The internal responsibility system

The internal responsibility system is the basis of the Occupational Health and Safety Act (OHSA) and a key indicator of the strength of a health and safety culture within an organization. The OHSA lays out the role of joint committees, safety representatives and trades committees, and identifies the duties of owners, constructors, employers, supervisors and workers. An internal responsibility system is a demonstration of everyone within an organization taking personal and direct responsibility for health and safety as a central part of their job.

The internal responsibility initiative was conducted across all sectors in two phases.

During phase 1, which ran from April 1, 2018 to March 31, 2019, the Ministry of Labour, Training and Skills Development worked with its various health and safety associations to provide training and education to employers. The goal was to help employers comply with requirements under the Occupational Health and Safety Act (OHSA) and its regulations.

During phase 2, which ran from June 1, 2018 to March 31, 2019, inspectors conducted their focused inspections.

Construction sector

During phase 1, the Ministry of Labour, Training and Skills Development worked with the Infrastructure Health and Safety Association (IHSA) to provide training and education to employers in the construction sector. The goal was to help employers comply with requirements under the OHSA and its regulations.

During phase 2, inspectors visited construction sites to check that employers were complying with the OHSA and Regulation 213/91. In particular they checked that employers were making sure that:

  • there was knowledge and understanding of rights and duties
  • the joint health and safety committee (JHSC), and/or health and safety representative (HSR) and/or trade committees were established and engaged
  • training of JHSC members or HSR had taken place
  • job hazard identification and controls were in place
  • health and safety policies and procedures were established
  • there were records of supervisor and worker training, certifications (for example, awareness, equipment, operation, violence and harassment)
  • there was maintenance and training on use of equipment, materials and personal protective devices
  • competent supervisors were on site appropriate to the number of workers
  • emergency plans had been established
  • communication of incidents and investigations take place

From June 1, 2018 to March 31, 2019, Ministry of Labour, Training and Skills Development inspectors:

  • conducted 5,843 field visits
  • visited 4,532 construction workplaces
  • issued 13,961 orders and 299 requirements, including 1,101 stop work orders
    • orders per field visit – 2.32
    • orders per workplace visited – 3.04

The goals of the initiative were to:

  • increase awareness of constructors, employers, supervisors and workers of the importance of a strong internal responsibility system
  • increase all workplace parties’ awareness of their role in creating and maintaining the internal responsibility system
  • monitor compliance with the law by workplace parties
  • strengthen the internal responsibility system to prevent injuries that could arise as a result of no and/or poor internal responsibility system

Health care sector

During phase 1, the Ministry of Labour, Training and Skills Development worked with Public Services Health and Safety Association (PSHSA) to provide training and education to employers. The goal was to help employers comply with requirements under the Occupational Health and Safety Act (OHSA) and its regulations.

During phase 2, inspectors visited health care workplaces with a focus on group homes, treatment clinics and specialized services and professional offices and agencies to check that employers were complying with the OHSA and its regulations, including the Health Care Residential Facilities Regulation (O. Reg. 67/93).

In health care workplaces, inspectors focused on:

  • training, information and instruction and supervisory competency
  • personal protective equipment (PPE) and protective devices
  • reporting incidents of workplace violence
  • notification requirements
  • duties of directors and officers of a corporation

From July 1, 2018 to March 31, 2019, Ministry of Labour, Training and Skills Development inspectors:

  • conducted 831 field visits
  • visited 580 workplaces
  • issued 1,404 orders and requirements, including 17 stop work orders
    • orders per field visit – 1.67
    • orders per workplace visited – 2.39

Mines and mining plants sector

Occupational disease is a leading cause of death in mines and mining plants with 170 mining-related Workplace Safety and Insurance Board (WSIB) occupational disease claims being allowed between 2005 and 2014 in the province. Occupational diseases can occur when workers are exposed to chemical, biological or physical hazards.

In the mining sector, the internal responsibility system initiative had a focus on occupational disease in mines and mining plants.

Ministry inspectors visited mines and mining plants to encourage a strong internal responsibility system in the workplace with a focus on occupational disease prevention. Inspectors checked that employers were complying with the Occupational Health and Safety Act and its regulations to protect workers from hazards that lead to occupational disease including:

  • underground mine ventilation
  • exposures to diesel exhaust, silica and other designated substances in mines
  • chemical or biological hazards assessments

From April 1, 2018 until March 31, 2019, Ministry of Labour, Training and Skills Development inspectors:

  • conducted 73 field visits
  • visited 65 workplaces
  • issued 343 orders and requirements, including 12 stop work orders
    • orders per field visit – 4.75
    • orders per workplace visited – 4.44