The Ministry of Labour (MOL) is seeking public input to help determine a future framework for workplace health and safety prevention programs in Ontario.
 
For health and safety advocates this is an opportunity to insist upon a new standard for effective prevention programs that achieves more than legal compliance. Done right, prevention programs can build capacity and commitment to bring about real improvements to working conditions and ultimately reduce work-related injury, illness and death.

Beyond legal minimums

A key recommendation of the 2010 Expert Advisory Panel on Occupational Health and Safety was to transfer prevention functions from the Workplace Safety and Insurance Board (WSIB) to the MOL. The Panel also concluded that workplaces need motivation to provide health and safety programs that go beyond minimum compliance—motivation that isn’t solely based upon financial incentives.
 
With a new prevention mandate and to fulfil the Expert Panel recommendations, the MOL created a Prevention Program Review Group, led a review of existing WSIB prevention programs and developed a proposed framework for new prevention programs—the basis for this current consultation.

Existing prevention programs

As a minimum, the Occupational Health & Safety Act requires employers to prepare and post an occupational health and safety policy and a program to implement it, yet no standard exists for workplace prevention programs.
 
Ontario’s health and safety system encourages prevention in a number of ways. Disincentives, by way of orders and fines through enforcement of the Act, is a key motivator to comply. The system’s network of health and safety delivery organizations also offers support to workplaces. Notably, the Workers Health & Safety Centre is the system’s only designated training centre.
 
The WSIB also administers incentive programs to encourage compliance. WSIB’s Workwell involves on-site health and safety audits of workplaces with higher than average rates of injury and illness.
 
The WSIB’s voluntary financial incentive prevention programs include Safe Communities Incentive Program (SCIP) and Safety Groups Program (SGP) which promote mentoring, sharing of resources and health and safety best practices. Validation for both programs includes attending training, participating in spot checks or filing action plans and year-end reports. Rebates to employers enrolled in these programs totalled more than $45 million in 2013, doubling in the last 10 years. However a 2011 WSIB internal program review found that only 10 per cent of SGP year-end reports were actually reviewed.
 
A Value for Money Audit of these programs found an association with reduced lost time injuries but was unable to make a firm conclusion about the overall cost-benefit to the WSIB. The auditors also suggested creating non-financial incentives and programs that would lead to employer accreditation.

Leading vs lagging indicators

Many more now believe that prevention programs based solely upon lagging indicators, such as lost-time injury statistics, are a poor measure of health and safety performance. This is further supported by studies which find that prevention programs tied to financial incentives can lead to underreporting of injuries and illnesses. As such it calls into question prevention programs which reward those with dubious reduced injury rates or who simply achieve minimum compliance.
 
The Institute of Work & Health is among those seeking real measures of health and safety. They reviewed research on potential leading indicators including safety culture (shared values and beliefs), safety climate (employee perceptions), joint health and safety committees, organizational policies and practices, and occupational health and safety management systems. The IWH found insufficient support for safety culture, safety climate and health and safety management systems as effective leading indicators but did conclude that “JHSCs are a core component of any internal responsibility system, and should be a core component of any set of measures intended to capture leading indicators.”

Employer accreditation—recognizing excellence

There is growing support and evidence for positive prevention programs that insist upon real workplace interventions and highly functioning JHSC’s. The Expert Panel is among those who support development of an employer health and safety accreditation program to recognize superior health and safety programs.
 
Health and safety advocates who contributed to the 2007 WSIB consultation on employer accreditation would still maintain today that a superior program should include, among other things, quality training which builds knowledge of legal rights and responsibilities and supports the capacity to identify, assess and control hazards. What’s more they would want to set a high standard for accreditation programs and require the participation of poor performers, not simply reward those who do the minimum.
 
Many look to the comprehensive Canadian Standards Association Occupational Health and Safety Management standard (Z1000-06) as a good place to start when designing, implementing and auditing workplace OHS programs. Among its prevention elements it considers worker participation, hazard identification and assessment, procurement policies, competence and training, and preventive and corrective action.
 
Learn more about MOL Prevention Program Review Consultation.
The consultation submission deadline is January 30, 2015.
Email: PPRC.MOL@ontario.ca
 
The Workers Health & Safety Centre offers a complete range of training and information resources to assist workplaces in assessing and setting up a comprehensive health and safety prevention program. Many WHSC programs not only meet but exceed legal training requirements. Contact us and ask to speak with a training services representative. 
 
Call:    1-888-869-7950
Visit:   www.whsc.on.ca
Email: contactus@whsc.on.ca