Occupational Health and Safety Program

Occupational Health & Safety Program COMPANIES WITH MORE THAN 20 EMPLOYEES

Complimentary manual courtesy of the NCDA and made possible with support from CADA

CADA continues to fight on your behalf.

CADA has been working to reduce the impact of COVID-19 on your business and your employees:

• Recognition as an essential service, allowing dealers to open • Expansion of emergency wage and loan programs to include most dealerships • Tax deferrals and payroll deduction reductions for dealerships • Clarified dealer sales and service agreements with OEMs • Advocated for financial relief on floor plans, term loans, and mortgages • Promoted expansion of the Business Development Bank of Canada’s credit and other programs for dealerships • Advocated for relaunch of the credit facility created in the 2008-09 financial crisis and a vehicle scrappage program • Pursuing federal job - loss insurance and an HST/GST exemption for vehicles • Working with provincial associations and regulators to establish “back-to-work” plans and procedures

CADA and your provincial association continue to fight on your behalf.

Find the latest information and details at cada.ca/COVID-19.

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CADA 1026 (02/18) NTL

Occupational Health and Safety Program

Contents

Welcome Message from the NCDA's President & CEO....................................................................................5

1 INTRODUCTION ........................................................................................................................................... 6 1.1

Purpose of the Occupational Health and Safety Program ........................................................ 6

1.2

Overview of the Occupational Health and Safety Program ...................................................... 6

1.3

New Car Dealers Association Profile ......................................................................................... 7

1.4

THE DEALER Occupational Health and Safety Program Policy................................................. 8

2 PLANNING .................................................................................................................................................... 9 2.1

Legal Requirements ................................................................................................................ 14

2.2

Hazard Management .............................................................................................................. 14

2.3

Contractors and Contract Workers ......................................................................................... 17

3 IMPLEMENTATION..................................................................................................................................... 19 3.1

Safe Work Rules ...................................................................................................................... 19

3.2

Safe Work Procedures ............................................................................................................ 21

3.3

Instruction and Training .......................................................................................................... 23

3.4

Emergency Preparedness ....................................................................................................... 26

3.5

Joint Health and Safety Committee (JHSC) ............................................................................. 29

3.6

Hazardous Materials and Environmental Control................................................................... 32

3.7

Violence in the Workplace and Working Alone ...................................................................... 36

3.8

Bullying and Harassment ........................................................................................................ 37

3.9

Ergonomics (MSI) .................................................................................................................... 40

3.10 Disability Case Management .................................................................................................. 42 3.11 Documentation (Records and Statistics)................................................................................. 45 4 EVALUATION .............................................................................................................................................. 47 4.1

Workplace Inspections ........................................................................................................... 47

4.2

Incident Investigation ............................................................................................................. 50

4.3

Health Monitoring .................................................................................................................. 55

4.4

Program Review & Management Meetings ........................................................................... 58

Occupational Health and Safety Program 5 RESOURCES ................................................................................................................................................ 59 6 SUPPLEMENTARY INSTRUCTIONS ............................................................................................................. 60 6.1

Supplementary Instruction - Hazard Management ................................................................ 60

6.2

Supplementary Instruction - Contractors & Contract Workers .............................................. 65

6.3

Supplementary Instruction - Safe Work Rules and Procedure ................................................. 68

6.4

Supplementary Instruction - Instruction and Training……………………........................................71

A Message from the NCDA President and CEO August 2020 - (Langley, B.C.) As another member benefit, the New Car Dealers Association of BC (NCDA) is pleased to provide to our members an updated Occupational Health and Safety Program Manual to adopt as applicable. The last major update to this was done in 2017.

This new Program is written with the intent to guide NCDA’s members to comply with the BC’s OHSR (Occupational Health and Safety Regulations) and the WCA (Workers’ Compensation Act), when the program is adopted and customized.

The Manual’s goals are to:  Help members understand and implement compliant Occupational Health and Safety Program elements and requirements;  Provide guidelines for meeting the BC Occupational Health and Safety Regulation (OHSR) and Workers Compensation Act (WCA);  Provide managers and employees of each member with information about their responsibilities in their Occupational Health and Safety Program; and  Provide a documentation system to show due diligence for everyone.

COVID-19 Response In addition to the health and safety measures required by WorkSafeBC in response to COVID-19, this Occupation Health and Safety Manual includes important resources for dealers. Make sure staff are familiarized with your Health and Safety plan. We are here to help. Throughout the pandemic, the NCDA was laser focused on providing the most up to date information in daily updates to its Dealer Members, including the latest federal and BC government information. The NCDA worked hard to make sure that BC’s dealerships could remain open and operating throughout the pandemic as an essential service, if they choose to. Our national association, CADA, was focused on working with the Federal government to make sure dealers would be eligible for the various supports available to businesses and we reached out to the provincial government on various issues including temporary layoff provisions.

We are proud of the hard work to keep staff and customers safe by our members and are inspired by efforts to stay safe, kind and calm. It’s all our responsibility to stay safe, so let’s do our part!

Sincerely,

Blair Qualey, President and CEO New car Dealers Association of BC (NCDA) P: 604.214.9964 E: bqualey@newcardealers.ca

Occupational Health and Safety Program

1 INTRODUCTION 1.1 Purpose of the Occupational Health and Safety Program The Occupational Health and Safety Program is for the New Car Dealers Association’s members to adopt as applicable. It: 1.

Helps members understand and implement compliant Occupational Health and Safety Program elements and requirements;

2.

Provides guidelines for meeting the BC Occupational Health and Safety Regulation (OHSR) and Workers Compensation Act (WCA);

3.

Provides managers and employees of each member with information about their responsibilities in their Occupational Health and Safety Program; and

4.

Provides a documentation system to show due diligence for everyone.

The program is written with intent to guide New Car Dealers Association’s members to comply with the BC OHSR the WCA when the program is adopted and customized.

Due to the prescriptive nature of BC’s regulatory requirements, this Occupational Health and Safety Program is written to ensure compliance is considered in all sections. The specific terminology and forms cited in this Occupational Health and Safety Program are taken from WorkSafeBC. *Note: A New Car Association member is referred to as “the Dealer” in the Occupational Health and Safety Program.

1.2 Overview of the Occupational Health and Safety Program The Occupational Health and Safety Program is organized in accordance with the Canadian Standards Association (CSA) Standard Z1000-06: Occupational Health and Safety Management. Each section has relevant subsections (elements). Each section is an important part of the successful implementation of the Occupational Health and Safety Program. The sections work interdependently meaning that each section relies on the implementation of the other sections.

All elements contain a purpose, definitions, specific responsibilities, and procedural information.

Some elements contain specific policies to further emphasis the commitment of Senior Managers.

Additionally, procedural information with applicable forms is found in the Supplementary Instructions section. Many elements have training information that employees can refer to as a resource.

Information resources used in the development of this Occupational Health and Safety Program were WorkSafeBC, the CSA Standard, the Occupational Safety and Health Association and the U.S. Environmental Protection Agency. Each Dealer will need to consider their local municipal environmental requirements.

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Occupational Health and Safety Program

1.3 New Car Dealers Association Profile The New Car Dealers Association of BC (NCDA - the Association) is an association of over 390 new car and truck franchised auto retailers throughout British Columbia. The association speaks on behalf of the retail automotive industry to the public, media, and government, and deals primarily with the legal, environmental, and consumer issues relating to vehicle sales in British Columbia. Members of the Association directly employ over 30,000 British Columbians and are responsible for more than $16 Billion of retail sales in the province. To learn more about the NCDA, visit: https://www.newcardealers.ca/ There are three facets for the Association members to consider when they implement their Occupational Health and Safety Program: 1. There are three primary subgroups: sales/administrative, service and a body shop. Each subgroup has its own unique health and safety issues along with many overlapping compliance needs. Some members may have more than one subgroup within its venue.

2. The members vary in size. They may be classified as a small employer (less than 20 employees) or a regular size employer (20 or more employees). This Occupational Health and Safety Program applies to a regular size employer.

3. The members work with the public who may create safety issues such as traffic hazards and potential for incidents involving violence.

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Occupational Health and Safety Program

1.4 THE DEALER Occupational Health and Safety Program Policy THE DEALER is committed to achieving a workplace where Safety, Quality, Production and the wellbeing of the Environment is of paramount importance in every decision made. THE DEALER is committed to promoting our employees to “do the job right” and to participate with our employees in a proactive approach to ensure their health and safety is maintained.

Roles and Responsibilities Senior Managers establish, provide and maintain systems, equipment, resources, policies and practices to ensure that all employees are aware of and accountable for THE DEALER’s commitment to a safe and healthy work environment.

Managers and Supervisors develop, maintain and review Safe Work Rules and Procedures, and educate and train their employees in the rules, policies and procedures. They perform regular safety inspections, investigate incidents and reported hazards, and actively participate in the Occupational Health and Safety Program by ensuring their employees remain healthy and safe while performing their work.

Employees are the primary component in developing and maintaining a healthy and safe work environment. They participate in the Occupational Health and Safety Program, recommend actions to improve its effectiveness, report incidents and hazards, and use the motto Think Safe, Be Safe, Ask Questions when performing their job tasks.

Joint Health and Safety Committee Representatives act as facilitators to achieve THE DEALER’s goal of a safe and healthy work environment. The Representatives promotes Safe Work practices, provides recommendations for health and safety issues, participates in site inspections and, where needed, assists in incident investigations.

Everyone is expected to ensure the health and safety of themselves and their coworkers. They are responsible for correcting and/or reporting unsafe conditions and activities and work cooperatively towards achieving a safe and healthy work environment. Everyone has the right to know, the right to refuse and the right to participate.

Name President THE DEALER

Date

Think Safe, Be Safe, Ask Questions

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Occupational Health and Safety Program

2 PLANNING 2.1 Legal Requirements Purpose The WCA requires employers to ensure their employees remain healthy and safe during the course of their work. The WCA and BC OHSR provide a legal framework for employers to meet this goal.

Definitions Section 217 of the Criminal Code Section 217 of the Criminal Code defines what a Crime of Negligence is - an organization or its members willfully and intentionally acted with recklessness and little to no disregard for the safety of others to the severity it deserves criminal punishment. Any person or group of people in the Dealership can be charged as it can be a combination of acts between various individuals that constitute the offence. Due Diligence would not be applicable in these situations.

Due Diligence Due diligence requires taking all reasonable steps to protect workers from harm. "All reasonable steps" is based on the level of judgment and care that a person would reasonably be expected to do under the circumstances.

Employee (Worker) A person who is on the payroll of the employer. It includes all levels of supervisors and line employees (workers).

Occupational Health and Safety Regulations (OHSR) The purpose of the BC OHSR is to provide a legal framework for employers to meet the WCA. It protects workers and other persons present at workplaces from work-related risks to their health, safety and wellbeing.

Senior Managers (The Dealer or Senior Managers) Senior Managers refer to the Senior Managers of THE DEALER and any other persons who have the power and authority to effect change in the organization.

Supervisor A person who directs, instructs and controls one or more employees in the performance of their duties.

Workers Compensation Act (WCA) Describes the Workers Compensation Board and its authority to make regulations, inspect workplaces, issue orders and impose penalties. It explains rights and responsibilities of employers, supervisors, and workers with respect to health and safety.

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Occupational Health and Safety Program

Responsibilities All people who supervise employees or who make policy decisions have the responsibility to ensure the Occupational Health and Safety Programs goals are implemented to achieve a safe and healthy workplace. The following responsibilities are used in all sections within the Occupational Health and Safety Program. Each section may have additional section specific responsibilities.

Senior Managers (also referred to as THE DEALER): 1. Ensure the health and safety of all employees and others at the workplace.

2. Ensure that supervisors and workers are educated and trained to an acceptable level of competency.

3. Establish occupational health and safety polices and an Occupational Health and Safety Program.

4. Provide leadership for the Occupational Health and Safety Program by acting as role models including providing general direction to supervisors and workers about their responsibilities and roles in providing a safe and healthy workplace.

5. Provide clear direction to all employees in their safety and health responsibilities and hold them accountable for meeting these responsibilities by providing them with the information, instruction, training, and supervision necessary to protect their health and safety.

6. Provide supervisors with the support and training necessary to carry out their health and safety responsibilities.

7. Make a copy of the WCA and BC OHSR readily available for review by workers.

8. Provide financial, human and organizational resources to plan, implement, review and correct the Occupational Health and Safety Program.

9. Ensure that health and safety is an integral part of THE DEALER current and future goals.

10. Review THE DEALER Occupational Health and Safety Program at planned intervals and perform an annual review.

11. Report on the Occupational Health and Safety Program’s performance to management, supervisors and workers.

12. Cooperate with and provide information requested by WorkSafeBC Prevention Officers or others carrying out health and safety duties.

Supervisors 1. Ensure the health and safety of all workers under their direct supervision.

2. Ensure that workers under their supervision are made aware of all known or reasonably foreseeable health and safety hazards where they work.

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Occupational Health and Safety Program 3. Act as role models by following and enforcing all company rules and policies.

4. Know and understand how to use the Occupational Health and Safety Program and relevant Occupational Health and Safety legislation and ensure that these are followed.

5. Assist in identifying and eliminating/controlling work-related hazards through hazard management, inspections and incident investigations.

6. Provide information, instruction, and assistance to employees so that they can remain healthy and safe.

7. Provide staff with tools and equipment relevant to their employees’ work tasks and applicable controls.

8. Participate in the evaluation of the Occupational Health and Safety Program.

9. Cooperate with and provide information requested by WorkSafeBC Prevention Officers or others carrying out health and safety duties.

Employees (or Workers): 1. Play an active role in the development, implementation and review of their Occupational Health and Safety Program.

2. Act as a role model for co-workers and new workers by following all company rules and policies.

3. Demonstrate due diligence by taking all reasonable care to protect themselves and their co-workers.

4. Know and comply with Safe Work Rules and Procedures.

5. Participate in training sessions for safety.

6. Perform work in a safe manner. Do not engage in horseplay, or work while impaired by drugs, alcohol or other causes.

7. Correct or immediately report any unsafe act or condition to your supervisor.

8. Inform a supervisor of any physical or mental impairment that may affect his ability to work safely.

9. Maintain ‘good housekeeping’ in the work area.

10. Report incidents and injuries to their first aid attendant and supervisor.

Joint Health & Safety Committee Representatives 1. Act as facilitators in promoting safe work practices by following all company rules and policies.

2. Consider and expeditiously deal with complaints relating to the health and safety of workers.

3. Assist in developing and applying Safe Work Rules and Procedures.

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Occupational Health and Safety Program 4. Make recommendations to the employer and the workers for the improvement of the occupational health and safety and occupational environment of workers.

5. Make recommendations to the employer on educational programs promoting the health and safety of workers and compliance with the OHS provisions and the regulations and to monitor their effectiveness.

6. Advise the employer on programs and policies required under the regulations for the workplace and to monitor their effectiveness.

7. Advise the employer on proposed changes to the workplace, including significant proposed changes to equipment and machinery, or the work processes that may affect the health or safety of workers.

8. Ensure that accident investigations and regular inspections are carried out as required by the OHS provisions and the regulations.

9. Participate in identifying situations that may be unhealthy or unsafe for workers and advise on effective systems for responding to those situations.

10.

Communicate health and safety information to employees and management by consulting with workers and the employer on issues related to occupational health and safety and occupational environment.

Procedural Information Internal and External Standards THE DEALER maintains its Occupational Health and Safety Program in compliance with both external and internal compliance standards: ▪ External standards include the WCA, the BC OHSR , Federal Laws, Canadian Standards Association, public health and environmental standards and regulations.

▪ Internal standards include safe work policies, procedures and rules.

The Senior Managers continuously review the occupational health and safety legislative requirements for THE DEALER’s Occupational Health and Safety Program. The review process is part of the agenda for management meetings.

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Occupational Health and Safety Program Safe Work Policy The Safe Work Policy is posted on the Safe Work bulletin board located in the staff lunchroom, near the first aid room or in another place which is easily accessible to the employees.

Training Training includes the following courses: Understanding the Safety Management System for Senior Managers 1.

2.

3.

4.

5.

6.

Review of the WCA and the BC OHSR. Roles and responsibilities for all levels of employees with a focus on supervisors.

Due diligence and Section 217 (Bill C45).

Elements of the Occupational Health and Safety Program.

Three rights of workers: including Right to Refuse Unsafe Work.

Other legislative bodies.

Supervisor Safety Management 1.

2.

3.

4.

5.

6.

7.

8.

Understanding the WCA and BC OHSR. Due diligence.

WorkSafeBC Officers’ roles and responsibilities.

Risk management.

Crew talks.

Inspections.

Incident investigations (Right to Refuse Unsafe Work).

Training on Emergency Preparedness and Response procedures which would cover fire, disaster, first aid etc.

Employee Awareness of Health and Safety 1.

2.

3.

4.

5.

6.

Understanding the WCA and the BC OHSR. Roles and responsibilities for all levels of employees with a focus on employees.

Due diligence.

Three rights of workers including Right to Refuse Unsafe Work.

Overview of the Occupational Health and Safety Program.

Awareness of Emergency Preparedness and Response procedures (covers fire, disaster, first aid etc).

Forms There are no forms for this section.

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2.2 Hazard Management Purpose THE DEALER’s primary objective is to provide a safe and healthy workplace for its employees. One method of meeting this goal is by hazard management.

Hazard identification, risk assessment and control is a process where real or potential hazards are identified in the work environment, work processes or workers’ actions are then assessed for their severity (impact) on the worker, equipment, process and/or building structure. Recommendations are developed to eliminate, reduce or control the hazard.

Definitions Administrative Controls The use and scheduling of work activities and providing resources in the workplace including planning, signs, organizing, staffing and coordinating for the purpose of controlling a hazard.

Engineering Controls The physical arrangement, design or alteration of workstations, equipment, material or other aspects of the physical work environment for the purpose of controlling a hazard.

Hazard A hazard is the action or inaction of people and their interaction with their environment. It is any activity, situation or substance that has the potential to cause immediate or long-term harm.

Job Hazard Assessment (JHA) A breakdown of a task into sequential steps (elements) and the identification of hazards associated with these steps and their respected control measures.

Personal Protective Equipment (PPE) Personal protective equipment is used as the last resort if engineering and/or administrative controls are not feasible or is used temporally until other controls are put in place. There are guidelines for a PPE policy for dealers at the end of this section.

Risk A risk measures the probability of a hazard occurring and the severity of harm or damage that could result.

Substitution Substitution is the elimination of the hazard by replacing it with something less hazardous. It is the first choice of hazard control.

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Occupational Health and Safety Program

Responsibilities Refer to Section 2.1 Supervisors: 1. Provide information and training when a new process, equipment or tool is introduced into the work site.

2. Know how to identify real or potential hazards, and near misses.

3. Train employees on how to identify real or potential hazards, and near misses.

4. Perform hazard assessments and implement the recommendations (controls).

5. Follow-up on the recommendations to ensure that the real or potential hazard is eliminated or controlled.

6. Report back to the employee who initially identified the hazard within three working days regarding the results of the hazard assessment and controls.

7. Ensure all employees who may perform the work task are knowledgeable about hazard controls.

8. Provide the required PPE and ensure that the workers are trained to use and care for it.

Employees: 1. Know how to identify real or potential hazards.

2. Report to their supervisor so that a hazard assessment is performed.

3. Ensure that they do not place themselves (or a co-worker) at personal risk of injury when performing a job task.

4. Participate in the hazard assessment process with the supervisor.

5. Understand and properly use and care for the required PPE.

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Occupational Health and Safety Program

Procedural Information Hazard Management Hazard Management is a three-step process that requires the completion of each step to ensure the risk of the hazard is as low as possible.

1. Hazard Identification.

2. Hazard Assessment.

3. Hazard Control.

These three steps are done in two main stages: 1. Site Hazard Assessment (SHA) • A detailed tour of the dealership and surrounding lot that notes actual or reasonably foreseeable hazards, followed by the assessment of the risk posed by these hazards, and the development of controls to reduce the risk.

2. Job Hazard Assessment (JHA) • A detailed examination of the jobs in the company, their associated duties and tasks, and the hazards at each step.

The Hazard Assessment process, the Site Hazard Assessment variation & Job Hazard Assessment process, as well as the required forms, are found in section 6.1.

Training Hazard management training includes the following course: Hazard Management 1. Overview of legislative requirements.

2. Identification of hazard and risk factors.

3. Types of hazards.

4. Job hazard/risk analysis.

5. Analyzing the hazard by identifying present and potential causes and outcomes.

6. Developing solutions with engineering, administrative and personal protective equipment controls.

7. Implementing the controls and evaluating their results.

Forms The supplementary instruction associated to this section contains the required forms. Refer to Supplementary Instruction 6.1.

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Occupational Health and Safety Program

2.3 Contractors and Contract Workers Purpose THE DEALER expects all contractors and their workers to perform their work tasks in accordance with their company’s health and safety program, THE DEALER’s Occupational Health and Safety Program, the WCA and BC OHSR. There are no exceptions to this expectation.

Definitions Notice of Project (NOP) Where applicable, a Notice of Project (NOP) is submitted to WorkSafeBC. It is posted on site and lists areas of responsibility for THE DEALER and all the contractors.

Safe Work Procedure (SWP) A documented procedure required for the safe performance of a work task.

Short Term Workers Short term visits by couriers, inspectors, and suppliers, etc. are not regarded as workers at the workplace; however, if these people are or have the potential to be exposed to a hazard, they must follow to the Safe Work Rules and Procedures.

Responsibilities Contractors have a key role to play in the safety of workers and clients. Contractors are expected to adhere to their legal responsibilities and those required under the OHSR. Contractors may be required to: • • • • • • • • • •

Attend and participate in safety meetings.

Prepare safe work procedures for contracted scope of work.

Provide trained, knowledgeable and competent workers and Supervisors for assigned activities.

Designate an OHS representative.

Regularly inspect activities and tasks of employees.

Report incidents to assigned representative and participate in investigations when required.

Set a good example for other workers.

Complete regular and documented safety meetings.

Abide by all regulatory OHSR requirements applicable to their scope of work.

Implement and enforce their own OHS program.

Prime Contractor: The prime contractor must ensure the activities of workers relating to occupational health and safety are coordinated, and to do everything reasonably practicable to establish and maintain a system or process that will ensure compliance with the regulation.

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Occupational Health and Safety Program

Procedural Information Expectations - THE DEALER: ▪ Expects safe behaviour from all contractors, employees and visitors and requires all policies and rules relating to occupational health and safety to be followed.

▪ Holds all contractors responsible for unsafe acts committed by contract employees; and ▪ Believes that all its employees and contractors must have knowledge and skills to perform their work in a safe and healthy manner.

Contract Specific Requirements There is only one prime contractor in a contract. If THE DEALER is not the designated prime contractor, it must give the prime contractor all the information necessary to identify and eliminate or control hazards at the workplace. Without a written agreement, THE DEALER is the prime contractor.

Training Refer to Section 2.1

Forms The supplementary instruction associated to this section contains the required forms. Refer to Supplementary Instruction 6.2.

1. Contract Risk Assessment Checklist.

2. Review of Tender’s Program.

3. Contractor Performance Report.

PPE Policy Personal Protective Equipment (PPE) is important for dealers to outline in a policy. Employers, supervisors, and workers all have responsibilities relating to PPE on the job. If you are an employer, you are responsible for providing and enforcing the use of personal protective equipment in your workplace, as required by the Occupational Health and Safety Regulation.

A policy should include what is required to be worn and when, who is responsible for providing it as well as training on use of specialized PPE and care and cleaning (including replacement of faulty or damaged PPE). In general, most service shops require CSA Standard safety footwear, hearing protection in environments over 85 dBA, safety eyewear where there is dust, filings, splash risks (oil), gloves when using cutting or grinding tools, face shields, gloves and fire resistant clothing when welding, N95 respirators when sanding vehicles (body shop), full breathing apparatus, helmet for painters, to name a few.

For information on responsibilities for personal protective equipment, see the following resources provided by WorkSafeBC – visit: https://www.worksafebc.com/en/health-safety/tools-machinery-equipment/personalprotective-equipment-ppe/responsibilities Updated: July 2020

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Occupational Health and Safety Program

3 IMPLEMENTATION 3.1 Safe Work Rules Purpose THE DEALER requires that rules are established and followed to ensure a safe and healthy workplace.

Employees are required to know and comply with all Safe Work rules. Failure to do so will result in corrective action.

Definitions Corrective Action A supervisor provides guidance to an employee who demonstrates incorrect or unsafe behaviour. A disciplinary process may be followed.

Procedure A procedure is ‘a series of steps followed in a regular definite order’. For THE DEALER, most procedures describe how to safely perform a work task.

Rule A rule is a ‘prescribed guide for conduct or action’. THE DEALER’s rules are legally binding; therefore, all employees must abide to them even if the rules go beyond minimum compliance standards as stipulated in WorkSafeBC’s WCA and BC OHSR.

Responsibilities Refer to Section 2.1.

Supervisors: 1. Provide supervisory guidance to employees and where needed, initiate the disciplinary process.

Procedural Information Rules Written rules ensure employees are provided with consistent information. Written rules are developed where the BC OHSR does not specifically apply but THE DEALER feels it is necessary.

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Occupational Health and Safety Program THE DEALER’s Safe Work Rules Refer to Supplementary Instruction 6.3 Corrective Action – Enforcement of THE DEALER’s Occupational Health and Safety Program Safety infractions are considered a serious matter and non-compliance with THE DEALER’s Occupational Health and Safety Program will have serious results. THE DEALER has a disciplinary process that is fair and consistent with the ultimate goal that employees choose to work safely. All employees have a responsibility to report unsafe acts to their supervisor. Non-compliance will result in corrective action.

Corrective Action – Responsibilities THE DEALER’s Senior Managers are responsible for issuing a suspension or termination. They review the written warnings to validate their decision.

Supervisors have the responsibility and duty to investigate all allegations of breach of THE DEALER’s rules, policies and procedures with respect to safety. Supervisors direct employees and give verbal and written warnings to employees who are noncompliant.

Corrective Action – Instruction and Coaching It is the supervisor’s responsibility to monitor his or her employees, to provide positive reinforcement when employees work safely and, to provide instruction and coaching to employees who are new, need further instructions, or need a reminder on how to work safely.

Training Refer to training programs in Section 2.1

Forms The following forms are used to meet the requirements of this section. Refer to Supplementary Instruction 6.3.

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Occupational Health and Safety Program

3.2 Safe Work Procedures Purpose THE DEALER’s goal is to provide a safe work environment. To achieve this goal, THE DEALER has Safe Work Rules and Procedures. Employees are required to comply with all Safe Work Procedures. Failure to do so will result in corrective action.

Definitions Refer to Section 3.1.

Responsibilities Refer to Section 2.1 and 2.2 Supervisors: Review Safe Work Procedures when:

• • • •

A task changes.

New or different material is used.

It is the outcome of an incident investigation.

At least annually.

Procedural Information Types of Safe Work Procedures There are two types of Safe Work Procedures:

•

General Safe Work Procedures General procedures are topic-based. Refer to Supplementary Instruction 6.3 for the General Safe Work Procedure Form.

•

Specific Safe Work Procedures Work tasks need written procedures to ensure employees understand how to work safely. A hazard assessment is performed for most work tasks to identify the risks in each step of the task (Refer to Section 2.2). Once an assessment is completed, a specific Safe Work Procedure is written.

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Occupational Health and Safety Program

Training Refer to training programs in Section 2.1 and 3.

Forms The supplementary instruction associated to this section contains the required forms.

1.

General Safe Work Procedure.

2.

Specific Safe Work Procedure.

3.

Infraction Notice.

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Occupational Health and Safety Program

3.3 Instruction and Training Purpose The goal is to ensure all employees know how to ‘do the job right’. By doing the job right, the highest level of safety, quality and production are achieved.

Definitions General Safe Work Orientation The General Safe Work Orientation is part of the new employee orientation. The supervisor provides the training session prior to the commencement of work.

New Employee A new employee is a person who is newly hired by THE DEALER, is assigned to a new work area where the hazards are different from his or her original work area, or faces hazards that have changed or developed while he or she is at work. A new worker is any age and may hold the position of a supervisor or worker.

Returning Employee Any employee who has been absent from work for a prolonged period of time. The length of time is determined by the type and complexity of work which the person will do upon returning to work and any procedural changes that have occurred during his or her absence.

Training Training is necessary when new techniques, new methods, and new tools are introduced into the work site.

Young Employee Any person who is under 25 years of age.

Responsibilities Refer to 2.1 Supervisors: 1. Receive training and instruction to supervise workers and carry out work safely.

2. Ensure employees receive a general orientation and complete the test found in the Employee Orientation & Safety Handbook.

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Occupational Health and Safety Program 3. Assess employee’s skills and knowledge through the orientation process and through continuous observation of the employee’s work.

4. Document all types of training.

5. Ensure employees understand their rights under the WCA. 6. Ensure employees are aware of all health and safety hazards in their work area.

Employees: 1. Read and understand THE DEALER’s Employee Orientation & Safety Handbook.

2. Participate in safety talks and training sessions.

3. Notify the supervisor if there are questions about workplace hazards or if safe work procedures are not clear.

Procedural Information Employees are aware of health and safety hazards in their job tasks and have the job skills to carry out their work safely. Initial and continuous instruction is provided to employees through orientations, on-the-job training and formal safety training.

New (Young and Returning) Employee Orientation Every new, young and returning employee (now referred to as new employee) receives training in THE DEALER’s safety rules, policies and procedures. The Employee Orientation and Safety Handbook is the guide to provide this information. The employee signs the training form when he or she has completed the orientation with his supervisor. General orientation occurs within one working day after starting with THE DEALER. On-the-Job Training Supervisors continuously assess the skills and knowledge of their workers. New employees, or employees lacking the experience or knowledge to work safely on their own, are supervised by a supervisor or another experienced worker until they are proven competent.

Instruction for Supervisors A person who supervises another person needs training to understand his functions and roles.

Training ensures that the supervisor acts duly diligent at all times.

Supervisors are vital links in the development and implementation of a successful health and safety program. They need to know how to supervise their workers. The New Employee’s Checklist form also includes criteria that new supervisors must be orientated to.

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Occupational Health and Safety Program

Training Refer to training programs in Sections 2.1, 3.1, 3.2, 4.1 and 4.2

Forms The supplementary instruction associated to this section contains the required forms.

1. Employee Orientation and Safety Handbook.

2. New Employee Orientation Checklist.

3. New Employee Orientation Quiz.

4. Employee Training Record.

5. Safety Talk/Crew Talk Minutes.

6. Training Session Attendance List.

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3.4 Emergency Preparedness Purpose THE DEALER is committed to providing a quick response in an emergency situation. An emergency situation is any situation where an employee or a customer is at risk for injury or illness. Situations include evacuation of the building and first aid situations.

Definitions Fire Safety/Evacuation Plan It is a plan that provides information for controlling fire hazards, maintaining fire protection systems, and evacuation procedures for the building.

First Aid When a person needs medical treatment, treatment is given to minimize the injury until medical treatment is obtained, or treatment of minor injuries that do not need medical treatment is given.

First Aid Attendant A person who holds a valid first aid certificate issued by WorkSafeBC or by a person recognized by WorkSafeBC and who is designated as a first aid attendant by the employer.

Injury An occupational disease or illness.

Muster Station The muster station or emergency meeting place is where employees meet during an evacuation. The muster station is located away from the building, and traffic and fire lanes.

Responsibilities Supervisors: 1. Ensure employees are familiar with the emergency procedures.

2. Train employees to report all injuries.

3. Know who is working each day and have a current employee list.

4. Complete evacuation report with recommendations.

5. Ensure first aid coverage.

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Occupational Health and Safety Program Employees: 1. Know what to do in an emergency situation.

2. Know how to summon a first aid attendant.

3. Ensure their supervisor knows that they are in the work area.

4. Report all work related injuries and illnesses to the first aid attendant.

5. Report the injury or illness to the supervisor after first aid treatment.

First Aid Attendants: 1. Provide first aid treatment according to their level of training.

2. Maintain first aid records in a confidential manner.

3. Document first aid treatment.

4. Inspect the first aid equipment on a regular basis and report any deficiencies to supervisor.

Procedural Information THE DEALER must conduct a risk assessment of the workplace that focuses on potential emergency scenarios. These scenarios are given procedures to reduce their potential harm. Most assessments aim for harm prevention, but these procedures focus on harm reduction. It is the supervisor’s responsibility to ensure that the employees are familiar with these procedures. The following information is in THE DEALER’s emergency preparedness plan.

Site Map A site map is posted by THE DEALER at key exit locations such as in or near the first aid room and any other location that workers and customers meet.

Evacuation Procedure and Drills THE DEALER has an evacuation procedure. The supervisor orients his or her workers to the procedure. The evacuation plan shows the routes to the muster station. Fire and Emergency Plan Drills are recommended as maintenance of all emergency equipment (exits, signage, fire suppression, alarm, lighting ), is required annually.

Location of Emergency Equipment and Exits Employees know where the closest fire alarm pull station and fire extinguisher are in their work area.

Workers Compensation Board (WCB) The WCB forms are required when there is a workplace injury or occupational disease.

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Occupational Health and Safety Program First Aid Attendants First Aid Attendants may not provide any medication. The only medicated treatment they provide is using saline solution, alcohol wipes and BZK (antiseptic) wipes or solution.

Training Emergency preparedness training consists of: 1. Orient all employees to the emergency protocols.

2. Drills.

3. Occupational First Aid training for assigned employees.

Forms The supplementary instruction associated to this section contains the required forms.

1. Evacuation Summary Report.

2. First Aid Risk Assessment.

3. Emergency Site Information.

4. Employee First Aid Report.

5. Customer First Aid Report.

6. First Aid Attendant Requirement.

7. First Aid Attendants contact information.

8. Employer’s Report of Injury or Occupational Disease.

9. Occupational First Aid Patient Assessment.

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3.5 Joint Health and Safety Committee (JHSC) Purpose THE DEALER is committed to ensuring employees work in an environment where safety is a primary consideration. One way of achieving this goal is through its Joint Health and Safety Committee.

The Joint Health & Safety Committee is composed of employer and employee representatives who work together in a collaborative environment to achieve THE DEALER’s goal of ensuring employees and contractors ‘do the job right’ by a proactive approach to health, safety and security.

Definitions Recommendation to Employer A recommendation is completed by the co-chairs once a majority vote is reached. It is a formal recommendation that the employer is obligated to respond to within 21 days in writing.

Informal Recommendation An informal recommendation is completed during the committee meeting and sent with the minutes to the responsible manager or supervisor.

Joint Health & Safety Committee A JHSC is composed of employer and employee representatives. The committee meets monthly and more often if needed to ensure the worksite remains safe.

Responsibilities Refer to Section 2.2.

Procedural Information The Joint Health & Safety Committee is composed of employer and employee representatives who work together in a collaborative environment to achieve THE DEALER’s goal of ensuring their employees and contractors ‘do the job right’ by a proactive approach to health, safety and security.

The Joint Health & Safety Committee acts as a facilitator to: ▪ ▪ ▪ ▪

Promote safe work practices by following all company rules and policies.

Consider and expeditiously deal with complaints relating to the health and safety of workers.

Assist in developing and applying Safe Work Rules and Procedures.

Make recommendations to the employer and the workers for the improvement of the occupational health and safety and occupational environment of workers.

▪ Make recommendations to the employer on educational programs promoting the health and safety of workers and compliance with the OHS provisions and the regulations and to monitor their effectiveness.

▪ Advise the employer on programs and policies required under the regulations for the workplace and to monitor their effectiveness.

▪ Advise the employer on proposed changes to the workplace, including significant proposed changes to equipment and machinery, or the work processes that may affect the health or safety of workers.

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Occupational Health and Safety Program ▪ Ensure that accident investigations and regular inspections are carried out as required by the OHS provisions and the regulations.

▪ Participate in identifying situations that may be unhealthy or unsafe for workers and advise on effective systems for responding to those situations.

▪ Communicate health and safety information to employees and management by consulting with workers and the employer on issues related to occupational health and safety and occupational environment.

The Committee uses the WCA and BC OHSR as the framework for its roles and functions, and specifies their application in the Rules of Procedure.

Rules of Procedure The Rules of Procedure are a constitution for the JHSC. The Rules of Procedure are developed by the elected employer and worker representatives in their first meeting. The Rules of Procedure are then ratified by a unanimous vote by the JHSC quorum. The Rules of Procedure must include: • • • • • • • • •

The names of the Health and Safety Committee members.

A statement of committee purpose.

A statement of committee duties and functions.

Composition (Co-Chairs, members, alternates).

The scope of representation (trades, departments, sub-contractors etc.).

Terms of Office (how long until membership expires).

Meeting requirements (frequency, quorum, special meetings.).

Procedures (agendas, meeting reports, elections, recommendations, resolving disagreements).

Amendments.

(SEE: WCA, Part 2, Division 5, Sections 31 to 44) Annual Evaluation The JHSC must ensure that an annual evaluation of the JHSC is completed. This can be done by designated JHSC members, a non JHSC member, or by a third party service provider.

Training In accordance with the WCA and BC OHSR, every worker and employer representative on the JHSC must receive eight hours of instruction and training. These eight hours do not replace the representative’s right to eight hours of annual educational leave unless those representatives have already received equivalent training and are opting to repeat it.

The eight hours of instruction for representatives must be completed as soon as reasonably practicable, but no longer than six months into a representative’s term with the JHSC.

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Occupational Health and Safety Program Joint Committee training consists of: 1. Regulation requirements for JHSC’s members.

2. Duties and functions of each type of member and the committee as a whole.

3. Meeting criteria and conducting a meeting.

4. Incident investigation (Refer to Section 4.2).

5. Inspection (Refer to Section 4.1).

6. Hazard management (Refer to Section 2.2).

7. The Refusal of Unsafe Work.

8. Requirements for an annual evaluation of the JHSC.

Forms The supplementary instruction associated to this section contains the required forms.

1. Joint Health & Safety Committee Meeting Minutes.

2. Joint Health & Safety Committee Members.

3. Joint Health & Safety Annual Evaluation.

4. Joint Health & Safety Committee Recommendation Form.

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3.6 Hazardous Materials and Environmental Control Purpose There are several federal legislations for hazardous materials in the workplace: Workplace Hazardous Materials Information System (WHMIS), Transportation of Dangerous Goods (TDG) and Environment Canada (waste management and pollution prevention).

THE DEALER uses hazardous materials (hazardous products). A WHMIS Program is implemented to ensure all workers and supervisors know how to safely work with and around the hazardous materials.

A Transportation of Dangerous Goods (TDG) Program is required if THE DEALER employees transport hazardous materials in the amounts specified under the Transportation of Dangerous Goods Act and Regulations. The program may also be required if THE DEALER ships hazardous materials from the worksite or receives a shipment of Dangerous Goods.

If THE DEALER uses hazardous products, a waste management and pollution prevention program is developed to ensure it remains in compliance.

Definitions Hazardous Products Any hazardous product covered by WHMIS, TDG Legislation (TDG Act or Regulations) or Hazardous Products Act. The hazardous product is purchased from a supplier.

Consumer Product A hazardous product is purchased from a retail store. It does not require an SDS or a supplier label; however, the store may provide a SDS on request.

Hazardous Materials Defined as hazardous products under the Hazardous Products Act. SDS A Safety Data Sheet (SDS) contains important safety information about the hazardous substance.

Information includes what is in the substance, first aid measures, PPE, and what to do in an emergency.

Pollution Prevention Resources for Automotive Industry Pollution Prevention for the Automotive Maintenance and Repair Industry https://www.canada.ca/en/environment-climatechange/services/pollution-prevention/resources/user-guide/guidancespecific-audiences.html http://www.sbeap.org Supplier Label A label provided by the supplier for all hazardous products.

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Occupational Health and Safety Program It must have three distinctive things to identify that the product is a controlled product: hatch mark border, bilingual (English and French) and needs to include: a reference to the SDS. • Product identifier – the brand name, chemical name, common name, generic name, or trade name of the hazardous product.

• Initial supplier identifier – the name, address, and telephone number of either the Canadian manufacturer or the Canadian importer.

• Pictogram(s) – hazard symbol within a red "square set on one of its points".

• Signal word – a word used to alert the reader to a potential hazard and to indicate the severity of the hazard.

• Hazard statement(s) – standardized phrases which describe the nature of the hazard posed by a hazardous product.

• Precautionary statement(s) – standardized phrases that describe measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous product or resulting from improper handling or storage of a hazardous product.

• Supplemental label information – some supplemental label information is required based on the classification of the product. Labels may also include supplementary information about precautionary actions, hazards not yet included, physical state, or route of exposure.

Transportation of Dangerous Goods (TDG) - General Prohibition in the Act 1992 No person should import, offer for transport, handle, or transport any dangerous goods. Guidelines in the TDG legislation for transporting dangerous goods must be followed.

Workplace Hazardous Materials Information System (WHMIS) WHMIS is a program that deals with hazardous substances (hazardous products) in the workplace. Its goal is to protect workers who use, handle, transport and/or store hazardous products.

Workplace Label A workplace label is used when a hazardous product is placed into a smaller workplace container or when the supplier label is unreadable.

Responsibilities Supervisors: 1. Instruct employees in the Safe Work procedures when working with hazardous materials.

2. Ensure WHMIS information is available to employees.

3. Ensure all hazardous products entering the worksite have proper labels and up to date SDS. 4. Ensure effective control measures are in place to protect the health and safety of workers.

5. Provide THE DEALER with a copy of all SDS. 6. If required, ensure employees are TDG Certified when transporting hazardous products.

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Occupational Health and Safety Program Employees: • • • •

Use and store the hazardous products according to the manufacturer’s and supplier’s instructions and THE DEALER Safe Work Procedures.

Participate in WHMIS and chemical safety training programs.

Take necessary steps to protect themselves and others.

Participate in identifying and controlling hazards.

Procedural Information Exposure Control Hazard Assessments and Safe Work Procedures Before a hazardous product is used or is produced due to a work process, the supervisor ensures that the manufacturer’s instructions are understood by the workers and Safe Work procedures are established.

Exposure Monitoring When a risk assessment determines that employees may be exposed to a concentration of hazardous product that exceeds WorkSafeBC occupational exposure limits, exposure monitoring is done to ensure that control measures are adequate.

Workplace Hazardous Material Information System (WHMIS) WHMIS is a program that deals with hazardous products in the workplace. There are three parts in the program: Safety Data Sheets, labels and worker education and training. Refer to Supplementary Instruction 6.7 for additional information.

Spill Procedures THE DEALER follows the Environment Canada legislation if spill procedures are required when THE DEALER has hazardous materials that may spill. The service areas and body shops contain hazardous materials such as paints, epoxies, solvents, lubricants, used oil, oil rags, absorbent used etc. THE DEALER has written spill procedures and spill cabinets in strategic locations throughout the service area or body shop. There should be mention of spill prevention including secondary containment measures, for example a breach in a container that leaks or spills.

Hazardous Waste If THE DEALER has a body shop and service area, an underground hazardous waste holding tank is placed below the work areas, with strategically placed drains throughout. THE DEALER has an external waste disposal company disposing of the contaminants. The procedures follow the legislative requirements found in the Provincial Waste legislation.

Preventative Maintenance Equipment maintenance schedules are required for for repair, lock out tag out programs etc.

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Training WHMIS Education and Training consists of: 1. WHMIS education consisting of: • elements of the WHMIS program, • major hazards of the hazardous products in use in the workplace, • rights and responsibilities of employers and workers; and, • content required on labels and SDSs, and the significance of this information.

2. All hazard information received from the supplier concerning that hazardous product as well as any further hazard information of which the employer is aware or reasonably ought to be aware concerning the use, storage, and handling of that hazardous product.

3. When a hazardous product is produced in the workplace, workers who work with or in proximity to the hazardous product or may be exposed to the hazardous product will be educated in the hazard information concerning the use, storage and handling of that hazardous product.

4. WHMIS Training consisting of: • • • •

the content required on a supplier label and workplace label, and the purpose and significance of the information contained on those labels. the content required on an SDS and the purpose and significance of the information contained on the SDS. procedures for the safe use, storage, handling, and disposal of the hazardous product. procedures to be followed in case of an emergency involving the hazardous product.

Forms The supplementary instruction associated to this section contains the required forms.

1. Spill Procedure.

2. Hazardous Product Inventory.

3. Workplace Label Sample.

4. Working Alone Hazard Assessment and procedures : Visit the BC’s Government’s resource page on how to conduct a risk assessment for working alone – click here For dealerships that require assistance with the working alone process, DealerPILOT HR provides guidance on this, and other compliance issues to their subscribers.

Contact DealerPILOT HR Sandra Conrad, CPHR,SHRM-SCP, BA, ABCP HR Lead and CSR C: (204) 291 9945 / Toll Free: (866) 806-7315 www.dealerpilothr.com

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3.7 Violence in the Workplace and Working Alone Purpose THE DEALER recognizes the potential for violent acts or threats directed against employees by the public or customers. THE DEALER does not tolerate any form of threat, whether verbal or physical, towards any DEALER employee. Disciplinary actions will occur if the source of the threat is a DEALER employee.

Definitions Violence The attempted or actual physical act by a person that causes injury to a worker. Violence also includes threatening statement or behaviour which gives a worker cause to believe that he or she is at risk of injury.

Working Alone Working in circumstances where assistance would not be readily available to the worker.

Responsibilities Refer to Section 2.1 and 3.1.

Procedural Information On rare occasions, an employee may work alone either early in the morning or in the evening.

Refer to Supplementary Instructions 6.8 for Procedural Information.

Training Preventing Workplace Violence training contains: 1. Legislative requirements.

2. Informing workers who may be exposed to the risk of violence of the nature and extent of the risk and risk assessment process.

3. Instruction in: a) the means for recognition of the potential for violence, (b) the procedures, policies and work environment arrangements which have been developed to minimize or effectively control the risk to workers from violence, (c) the appropriate response to incidents of violence, including how to obtain assistance, and (d) procedures for reporting, investigating and documenting incidents of violence

Forms The following form is used to meet the requirements of this section.

1. Risk Assessment – Violence in the Workplace and Working Alone.

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3.8 Bullying and Harassment Purpose DEALER recognizes the potential for violent acts, threats, bullying and/or harassment directed against employees by coworkers and customers. DEALER does not tolerate any form of threat, whether verbal or physical, towards any DEALER employee.

DEALER is committed to building and preserving a safe and healthy work environment for its workers, management team and customers. In pursuit of this goal, DEALER strictly prohibits any act or behaviour that is discriminatory, harassing or violent. DEALER will take every reasonable precaution and implement measures to protect all workers from potentially violent and/or harassing situations that are at THE DEALER’s workplace.

This policy is not intended to restrict the duties and responsibilities of management and/or supervisory staff that fulfill their duties using counselling, performance appraisals, assignment of duties and work, or the implementation of appropriate disciplinary actions. These processes are not defined as forms of harassment, bullying or violence and are necessary functions of the organization.

Definitions For the purposes of clarity, some prohibited behaviours are defined below. However, other Canadian legal definitions of prohibited behaviour (such as those in the BC Human Rights Legislation) are also recognized in this policy. Any behaviour suspected to meet any of these definitions will be investigated and dealt with accordingly.

Prohibited behaviours include, but are not limited to: A. Discrimination is defined as the unjust or prejudicial treatment of different categories of people. The British Columbia Human Rights Code details the following categories as unjust grounds for differential treatment: i. Race ii. Colour iii. Ancestry iv. Place of Origin v. Political Belief vi. Religion vii. Marital Status viii. Family Status ix. Physical or Mental Disability x. Sex xi. Sexual Orientation xii. Age xiii. Conviction of a criminal or summary conviction offence that is unrelated to the employment or to the intended employment of that person (Queen's Printer, Victoria, BC, Canada, 2011).

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Occupational Health and Safety Program B.

Personal Harassment or Bullying is conduct that is reasonably known to be unjust or unwelcome. It can be in the form of behaviours, words, or actions and can consist of a single incident or several incidents over a period of time. WorkSafeBC considers bullying or harassment significant when it exceeds the intensity and/or duration expected from the normal pressures or tensions of the worker's workplace.

C.

Workplace Violence is defined by the WCA as the attempted or actual exercise of any physical force intended to cause injury by a person other than a worker towards a worker. This includes any statement or behaviour that gives the worker reason to believe he or she is at a risk of injury. Specific examples of violence include: i. Sexual, emotional, financial or psychological threats, ii. Destruction of property, iii. Shoving or aggressive confrontation, etc.

D. Discriminatory Action is any act or omission by an employer or union, or a person acting on behalf of an employer or union, that adversely affects a worker with respect to any term or condition of employment, or of a membership in a union. Discriminatory action includes: i. Suspension, lay-off or dismissal, ii. demotion or loss of opportunity for promotion, iii. transfer of duties, change of location of workplace, reduction in wages or change in working hours, iv. coercion or intimidation, v. imposition of any discipline, reprimand or other penalty, and the discontinuation or elimination of the job of the worker.

•

Complainant: Any employee that reports an incident of prohibited behaviour in the workplace.

•

Respondent: The person(s) identified by the complainant as being the instigator, or accomplice to the instigation, of prohibited behaviour.

•

Investigator: The person(s) designated by DEALER to conduct an investigation into the complainant’s report.

Responsibilities Worker Every DEALER worker is responsible for: • Not engaging in, or escalating moments of, prohibited behaviour.

• For reporting incidents of prohibited behaviour and cooperating with investigations into prohibited behaviour.

• Complying with DEALER’s policies on prohibited behaviours.

• Assisting in the elimination and prevention of discrimination, harassment, bullying, workplace violence and acts of retaliation in the workplace.

• Promptly reporting all acts of discrimination, harassment, bullying, workplace violence and retaliation that threaten, or are perceived to threaten, a healthy and safe work environment.

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Supervisors and Managers DEALER and its leadership are legally responsible for: • • •

• • •

Creating and maintaining a workplace free from improper conduct or prohibited behaviour (See: WCA, Part 2, Sections 21-23, and Policy Item P2-21-2, P2-22-2 and P2-23-2).

Taking steps to prevent where possible, or otherwise minimize, workplace bullying and harassment, violence, discrimination, and acts of retaliation.

Developing and maintaining policies and procedures for workers to report incidents or complaints including how, when and to whom a worker should report incidents or complaints. Included must be procedures for a worker to report if the employer, supervisor, or person acting on behalf of the employer, is the alleged bully and harasser.

Maintaining this policy (including its provisions for investigation).

Ensuring all appropriate records are maintained.

Developing and implementing procedures for how the employer will deal with incidents or complaints including: • how and when investigations will be conducted; • what will be included in the investigation; • roles and responsibilities of employers, supervisors, workers and others; • follow-up to the investigation (description of corrective actions, timeframe, dealing with adverse symptoms, etc.); and, • record keeping requirements; • Informing workers of the policy statements and policies.

• Training supervisors and workers on: • recognizing the potential for bullying and harassment; • responding to bullying and harassment; and, • procedures for reporting, and how the employer will deal with incidents or complaints of bullying and harassment in (c) and (d) respectively.

Procedural Information Refer to Supplementary Instructions 6.9 for Procedural Information.

Forms The supplementary instruction associated to this section contains the required forms.

1. Procedures for Investigating Bullying and Harassment.

2. Workplace Misconduct Report.

3. Workplace Misconduct Witness Statement.

4. Workplace Misconduct investigation Summary.

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3.9 Ergonomics (MSI) Purpose Ergonomics is the science of adapting work processes and conditions to fit the physical capabilities of workers. THE DEALER’s goal is to minimize the incidents of musculoskeletal injuries (MSI) by incorporating ergonomic principles, where practicable, in all of its work tasks.

Definitions Ergonomics Ergonomics reduces the incidence of musculoskeletal injuries (MSI) by minimizing or eliminating MSI risk factors. It fits products, tasks, and environments to people.

Musculoskeletal Injuries (MSI) MSI are injuries of the soft tissues (muscles, joints, tendons, ligaments, and cartilage) and nervous system. The most common examples are repetitive strain injuries such as tendonitis and carpal tunnel syndrome, and back injuries.

Repetitive Strain Injuries (RSIs) When there are many repetitions of the same movement, there is a greater degree of risk to soft tissues such as muscles, ligaments and tendons around the joint. Other risk factors such as force, posture, duration, and recovery time also contribute to RSIs.

Responsibilities Refer to Section 2.1.

Supervisors: 1. Identify risk factors that may contribute to musculoskeletal injuries.

2. Consider ergonomic principles when reviewing proposed work processes, equipment and tools.

3. Eliminate or, if not practicable, minimize the risk of injury to workers.

4. Perform risk assessments on work tasks, equipment and tools.

5. Train workers in the use of equipment, tools and work procedures that minimize their exposure to injury.

6. Train workers to recognize early MSI signs and symptoms and to report them to their supervisor and first aid attendant.

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Occupational Health and Safety Program Employees: 1. Recognize MSI signs and symptoms and report them.

2. Identify risk factors that may contribute to MSI. 3.

Understand basic ergonomic factors.

Procedural Information An MSI Risk Assessment is similar to a risk assessment performed for other forms of hazards. (Refer to Section 2.2 and 3.2).

Supervisors continuously monitor the effectiveness of the control measures in place to minimize MSI.

Training Ergonomic training consists of hazard identification (Refer to Section 2.2) and the following topics: 1. Legislative requirements.

2. Education in risk identification related to the work, including the recognition of early signs and symptoms of MSIs and their potential health effects.

3. Training in the specific measures to control the risk of MSI, including training in the use of those measures, including, where applicable, work procedures, mechanical aids and personal protective equipment.

Forms The supplementary instruction associated to this section contains the required forms.

1. General Ergonomic Assessment Form.

2. Ergonomic Assessment – Office.

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3.10 Disability Case Management (Gradual Return to Work Program)

Purpose Disability Case Management is a collaborative team process that links THE DEALER’s supervisor with the injured or ill worker, insurance companies (includes WCB but may be used for other health insurance providers) and health service providers to prevent disability or to minimize its impact through early intervention, support and resource coordination. It optimizes recovery and facilitates prompt return to work in a proactive approach.

Definitions Alternative Work Alternative work is a permanent placement offered to recovering employees, or those with diminished capacity, when it is medically determined that the employee will not return to their own position or occupation.

Bona Fide Occupational Requirement (BFOR) A BFOR is needed to adequately perform the work safely and economically and not for reasons that go against the HR Act. It is a necessary requirement of the job to ensure that the worker, coworkers and general public are not endangered.

Collaborative Team Process Collaborative team process requires a multidisciplinary approach where many stakeholders (i.e. supervisor, worker, health care provider, insurance provider and health & safety Manager) work together for a common outcome (the successful return of an injured worker to work).

Disability Disability is any restriction or lack (resulting from an impairment) of ability to perform an activity in the manner or within the range considered normal for a person.

Duty to Accommodate An employer has the legal obligation to thoroughly investigate all possibilities of accommodating an injured or ill worker back into his or her pre-injury job or another assigned job, up to the point of undue hardships. However, an employer has a right to operate and organize its operations in an efficient manner.

Gradual Return to Work (GRTW) Program Gradual return to work is gradually reintegrating an injured or ill worker back into his/her normal work tasks.

Health Service Providers Health service providers include medical physicians, physiotherapists, massage therapists and other recognized providers.

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Occupational Health and Safety Program Impairment Impairment is any loss or abnormality of psychological, physiological or anatomical structure or function.

Modified Work Modified work is the change of work duties or time to accommodate a worker currently off work due to illness or injury. It is interim work offered to an ill or injured employee who is experiencing a diminished capacity when it is medically foreseen that the employee will return to his or her own occupation.

Responsibilities Senior Managers: 1. Review annually the effectiveness of the Disability Case Management (DCM) Program.

2. Ensure that an employee is accommodated or re-employed. The employer will make effort to place employees in suitable, alternative positions.

3. Hold any personal information received from or about the employee in the strictest confidence.

4. Ensure resources are made available to provide gradual and consistent rehabilitation to all employees.

Supervisors: 1. Act as coordinators in implementing and evaluating the DCM Program.

2. Act as facilitators to assist their employees to return to full duties injury free.

3. Keep informed of the employee’s progress, support the employee during their return to work and encourage the employee to return to regular work as soon as they are able.

4. Monitor the employees’ progress by maintaining regular contact with the employee and by meeting with them on the frequency dictated by the employees individual plan.

5. Hold any personal information received from or about the employee in the strictest confidence.

Employees: 1. Report any injury or illness to your Supervisor immediately. Report the injury and seek medical help from the First Aid Attendant.

2. Participate in the DCM Program as instructed by their physician or insurance carrier.

3. Only perform the assigned tasks that are allowed within the limits of your physical ability.

4. Play an active role in the decision-making process for their successful early return to work.

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Procedural Information The Disability Case Management (DCM) Program applies to any employee who is off work due to injury or illness. It is a joint effort between the employee, supervisor and the insurance carrier.

The cause of the disability may be work or non work-related. If it is work-related, WCB is involved in the GRTW process. If the cause is not work related, the attending physician and insurance carrier participate in the GRTW process.

Training Disability case management training consists of: 1. Legislative requirements.

2. Roles for all levels of employees (including Senior Managers).

3. Procedure for initiating and implementing a GRTW Program.

4. Documentation.

Forms The supplementary instruction associated to this section contains the required forms.

1. Employee Letter.

2. Physician Letter.

3. Physical Assessment Form.

4. Gradual Return to Work Program Form – Outline for supervisor.

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3.11 Documentation (Records and Statistics) Purpose Documents, records, and statistics are compiled and maintained to validate how effective the Occupational Health and Safety Program is in ensuring THE DEALER’s employees are working in a safe and healthy environment.

Definitions None for this section.

Responsibilities Senior Managers: 1. Review on a regular basis all training documents and statistics related to the Occupational Health and Safety Program to identify trends and elements that need improvement. Included in this is the maintenance of records and statistics, including reports of inspections and incident investigations, with provision for making this information available to members of the JHSC. Supervisors: 1. Develop and maintain documents and statistics required to show their due diligence.

2. Provide reports to the Senior Managers, employees and safety representative.

3. Identify trends and areas that need attention.

Procedural Information Maintenance of Records The following records are maintained to ensure due diligence is demonstrated. This is not an all inclusive list. Each program section has examples of the applicable records. Records are to be maintained for a period of not less than 10 years and for length of employment for all worker related orientations and training records.

1. Education and training.

2. Management meeting minutes.

3. Contractor records.

4. Inspections.

5. Maintenance and repair records of equipment and machinery.

6. Incident investigations.

7. First aid records and statistics.

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Occupational Health and Safety Program 8. Worker exposure air monitoring results.

9. Risk assessments.

10. WHMIS Safety Data Sheets and workplace labels.

11. WorkSafeBC Inspection Reports.

12. Hazard Management Reports.

13. Emergency Response Plan.

Statistics Statistics are maintained for identifying incident trends, total time loss and claims cost for each type of injury.

Records and statistics are used to develop strategies for the prevention of injuries and disease in the workplace.

Training There is no training for this section.

Forms There are no forms for this section.

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4 EVALUATION 4.1 Workplace Inspections Purpose

The goal of workplace inspections is to identify unsafe work conditions and practices before an incident occurs. Any hazards discovered during an inspection are corrected in a timely manner.

Equipment and tools have in a preventative maintenance program to ensure they remain in good working order. Regular inspections are required to be made of all workplaces, including buildings, structures, grounds, pits, tools, equipment, machinery and work methods and practices, at intervals that will prevent the development of unsafe working conditions.

Definitions Hazard A thing or condition that may expose a person to a risk of injury or occupational disease.

Inspections Inspections evaluate the workplace elements - the environment, the equipment and the process. The environment includes such hazards as noise, vibration, lighting, temperature, and ventilation.

Equipment includes materials, tools and equipment. This includes work methods and practices.

Responsibilities Refer to Section 2.1 and 3.7.

Managers: 1. Whenever possible, be involved in the inspection process.

2. Be aware of the conditions that exist in the workplace and the various procedures necessary to carry out the work process.

3. Review inspection reports and ensure that proper action is taken to correct any hazards that are reported.

Supervisors: 1. Continuously monitor and inspect the work environment and employees’ work practices to ensure hazards do not develop.

2. Ensure informal, site, special and preventative maintenance inspections are completed and documented when required.

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Occupational Health and Safety Program 3. Ensure preventative maintenance inspections are completed on machinery and equipment.

4. Correct unsafe conditions and work practices in a timely manner.

Employees: 1. Perform a pre-shift inspection of tools, machinery and equipment.

2. Take action to correct hazardous situations or report the situation to a supervisor.

3. Participate in inspections when requested by a supervisor or JHSC.

Procedural Information Types of Workplace Inspections There are four types of workplace inspections. The type and frequency of an inspection is determined by the risks that workers are exposed to.

1. Regular workplace inspections.

2. Non-regular (informal) inspections.

3. Special inspections.

4. Preventative maintenance – e.g. Pre/post operational inspection.

Training Inspections will be done by employees who are familiar with the work process and the areas they are inspecting. Site inspection training consists of: 1. Legislative requirements.

2. Roles and responsibilities.

3. How to perform the different types of inspections.

4. How to identify hazards.

5. Writing the report.

6. Report distribution.

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Forms The supplementary instruction associated to this section contains the required forms.

1.

Inspection Checklist.

2.

Inspection Guidelines.

3.

Inspection Hazard Rating.

4.

Inspection form.

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4.2 Incident Investigation Purpose All incidents that cause injury (or illness) or have the potential to cause injury (or illness) are investigated to identify the root and basic causes. Recommendations are implemented as soon as possible to reduce the risk of injury to other workers or other losses.

Definitions Incident The term incident can be defined as an occurrence, condition, or situation arising in the course of work that resulted in or could have resulted in injuries, illnesses, damage to health, or fatalities.

Accident An accident can be defined as an unplanned event that interrupts the completion of an activity, and that may (or may not) include injury or property damage.

Medical Aid Injury An injured employee is sent to a medical facility to be assessed by a medical doctor.

Near Miss An event that could have resulted in a loss. It could become an incident with loss if the causes are not addressed.

Root Cause Answers the question – Why did the incident occur? It considers that there are many causes, direct and underlying, for the incident and each one needs to be investigated.

Time Loss Injury An employee has a work-related injury and is required to take time off work to recover from his injury, not including time missed on the date/shift of the injury.

Responsibilities Refer to Section 2.1 and 4.3 Investigating Team An employer and a worker representative must participate, if they are available. The investigating team is responsible for: • Being knowledgeable about the type of work involved at the time of the incident; • Following DEALER’s investigation procedures; • Ensuring all legislative requirements for reporting and investigation are completed; • Filing an Incident Investigation Report to all relevant people; • Participating in Incident investigation training offered by the employer; and, • WorkSafeBC requires that a preliminary investigation, interim corrective actions report, full investigation report and a full corrective action report are performed.

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Occupational Health and Safety Program Employer The employer is responsible for: • • • • • • • •

Ensuring that no one disturbs or manipulates the scene of an incident, when required.

Providing any necessary incident investigation training.

Ensuring all legislative requirements for reporting and investigation are completed.

Providing any resources required by the investigating team to complete a proper investigation.

Cooperating with the investigation process.

Ensuring that a Preliminary Incident Investigation Report is completed within 48 hours of the incident.

Ensuring that a Full Employer Incident Investigation Report is completed and submitted to WorkSafeBC within 30 days of the incident.

Ensuring all recommended corrective/follow-up actions are completed and recorded.

Supervisor The supervisor is responsible for: • Not disturbing or manipulating the scene of an accident.

• Ensuring all legislative requirements for reporting and investigation are completed.

• Cooperating with the investigation process.

• Ensuring all recommended corrective/follow-up actions they are given responsibility for are completed and recorded.

Worker The worker is responsible for: • Not disturbing or manipulating the scene of an accident.

• Cooperating with the investigation process.

• Ensuring all recommended corrective/follow-up actions they are given responsibility for are completed and recorded.

Procedural Information Types of Incidents The following types of incidents require a Preliminary Investigation to be completed within 48 hours of the incident and a Full Employer Incident Investigation is completed and reported to WorkSafeBC within 30 days of the following incidents: ▪ Those that resulted in injury to a worker requiring medical treatment.

▪ Those that did not involve injury to a worker, or involved only minor injury not requiring medical treatment, but had a potential for causing serious injury to a worker.

▪ Serious incidents (see below).

Serious Incidents 1. DEALER must report all time-loss injury injuries to WCB within 72 hours. DEALER satisfies this requirement by filing an “Employer’s Report of Injury or Occupational illness – Form 7”. This form is available online at: • http://www.worksafebc.com/forms/assets/PDF/7.pdf

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Occupational Health and Safety Program 2. It also a legal requirement that certain incidents, regardless of injuries, are immediately reported to WorkSafeBC. These include incidents that: • Resulted in serious injury or death.

• Involved a major structural failure or collapse of a building, bridge, tower, crane, hoist, temporary construction support system or excavation.

• Involved the major release of a hazardous substance.

• Involved a fire or explosion that had a potential for causing serious injury to a worker.

• Were otherwise required by regulation to be reported.

(SEE: WCA Part 2, Division 10, Section 68) NOTE: “Immediately” alerting WorkSafeBC of an incident should not intrude on the care for the injured, but otherwise must be done without any delay.

Provincial Workers’ Compensation Board Phone Numbers ▪ British Columbia

Workers Compensation Board WorkSafeBC

1.888.967.5377 1.888.621.7233

▪ DEALER’s Senior Managers Contact Information: ▪ Fatalities - notify the local Police Department: Other Incidents that must be investigated The following incidents require an investigation: Property damage or loss ▪ Property damage or loss exceeding $500; and, ▪ Any damage to a licensed company vehicle.

An Equipment Loss/Damage Report is completed and the incident is reported to THE DEALER’s Senior Managers.

Incidents involving the public ▪ Any damage to public or private property; and, ▪ Any injury involving the public.

The incident is documented on the Incident Investigation Report and reported to THE DEALER’s Senior Managers.

WCB Forms Refer to Section 3.4 regarding WCB Forms.

Investigation Team The supervisor responsible for the injured worker chooses one worker representative (if the injured worker is unable to be involved) to take part in the investigation. At least one investigator is to be knowledgeable about the type of work involved at the time of the incident.

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Occupational Health and Safety Program Investigation Reports Preliminary Investigation, Report, and Interim Corrective Actions Report The purpose of a preliminary investigation is to outline the facts of the incident, including the names of injured workers and witnesses and also to describe the sequence of events leading up to the incident and what happened when the incident occurred. The unsafe conditions or acts that significantly contributed to the incident will be identified and a list of the recommended corrective actions will be made. An Interim corrective actions report should also be completed after the preliminary investigation is done or at the same time. The interim corrective actions report should address the findings of your preliminary investigation and describe the recommended steps taken to prevent similar incidents.

A preliminary investigation is not required to be submitted to WCB. However, it must be available upon request by WorkSafeBC. Thus, a preliminary investigation must: • • • • •

Be completed within 48 hours of the incident.

Identify any obvious unsafe conditions, acts, or procedures that contributed to the incident.

Produce a corrective action report that identifies any corrective actions that can be undertaken in the short term.

Produce a report of all the corrective actions that were taken.

Distribute the corrective action reports to the management team and post in the workplace.

Full Investigation, Report, and Follow-up Action The full procedure for conducting the investigation, and appropriate follow-up, is detailed in the sections below. However, a full report must be completed and submitted to WorkSafeBC within 30 days of the incident.

Requests for extensions are possible but must be made prior to the 30-day deadline and are only granted at the discretion of WorkSafeBC. All investigations are documented on the Incident Investigation Report. Additional information (including information that will not fit on the form, photos, drawings, etc.) are attached to the form. It is completed by the supervisor of the injured worker and signed off by the worker (or worker rep).

Incident Statistics Incident statistics are summarized in a monthly report by THE DEALER’s Senior Managers. The number of incidents, number of lost days, causes of incidents and type of injuries and number of investigations are included in the report.

Involvement of the JHSC An incident investigation must involve at least one elected worker and employer representative from THE DEALER’s JHSC. These representatives must be alerted of the incident without delay and make every effort to reach the scene quickly. These representatives must partake in both the Preliminary Investigation and the Full Investigation. Their role in this investigation can include: • • • • •

Viewing the scene of the incident with the lead investigators.

Advising on the methods or scope of the investigation.

Assisting in gathering information where trained.

Analyzing the information gathered.

Develop corrective actions in cooperation with the investigator.

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Occupational Health and Safety Program

Training Incident Investigation training consists of: 1. Legislative requirements.

2. Roles and responsibilities.

3. Conducting an investigation, including how to: •

gather information

•

interview

•

collecting samples

•

analyzing information

•

identifying contributing factors

•

Identifying immediate, direct causes and associated underlying causes

•

developing recommendations

4. Writing the report.

5. Report distribution.

Forms The supplementary instruction associated to this section contains the required forms.

1. Incident Investigation & Preliminary Report Form Guide.

2. Incident Investigation & Preliminary Report Form.

3. Injury reporting.

4. Investigation & Interview process.

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4.3 Health Monitoring Purpose The purpose of health monitoring is to protect workers from developing occupational disease by detecting biological indicators or adverse health effects at an early stage. Action can then be taken to prevent, reverse, reduce the severity, or arrest the progression of the adverse health effect or disease. Biological Action Values (BAV) for biological indicators are established by WorkSafeBC.

Definitions Noise Exposure Limits An employer must ensure that a worker is not exposed to noise levels above either of the following exposure limits: (a) 85 dBA daily noise exposure level; or (b) 140 dBA peak sound level.

Occupational Exposure Limit (OEL) This represents the maximum airborne concentration of a toxic substance to which a worker can be exposed over a period of time without suffering any harmful consequences. These limits are set out by many professional organizations around the world, such as the American Conference of Governmental Industrial Hygienists (ACGIH), and the National Institute for Occupational Safety and Health (NIOSH) in the United States and are adopted by WorkSafeBC. Threshold Limit Value - Time Weighted Average (TLV-TWA) The concentration of a hazardous substance in the air averaged over an 8-hour workday and a 40hour workweek to which it is believed that workers may be repeatedly exposed, day after day, for a working lifetime without adverse effects.

Threshold Limit Value - Short Term Exposure Limit (TLV-STEL) A 15-minute time weighted average exposure that should not be exceeded at any time during a workday.

Threshold Limit Value - Ceiling (TLV-C) This is the concentration that should not be exceeded during any part of the working exposure.

Responsibilities Refer to Section 2.1.

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Procedural Information Health Monitoring Health monitoring will be considered when: • • •

there is reasonable likelihood of a workplace exposure, the exposure can potentially cause an occupational disease or adverse health effect, or there is a means of detecting or measuring the disease, adverse health effect or its precursor or biological indicator.

Substances for which WorkSafeBC considers health monitoring may be appropriate include, but are not limited to: lead, cadmium, mercury, respiratory sensitizers (such as cedar dust or isocyanates), 4,4'methylene bis[2-chloroaniline] or MOCA, and organophosphate compounds.

Health Evaluation of Employees Health evaluations of employees are in four categories: 1. Pre-assignment. The health status of new or current employees is determined before recommending work assignments to ensure that workers are capable of performing the job safely and without harming others.

2. Periodic Medical Surveillance. The health status of employees is reviewed periodically to ensure that no work-related illnesses have developed. Reviews are limited to appropriate organ(s) or organ system(s). The frequency of reviews is related to the potential hazard(s).

3. Post-illness or Post-injury Review. The health status of an employee is reviewed after a prolonged illness or injury to ensure that the employee is capable of returning to work safely and that, if necessary, the work assignment can be adjusted until recovery is complete.

4. Termination or Post-employment Exams. The termination exam is not specifically included as an essential component of the Occupational Health and Safety Program however; a record of post employment health status may be required for specific health hazard exposures.

Personal Protective Equipment (PPE) The Occupational Health and Safety Program requires that employees are provided with personal protective equipment and training in its proper use and maintenance. PPE includes earplugs, earmuffs, safety glasses and respirators. (Refer to Section 3.1 Safe Work Rules).

Noise Exposure When noise levels in the workplace exceed 85 dBA daily exposure and 140 dBA peak sound level, THE DEALER implements a Noise Control and Hearing Conservation Program.

Temperature Extremes If workers are required to work in conditions of extreme hot or cold environments, risk assessments are performed and the required protective equipment or procedures are implemented.

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Training Training is required for the fit, limitations, use and care of various types of PPE such as respirators and hearing protection.

Forms The supplementary instruction associated to this section contains the required forms.

1. Respirator User Screening.

2. Fit Test Record.

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4.4 Program Review & Management Meetings 4.4.1 Purpose THE DEALER’s Senior Managers want to ensure the Occupational Health and Safety Program is meeting its goal. They review the program annually to evaluate the program’s safety activities and performance during the previous year and to set objectives for the coming year.

4.4.2 Definitions None for this section.

4.4.3 Responsibilities Senior Managers: 1. Work with a supervisor, worker representative and JHSC to review the Occupational Health and Safety Program.

2. Provide resources to implement the recommendations.

4.4.4 Procedural Information The program review includes: 1. Identifying actual or potential health and safety issues or hazards not addressed or not being resolved in the Occupational Health and Safety Program.

2. Assess the issues and provide recommendations to resolve them.

3. Implement the recommendations.

4. Monitoring activities to ensure the desired results are achieved and sustained.

5. Documenting the effectiveness of the overall program to enhance safety and health in the workplace and prevent injuries and diseases.

Along with an annual review, the Senior Managers and supervisors meet regularly (e.g. bi-monthly or more frequently) to discuss the Occupational Health and Safety Program and any issues that have developed at the work sites.

4.4.5 Training and Forms None at this time.

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5 RESOURCES Provincial Website WorkSafeBC .......................................................................................................... www.worksafebc.com (Regulation and Guidelines, Hazard Alerts) Federal Websites Criminal Code of Canada .................................................. www.ccohs.ca/oshanswers/legisl/billc45.html WHMIS and TDG................................................................................................... https://www.canada.ca/en/employment-social-development/services/healthsafety/prevention/whmis.html Standards Development Organizations Canadian Standards Association ............................................................................................. www.csa.ca Canadian General Standards Board ......................................................................... www.tpsgc-pwgsc.ca Underwriters Laboratories Canada ......................................................................................... www.ulc.ca Industry and Trade Association Codes Canadian Chemical Producers Association Responsible Care ................................................https://canadianchemistry.ca/responsible-care/about-responsible-care/ American Conference of Government Industrial Hygienist ...............................................www.acgih.org BC Employers ......................................................................................................... www.labour.gov.bc.ca BC Workers Advisory ......................................................................................www.labour.gov.bc.ca/wab Canadian Centre for Occupational Health and Safety......................................................... www.ccohs.ca CCAR – Green Link (Virtual Auto Service Shop) .................................................. www.ccar-greenlink.org

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6 SUPPLEMENTARY INSTRUCTIONS 6.1 Supplementary Instruction - Hazard Management Step 1 - Hazard Identification Hazards are identified when: ▪ A job is broken down into its smallest unit (element); or

▪ When a worker or supervisor identifies a real or potential hazard while performing their job task or during an incident investigation or an inspection.

Sources of real or potential hazards are: ▪ Tasks with known or obvious hazards; ▪ Tasks which have potential to cause serious injuries;

▪ Tasks with high incident or injury frequency, work related MSI claims or FA reports;

▪ New tasks with no incident history;

▪ Tasks with new or unsafe equipment;

▪ Unusual tasks and tasks that are performed infrequently; and,

▪ Tasks which are repetitive or routine.

Step 2 - Hazard Assessment A hazard assessment is performed when employees are at risk or have the potential to be at risk.

There are 2 types of hazards in the workplace: Safety Hazards A safety hazard may cause physical injury to the worker and/or property damage (loss). It is a force that originates from an energy source such as: ▪ ▪ ▪ ▪

Thermal (i.e. radiation, UV light, weather) Mechanical (i.e. pinch points, moving parts) Electrical (i.e. static, electrical shorts) Chemical (i.e. reaction causing explosion, acid burn)

Or it may result from unsafe work conditions or movements such as: ▪ Struck by (hit by a moving object)

▪ Struck against (running or bumping into)

▪ Contacted by (chemical, physical or biological hazards) ▪ Caught between (crushed or amputated) ▪ Slip/fall

▪ Fall to a lower level

▪ Overexertion, overstressed, overload of person or equipment

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Occupational Health and Safety Program Health Hazards A health hazard has the potential to cause immediate or long term occupational illness. It is often referred to as an environmental hazard such as: ▪ Chemical hazards (e.g. dusts, fumes, mists, vapours and gases) ▪ Physical hazards (e.g. noise or UV exposure)

▪ Biological hazards (e.g. moulds, fungus, blood or body fluids)

▪ Ergonomic hazards (e.g. poorly designed equipment or work processes)

▪ Psychosocial hazards (e.g. pace of work, workplace violence, or lack of training) The hazard assessment addresses routine work activities and non-routine activities such as those which may lead to an injury or emergency situation.

Step 2.1 - Hazard Assessment – Job Hazard Assessment (JHA) A hazard assessment quantifies the risk and rates the possible recommendations. The Hazard Zone Job’s Checklist can help assess specific work tasks and the frequency they are performed. There are 3 questions to ask: 1. Consequence: What are the most probable results of injury or illness due to the hazard?

2. Exposures: How often are workers exposed to the hazard that could result in the injury or illness?

3. Probability: What is the likelihood the hazard will lead to the most likely injury or illness?

The hazard is rated according to the risk score and is classified as: Type “A” Hazard A condition or work practice where there is a potential of permanent disability, loss of life or significant property or equipment damage. This hazard requires immediate corrective action.

Type “B” Hazard A condition or work practice where there is a potential for causing serious disabling injury or property damage, but it is not a life-threatening hazard. Corrective action should be completed as soon as possible (within 5 to 7 days).

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Occupational Health and Safety Program Type “C” Hazard A condition or work practice that has a risk of minor injury or non-disruptive property damage. One example is an employee not using ergonomic principles when performing a job task. Corrective actions should be completed within a designated period of time (e.g. no more than one month) or a long-term action plan should be developed.

Step 3 – Hazard Controls To ensure the highest level of protection is implemented, a hierarchy of hazard control is used:

Substitution and Engineer Controls: Substitution, followed by engineered controls, are the best types of hazard controls because substitution eliminates the hazard and engineering controls protect the worker from the hazard. There are several types of controls: 1. Substitution of the hazard for a less hazardous task, product or equipment.

2. Containment of the hazard in a room, building, etc.; or 3. Isolation of the hazard such through the use of a barrier.

Administrative Controls: Administrative controls manage work processes and resources such as staffing, rotation of workers, work practices and training. There are several questions to ask when considering administrative controls: 1. Can different work procedures be developed to reduce exposure to the hazard?

2. Can the workplace be reorganized to provide distance between the hazard and the workers?

3. Can work be scheduled to reduce the worker’s exposure (e.g. provide breaks or rotate work assignments)?

4. Can susceptible workers (e.g., to certain chemicals) be transferred to other duties?

5. Can tasks be organized so that two workers do the lifting (instead of one worker) to prevent a physical injury?

Personal Protective Equipment (PPE): PPE is the last recommended hazard control because it does not eliminate the hazard. PPE includes respirators, safety boots and eye protection. As a control option, PPE is used when the other two hazard controls were considered and found to be impracticable or when additional protection is required because engineering or administrative controls are insufficient to reduce exposure below the applicable exposure limits.

PPE is also a practicable control measure during temporary or emergency situations. When PPE is used, training and safe work procedures are needed to ensure the worker can work safely. For example, training in the use of respiratory protection is required before working with sanding equipment.

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Procedure for Reporting Hazards When a hazard is identified by an employee or by a supervisor, the supervisor completes the Hazard Assessment form. The employee participates in the hazard assessment and identifying controls. A member of the JOHSC may assist in the hazard assessment.

Personal Protective Equipment (PPE) If a real or potential hazard cannot be hazardous by engineering and/or administrative controls, PPE is required to minimize the risk exposure. Supervisors ensure that all appropriate PPE is provided to the employees prior to starting the work task. Employees are responsible for wearing and maintaining their PPE according to their training and the manufacturer’s instructions.

All PPE used by THE DEALER’s employees must meet WorkSafe BC’s requirements which may include CSA or NIOSH certification.

Failure to wear the appropriate PPE will result in disciplinary action.

All employees and visitors who walk through the specific work areas that require PPE must wear the appropriate PPE. Training The supervisor is responsible to ensure his employees are trained prior to starting the work task in the: ▪ Use. ▪ Limitations.

▪ Care, inspection and storage.

▪ Replacement procedures of the PPE. All training is documented by the supervisor and a copy of the record is sent to THE DEALER’s Senior Managers.

Safety Footwear Safety footwear is required when there is a real or potential danger for foot injuries. If a DEALER’s employee who normally does not work in the designated areas but is required to enter it, he or she must either wear safety footwear or stay within the safe walking zone. Additionally, customers should not be in the areas designated as requiring safety footwear. If a customer needs to enter the area (e.g. to get his or her vehicle), he or she should be accompanied by THE DEALER’s employee and kept within the safe walking zone.

The following work areas require safety footwear: ▪ Service area.

▪ Body shop.

Reflective Vests Reflective vests are required where there is mobile equipment and vehicle traffic. The following work areas and tasks require reflective vests: (This is not an all inclusive list) ▪ When moving a customer’s vehicle to the service parking lot or to an off premises lot.

▪ In the service parking lot.

▪ When moving a customer’s car into or out of the service area or body shop.

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Occupational Health and Safety Program Respiratory Protection Respiratory protection is required if any airborne contaminants exceed WorkSafeBC occupational exposure limits, when using products that contain isocyanates or if the concentration of oxygen is less than 20.9%.

Such tasks include: ▪ Sanding or grinding.

▪ Where required, applying paint or epoxy if the local ventilation system is not sufficient.

▪ Other work tasks that create a particulate or gas / vapour hazard.

Other PPE Gloves are required when there is a potential or real danger of injury to the hands. Hazards may include chemical, electrical, or mechanical sources.

Eye protection (goggles and impact glasses) is required in areas such as the service area or body shop where there is a projectile or splash hazard.

Hearing protection (ear plugs or earmuffs) is required in designated areas or performing specific work tasks such as grinding, sanding and drilling.

Emergency PPE is tested or inspected monthly. Emergency equipment includes emergency showers, eyewash stations and spill containers. Annual testing and preventative maintenance is completed for fire suppression equipment.

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6.2 Supplementary Instruction - Contractors & Contract Workers Two Types of Contractors There are two types of contractors. They have many similar legal obligations related to maintaining a health and safety work environment. The primary difference is the definition of a direct (hands on) and an indirect (hands off) approach for workers’ health and safety.

THE DEALER as the Primary Contractor THE DEALER has a hands-on approach where it is directly involved in coordinating the work of the contractors. THE DEALER is considered the employer of the contractor and any workers. It is completely responsible for ensuring the health and safety of these workers.

Prime (Qualified) Contractor THE DEALER has a hands-off approach where it contracts away some of its responsibility and potential liability to the primary contractor. The primary contractor has the responsibility for ensuring the legislative provisions are complied with and safe workplace practices are carried out at the worksite. This includes the planning and implementing of work and hiring of sub-contractors. The Prime Contractor has authority to ensure health and safety compliance over THE DEALER’s workers who enter the contractor’s work area.

THE DEALER is not considered an employer of the primary contractor’s workers, however; THE DEALER still practices due diligence by ensuring compliance of WorkSafe legislation.

Process for Contract Management The overall process of contract management is fairly simple because THE DEALER normally has one work site. Most of the contractual work involves the building structure, its interior systems or equipment and machinery in the service area or body shop.

The implementation of the following steps is dependent upon the scope of the proposed work. If it is a small project or preventative maintenance contract, THE DEALER will do an initial risk assessment to determine if a tendering process is required.

If the scope of proposed work is a major structural renovation or construction of a new building, THE DEALER should follow each of the following steps to ensure they meet their due diligence requirements.

Risk Assessment Prior to arranging tenders or awarding a contract, THE DEALER assesses the level of risk (Refer to Contract Risk Assessment Checklist). The contract may be assessed as either: ▪ Significant Risk.

▪ Low Risk.

▪ Very low risk (in which case the procedures in this section will not normally be applied).

Tendering process This process varies depending on the scope of the proposed work, contractors involved and other factors. The tendering process involves an evaluation of the Tender’s:

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Occupational Health and Safety Program 1. Past OHS performance and their proposal for addressing the major OHS risks.

2. Health and safety procedures such as Fall Protection, Demolition, Asbestos and WHMIS. (Refer to Review of Tender’s Program).

Start of the Project THE DEALER as the Prime Contractor provides the contract workers with a safety orientation prior to the start of work. Orientation records are maintained by THE DEALER. During the Project 1. The Contractor obtains further Clearance to Work Permit(s) or other permits as required by THE DEALER and applicable legislative bodies.

2. The Contractor reports all WorkSafeBC orders.

3. The Contractor conducts inspections and other regular functions in accordance with the Contractor OHS Plan. Inspections are completed at least weekly. THE DEALER uses the Contractor Performance Report as an inspection tool.

Contractor OHS Reporting Order Reporting The Contractor provides THE DEALER with a copy of any correspondence pertaining to the contract from WorkSafeBC regarding: ▪ Inspection reports explaining any violations and orders to improve work issued by WorkSafeBC, within 2 days of receiving it.

▪ An order to stop work. THE DEALER is verbally notified within 2 hours, or as soon as reasonably practicable.

Incident Reporting The Contractor notifies THE DEALER of incidents, injuries and disease events. Incidents that must be reported and investigated are: ▪ ▪ ▪ ▪

Lost Time Injury/Disease (i.e. where the employee is off work one full day or longer).

Medical Treatment Injury (requiring treatment from a Medical Practitioner).

Injuries to the public.

Incidents having the obvious potential to cause any of these outcomes “near misses”.

Verbal notification is required within 5 hours, with an investigation report provided within two working days to THE DEALER. The Contractor may use their Incident Report form. The Contractor may also use THE DEALER’s Incident Report Form.

The Contractor will notify WorkSafeBC of any reportable incidents under the regulatory requirements.

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Occupational Health and Safety Program Failure to Comply with the Contract If the Contractor fails to comply with the contractual requirements, immediate communication occurs with the people who signed the contract and THE DEALER. They review the cause for non-compliance and decide on one of the following actions: ▪ A written warning is placed in the Contractor’s file. THE DEALER, depending on the seriousness of the violation, determines the number of warnings it will permit before terminating the contract.

▪ If non-compliance results in an incident or workers are placed in an IDHL (immediately dangerous to health and life) situation, the contract is terminated without penalty to THE DEALER. If a contract is terminated, THE DEALER will not hire that contractor again.

If a written warning is placed on the contractor’s file, THE DEALER may consider hiring the contractor for future work if that contractor’s health and safety program demonstrates full compliance with legislative requirements.

Forms and Charts The following forms and charts pertain to this section: 1. Contract Risk Assessment Checklist.

2. Review of Tender’s Program.

3. Contractor Performance Report.

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6.3 Supplementary Instruction – Safe Work Rules and Procedure The following Safe Work Rules apply to all employees while they are employed by THE DEALER. 1. Read, understand, and follow the instructions and recommendations described in the operating and maintenance manuals for tools and equipment you use.

2. Stop the engine and disengage power before servicing.

3. Work as a team. Do not start an engine, engage power, raise, or lower an implement or hoist without warning other people in the area.

4. Lock Out equipment by removing the ignition key and by disconnecting the battery cables.

5. Always disable the electrical system by disconnecting a battery cable or removing fuses for a circuit when working on the electrical system (e.g., starter motor, radio, wiring, ignition, etc.).

6. It is good practice to disable the electrical system when working on or near the safety air bags.

7. Know how to work safely with all tools and equipment.

8. Attach a "Do Not Operate" tag to the vehicle's control panel with the reason stated (such as 'no brakes').

9. Use jacks and hoists to move and handle heavy components.

10. Use solvents with a flashpoint above 60°C where possible to reduce the risk of fire.

11. Clean up spilled oil, grease, fuel and other slipping and fire hazards immediately.

12. Inspect compressed air hoses regularly, and immediately replace any which are cracked, worn or frayed.

13. Ensure that air pressure reducers, gauges and moisture/dirt traps are cleaned and functioning.

14. Dispose or recycle waste materials in accordance with government regulations.

15. Above and underground tanks, pump pits, and similar areas are considered confined spaces and can be dangerous. Each confined space must be identified in an inventory, identified by signs or otherwise restricted from access. A compliant confined space entry program as per 9.5 of the BC OHSR is required if workers need to enter these areas. Only specifically trained individuals are allowed entry. Contact your local jurisdiction for more information.

16. Do not use gasoline for cleaning. Use cleaning solvents in approved containers.

17. Do not wear rings, watches, ties, jewelry, or torn or loose clothing. Button up shirt front and sleeves. Tie back long hair.

18. Do not run engines inside unless ventilation systems are attached, and the exhaust is vented outside.

19. Change oily clothing and launder regularly to prevent skin irritation and dermatitis.

20. Use safe lifting techniques when moving heavy parts.

21. Do not allow customers, family or unauthorized people in the work area.

22. Personal protective equipment (PPE) is used at all times for job tasks that identify the need to wear it.

23. The use of alcoholic beverages, drugs or other mood altering substances is strictly forbidden. No one enters THE DEALER’s worksite under the influence of such substances.

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Occupational Health and Safety Program 24. No employee engages in horseplay, scuffling, fighting, practical jokes or any other behaviour that may create a hazard to him or her or other employees.

25. Good housekeeping practices are mandatory at all times.

26. Hazards such as defective equipment are immediately reported to the supervisor.

27. No employee removes, impairs, alters or renders ineffective any safeguard provided for the protection of himself or herself or another employee. Smoking is only permitted in designated smoking areas.

28. All injuries are immediately reported to the first aid attendant and supervisor.

29. Smoking is not allowed in THE DEALER’s buildings, worksites, enclosed work areas, inflow vents or near external doors.

30. Combustible materials are not accumulated on the job site.

31. Compressed air is not used to clean any employee’s work clothing.

32. Failure to follow THE DEALER’s Safe Work rules and procedures will result in disciplinary action.

Discipline Process Corrective Action – Discipline Process 1. Verbal Warning – by the Supervisor a. Discuss the safety issue to find causes for not following the Safe Work Procedure or rule. b. Provide instructions to the employee so that he or she understands what the hazard is and how to work safely. c.

Have the employee give a return demonstration of the work task to ensure he or she understands the safe work behaviour.

d. Document the verbal warning on the employee’s file.

2. First Written Warning – by the Supervisor a. Provide a written warning using the Infraction Notice to the employee. b. Review the written warning so that the worker understands the need to work safely and future consequences. c.

Inform the worker that he or she will be observed on a regular bases for a period of time (frequency will vary depending upon the work task) to ensure that he or she understands the safe work behaviour.

d. Give the original written warning to the employee, keep a copy in the supervisor’s file and send a copy to THE DEALER’s Senior Managers.

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3. Second Written Warning – by the Supervisor a. Provide a second written warning to the employee. b. Review first and second written warnings with the employee. Provide instruction to assist the worker in practicing safe work behavior. c.

Inform the worker that he will be observed on a daily basis for a period of one month to ensure that he understands the safe work procedures. At the end of the one month, the supervisor and employee will meet to discuss the supervisor’s observations and if more coaching is needed.

d. Give the original second written warning to the employee, keep a copy in the supervisor’s file and send a copy to the Senior Managers and the employee’s file.

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6.4 Supplementary Instruction - Instruction and Training Specific Requirements for Young and New Workers Young and new workers need special attention because they are more at risk of injury than their older or more experienced counterparts. Supervisors provide orientation training prior to the new or young worker starting work.

The apprentices and young workers who work in the service area and body shop have basic health and safety knowledge if they recently attended or are attending a training program from such places as Vancouver Community College or BCIT. Topics that are taught at these institutions include (but are not limited to): ▪ ▪ ▪ ▪ ▪

WHMIS. Hazardous Materials.

Environmental Safety.

Health and Safety for refinishing.

Basic Occupational Health and Safety in the workplace.

Young workers may be partnered with older, knowledgeable workers as long as the latter workers instruct the young workers on all steps within the work procedures.

How to Conduct an Orientation for New and Young Employees There are four basic steps to an orientation session: Step 1: Evaluate the Situation The supervisor decides what areas the worker needs training in. He or she compares the worker’s job description to the New Employee Orientation Checklist. If this is the first time the worker is being orientated, more time is needed to ensure all topics on the checklist are reviewed. If the worker is being re-orientated, the supervisor won’t need to do the complete orientation. He or she will need to focus on the topics that relate to the new situation or new hazards.

Step 2: Train the Employee The checklist is reviewed by the supervisor and employee. Additionally, a physical orientation to the worksite is completed to identify emergency exits, eyewash stations and first aid facilities, and to demonstrate Safe Work procedures. An orientation will vary depending upon the number of Safe Work procedures and hazards that the new employee may be exposed to.

Step 3: Test the Employee The employee must demonstrate his or her understanding of the orientation information. The supervisor asks questions during the orientation session along with providing the employee with the New Employee Orientation quiz.

Step 4: Keep Records of the Orientation Orientation training is documented on the New Employee Orientation Checklist. The new employee receives a copy of the checklist. The supervisor keeps a copy on file.

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Occupational Health and Safety Program New (Young and Returning) Employee Orientation Quiz The New Employee Quiz is given by the supervisor to the new employee. The time given for the quiz is 20 minutes. The employee may use the New Employee Orientation and Safety handbook as a reference source. The passing grade is 100%. The supervisor marks the quiz and reviews any wrong answers with the employee. Once the employee understands the correct answers, he or she is given the quiz again. The quiz is kept in the employee’s personnel file.

Crew Talks Crew talks are five to ten-minute safety reviews of one aspect of the work or one topic. They are done every week. The talks are documented along with the names of the workers that were in attendance. Examples of crew talk topics are: ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

A recent incident.

Housekeeping on the job, especially cleaning up spills in the service area/body shop.

Safety while working under the hoist.

Inspecting a hoist.

Working with solvents.

Working with the sander.

Preventing MSIs when working over shoulder height.

Reporting hazards.

Using and caring for personal protective equipment such as a respirator.

Safe Work rules.

Traffic flow or speed.

Safety Training If a supervisor determines that crew talks are insufficient training, a safety training session is organized. THE DEALER’s Senior Managers plan with the supervisor on how to provide the safety training.

Employee Training Record and Training Certificates The Employee Training Record documents training that the employee receives along with identifying training topics that he or she must attend. The record is kept by the supervisor.

Training certificates are required for some work activities such as working as a First Aid Attendant. The supervisor keeps a copy on file.

CONTACT US

The New Car Dealers Association of BC (NCDA) is pleased to provide this complimentary copy of the Occupational Health and Safety Program for your dealership, made possible by the generous support from CADA. If you have any questions or concerns related to the content, please call or email us: info@newcardealers.ca / 604.214.9964

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WE APPLAUD OUR FRONTLINE WORKERS. On behalf of the New Car Dealers of British Columbia, we thank our health care professionals and ďŹ rst responders for working hard to keep British Columbians safe.

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