSM 4.1.3 The EHS HQ Coordinator shall be responsible for quarterly reporting on program EHS performance to Regional Directors and the Director HQ.                
4 EHSCSM 4.1.3 The EHS HQ Coordinator, in cooperation with the RD OGGO PWGSC, shall develop and oversee implementation of the EHS MS audit program (described in Section 4.4), the purpose of which will be to determine conformance and compliance with EHS MS requirements, the EHS Policy and relevant legislation.                
4 EHSCSM 4.1.3 The EHS HQ Coordinator, in cooperation with the Regional EHS Coordinator and the RD OGGO PWGSC, shall organize and oversee site inspections on an as needed basis.                
4 EHSCSM 4.1.3 NCSP Project Managers, consultants and contractors shall develop procedures that describe the way their processes and work activities are monitored and controlled, including workplace and project inspections. These procedures shall include the required time intervals for tracking performance against EHS objectives and targets.                
4 EHSCSM 4.1.3 Project Managers, consultants and contractors shall develop procedures for the calibration and maintenance of monitoring equipment, which will include record maintenance and retention times.                
4 EHSCSM 4.2.3 At the Program level, non-conformance and non-compliance will be identified during:                
4 EHSCSM 4.2.3
  • Monitoring and reporting of EHS performance;
               
4 EHSCSM 4.2.3
  • Investigations (by INAC, PWGSC, regulator);
               
4 EHSCSM 4.2.3
  • Audits; and
               
4 EHSCSM 4.2.3
  • Management reviews.
               
4 EHSCSM 4.2.3 For non-conformance and non-compliance events identified in 4.2.3.1, a root cause analysis should be conducted to determine the direct cause of the non-conformance / non-compliance. Corrective and Preventive Action Plans shall be developed for all identified non-conformances / non-compliances using the Corrective and Preventive Action Plan template found in the EHS Audit Program Guide.                
4 EHSCSM 4.2.3 EHS Policy and SOPs Manual infractions by personnel will be dealt with through a system of verbal and written warnings with review.                
4 EHSCSM 4.2.3 Project Managers shall report results quarterly (as part of regular project quarterly reporting) and the reports will be used for assessing the effectiveness of the EHS MS.                
4 EHSCSM 4.2.3 The audit process, quarterly reporting, and the EHS MS management review will determine the effectiveness of the corrective and preventive actions.                
4 EHSCSM 4.4.3 The EHS HQ Coordinator, in cooperation with Regional Directors and the RD OGGO PWGSC when necessary, shall develop and coordinate an annual EHS MS audit plan according to the requirements of the NCSP EHS Audit Program Guide. The audit plan shall, at a minimum, detail the frequency of audits and the sites subject to upcoming audits.                
4 EHSCSM 4.4.3 Audits shall be conducted to assess compliance with regulatory requirements and to ensure the EHS MS is implemented in accordance with the requirements of the EHS MS Manual (this document), the EHS SOP Manual, ISO 14001 and OHSAS 18001. Where feasible, joint INAC/PWGSC audits may be conducted.                
4 EHSCSM 4.4.3 Among other things, the EHS MS audit shall determine whether or not the:                
4 EHSCSM 4.4.3
  • EHS MS conforms to the ISO 14001 and OHSAS 18001 framework;
               
4 EHSCSM 4.4.3
  • EHS MS has been properly implemented and maintained according to internal standards;
               
4 EHSCSM 4.4.3
  • Regional and Project activities and management systems are conducted in conformance with the elements of the EHS MS Manual;
               
4 EHSCSM 4.4.3
  • EHS MS is achieving regulatory compliance;
               
4 EHSCSM 4.4.3
  • EHS MS is effective in meeting EHS Policy and EHS procedures;
               
4 EHSCSM 4.4.3
  • EHS MS is effective in meeting EHS objectives and targets; and
               
4 EHSCSM 4.4.3
  • PWGSC contractors are meeting EH&S requirements, where applicable.
               
4 EHSCSM                    
4 EHSCSM 4.4.3 The frequency of audits may be based on:                
4 EHSCSM 4.4.3
  • The risk profile of sites;
               
4 EHSCSM 4.4.3
  • The results of previous audits;
               
4 EHSCSM 4.4.3
  • Public or regulatory concerns and complaints;
               
4 EHSCSM 4.4.3
  • Significant changes to the Program activities or significant aspects;
               
4 EHSCSM 4.4.3
  • Significant changes in regulatory requirements;
               
4 EHSCSM 4.4.3
  • Increases or decreases in non-conformances; and
               
4 EHSCSM 4.4.3
  • The frequency or occurrence of incidents.
               
4 EHSCSM 4.4.3 Certified professional auditors shall conduct the audits in accordance with generally accepted audit principles and practices specified in the Guidelines for Quality and/or Environmental Management System Auditing, ISO 19011 and as outlined in the NCSP EHS Audit Program Guide.                
4 EHSCSM 4.4.3 The audit findings shall be documented and considered in EHS MS management reviews (described in Section 5.1.3).                
4 EHSCSM 4.4.3 The person responsible for an activity or area that has been audited shall prepare Corrective and Preventive Action Plans to address the deficiencies found by the audit, following the requirements provided in the NCSP EHS Audit Program Guide.                
4 EHSCSM 5.1.3 The EHS HQ Coordinator shall prepare and present the EHS MS assessment report to the Steering Committee and/or the Directors Committee annually. The review may include items such as:                
4 EHSCSM 5.1.3
  • An evaluation of the continuing suitability of the EHS Policy;
               
4 EHSCSM 5.1.3
  • Performance relative to annual EHS objectives and targets;
               
4 EHSCSM 5.1.3
  • Proposed EHS objectives and targets in consideration of changing program and site conditions, regulatory requirements and other information;
               
4 EHSCSM 5.1.3
  • Any significant incidents and repeated near misses, and the results of investigations, audits and inspections;
               
4 EHSCSM 5.1.3
  • Corrective and preventive actions taken as a result of investigations, audits and inspections following significant incidents;
               
4 EHSCSM 5.1.3
  • An evaluation of the suitability and adequacy of the EHS MS and SOP Manual; and
               
4 EHSCSM 5.1.3
  • Consideration of concerns among relevant interested parties.
               
4 EHSCSM 5.1.3 The results of the review, including any changes to be made to the EHS MS and new EHS objectives and targets, shall be communicated to the HQ EHS Coordinator, Program Directors, regional health and safety personnel, and Project Managers. The results of the review shall be documented by the HQ EHS Coordinator and maintained on file as an EHS MS record.                
4 EHSCSM A.2.3 PWGSC will review and consolidate EHS requirements in specifications                
4 EHSCSM A.2.3 At start-up meetings:
  • It is the Crown's duty to communicate known risks
  • The Crown will provide its EHS MS as an example
  • PWGSC and INAC NCSP will review EHS requirements in contract documents
               
4 EHSCSM A.2.3 Crown to review the Prime's EHS Plan
  • If issues are identified, work shall be done to resolve the issues
  • If the Crown's issues are not addressed, the authorities having jurisdiction will be informed
               
4 EHSCSM A.2.3 INAC and PWGSC parties will determine and implement site-specific reporting, inspections and auditing requirements                
4 EHSCSM A.2.4 Identify and assess the significance of EHS aspects (risk factors and hazards) and potential impacts associated with their plans, activities and operations;                
4 EHSCSM A.2.4 Identify and keep up to date with legal and other requirements;                
4 EHSCSM A.2.4 Focus management priorities by setting EHS objectives and targets;                
4 EHSCSM A.2.4 Establish management programs to achieve EHS objectives and targets;                
4 EHSCSM A.2.4 Establish roles, responsibilities and requirements to meet EHS objectives and targets;                
4 EHSCSM A.2.4 Establish effective internal and external communication methods regarding EHS management;                
4 EHSCSM A.2.4 Develop EHS documentation, document control and records management practices;                
4 EHSCSM A.2.4 Ensure compliance with EHS requirements through monitoring and measurement, internal and external audits, non-conformance investigations and effective corrective actions; and                
4 EHSCSM A.2.4 Conduct regular management review to assess EHS performance and performance of the MS.                
4 EHSCSM Policy Statement Senior managers are responsible for ensuring that all the requirements of this EHS Policy are fully implemented.                
4 EHSCSM Policy Statement All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations.                
4 EHSCSM Policy Statement All personnel are required to support and comply with the EHS program, making safety, health and protection of the environment a part of their daily routine, and ensuring that they follow safe work methods and relevant regulations.                
4 EHSCSM Policy Statement All personnel will be held accountable for implementing, and adhering to, the requirements of the EHS program.                
4 EHSCSM Policy Statement All personnel are accountable for reporting to their immediate supervisor any unsafe practices or areas in need of improvement. Personnel are further accountable for bringing such reports to the attention of higher levels in the organization, without fear of reprisal, if the situation is not addressed appropriately.                
4 EHSCSM Policy Statement All relevant Territorial and Federal laws, regulations and policies, including the requirements of INAC's NAO Northern Contaminated Sites Program Management Framework, are incorporated into our program as minimum standards.                
4 EHSCSM Policy Statement Pollution prevention practices and programs to achieve continuous improvement will be implemented as an ongoing requirement of the program.                
4 EHSCSM Policy Statement Where a conflict arises due to different standards or requirements between different regulations or standards, the more stringent of the two will apply.                
4 EHSCSM Policy Statement Each Region shall establish EHS Procedures consistent with the ISO 14001 and OHSAS 18001 requirements, appropriate to the nature, scale and EHS impacts of all Northern Contaminated Sites Program activities. These Procedures shall be documented in a Regional EHS Manual and shall include a commitment to:
  • Continual improvement of the EHS program;
  • Prevention of pollution or other adverse environmental impacts;
  • Prevention of accidents and lost-time injuries;
  • Compliance with all relevant EHS legislation, regulations and other applicable federal policies and requirements;
  • Development of objectives and targets approved by senior management, to ensure the requirements of the EHS management system are met; and
  • Regular monitoring and reporting of the performance against EHS objectives and targets to senior management.
               
4 EHSCSM Policy Statement Project and Site Level EHS Procedures shall be developed and implemented where:
  • Required to ensure full implementation of this EHS Policy, and/or
  • Where the project level risk assessment identifies significant risks not covered by the NAO Corporate EHS Manual or Regional Procedures.
               
4 EHSCSM Policy Statement Overall responsibility for the EHS Policy rests with the Assistant Deputy Minister (ADM).                
4 EHSCSM                    
4 EHSCSM Policy Statement Senior Management (Director General, and Program Directors)                
4 EHSCSM Policy Statement Approve EHS policies and programs,                
4 EHSCSM Policy Statement Ensure regional and project level EHS programs are in place, and                
4 EHSCSM Policy Statement Ensure the EHS Policy is being implemented as intended.                
4 EHSCSM Policy Statement                  
4 EHSCSM Policy Statement Project and Program Managers                
4 EHSCSM Policy Statement Develop project level EHS procedures as required for all EHS risks,                
4 EHSCSM Policy Statement Ensure all individuals involved with a project (i.e., including Site Operator and INAC employees, consultants and contractors, and visitors) are aware of and comply with the EHS policy,                
4 EHSCSM Policy Statement Maintain original copies of the EHS policy and revisions, signed by Senior Management, and                
4 EHSCSM Policy Statement Coordinate the communication of the EHS policy internally and externally.                
4 EHSCSM Policy Statement                  
4 EHSCSM Policy Statement Site Manager, Line Supervisors, and Task Leaders                
4 EHSCSM Policy Statement Are aware of and understand the EHS Policy and Procedures, and                
4 EHSCSM Policy Statement Ensure work activities are performed consistent with the EHS Policy and Procedures.                
4 EHSCSM Policy Statement                  
4 EHSCSM Policy Statement Workers                
4 EHSCSM Policy Statement Are aware of and understand the EHS Policy and Procedures, and                
4 EHSCSM Policy Statement Perform work activities consistent with the EHS Policy and Procedures.                
4 EHSCSM Policy Statement                  
4 EHSCSM Policy Statement Site Visitors                
4 EHSCSM Policy Statement Are aware of and understand the EHS Policy and Procedures.                
4 EHSCSM 2.1.3.1 The EHS HQ Coordinator shall prepare a composite list of EHS aspects and hazards from the INAC NCSP Risk Register and review this list at least annually, based on the risk assessments done at the project-level as part of the annual detailed work planning process, and other relevant information. The list shall be based primarily on the following risk categories: human health and safety, environmental impact, and legal obligations. All EHS aspects and hazards ranked as 'Moderate Risk' or higher shall be considered significant for the purposes of the EHS MS.                
4 EHSCSM 2.1.3.2 The EHS HQ Coordinator shall document and maintain the EHS aspects and hazards in the EHS Aspects and Hazards Register (Appendix B, Register of EHS Aspects).                
4 EHSCSM 2.1.3.3 The EHS HQ Coordinator shall prepare a summary analysis of the EHS Aspects and Hazards Register in January of each year and provide recommendations related to the management of program-level aspects and hazards to the Director - NCSP HQ, which will be considered in annual work planning.                
4 EHSCSM 2.1.3.4 Regional Directors, with support from the EHS Regional Coordinator shall analyse EHS risks, assign actions related to the management of regional aspects and hazards to appropriate individuals, provide these individuals with the necessary resources and monitor progress as part of the general operation of this EHS MS. Project Managers will analyse EHS risks, assign actions related to the management of project aspects and hazards to appropriate individuals, provide these individuals with the necessary resources and monitor progress as part of the general operation of this EHS MS. Project staff are required to communicate to their supervisors any EHS risks that are not covered by the EHS MS.                
4 EHSCSM 2.1.3.5 A hazard assessment is required before commencing any project. Project specific job / task hazards will be identified by the site supervisor (or the Project Manager if no supervisor is assigned for a site) and addressed using the job safety analysis procedure found in the Standard Operating Procedures (SOP) Manual. Results of the hazard assessment are to be communicated to the appropriate staff.                
4 EHSCSM 2.1.3.6 Known hazards at non-active sites (i.e., those awaiting assessment, remediation or monitoring) shall be included in the Regional EHS aspects and hazards register to ensure such hazards are managed.                
4 EHSCSM 2.2.3.1 The EHS HQ Coordinator shall maintain an up-to-date register of federal laws, regulations, policies and other requirements that apply to the NCSP in the Regulatory Summary (Appendix C - Applicable Acts, Regulations and Guidelines).                
4 EHSCSM 2.2.3.2 Regional Directors, with support from the Regional EHS Coordinator and Project Managers, shall maintain an up-to-date register of applicable territorial laws, regulations, licences, policies and other requirements as applicable in the Regulatory Summary (Appendix C - Applicable Acts, Regulations and Guidelines).                
4 EHSCSM 2.2.3.3 Applicable territorial laws and regulations, licences, policies and other requirements vary between sites and within sites, depending on type of site and the phase and nature of the work (e.g., assessment and monitoring vs. active remediation). The regions shall classify sites into two categories - assessment and remediation - and follow the sections of regulations applicable to sites of these two types (e.g., Part XV "Exploration" of the NWT Mine Health and Safety Act and Regulations could be followed in the case of assessment projects; other sections to remediation projects).                
4 EHSCSM 2.3.3.1 The EHS HQ Coordinator shall develop and recommend annual EHS objectives and targets for the NAO NCSP. The Director NCSP, as Chair of the Directors' Committee, is responsible for approving these objectives and targets. NCSP EHS objectives and targets shall be documented in the Performance Measurement Strategy of the program RMAF.                
4 EHSCSM 2.3.3.2 The EHS Regional Coordinator shall develop and recommend annual EHS objectives and targets for their region. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in regional-level work plans.                
4 EHSCSM 2.3.3.3 Project Managers shall develop and recommend annual EHS objectives and targets for their project. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in project-level detailed work plans.                
4 EHSCSM 2.3.3.4 Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning processes and EHS Management Review.                
4 EHSCSM 3.1.3.2
  • Headquarters: has the lead responsibility for monitoring implementation of the EHS Policy, monitoring implementation of the EHS MS, and high-level oversight in monitoring compliance with EHS legislative and contractual requirements.
               
4 EHSCSM 3.1.3.2
  • Regions: have responsibility for monitoring implementation of the EHS Policy, with an emphasis on implementation and monitoring of the EHS MS, and have a significant oversight role in monitoring compliance with EHS legislative and contractual requirements.
               
4 EHSCSM 3.1.3.2
  • Projects: have responsibility for on-site legislative, contractual and project-specific controls and adherence to EHS MS minimum requirements.
               
4 EHSCSM 3.1.3.3 HQ CSP Director is responsible for:                
4 EHSCSM 3.1.3.3
  • Approving EHS sub-policies, objectives, targets, programs and procedures;
               
4 EHSCSM 3.1.3.3
  • Ensuring clear roles and responsibilities for achieving EHS performance;
               
4 EHSCSM 3.1.3.3
  • Ensuring regional- and project-level EHS systems are in place and functioning as intended by receiving regular reports on performance and taking appropriate action;
               
4 EHSCSM 3.1.3.3
  • Participating in the annual Management Review of the EHS Policy and EHS MS to ensure they are implemented as intended and taking appropriate action as required;
               
4 EHSCSM 3.1.3.3
  • Reviewing quarterly reports; and
               
4 EHSCSM 3.1.3.3
  • Participating and reviewing the annual management review of the EHS MS.
               
4 EHSCSM 3.1.3.4 The EHS HQ Coordinator is responsible for:                
4 EHSCSM 3.1.3.4
  • Ensuring the EHS MS is developed, implemented and maintained;
               
4 EHSCSM 3.1.3.4
  • Reporting to Senior Management on the performance of the EHS MS including recommendations for improvement, on a regular basis and at least annually as part of the Management Review;
               
4 EHSCSM 3.1.3.4
  • Maintaining original copies of the EHS Policy and revisions;
               
4 EHSCSM 3.1.3.4
  • Maintaining the Registers of EHS Aspects and Hazards (Appendix B) and Regulatory Requirements (Appendix C);
               
4 EHSCSM 3.1.3.4
  • Controlling all EHS MS documents and data;
               
4 EHSCSM 3.1.3.4
  • Developing and implementing processes for identifying, reporting and following-up on non-conformance with the EHS MS;
               
4 EHSCSM 3.1.3.4
  • Reviewing the EHS components of quarterly reports;
               
4 EHSCSM 3.1.3.5
  • Conducting the annual Management Review of the EHS MS;
               
4 EHSCSM 3.1.3.4
  • Planning and conducting EHS MS audits to monitor implementation of the EHS MS and identify any need for corrective action;
               
4 EHSCSM 3.1.3.4
  • Reporting on implementation of Corrective and Preventive Action Plans for audit findings related to HQ responsibilities;
               
4 EHSCSM 3.1.3.4
  • Monitoring the implementation of Corrective and Preventive Action Plans; and
               
4 EHSCSM 3.1.3.4
  • Preparing an annual status report on the EHS audit program.
               
4 EHSCSM 3.1.3.5 Regional Directors are responsible for:                
4 EHSCSM 3.1.3.5
  • Ensuring appropriate amplification of the EHS MS at the regional-level (including but not limited to the identification of legal and other requirements; objectives, targets and management programs; roles and responsibilities; training requirements; EHS communications; Standard Operating Procedures; environmental emergency response; and regional MS review);
               
4 EHSCSM 3.1.3.5
  • Providing resources for regional EHS MS training and awareness;
               
4 EHSCSM 3.1.3.5
  • Conducting the annual Management Review of the EHS MS;
               
4 EHSCSM 3.1.3.5
  • Providing input into the annual audit plan (e.g., selection of sites, scheduling);
               
4 EHSCSM 3.1.3.5
  • Reviewing the EHS audit report for audits in their region;
               
4 EHSCSM 3.1.3.5
  • Approving and monitoring implementation of Corrective and Preventive Action Plans;
               
4 EHSCSM 3.1.3.5
  • Reviewing Corrective and Preventive Action Plans implementation and/or close-out; and
               
4 EHSCSM 3.1.3.5
  • Reviewing the EHS component of quarterly reports.<
/td>
               
4 EHSCSM 3.1.3.6 INAC Project Managers / Contaminated Sites Specialists shall be responsible for:                
4 EHSCSM 3.1.3.6
  • Ensuring all individuals involved with a project (i.e., including INAC employees, PWGSC, site operators, consultants, contractors, and visitors) are aware of and comply with the EHS Policy and associated MS requirements;
               
4 EHSCSM 3.1.3.6
  • Identifying project EHS aspects and hazards and developing project-level procedures and programs for all EHS aspects and hazards not covered by corporate or regional procedures, as required (i.e., amplifying the SOP Manual);
               
4 EHSCSM 3.1.3.6
  • Coordinating the communication of the EHS Policy to project staff;
               
4 EHSCSM 3.1.3.6
  • Ensuring all INAC employees involved in the project understand the EHS MS Manual and SOP Manual and conduct their activities to ensure compliance with these requirements;
               
4 EHSCSM 3.1.3.6
  • Ensuring the requirements of the EHS Policy, EHS MS Manual and SOP Manual are transferred to non-INAC project participants (e.g., PWGSC, contractors and consultants) as minimum requirements, through SSAs or contracts;
               
4 EHSCSM 3.1.3.6
  • Requesting and reviewing site specific EHS Plans to ensure EHS requirements are documented, and inspecting project activities and operations to ensure site activities conform to requirements;
               
4 EHSCSM 3.1.3.6
  • Communicating known site EHS aspects and hazards to PWGSC project managers;
               
4 EHSCSM 3.1.3.6
  • Participating with PWGSC project managers in start-up meetings that discuss EHS requirements prior to initiation of site work; and
               
4 EHSCSM 3.1.3.6
  • Reviewing EHS practices of PWGSC and contractors during each site visit.
               
4 EHSCSM 3.1.3.7 PWGSC (includes PM and EHS staff for PWGSC-managed project sites) shall:                
4 EHSCSM 3.1.3.7
  • Prepare specification and incorporate all relevant EHS requirements;
               
4 EHSCSM 3.1.3.7
  • Highlight EHS requirements at contractor bidders' conferences;
               
4 EHSCSM 3.1.3.7
  • Provide the SOP Manual to the contractors for guidance and as minimum requirements;
               
4 EHSCSM 3.1.3.7
  • Forward project-specific EHS plan submittals to qualified professional for review;
               
4 EHSCSM 3.1.3.7
  • Communicate known site hazards to contractor;
               
4 EHSCSM 3.1.3.7
  • Participating in start-up meetings prior to initiation of site work that explicitly address EHS requirements;
               
4 EHSCSM 3.1.3.7
  • Reviewing EHS practices relative to specification during each site visit;
               
4 EHSCSM 3.1.3.7
  • Reviewing contractor's and Crown representative's inspection reports;
               
4 EHSCSM 3.1.3.7
  • Reviewing incident reports;
               
4 EHSCSM 3.1.3.7
  • Managing and implementing the EHS audit program for INAC NCSP sites;
               
4 EHSCSM 3.1.3.7
  • Approving Corrective and Preventive Action Plans to respond to EHS audits;
               
4 EHSCSM 3.1.3.7
  • Monitoring Corrective and Preventive Action Plan implementation and/or close-out; and
               
4 EHSCSM 3.1.3.7
  • Providing monthly reports that include EHS data, summary of inspection results and incident reports, and Corrective and Preventive Action Plan status to INAC PM.
               
4 EHSCSM 3.2.3 The EHS HQ Coordinator shall develop an EHS MS awareness training package to communicate, as a minimum, the following: the EHS Policy, the process required to identify EHS aspects and hazards of contaminated work sites; the EHS objectives, targets, and performance measures of the NCSP; roles, responsibilities, and authorities of everyone involved with NCSP sites; legal compliance requirements and the consequences of non-compliance; the Internal Responsibility System (IRS); and due diligence.                
4 EHSCSM 3.2.3 The EHS HQ Coordinator shall ensure the EHS MS awareness-training package is delivered to all employees, and to new employees, students, consultants and contractors as part of a new job / site orientation, and afterwards as circumstances require. Everyone must be aware of:                
4 EHSCSM 3.2.3
  • The importance of conforming to the EHS Policy;
               
4 EHSCSM 3.2.3
  • The significant aspects and hazards of their work at the site;
               
4 EHSCSM 3.2.3
  • Their roles and responsibilities for achieving compliance with the EHS MS within the IRS framework; and
               
4 EHSCSM 3.2.3
  • The potential impacts of non-conformance with EHS Policy and procedures as described in 4.2 Non-Conformance and Corrective and Preventive Action.
               
4 EHSCSM 3.2.3 The EHS HQ Coordinator shall develop a training package on the Standard Operating Procedures Manual to support EHS programs and provide NCSP personnel with the knowledge required to mitigate EHS risks, hazards, and impacts. This training will be provided to INAC staff involved in operational activities and will be refreshed on a regular basis and whenever circumstances require retraining. Regional Directors are responsible to ensure that training is delivered as required.                
4 EHSCSM 3.2.3 The EHS HQ Coordinator and the EHS Regional Coordinator shall annually assess the effectiveness and delivery of the EHS MS training package and specific training programs. They shall ensure these programs are modified as required to meet specific training needs. Individual employee responsibilities, abilities, and risk factors of the work sites shall be used as criteria to assess training needs.                
4 EHSCSM 3.2.3 The EHS Regional Coordinator shall review the job descriptions or other suitable vehicles for INAC project managers, field supervisors and field workers as new positions are created or before existing ones are posted for existence of EHS requirements, and shall recommend modifications where necessary to assure the appropriate EHS qualification.                
4 EHSCSM 3.2.3 Project Managers shall ensure that SSA and contract documents contain specifications regarding EHS competencies of key site personnel (e.g., site manager, EHS site supervisor) and that contractors are selected with due regard for the EHS competencies of the proposed teams.                
4 EHSCSM 3.2.3 Training records for all EHS training sessions and site orientations delivered by INAC personnel shall be maintained on file at the appropriate location (i.e., project site, regional office, or HQ) for a minimum of five years. The party responsible for overseeing delivery of the program (i.e., EHS HQ Coordinator, EHS Regional Coordinator or Project Manager) is responsible for ensuring training records is maintained.                
4 EHSCSM 3.3.3 NCSP Directors and Managers shall add EHS items to the standing agenda of existing monthly (or more frequent) staff meetings to:                
4 EHSCSM 3.3.3
  • Share information on the performance of the EHS MS (e.g., performance against EHS objectives and targets), non-conformances, EHS incidents, remediation actions, lessons learned, and other EHS concerns;
               
4 EHSCSM 3.3.3
  • Receive and discuss progress reports on EHS programs; and
               
4 EHSCSM 3.3.3
  • Report on EHS audits and management review.
               
4 EHSCSM 3.3.3 Significant changes to the EHS MS including objectives and targets, programs, procedures and responsibilities shall be communicated internally to appropriate personnel. Methods for communication include e-mails, postings on an intranet site and bulletin boards, awareness training sessions and staff meetings.                
4 EHSCSM 3.3.3 Required changes to SOPs identified by regional staff shall be communicated to the Regional Director for review and approval and acted upon by the HQ EHS Coordinator.                
4 EHSCSM 3.3.3 Required changes to regional amplification of SOPs identified by regional staff shall be communicated to the Regional Director and acted upon by the regional EHS Coordinator.                
4 EHSCSM 3.3.3 The Project Manager shall ensure that contractor and consultant EHS requirements are documented in the contract documents. The Project Manager will ensure that start-up meetings are held with contractors and consultants to review the work requirements, including health & safety and environmental protection requirements, prior to starting work. In addition, contractors and consultants will issue progress reports that include an EHS reporting component, via e-mail, progress meetings and/or conference calls. Communication will take place within an appropriate timeframe, which may be weekly, monthly, or as required.                
4 EHSCSM 3.3.3 Concerns or issues related to sites where the site operator is a PWGSC contractor shall be communicated between the EHS HQ Coordinator and the RD, OGGO PWGSC.                
4 EHSCSM 3.3.3 Anyone who becomes aware of an unsafe situation shall take immediate action to manage the risk in the case of serious situations. In all other cases, the risk shall be communicated and documented in writing to the immediate supervisor, with copy to PWGSC (if the site operator is a PWGSC contractor) and to the Regional EHS Coordinator.                
4 EHSCSM 3.3.3 The EHS HQ Coordinator working with INAC Communications and others shall produce and distribute as appropriate: brochures, fact sheets, videos, reports, web page and other materials that describe the EHS MS. The HQ EHS Coordinator, regional health and safety personnel, and project managers will ensure the EHS Policy is publicly available.                
4 EHSCSM 3.5.3 All EHS MS documents shall contain standard identification on each page (i.e., header or footer with title, revision number, date, and page number and total) and be provided with a file number.                
4 EHSCSM 3.5.3 Document control is divided into two areas:                
4 EHSCSM 3.5.3
  • EHS MS Documentation; and
               
4 EHSCSM 3.5.3
  • Records.
               
4 EHSCSM 3.5.3 EHS MS Documentation:                
4 EHSCSM 3.5.3
  • Only controlled copies of EHS MS documents shall be used for guidance by NCSP staff.
               
4 EHSCSM 3.5.3
  • Uncontrolled copies of EHS MS documents, clearly identified as uncontrolled, are available from the EHS HQ Coordinator to individuals not on the distribution list (including the general public) if requested. These individuals are responsible for obtaining updates.
               
4 EHSCSM                    
4 EHSCSM 3.5.3
  • All records shall be maintained for a period of seven years before destruction, unless a longer period is required.
               
4 EHSCSM 3.6.3 The EHS HQ Coordinator shall develop the EHS MS SOP Manual, in consultation with the EHS Regional Coordinator and Program/Project Managers. The SOPs shall be designed to establish suitable controls for the significant aspects and hazards identified for the NCSP, and control situations where their absence could lead to the deviation from the EHS Policy, objectives and targets.                
4 EHSCSM 3.6.3 The EHS Regional Coordinator shall develop additional regional EHS SOPs where the regional risk assessment identifies significant aspects or hazards not covered by the EHS SOP Manual, or where procedures need to be customized to reflect regional circumstances. These regional procedures form an important component of the Regional EHS MS Manual.                
4 EHSCSM 3.6.3 All sites/projects require a site specific EHS Plan. The Project Manager shall ensure that a site specific EHS Plan has been developed that meets or exceeds all regulatory requirements, as well as meets or exceeds all of the requirements in the EHS Policy. When two or more regulatory requirements apply, the most stringent will be followed. Where the project level risk assessment identifies significant aspects or hazards not covered by the Corporate or Regional EHS SOPs, site specific SOPs must be developed. These regional procedures form an important component of the Site EHS Plan. Where the site operator is a PWGSC contractor, the PWGSC project manager makes sure that this requirement is met through the contractors' site specific EHS plan.                
4 EHSCSM 3.6.3 Any new activity on site shall undergo a risk assessment/job hazard analysis to ensure that mitigation measures appropriate to the hazard are developed and implemented. The Project Manager is responsible for ensuring the risk assessment/job hazard analysis is completed in advance of commencing any new activity.                
4 EHSCSM 3.6.4 The Project Manager shall ensure specific emergency preparedness and response procedures are developed for all sites/projects.                
4 EHSCSM 3.6.4 Each Project Manager shall ensure that health and safety and spill contingency emergency procedures for their sites are tested at least annually through either mock incidents or drills, or tabletop exercises. The results of these exercises shall be documented and maintained on file as an EHS MS record.                
4 EHSCSM 3.6.4 After the occurrence of accidents and emergency situations, the Project Manager shall ensure that emergency procedures are reviewed and revised, where necessary. A record of the critical review of each situation, and the identified corrective and preventive action, shall be maintained on file as an EHS MS record.                
4 EHSCSM 4.1.3 The EHS MS performance shall be monitored and measured through:                
4 EHSCSM 4.1.3
  • Regular monitoring and reporting;
               
4 EHSCSM 4.1.3
  • Audits and inspections; and
               
4 EHSCSM 4.1.3
  • Management review.
               
4 EHSCSM 4.1.3 Project Managers shall be responsible for preparing quarterly project reports that provide the required information to assess progress towards the EHS objectives and targets at the project and Program level. Information required for this report shall be collected, compiled and reported by the Project Managers and the regional health and safety personnel, including:                
4 EHSCSM 4.1.3
  • Lost-time accidents;
               
4 EHSCSM 4.1.3
  • Days since last time-lost accident;
               
4 EHSCSM 4.1.3
  • Total hours worked in quarter;
               
4 EHSCSM 4.1.3
  • Near misses;
               
4 EHSCSM 4.1.3
  • Significant environmental incidents;
               
4 EHSCSM 4.1.3
  • Outstanding compliance issues;
               
4 EHSCSM 4.1.3
  • Inspections;
               
4 EHSCSM 4.1.3
  • Audits;
               
4 EHSCSM 4.1.3
  • Awareness training;
               
4 EHSCSM 4.1.3
  • Health and safety training;
               
4 EHSCSM 4.1.3
  • Environmental training; and
               
4 EHSCSM 4.1.3
  • Other corrective actions.
               
4 EHSCSM                    
4 EHSCSM 4.1.3 The EHS HQ Coordinator shall be responsible for quarterly reporting on program EHS performance to Regional Directors and the Director HQ.                
4 EHSCSM 4.1.3 The EHS HQ Coordinator, in cooperation with the RD OGGO PWGSC, shall develop and oversee implementation of the EHS MS audit program (described in Section 4.4), the purpose of which will be to determine conformance and compliance with EHS MS requirements, the EHS Policy and relevant legislation.                
4 EHSCSM 4.1.3 The EHS HQ Coordinator, in cooperation with the Regional EHS Coordinator and the RD OGGO PWGSC, shall organize and oversee site inspections on an as needed basis.                
4 EHSCSM 4.1.3 NCSP Project Managers, consultants and contractors shall develop procedures that describe the way their processes and work activities are monitored and controlled, including workplace and project inspections. These procedures shall include the required time intervals for tracking performance against EHS objectives and targets.                
4 EHSCSM 4.1.3 Project Managers, consultants and contractors shall develop procedures for the calibration and maintenance of monitoring equipment, which will include record maintenance and retention times.                
4 EHSCSM 4.2.3 At the Program level, non-conformance and non-compliance will be identified during:                
4 EHSCSM 4.2.3
  • Monitoring and reporting of EHS performance;
               
4 EHSCSM 4.2.3
  • Investigations (by INAC, PWGSC, regulator);
               
4 EHSCSM 4.2.3
  • Audits; and
               
4 EHSCSM 4.2.3
  • Management reviews.
               
4 EHSCSM 4.2.3 For non-conformance and non-compliance events identified in 4.2.3.1, a root cause analysis should be conducted to determine the direct cause of the non-conformance / non-compliance. Corrective and Preventive Action Plans shall be developed for all identified non-conformances / non-compliances using the Corrective and Preventive Action Plan template found in the EHS Audit Program Guide.                
4 EHSCSM 4.2.3 EHS Policy and SOPs Manual infractions by personnel will be dealt with through a system of verbal and written warnings with review.                
4 EHSCSM 4.2.3 Project Managers shall report results quarterly (as part of regular project quarterly reporting) and the reports will be used for assessing the effectiveness of the EHS MS.                
4 EHSCSM 4.2.3 The audit process, quarterly reporting, and the EHS MS management review will determine the effectiveness of the corrective and preventive actions.                
4 EHSCSM 4.4.3 The EHS HQ Coordinator, in cooperation with Regional Directors and the RD OGGO PWGSC when necessary, shall develop and coordinate an annual EHS MS audit plan according to the requirements of the NCSP EHS Audit Program Guide. The audit plan shall, at a minimum, detail the frequency of audits and the sites subject to upcoming audits.                
4 EHSCSM 4.4.3 Audits shall be conducted to assess compliance with regulatory requirements and to ensure the EHS MS is implemented in accordance with the requirements of the EHS MS Manual (this document), the EHS SOP Manual, ISO 14001 and OHSAS 18001. Where feasible, joint INAC/PWGSC audits may be conducted.                
4 EHSCSM 4.4.3 Among other things, the EHS MS audit shall determine whether or not the:                
4 EHSCSM 4.4.3
  • EHS MS conforms to the ISO 14001 and OHSAS 18001 framework;
               
4 EHSCSM 4.4.3
  • EHS MS has been properly implemented and maintained according to internal standards;
               
4 EHSCSM 4.4.3
  • Regional and Project activities and management systems are conducted in conformance with the elements of the EHS MS Manual;
               
4 EHSCSM 4.4.3
  • EHS MS is achieving regulatory compliance;
               
4 EHSCSM 4.4.3
  • EHS MS is effective in meeting EHS Policy and EHS procedures;
               
4 EHSCSM 4.4.3
  • EHS MS is effective in meeting EHS objectives and targets; and
               
4 EHSCSM 4.4.3
  • PWGSC contractors are meeting EH&S requirements, where applicable.
               
4 EHSCSM                    
4 EHSCSM 4.4.3 The frequency of audits may be based on:                
4 EHSCSM 4.4.3
  • The risk profile of sites;
               
4 EHSCSM 4.4.3
  • The results of previous audits;
               
4 EHSCSM 4.4.3
  • Public or regulatory concerns and complaints;
               
4 EHSCSM 4.4.3
  • Significant changes to the Program activities or significant aspects;
               
4 EHSCSM 4.4.3
  • Significant changes in regulatory requirements;
               
4 EHSCSM 4.4.3
  • Increases or decreases in non-conformances; and
               
4 EHSCSM 4.4.3
  • The frequency or occurrence of incidents.
               
4 EHSCSM 4.4.3 Certified professional auditors shall conduct the audits in accordance with generally accepted audit principles and practices specified in the Guidelines for Quality and/or Environmental Management System Auditing, ISO 19011 and as outlined in the NCSP EHS Audit Program Guide.                
4 EHSCSM 4.4.3 The audit findings shall be documented and considered in EHS MS management reviews (described in Section 5.1.3).                
4 EHSCSM 4.4.3 The person responsible for an activity or area that has been audited shall prepare Corrective and Preventive Action Plans to address the deficiencies found by the audit, following the requirements provided in the NCSP EHS Audit Program Guide.                
4 EHSCSM 5.1.3 The EHS HQ Coordinator shall prepare and present the EHS MS assessment report to the Steering Committee and/or the Directors Committee annually. The review may include items such as:                
4 EHSCSM 5.1.3
  • An evaluation of the continuing suitability of the EHS Policy;
               
4 EHSCSM 5.1.3
  • Performance relative to annual EHS objectives and targets;
               
4 EHSCSM 5.1.3
  • Proposed EHS objectives and targets in consideration of changing program and site conditions, regulatory requirements and other information;
               
4 EHSCSM 5.1.3
  • Any significant incidents and repeated near misses, and the results of investigations, audits and inspections;
               
4 EHSCSM 5.1.3
  • Corrective and preventive actions taken as a result of investigations, audits and inspections following significant incidents;
               
4 EHSCSM 5.1.3
  • An evaluation of the suitability and adequacy of the EHS MS and SOP Manual; and
               
4 EHSCSM 5.1.3
  • Consideration of concerns among relevant interested parties.
               
4 EHSCSM 5.1.3 The results of the review, including any changes to be made to the EHS MS and new EHS objectives and targets, shall be communicated to the HQ EHS Coordinator, Program Directors, regional health and safety personnel, and Project Managers. The results of the review shall be documented by the HQ EHS Coordinator and maintained on file as an EHS MS record.                
 

 

Appendix 2

Appendix 2A –E-mail Survey – Employees

Survey Name: Audit Questionnaire 1-2

1 Name the Sector you work in:
2 Name the Region/HQ you work in:
3 How long have you been in the Department?
4 As part of your job do you visit project sites where construction or remediation work is being performed?
5 Have you received training from INAC in the hazards associated with construction / remediation sites?
6 Does INAC provide you with any of the following types of personal protective equipment:
7 Have you received training from INAC in the use, wearing and care of any of this equipment?
8 As part of your job do you travel to remote isolated locations?
9 Do you travel to these locations exclusively by car, truck or SUV?
10 Is it equipped with any of the following emergency equipment:
11 Have you received training from INAC in the use, wearing and care of any of this equipment?
12 Do you ever travel to these locations by all-terrain vehicle?
13 Is it equipped with a roll-over protection bar or canopy?
14 Is it equipped with any of the following emergency equipment:
15 Have you received training from INAC in the use, wearing and care of any of this equipment?
16 Do you travel to these locations by snowmobile?
17 Is it equipped with any of the following emergency equipment:
18 Have you received training from INAC in the use, wearing and care of any of this equipment?
19 Do you ever travel to these locations by small airplane?
20 Have you received training in safety around small airplanes?
21 Do you ever travel to these locations by helicopter?
22 Have you received training in safety around helicopter?
23 Do you ever travel to these locations by boat?
24 Have you received training in safe operation and travel on boats?
25 Is it equipped with any of the following emergency equipment:
26 Before traveling, is a travel plan prepared and filed with someone in INAC or an external agency?
27 Does the travel plan require you to periodically check-in?
28 Does the travel plan identify how emergency search and rescue would occur if necessary?
29 Have you received wilderness survival training?
30 As part of your job do you periodically encounter situations where you experience or perceive threats to your personal security? If yes, please describe some examples of those situations.
31 Have you received training in any of the following:
32 What measures are in place or available to you for your protection against persons who may pose a threat of harm to you:
 

Appendix 2B – E-mail Survey - Managers & Supervisors

Survey Name: Audit Questionnaire 1-1

1 Name the Sector you work in:
2 Name the Region/HQ you work in:
3 How long have you been in the Department?
4 Does your program / sector / region have a Health and Safety Advisor?
5 If so, has the Health and Safety Advisor been helpful to you in any of the following:
6 Do you believe that your program / sector / region / organizational unit has:
7 Do you believe that you have an adequate understanding of the OHS hazards faced by the personnel for whom you are responsible?
8 What OHS training have you been provided by INAC?
9 Do you believe that you have adequate OHS policies, procedures, and guidelines for the work performed by your personnel?
10 Do you believe that your personnel have had sufficient OHS training to enable them to work safely?
11 Have you ever been unable to address an OHS need to your personnel because of insufficient budget / funding?
12 Do you or your personnel have any other specific OHS needs that you feel are not being met? If so, what are they?
13 Are you aware of an incident investigation procedure?
14 Have you been trained in incident investigation?
15 What are the reporting requirements?
16 How do you ensure incidents get reported and investigated?
17 Have you received instruction to identify the kinds of health and safety records that are to be kept?
18 Do you keep such health and safety records?
19 List the health and safety records INAC requires you to keep.
20 Are there any examples of OHS initiatives that you specifically planned and budgeted for from 2007 to present? If so, what were those OHS initatives?
21 How much money did you budget for those OHS initiatives?
22 What do you consider to be examples of "essential OHS resources" for your area of responsibility (e.g. personal protective equipment, training services, ect.)?
23 Do you formally plan and budget for these essential OHS resources?
24 Approximately how much do you expect to spend on each of these essential OHS resources in 2008?
25 How much do you expect to spend on each of these essential OHS resources in 2009?
 

Appendix 2C – E-mail Survey - Director & Director Generals

Survey Name: Audit Questionnaire 1-1

1 Name the Sector you work in:
2 Name the Region/HQ you work in:
3 How long have you been in the Department?
4 Are there any examples of OHS initiatives that you specifically planned and budgeted for from 2007 to present? If so, what were those OHS initiatives?
5 How much money did you budget for those OHS initiatives?
6 What do you consider to be examples of "essential OHS resources" for your area of responsibility (e.g. personal protective equipment, training services, ect.)?
7 Do you formally plan and budget for these essential OHS resources?
8 Approximately how much was spent on each of these essential OHS resources in 2008?
9 How much do you expect to spend on each of these essential OHS resources in 2009?
10 Are you aware of an incident investigation procedure?
11 Have you been trained in incident investigation?
12 What are the reporting requirements?
13 How do you ensure incidents get reported and investigated?
14 Have you received instruction to identify the kinds of health and safety records that are to be kept?
15 Do you keep such health and safety records?
16 List the health and safety records INAC requires you to keep.
 

 

Appendix 3

Appendix 3A - Document Request List for Corporate and Regional HS Staff / Advisors

Audit Checklist 2-1 (Documents Required by CLC-II or Treasury Board)

Audit Subjects: Corporate and Regional Health and Safety Staff / Advisors
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:

ITEM SOURCE MANDATORY DOCUMENTS / DOCUMENT REQUEST LIST PROVIDED NOT LOCATED
1 TBOHSD Part 1, General Procedure for resolution of "qualified person" dispute    
2 TBOHSD 7.1 Report of any noise exposure investigation    
COHSR 7.3(5)
3 TBOHSD 9.2.7 Contingency procedures for cases in which there is a temporary interruption in the supply of drinking water and water for the removal of water-borne waste    
4 TBOHSD 10.1 Record of all hazardous substances that, in the work place, are used, produced, handled, or stored    
COHSR 10.3
5 TBOHSD 10.5 Written reports of any investigation or testing of exposure to hazardous substance    
COHSR 10.5
6 COHSR 10.5(b) Written procedure for the control of the concentration or level of a hazardous substance in the work place    
7 COHSR 10.15 Records of instruction and training for hazardous substances    
8 TBOHSD 10.6 Asbestos management program    
9 CLCII 125.1(z.13) Program for the provision of personal protective equipment, clothing, devices or materials    
10 COHSR 12.14(1) Record of all protective equipment provided by the employer    
11 TBOHSD 15.1.1 Hazardous occurrence investigation procedures and methodology    
12 COHSR 15.7(1) Record of each minor injury    
13 COHSR 15.8 Hazardous occurrence reports    
14 TBOHSD 16.1.2 Procedures respecting the availability of first-aid services    
15 TBOHSD 16.2.2 Written record of every injury or illness that requires first-aid treatment    
16 COHSR 16.2(1) Written first aid instructions that provide for the prompt rendering of first aid to an employee for an injury, an occupational disease or an illness    
17 COHSR 16.13 On-site first aid-records    
18 COHSR 16.13(2) Off-site first aid-records    
19 COHSR 16.13(6) Record of the expiry dates of the first aid certificates of the first aid attendants    
20 TBOHSD 1.0 Health and Safety policy statement    
CLCII 125.1(d)(2)
21 CLCII 125.1(z.03) Hazard prevention program document    
COHSR 19.1
22 COHSR 19.8 Hazard prevention program evaluation report    
23 COHSR 20.7 Record of review of the effectiveness of work place violence prevention measures    
24 COHSR 20.10 Records of information, instruction and training provided to each employee exposed to work place violence or a risk of work place violence    
25 CLCII 125.1(z.17) Name, work telephone numbers and work locations of work place committee members and HS representatives    
26 COHSR 2.27(1) Procedure for investigating situations in which the health or safety of an employee in the work place is or may be endangered by the air quality    
27 COHSR 2.27(7) Records of every indoor air quality complaint and investigation for the past five years    
28 COHSR 7.7(2)(a) Procedures for hearing protection fit, care and use    
29 COHSR 10.15 Employee education program for hazardous substances (e.g. WHMIS training)    
30 COHSR 19.6(5) Records of health and safety education, including education relating to ergonomics    
31 COHSR 10.49(d) Maintenance and operating procedures to prevent the escape of flammable liquids and combustible liquids    
32 COHSR 12.15(1) Written instructions in the use, operation and maintenance of the equipment    
33 COHSR   Written emergency procedures    
34 COHSR 17.4(1) Emergency procedures for spills, leaks, failure of lighting, fires    
35 COHSR 17.8(2) Record of all instruction and training provided to every emergency warden, deputy emergency warden and monitor    
36 COHSR 17.5(2) Emergency evacuation plan, where applicable, or a plan for evacuating employees who require special assistance in the event of a fire    
37 COHSR 17.10(2) Record of each Emergency Warden meeting    
38 COHSR 17.10(2) Record of each emergency evacuation drill    
39 COHSR 14.20 Record of maintenance, use and testing of material handling equipment before initial use    
40 COHSR 14.23(4) Record of training for operators of material handling equipment    
41 COHSR 14.29(4) Record of any repair or modification work and of any restriction on use imposed on material handling equipment    
42 COHSR 15.4 Records of any motor vehicle accident    
43 COHSR 15.10 Annual report to HRSDC Labour Program, outlining the number of accidents, occupational diseases and other hazardous occurrences for each identified workplace of which management is aware    
44 COHSR 17.9 Record of inspection of all fire escapes, exits, stairways and fire protection equipment in a building    
45 COHSR 20.9 Records of investigation of employee reports of violence    
46 COHSR 20.5 Assessment of potential for work place violence    
47 COHSR 20.6(3) Procedures for appropriate follow-up maintenance and corrective measures for violence control measures that have been established    
48 COHSR 19.5(2) Preventive maintenance program in respect of equipment or systems where failures could harm employees    
 

Appendix 3B - Document Request List for Committees, HS Representatives and Designated Managers

Audit Checklist 3-1 (Functions of PHSC, WHSC, HSRs)

Audit Subjects:
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:

ITEM SOURCE APPLI-CATION AUDIT CRITERIA AUDIT QUESTIONS RESPONSE AFF/NEG REQUIRED SUPPORTING EVIDENCE FOR AFFIRMATIVES
1 CLCII 136(2) HSR The health and safety representative for a work place shall be selected as follows: (a) the employees at the work place who do not exercise managerial functions shall select from among those employees the person to be appointed; or (b) if those employees are represented by a trade union, the trade union shall select the person to be appointed, in consultation with any employees who are not so represented, and subject to any regulations made under subsection (11). How were you selected or appointed the HSR?    
2 CLCII 136(5)(b) HSR Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints. Who maintains records for work accidents, injuries, and any health and safety complaints for this workplace?   Hazardous occurrence / injury / accident reports.
3 CLCII 136(5)(b) HSR Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints. Do you periodically review monitor data relating to those accidents, injuries, hazards and complaints?    
4 CLCII 136(5)(b) HSR Shall ensure that adequate records are maintained pertaining to work accidents, injuries, health hazards and the disposition of complaints related to the health and safety of employees and regularly monitor data relating to those accidents, injuries, hazards and complaints. How many accidents, injuries, hazards and complaints have there been in this workplace in the past 12 months?    
5 CLCII 136(5)(d) HSR Shall participate in the implementation and monitoring of the hazard prevention program. Is there a hazard prevention program for your workplace?   Copy of program document.
6 CLCII 136(5)(d) HSR Shall participate in the implementation and monitoring of the hazard prevention program. What role do you play in implementation and monitoring the hazard prevention program?    
7 CLCII 136(5)(e) HSR Where the hazard prevention program does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in healt and safety matters related to those hazards. What information, instruction or training have employees received in this workplace on those additional hazards?   Copy of relevant information, instruction or training materials. Records of training delivery / attendance.
8 CLCII 136(5)(e) HSR Where the hazard prevention program does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in healt and safety matters related to those hazards. What additional hazards do employees in this workplace encounter that are not included in the hazard prevention program?   Copy of program document.
9 CLCII 136(5)(e) HSR Where the hazard prevention program does not cover certain hazards unique to that work place, shall participate in the development, implementation and monitoring of a program for the prevention of those hazards that also provides for the education of employees in healt and safety matters related to those hazards. What role have you played in developing any programs for these additional hazards?    
10 CLCII 136(5)(g) HSR Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise to advise the representative on those matters. What health and safety inquiries, investigations, studies and inspections have you participated in?   Copies of any such studies or inspection records.
11 CLCII 136(5)(i) HSR Shall participate in the implementation of changes that may affect occupational health and safety, including work processes and procedures. Have you been involved in planning or implementing changes in the workplace that may affect employee health or safety - for example, renovations, introduction of new equipment or materials, significant changes in work procedures or practices?    
12 CLCII 136(5)(j) HSR Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; Do you inspect each month all or part of the work place, and is the entire workplace covered over the course of a year?   Inspection records.
13 CLCII 136(5)(k) HSR Shall participate in the development of health and safety policies and programs; Have you been involved in planning or implementing health and safety policies or programs at the workplace?   Referenced health and safety policy and program documents.
14 CLCII 136(5)(l) HSR Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; and Have you participated in any investigations of exposure of employees to hazardous substances?   Exposure assessment reports.
15 CLCII 136(5)(m) HSR Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials. Have you participated in the implementation and monitoring any personal protective clothing use programs?   Program documents.
16 OHSSRR   HSR Oversee and monitor the implementation of the OHS program within their area of responsibility. Do you ever conduct observations or reviews to determine if requirements of health and safety programs are being adhered to by personnel?    
17 OHSSRR   HSR Oversee and monitor the implementation of the OHS program within their area of responsibility. What kinds of observations or reviews have you performed (e.g. inspections, review of records, etc.)?    
18 OHSSRR   HSR Oversee and monitor the implementation of the OHS program within their area of responsibility. What have you observed / found?    
19 CLCII 134.1(4)(a) PHSC Shall participate in the development of health and safety policies and programs; Has PHSC participated in the development of health and safety policies and programs?   Minutes reflecting these activities.
20 CLCII 134.1(4)(c) PHSC Shall participate in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters; Has PHSC participated in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters?   Minutes reflecting these activities, and the referenced hazard prevention program document.
21 CLCII 134.1(4)(d) PHSC Shall participate to the extent that it considers necessary in inquiries, investigations, studies and inspections pertaining to occupational health and safety; Has PHSC participated to the extent that it considers necessary in inquiries, investigations, studies and inspections pertaining to occupational health and safety?   Minutes reflecting these activities, and the referenced investigation / inspection reports and studies.
22 CLCII 134.1(4)(e) PHSC Shall participate in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials; Has PHSC participated in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials?   Minutes reflecting these activities, and the referenced personal protective equipment program document.
23 CLCII 134.1(4)(g) PHSC Shall monitor data on work accidents, injuries and health hazards; and Does PHSC monitor data on work accidents, injuries and health hazards?   Minutes reflecting this activity, and the data records.
24 CLCII 134.1(4)(h) PHSC Shall participate in the planning of the implementation and in the implementation of changes that might affect occupational health and safety, including work processes and procedures. Does PHSC participate in the planning of the implementation and in the implementation of changes that might affect occupational health and safety, including work processes and procedures?   Minutes reflecting this activity.
25 CLCII 134.1(4)(i) PHSC Shall meet during regular working hours at least quarterly and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours. How many meetings has the PHSC held in 2008/2009?   Minutes of the meeting.
26 CLCII 135.1(1) PHSC A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have been selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented. Is the PHSC comprised of at least 2 members?   Minutes, and / or records of appointment.
27 CLCII 135.1(1) PHSC A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have been selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented. Are 50% or more of the PHSC members non-managerial personnel?   Job titles of personnel from INAC employee directory, with confirmation from INAC HR Directorate of the status of any positions where managerial / non-managerial status is uncertain.
28 CLCII 135.1(6) PHSC The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b). Does the PHSC have alternate members?   Minutes or records of appointment.
29 CLCII 135.1(7) PHSC A committee shall have two chairpersons selected from among the committee members. One of the chairpersons shall be selected by the employee members and the other shall be selected by the employer members. Who are the management and non-management co-chairs?   Minutes or records of appointment.
30 CLCII 135.1(8) PHSC The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member us designated, the member shall be an employee member. Have committee members been formally assigned responsibilities (e.g. inspections)?   Minutes evidencing same.
31 CLCII 135.1(8) PHSC The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member us designated, the member shall be an employee member. Are at least half of the members assigned specific functions non-management members?   Minutes.
32 CLCII 135.1(9) PHSC A committee shall ensure that accurate records are kept of all of the matters that come before it and that minutes are kept of its meetings. The committee shall make the minutes and records available to a health and safety officer at the officer's request Has the committee maintained minutes?   Minutes.
33 OHSSRR   PHSC Make recommendations and report its activities to the Deputy Minister through the National Union Management Consultation Committee. Does the PHSC make recommendations and report on its activities to the National Union Management Consultation Committee?   Any written recommendations or reports to the National Union Management Consultation Committee, or Minutes of the NUMCC evidencing same.
34 OHSSRR   PHSC Policy Health and Safety Committee shall address strategic departmental health and safety matters. Do you believe that the PHSC deals primarily with OHS matters that are important and effect all or most of INAC, or employees facing the highest risks?   Minutes.
35 HSCRR 3 WHSC The employer shall select the member or members of a safety and health committee to represent him from among persons who exercise managerial functions. How were the management members selected or appointed?   Minutes or records of appointment.
36 HSCRR 4 WHSC Where any employees at a work place are not represented by a trade union, those employees shall select, by majority vote, the member or members of the safety and health committee to represent them. How were the non-management members selected or appointed?   Minutes or records of appointment.
37 HSCRR 7 WHSC Where a member of a safety and health committee resigns or ceases to be a member for any other reason, the vacancy shall be filled within 30 days after the next regular meeting of the committee. Have vacancies been filled within 30 days?   Minutes.
38 HSCRR 8 WHSC Quorum of a safety and health committee shall consist of the majority of the members of the committee, of which at least half are representatives of the employees and at least one is a representative of the employer. Do all meetings comply with quorum requirements?   Minutes.
39 HSCRR 10 WHSC The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen reffered to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report reffered to in paragraph (a), post a copy of the report in the conspicious place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months. Has the committee prepared the annual report?   Copies of past annual reports.
40 HSCRR 10 WHSC The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen reffered to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report reffered to in paragraph (a), post a copy of the report in the conspicious place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months. Have these annual reports been submitted to HRSDC?   Evidence of submittal.
41 HSCRR 10 WHSC The chairman selected by the representatives of the employer shall (a) not later than March 1 in each year, submit a report of the safety and health committee's activities during the 12-month period ending on December 31 of the preceding year, signed by both chairmen reffered to in subsection 5(1), in the form set out in the schedule and containing the information required by that form, where the safety and health committee is established, (v) in respect of employees to whom the Canada Occupational Safety and Health Regulations apply, to a regional safety officer; and (b) as soon as possible after submitting the report reffered to in paragraph (a), post a copy of the report in the conspicious place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for two months. Have these annual reports been posted?   Evidence of posting.
42 CLCII 135.1(1) WHSC A policy committee or a work place committee shall consist of at least two persons and at least half of the members shall be employees who (a) do not exercise managerial functions; and (b) subject to any regulations made under subsection 135.2(1), have be selected by (i) the employees, if the employees are not represented by a trade union, or (ii) the trade union representing employees, in consultation with any employees who are not so represented. Is the WHSC comprised of at least 2 members?   Procès-verbaux et/ou dossiers des nominations
43 CLCII 135.1(10) WHSC Work place committee shall meet during regular working hours at least nine times a year at regular intervals and, if other meetings are required as a result of an emergency or other special circumstances, the committee shall meet as required during regular working hours or outside those hours. Are 50% or more of the WHSC members non-managerial personnel?   Job titles of personnel from INAC employee directory, with confirmation from INAC HR Directorate of the status of any positions where managerial / non-managerial status is uncertain.
44 CLCII 135.1(6) WHSC The employer and employees may select alternate members to serve as replacements for members selected by them who are unable to perform their functions. Alternate members for employee members shall meet the criteria set out in paragraphs (1)(a) and (b). Does the WHSC have alternate members?   Minutes or records of appointment.
45 CLCII 135.1(7) WHSC A committee shall have two chairpersons selected from among the committee members. One of the chairpersons shall be selected by the employee members and the other shall be selected by the employer members. Who are the management and non-management co-chairs?   Minutes or records of appointment.
46 CLCII 135.1(7)(a) WHSC Shall consider and expeditiously dispose of matters concerning health and safety raised by members of the committee or referred to it by a work place committee or a health and safety representative; Does the WHSC receive and discuss OHS concerns or complaints raised by employees?   Minutes evidencing same.
47 CLCII 135.1(7)(b) WHSC Shall participate in the implementation and monitoring of the hazard prevention program. Is there a hazard prevention program for your workplace?   Copy of program document.
48 CLCII 135.1(7)(b) WHSC Shall participate in the implementation and monitoring of the hazard prevention program. What role does the WHSC play in implementation and monitoring the hazard prevention program?   Minutes evidencing same.
49 CLCII 135.1(7)(c) WHSC Shall participate in the development, implementation and monitoring of a program for the prevention of those hazards (not covered by the hazard prevention program) that also provides for the education of employees in health and safety matters related to those hazards; Has the WHSC participated in the development and monitoring of a program for the prevention of hazards in the work place that also provides for the education of employees in health and safety matters?   Minutes reflecting these activities, and the referenced hazard prevention program document.
50 CLCII 135.1(7)(e) WHSC Shall participate in all of the inquiries, investigations, studies and inspections pertaining to the health and safety of employees, including any consultations that may be necessary with persons who are professionally or technically qualified to advise the committee on those matters; What health and safety inquiries, investigations, studies and inspections has the WHSC participated in?   Minutes evidencing same.
51 CLCII 135.1(7)(f) WHSC Shall participate in the implementation and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials and, where there is no policy committee, shall participate in the development of the program; Has the WHSC participated in the development and monitoring of a program for the provision of personal protective equipment, clothing, devices or materials?   Minutes reflecting these activities, and the referenced personal protective equipment program document.
52 CLCII 135.1(7)(g) WHSC Shall ensure that adequate records are maintained on work accidents, injuries and health hazards relating to the health and safety of employees and regularly monitor data relating to those accidents, injuries and hazards; Who maintains records for work accidents, injuries, and any health and safety complaints for this workplace?   Hazardous occurrence / injury / accident reports.
53 CLCII 135.1(7)(g) WHSC Shall ensure that adequate records are maintained on work accidents, injuries and health hazards relating to the health and safety of employees and regularly monitor data relating to those accidents, injuries and hazards; Does the WHSC periodically review monitor data relating to those accidents, injuries, hazards and complaints?   Minutes evidencing same
54 CLCII 135.1(7)(i) WHSC Shall participate in the implementation of changes that might affect occupational health and safety, including work processes and procedures. Has the WHSC been involved in planning or implementing changes in the workplace that may affect employee health or safety - for example, renovations, introduction of new equipment or materials, significant changes in work procedures or practices?   Minutes evidencing same
55 CLCII 135.1(7)(j) WHSC Shall assist the employer in investigating and assessing the exposure of employees to hazardous substances; Has the WHSC participated in any investigations of exposure of employees to hazardous substances?   Exposure assessment reports.
56 CLCII 135.1(7)(k) WHSC Shall inspect each month all or part of the work place, so that every part of the work place is inspected at least once each year; and Does the WHSC inspect each month all or part of the work place, and is the entire workplace covered over the course of a year?   Inspection records.
57 CLCII 135.1(8) WHSC The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member. Have committee members been formally assigned responsibilities (e.g. inspections)?   Minutes evidencing same
58 CLCII 135.1(8) WHSC The chairpersons of a committee shall jointly designate members of the committee to perform the functions of the committee under this Part as follows: (a) if two or more members are designated, at least half of the members shall be employee members; or (b) if one member is designated, the member shall be an employee member. Are at least half of the members assigned specific functions non-management members?   Minutes
59 CLCII 135.1(9) WHSC A committee shall ensure that accurate records are kept of all of the matters that come before it and that minutes are kept of its meetings. The committee shall make the minutes and records available to a health and safety officer at the officer's request. Has the committee maintained minutes?   Minutes
60 HSCRR 5(1) WHSC A safety and health committee shall have two chairmen selected from among the members of the committee, one being selected by the representatives of the employees and the other by the representatives of the employer. Are there management and non-management co-chairs for the WHSC?   Minutes
61 HSCRR 5(2) WHSC The chairmen referred to in subsection (1) shall act alternately for such period of time as the safety and health committee specifies in its rules of procedure. How has the WHSC decided on which co-chair will chair which meetings?   Minutes or terms of reference explaining same.
62 HSCRR 9(1) WHSC The minutes of each safety and health committee meeting shall be signed by the two chairmen referred to in subsection 5(1). Are minutes signed by the co-chairs?   Minutes
63 HSCRR 9(2) WHSC The chairman selected by the representatives of the employer shall provide, as soon as possible after each safety and health committee meeting, a copy of the minutes referred to in subsection (1) to the employer and to each member of the safety and health committee. Are minutes distributed within a month of each meeting?   For minutes, check meeting dates against minutes issuance dates (if indicated).
64 HSCRR 9(3) WHSC The employer shall, as soon as possible after receiving a copy of the minutes referred to in subsection (2), post a copy of the minutes in the conspicuous place or places in which the employer has posted the information referred to in subsection 135(5) of the Act and keep the copy posted there for a month. Are minutes posted in a conspicuous place?    
65 HSCRR 9(4) WHSC A copy of the minutes referred to in subsection (1) shall be kept by the employer at the work place to which it applies or at the head office of the employer for a period of two years from the day on which the safety and health committee meeting is held in such a manner that it is readily available for examination by a safety officer. Are minutes retained for at least two years?    
66 OHSSR   WHSC Committees shall report to the most senior officer responsible for that workplace, or to their delegate. What senior officer does the WHSC report to?    
 

Appendix 3C - Document Request List for Corporate (HQ) and Regional CSMP EHS Coordinators

Audit Checklist 4-1 (Documents Required by EHS Contaminated Sites Manual - EHS Coordinators)

Audit Subjects:
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:

AUDIT AREA SOURCE APPLI-CATION AUDIT CRITERIA DOCUMENT REQUEST LIST PROVIDED? PROPER STD IDENTIFIERS? CONTENT MEETS SPECS?
4 EHSCSM 3.3.3 HQ EHSC Significant changes to the EHS MS including objectives and targets, programs, procedures and responsibilities shall be communicated internally to appropriate personnel. Methods for communication include e-mails, postings on an intranet site and bulletin boards, awareness training sessions and staff meetings. Any e-mails, internet postings or other internal communications advising of significant changes to the Contaminated Sites EHS Management System, in 2007 to date.      
4 EHSCSM 3.3.3 HQ EHSC Concerns or issues related to sites where the site operator is a PWGSC contractor shall be communicated between the EHS HQ Coordinator and the RD, OGGO PWGSC. Any e-mails to PWGSC respecting contractor EHS activities, EHS non-compliance, or EHS poor performance, 2007 to date.      
4 EHSCSM 4.1.3 HQ EHSC The EHS HQ Coordinator, in cooperation with the Regional EHS Coordinator and the RD OGGO PWGSC, shall organize and oversee site inspections on an as needed basis. Project Site inspection records.      
4 EHSCSM 2.1.3.3 HQ EHSC The EHS HQ Coordinator shall prepare a summary analysis of the EHS Aspects and Hazards Register in January of each year and provide recommendations related to the management of program-level aspects and hazards to the Director – NCSP HQ. Annual summary analysis of the EHS Aspects and Hazards Register, and recommendations.      
4 EHSCSM 2.3.3.1 HQ EHSC The EHS HQ Coordinator shall develop and recommend annual EHS objectives and targets for the NAO NCSP. The Director NCSP, as Chair of the Directors' Committee, is responsible for approving these objectives and targets. NCSP EHS objectives and targets shall be documented in the Performance Measurement Strategy of the program RMAF. The Performance Measurement Strategy of the Results-Based Management and Accountability Framework.      
4 EHSCSM 2.3.3.1 HQ EHSC The EHS HQ Coordinator shall develop and recommend annual EHS objectives and targets for the NAO NCSP. The Director NCSP, as Chair of the Directors' Committee, is responsible for approving these objectives and targets. NCSP EHS objectives and targets shall be documented in the Performance Measurement Strategy of the program RMAF. The 2007 and 2008 annual EHS objectives and targets provided to the Director - NCSP.      
4 EHSCSM 2.3.3.4 HQ EHSC Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning. Programs to achieve the annual EHS objectives and targets.      
4 EHSCSM 3.6.3 HQ EHSC The EHS HQ Coordinator shall develop the EHS MS SOP Manual, in consultation with the EHS Regional Coordinator and Program/Project Managers. The SOPs shall be designed to establish suitable controls for the significant aspects and hazards identified for the NCSP, and control situations where their absence could lead to the deviation from the EHS Policy, objectives and targets. EHS Management System Standard Operating Procedures Manual.      
4 EHSCSM 4.1.3 HQ EHSC The EHS HQ Coordinator shall be responsible for quarterly reporting on program EHS performance to Regional Directors and the Director HQ. Quarterly reports on program EHS performance to Regional Directors and the Director HQ, for 2007 to date.      
4 EHSCSM 4.4.3 HQ EHSC The person responsible for an activity or area that has been audited shall prepare Corrective and Preventive Action Plans to address the deficiencies found by the audit, following the requirements provided in the NCSP EHS Audit Program Guide. Corrective and Preventive Action Plans prepared as part of NCSP EHS Audits.      
4 EHSCSM 2.4 HQ EHSC There shall be an EHS Audit Program Guide. The NCSP EHS Audit Program Guide.      
4 EHSCSM 5.1.3 HQ EHSC The EHS HQ Coordinator shall prepare and present the EHS MS assessment report to the Steering Committee and/or the Directors Committee annually. The review may include items such as:
  • An evaluation of the continuing suitability of the EHS Policy;
  • Performance relative to annual EHS Policy
  • Proposed EHS objectives and targets in consideration of changing program and site conditions, regulatory requirements and other information;
  • Any significant incidents and repeated near misses, and the results of investigations, audits and inspections following significant incidents;
  • An evaluation of the suitability and adequacy of the EHS MS and SOP Manual; and
  • Consideration of conscerns amonf relevant interested parties.
Annual EHS Management System assessment reports for 2007 and 2008.      
4 EHSCSM 5.1.3 HQ EHSC The results of the review, including any changes to be made to the EHS MS and new EHS objectives and targets, shall be communicated to the HQ EHS Coordinator, Program Directors, regional health and safety personnel, and Project Managers. The results of the review shall be documented by the HQ EHS Coordinator and maintained on file as an EHS MS record. Documents describing the results of senior management reviews of the EHS Management System.      
4 EHSCSM 3.3.3 HQ EHSC Required changes to SOPs identified by regional staff shall be communicated to the Regional Director for review and approval and acted upon by the HQ EHS Coordinator. Changes made to SOPs in response to requests of Regional Directors.      
4 EHSCSM 4.4.3 HQ EHSC The EHS HQ Coordinator, in cooperation with Regional Directors and the RD OGGO PWGSC when necessary, shall develop and coordinate an annual EHS MS audit plan according to the requirements of the NCSP EHS Audit Program Guide. The audit plan shall, at a minimum, detail the frequency of audits and the sites subject to upcoming audits. The annual EHS Management System audit plans for 2008, 2009 and 2010.      
4 EHSCSM 4.4.3 HQ EHSC Among other things, the EHS MS audit shall determine whether or not the: Reports of EHS Management System audits, 2007 to date.      
4 EHSCSM 4.4.3 HQ EHSC
  • EHS MS conforms to the ISO 14001 and OHSAS 18001 framework;
       
4 EHSCSM 4.4.3 HQ EHSC
  • EHS MS has been properly implemented and maintained according to internal standards;
       
4 EHSCSM 4.4.3 HQ EHSC
  • Regional and Project activities and management systems are conducted in conformance with the elements of the EHS MS Manual;
       
4 EHSCSM 4.4.3 HQ EHSC
  • EHS MS is achieving regulatory compliance;
       
4 EHSCSM 4.4.3 HQ EHSC
  • EHS MS is effective in meeting EHS Policy and EHS procedures;
       
4 EHSCSM 4.4.3 HQ EHSC
  • EHS MS is effective in meeting EHS objectives and targets; and
       
4 EHSCSM 4.4.3 HQ EHSC
  • PWGSC contractors are meeting EHS requirements, where applicable.
       
4 EHSCSM 4.4.3 HQ EHSC The frequency of audits may be based on:        
4 EHSCSM 4.4.3 HQ EHSC
  • The risk profile of sites;
       
4 EHSCSM 4.4.3 HQ EHSC
  • The results of previous audits;
       
4 EHSCSM 4.4.3 HQ EHSC
  • Public or regulatory concerns and complaints;
       
4 EHSCSM 4.4.3 HQ EHSC
  • Significant changes to the Program activities or significant aspects;
       
4 EHSCSM 4.4.3 HQ EHSC
  • Significant changes in regulatory requirements;
       
4 EHSCSM 4.4.3 HQ EHSC
  • Increases or decreases in non-conformances; and
       
4 EHSCSM 4.4.3 HQ EHSC
  • The frequency or occurrence of incidents.
       
4 EHSCSM 4.4.3 HQ EHSC Certified professional auditors shall conduct the audits in accordance with generally accepted audit principles and practices specified in the Guidelines for Quality and/or Environmental Management System Auditing, ISO 19011 and as outlined in the NCSP EHS Audit Program Guide. Names and qualifications of auditors.      
4 EHSCSM Policy Statement HQ EHSC All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations. Roster of EHS training programs offered and provided to NCSP employees.      
4 EHSCSM 3.2.3 HQ EHSC The EHS HQ Coordinator shall develop an EHS MS awareness training package to communicate, as a minimum, the following: the EHS Policy, the process required to identify EHS aspects and hazards of contaminated work sites; the EHS objectives, targets, and performance measures of the NCSP sites; legal compliance requirements and the consequences of non-compliance; the Internal Responsibility System (IRS); and due diligence. The EHS MS Awareness Training Package.      
4 EHSCSM 3.2.3 HQ EHSC The EHS HQ Coordinator shall ensure the EHS MS awareness-training package is delivered to all employees, and to new employees, students, consultants and contractors as part of a new job / site orientation, and afterwards as circumstances require. Records of training of NCSP employees in the EHS MS Awareness Training Package.      
4 EHSCSM 3.2.3 HQ EHSC The EHS HQ Coordinator shall develop a training package on the Standard Operating Procedures Manual to support EHS programs and provide NCSP personnel with the knowledge required to mitigate EHS risks, hazards, and impacts. This training will be provided to INAC staff involved in operational activities and will be refreshed on a regular basis and whenever circumstances require retraining. Regional Directors are responsible to ensure that training is delivered as required. The training package on the EHS MS Standard Operating Procedures Manual.      
4 EHSCSM 3.2.3 HQ EHSC The EHS HQ Coordinator shall develop a training package on the Standard Operating Procedures Manual to support EHS programs and provide NCSP personnel with the knowledge required to mitigate EHS risks, hazards, and impacts. This training will be provided to INAC staff involved in operational activities and will be refreshed on a regular basis and whenever circumstances require retraining. Regional Directors are responsible to ensure that training is delivered as required. Records of employee training in the EHS MS Standard Operating Procedures Manual.      
4 EHSCSM 3.2.3 HQ EHSC The EHS HQ Coordinator and the EHS Regional Coordinator shall annually assess the effectiveness and delivery of the EHS MS training package and specific training programs. They shall ensure these programs are modified as required to meet specific training needs. Individual employee responsibilities, abilites, and risk factors of the work sites shall be used as criteria to assess training needs. Records of assessments of the effectiveness and delivery of the EHS Management System Training Package, and the delivery of specific EHS training programs.      
4 EHSCSM Policy Statement REG EHSC All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations. Roster of EHS training programs offered and provided to NCSP employees.      
4 EHSCSM Policy Statement REG EHSC All managers and supervisors are responsible for ensuring that their employees are trained in safe work procedures, to undertake their assigned duties without accidents, injuries or harm to the environment, and for ensuring that employees follow safe work methods and all related regulations. Records of EHS training of NCSP employees.      
4 EHSCSM Policy Statement REG EHSC Each Region shall establish EHS Procedures consistent with the ISO 14001 and OHSAS 18001 requirements, appropriate to the nature, scale and EHS impacts of all Northern Contaminated Sites Program activities. These Procedures shall be documented in a Regional EHS Manual and shall include a commitment to:
  • An evaluation of the continuing suitability of the EHS Policy;
  • Prevention of pollution or other adverse environmental impacts;
  • Prevention of accidents and lost-time injuries;
  • Compliance with all relevant EHS legislation, regulations and other applicable federal policies and requirements;
  • Development of objectives and targets approved by senior management, to ensure the requirements of the EHS management system are met; and
  • Regular monitoring and reporting of the performance against EHS objectives and targets to senior management.
Regional EHS Procedures.      
4 EHSCSM 2.1.3.6 REG EHSC Known hazards at non-active sites (i.e., those awaiting assessment, remediation or monitoring) shall be included in the Regional EHS aspects and hazards register to ensure such hazards are managed. Regional EHS Aspects and Hazard Register.      
4 EHSCSM 2.3.3.2 REG EHSC The EHS Regional Coordinator shall develop and recommend annual EHS objectives and targets for their region. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in regional-level work plans. Regional-level workplans for 2007 to 2009 showing EHS Annual Objectives and Targets.      
4 EHSCSM 3.6.3 REG EHSC The EHS Regional Coordinator shall develop additional regional EHS SOPs where the regional risk assessment identifies significant aspects or hazards not covered by the EHS SOP Manual, or where procedures need to be customized to reflect regional circumstances. These regional procedures form an important component of the Regional EHS MS Manual. Regional EHS Standard Operating Procedures.      
4 EHSCSM 3.3.3 REG EHSC Required changes to regional amplification of SOPs identified by regional staff shall be communicated to the Regional Director and acted upon by the regional EHS Coordinator. Examples of Regional EHS SOPs amended in response to requests of the Regional Director.      
4 EHSCSM 3.2.3 REG EHSC The EHS Regional Coordinator shall review the job descriptions or other suitable vehicles for INAC project managers, field supervisors and field workers as new positions are created or before existing ones are posted for existence of EHS requirements, and shall recommend modifications where necessary to assure the appropriate EHS qualification. Examples of job descriptions amended on the advice of the EHS Regional Coordinator to incorporate EHS qualifications requirements.      
4 EHSCSM 3.2.3 REG EHSC Training records for all EHS training sessions and site orientations delivered by INAC personnel shall be maintained on file at the appropriate location (i.e., project site, regional office, or HQ) for a minimum of five years. Records of EHS training (list of courses and dates, lists of attendees) that has been provided in the region.      
4 EHSCSM 2.3.3.4 REG EHSC Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning. Regional-level Programs to achieve EHS annual objectives and targets.      
 

Appendix 3D - Document Request List for CSMP Project Managers

Audit Checklist 4-2 (Documents Required by EHS Contaminated Sites Manual - Project Managers)

Audit Subjects:
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:

AUDIT AREA SOURCE APPLI-CATION AUDIT CRITERIA DOCUMENT REQUEST LIST PROVIDED? PROPER STD IDENTIFIERS? CONTENT MEETS SPECS?
4 EHSCSM 2.3.3.4 PROJ MGR Programs to achieve objectives and targets will be identified and developed at the Program-level by the EHS HQ Coordinator, at the regional-level by the Regional Directors, and at the project-level by Project Managers, as part of annual NCSP work planning. Project-level programs to achieve the annual EHS objectives and targets.      
4 EHSCSM A.2.3 PROJ MGR PWGSC will review and consolidate EHS requirements in specifications. Project specifications (sample size to be determined).      
4 EHSCSM A.2.3 PROJ MGR At start-up meetings:
  • It is the Crown's duty to communicate known risks
  • The Crown will provide its EHS MS as an example
  • PWGSC and INAC NCSP will review EHS requirements in contract documents
Project start-up meeting minutes (sample size to be deteremined).      
4 EHSCSM A.2.3 PROJ MGR Crown to review the Prime's EHS Plan
  • If issues are identified, work shall be done to resolve the issues
  • If the Crown's issues are not addressed, the authorities having jurisdiction will be informed
Prime Contractors EHS Plans for projects (sample size to be determined).      
4 EHSCSM A.2.3 PROJ MGR INAC and PWGSC parties will determine and implement site-specific reporting, inspections and auditing requirements. Documents describing site-specific EHS reporting, inspections and auditing requirements (sample size to be determined).      
4 EHSCSM Policy Statement PROJ MGR Ensure all individuals involved with a project (i.e., including Site Operator and INAC employees, consultants and contractors, and visitors) are aware of and comply with the EHS policy. Documents describing how the NCSP EHS Policy is communicated to all persons involved in a project.      
4 EHSCSM 2.1.3.5 PROJ MGR A hazard assessment is required before commencing any project. Project specific job / task hazards will be identified by the site supervisor (or the Project Manager if no supervisor is assigned for a site) and addressed using the job safety analysis procedure found in the Standard Operating Procedures (SOP) Manual. Results of the hazard assessment are to be communicated to the appropriate staff. Pre-project hazard assessments (sample size to be determined).      
4 EHSCSM 3.1.3.6 PROJ MGR Identify project EHS aspects and hazards and develop project-level procedures and programs for all EHS aspects and hazards not covered by corporate or regional procedures, as required (i.e., amplifying the SOP Manual); Project-level EHS procedures (sample size to be determined, will overlap with projects for which hazard assessments are requested).      
4 EHSCSM 3.1.3.6 PROJ MGR Ensure the requirements of the EHS Policy, EHS MS Manual and SOP Manual are transferred to non-INAC project participants (e.g., PWGSC, contractors and consultants) as minimum requirements, through SSAs or contracts; Project contracts (sample size to be determined).      
4 EHSCSM 3.1.3.6 PROJ MGR Ensure the requirements of the EHS Policy, EHS MS Manual and SOP Manual are transferred to non-INAC project participants (e.g., PWGSC, contractors and consultants) as minimum requirements, through SSAs or contracts; Project staff service agreements with PWGSC.      
4 EHSCSM 3.1.3.6 PROJ MGR Request and review site specific EHS Plans to ensure EHS requirements are documented, and inspecting project activities and operations to ensure site activities conform to requirements; Project site specific EHS plans (sample size to be determined, will overlap with projects for which hazard assessments are requested).      
4 EHSCSM 3.1.3.6 PROJ MGR Request and review site specific EHS Plans to ensure EHS requirements are documented, and inspecting project activities and operations to ensure site activities conform to requirements; Project EHS inspection records - prepared by any party (sample size to be determined, will overlap with projects for which hazard assessments are requested).      
4 EHSCSM 3.1.3.7 PROJ MGR Forward project-specific EHS plan submittals to qualified professional for review; Project-specific EHS plan reviews performed by third party professionals (sample size to be determined, will overlap with projects for which hazard assessments are requested).      
4 EHSCSM 4.1.3 PROJ MGR NCSP Project Managers, consultants and contractors shall develop procedures that describe the way their processes and work activities are monitored and controlled, including workplace and project inspections. These procedures shall include the required time intervals for tracking performance against EHS objectives and targets. Procedures developed by any of NCSP Project Managers, consultants or contractors that describe the way their processes and work activities are monitored and controlled, including workplace and project inspections.      
4 EHSCSM 4.2.3 PROJ MGR or non-conformance and non-compliance events identified in 4.2.3.1, a root cause analysis should be conducted to determine the direct cause of the non-conformance / non-compliance. Corrective and Preventive Action Plans shall be developed for all identified non-conformances / non-compliances using the Corrective and Preventive Action Plan template found in the EHS Audit Program Guide. Root causes analysis reports for any identified instances of non-compliance or non-comformance.      
4 EHSCSM 4.2.3 PROJ MGR Project Managers shall report (non-conformance and non-compliance) results quarterly (as part of regular project quarterly reporting) and the reports will be used for assessing the effectiveness of the EHS MS. Quarterly non-conformance and non-compliance reports of Project Managers (sample size to be determined).      
4 EHSCSM 2.3.3.3 PROJ MGR Project Managers shall develop and recommend annual EHS objectives and targets for their project. The Regional Director is responsible for approving these objectives and targets. These EHS objectives, targets, and programs shall be documented in project-level detailed work plans. Project-level detailed work plans that contain annual EHS objectives and targets for the project (sample size to be determined).      
4 EHSCSM 4.2.3 PROJ MGR EHS Policy and SOPs Manual infractions by personnel will be dealt with through a system of verbal and written warnings with review. Written warnings on record (sample size of projects to be determined).      
4 EHSCSM 4.2.3 PROJ MGR Training records for all EHS training sessions and site orientations delivered by INAC personnel shall be maintained on file at the appropriate location (i.e., project site, regional office, or HQ) for a minimum of five years. Training records for all EHS training sessions and site orientations delivered by INAC personnel for the project (sample size of projects to be determined).      
 

 

Appendix 4a

Appendix 4A – OHS Program Documents and Records

Appendix 4A - Document Request List for Corporate and Regional HS Staff / Advisors

Audit Checklist 2-1 (Documents Required by CLCII or Treasury Board)

Audit Subjects: Corporate and Regional Health and Safety Staff / Advisors
INAC Location / Address:
Data Collection Date(s):
Auditor:
Audit Record No.:

Item Source Mandatory Documents /
Document Request List
Regional Program Document Regional Activity Record Corporate Program Document Corporate Activity Record
1 TBOHSD Part 1, General Procedure for resolution of "qualified person" dispute     x  
2 TBOHSD 7.1 Report of any noise exposure investigation       x
  COHSR 7.3(5)
3 TBOHSD 9.2.7 Contingency procedures for cases in which there is a temporary interruption in the supply of drinking water and water for the removal of water-borne waste x   x  
4 TBOHSD 10.1 Record of all hazardous substances that, in the work place, are used, produced, handled, or stored   x    
  COHSR 10.3
5 TBOHSD 10.5 Written reports of any investigation or testing of exposure to hazardous substance   x    
  COHSR 10.5
6 COHSR 10.5(b) Written procedure for the control of the concentration or level of a hazardous substance in the work place x      
7 COHSR 10.15 Records of instruction and training for hazardous substances   x    
8 TBOHSD 10.6 Asbestos management program x      
9 CLCII 125.1z.13) Program for the provision of personal protective equipment, clothing, devices or materials x      
10 COHSR 12.14(1) Record of all protective equipment provided by the employer   x    
11 TBOHSD 15.1.1 Hazardous occurrence investigation procedures and methodology x   x  
12 COHSR 15.7(1) Record of each minor injury   x    
13 COHSR 15.8 Hazardous occurrence reports   x    
14 TBOHSD 16.1.2 Procedures respecting the availability of first-aid services x   x  
15 TBOHSD 16.2.2 Written record of every injury or illness that requires first-aid treatment   x    
16 COHSR 16.2(1) Written first aid instructions that provide for the prompt rendering of first aid to an employee for an injury, an occupational disease or an illness x      
17 COHSR 16.13 On-site first aid-records   x    
18 COHSR 16.13(2) Off-site first aid-records       x
19 COHSR 16.13(6) Record of the expiry dates of the first aid certificates of the first aid attendants   x    
20 TBOHSD 1.0