Hazard Identification, Elimination and Control

Code Requirements

Code Explanation Guide

All other requirements in the OH&S code must be read with this very important new section in mind.

  • The Code defines a "hazard" to mean "a situation, condition or thing that may be dangerous to the safety or health of workers." This means employers must not just identify obvious hazards, they must consider what may cause harm to workers and they are legally held to a very high standard in doing this.

  • Employers must identify and eliminate or control workplace hazards as laid out in this part of the Code.

  • Employers must assess a worksite and identify existing or potential hazards before work begins or any time the work or worksite changes. They must keep the assessments up to date. Examples of changes which should trigger hazard assessments are changes in patient acuity level, moving to a new building or office, working with new equipment, changes to workload, changes to occupational exposure levels of the chemicals you work with and changes in parking arrangements. The assessment should occur before workers have to face the hazards - not after the fact.

  • Employers must prepare a report in writing with the results of the hazard assessment.

  • Employers must say in writing what methods they will use to eliminate or control the hazards they identified.

  • Employers must involve affected workers in the hazard assessment and in the control or elimination of the hazards identified.

  • An employer must ensure that workers affected by the hazards identified in a hazard assessment report are informed of the hazards and the methods used to control or eliminate the hazards.

The Code goes even further and lays out what we call a "hierarchy of controls."

  • The first requirement is to use "engineering controls" to eliminate or control the hazard.

    Examples of engineering controls are adaquate ventilation systems for areas where chemicals are used, mechanical lifting devices to avoid unsafe manual lifts or safety engineered sharps, which retract or even cover waste needles.

  • Only if "engineering controls" can not eliminate or control the hazards, "administrative controls" must be used to control the hazard to a low a level as possible. Administrative controls include rules and regulations. Hand washing is accepted as an effective tool to prevent the spread of infection. Rules requiring hand washing would be an effective administrative control in the health-care work environment. Most health-care facilities have rules requiring waste needles to be safely disposed in a sharps container at the point of use. These rules would be administrative controls.

  • Personal protective devises may only be used if engineering or administrative controls cannot eliminate or control the hazard. N95 Respirators, which must be individually fit-tested, are an example of personal protective equipment which is required because health-care workers cannot be adquately protected against some airborne infectious diseases (SARS, pandemic influenza) with engineering and administrative controls alone.

  • There is one final option and that is to combine all three options - engineering and administrative controls and use of personal protective devises.

    Reading legislation is very similar to reading a collective agreement. Specific clauses have to be read together with more general clauses so you understand the "whole picture." For example, the Act tells us the employer has a general duty to ensure the health and safety of workers or others present at the worksite. The Regulations say when an employer is required to make a report or a plan or develop procedures and implement them "it must be in writing and be available to the workers at the worksite affected by it." Part 2 of the Occupational Health and Safety Code requires employers to identify and eliminate or control hazards. Therefore, workers must be informed of the hazards they face and hazard assessments must be in writing and available to the worker!

    Part 2 of the Code requires employers to use the highest level of protection possible to eliminate or control hazards. Engineering controls must be used before administrative controls or personal protective devices. Part 35 of the Code prohibits the recapping of waste needles and requires the use of safety engineered sharps, such as needles, scalpels and other sharp medical instruments when clinically appropriate and commercially available.