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As the year comes to an end, it is important for employers to check in on their existing workplace policies and make sure that they are compliant. Ontario’s Occupational Health & Safety Act (OHSA) requires certain employers to prepare and review at least annually, a written occupational health and safety policy, and to develop and maintain a program to implement that policy.

When reviewing your occupational health and safety policies, you will want to consider the following:

  • Does the policy express a commitment to health, safety, and well-being?
  • Are the employer’s obligations towards employees made clear?
  • Does the policy say which senior officer is responsible for seeing that the policy is implemented and for keeping the policy under review, and how this will be done?
  • Have the views of managers and supervisors, safety professionals, and health and safety committees or representatives been taken into account in drafting the policy?
  • Were the duties set out in the policy discussed with the people concerned? Do interested parties understand how their performance is to be assessed and what resources they have access to in order to carry out their tasks safely?
  • Does the policy make clear that the cooperation of all employees is vital to the success of the health and safety policy?
  • Does the policy say how employees are to be involved in health and safety matters, for example, by being consulted, by taking part in inspections, or by joining a health and safety committee?
  • Does the policy clearly explain how the duties for health and safety are allocated and does it thoroughly describe the responsibilities at different levels?
  • Does the policy include the names of individual managers who are responsible for overseeing the safety policy in specific areas or departments?
  • Does the policy state the employer’s duty to provide health and safety education and training to all employees?
  • Does the policy outline the development and maintenance of health and safety rules and procedures?
  • Does the policy include planned future programs for health and safety at work?
  • Does the policy ensure that health and safety matters will be taken into account when planning new methods, processes or premises?
  • Do all employees have copies of their employer’s health and safety policy?
  • Are workplace representatives consulted about periodic revisions to the employer’s health and safety policy?
  • Has the policy been reviewed with the health and safety committee?
  • Does the policy state who will review the policy and how often it will be reviewed?
  • Are there effective arrangements for drawing the policy to the attention of all employees?
  • Is it clear in the policy that the ultimate responsibility for safety rests with senior management?
  • Are the responsibilities of senior managers written into the policy or into relevant job descriptions?
  • Are there procedures and controls in place to ensure accountability?

To ensure that your company is in compliance, you should have your occupational health and safety policy reviewed periodically by legal counsel. To have your policy reviewed/drafted contact Toronto employment lawyers Sultan Lawyers at 416-214-5111 or via email at mlahert@sultanlawyers.com.


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