Conducting a hazard assessment and developing an exposure control plan

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In order to limit exposure to COVID-19, all employers are required to develop and implement an exposure control plan for their workplace. Section 6-22(1) of the Occupational Health and Safety Regulations, 2020 specifies the informational elements that must be included in your exposure control plan. These elements are outlined below.

It is also important to note that personal information must not be included in an exposure control plan. Personal information is any recorded information that uniquely identifies a person, such as a person’s name, age, sex, race, religion, sexual orientation, disability, blood type, criminal or employment history, financial information, education or health information.

An exposure control plan must:

  • Be in writing.
  • Identify any workers who may be exposed.
  • Identify categories of tasks and procedures that may put workers at risk of exposure.
  • Describe the ways in which an infectious material or organism can enter the body and the risks associated with that entry.
  • Describe the signs and symptoms of any disease that may arise for a worker exposed at a place of employment.
  • Describe infection control measures to be used such as:
    • vaccination
    • engineering controls
    • personal protective equipment
    • safe work practices and procedures
    • standard practices that incorporate universal precautions
  • Identify limitations of the infection control measures (listed above).
  • Set out procedures to be followed in each of the following circumstances:
    • if there has been a spill or a leak of an infectious material or organism
    • if a worker has been exposed
    • if a worker believes that he or she has been exposed
  • Develop and implement methods of cleaning, disinfecting or disposing of clothing, personal protective equipment or other equipment contaminated with an infectious material or organism. Indicate who is responsible for carrying out these activities.
  • Describe the training that will be provided to workers that may be exposed and the means by which this training will be provided.
  • Require the investigation and documentation, in a manner that protects the confidentiality of the exposed worker, of any work related exposure incident, including the route of exposure and the circumstances in which the exposure occurred.
  • Require the investigation of any occurrence of an occupationally transmitted infection or infectious disease to identify the route of exposure and implement measures to prevent further infection.

A workplace hazard assessment will help identify some of the information required for the exposure control plan. This planning tool will guide you through six steps in the process of conducting a hazard assessment. This tool is one resource to help develop your exposure control plan, and additional information may be required depending on the specific work environment at your place of employment.

  1. Step one: Assess the hazards in your workplace

COVID-19 spreads in several ways. It can be transmitted from person-to-person via coughing and sneezing (droplet transmission). It can also be spread by touching contaminated surfaces and then touching your mouth, nose or eyes before washing or sanitizing your hands. While it is not yet known exactly how long COVID-19 lives on surfaces, preliminary evidence suggests it can live on surfaces from a few hours to several days.

Involve workers when assessing the workplace. Identify areas where there may be potential risks of COVID-19 exposure either through close physical proximity or through contaminated surfaces.

Checklist

  • We have involved frontline workers, supervisors, managers and occupational health committee (OHC) members or occupational health and safety representatives.
  • We have done a walkthrough of the workplace to identify categories of tasks and procedures that may put workers at risk for exposure. The level of risk to workers should be identified as low, moderate or high.
  • We have identified areas where people gather, such as break rooms, production lines and meeting rooms.
  • We have identified job tasks and processes where workers are close to one another or to members of the public. This can occur in our workplace, in worker vehicles or at other work locations.
  • We have identified the tools, machinery and equipment that workers share.
  • We have identified surfaces that people touch often, such as doorknobs, elevator buttons, faucets and light switches.
  1. Step two: Implement protocols to reduce the hazards

Implement protocols to minimize the risks of transmission. The following information may provide some guidance:

  • Review the industry specific guidelines available in the Re-Open Saskatchewan plan to determine if any are relevant to your industry.
  • If guidelines specific to your sector or industry are available, implement these where they are applicable to the hazards at your workplace. You may also need to implement additional control measures to address the hazards to your workers.
  • Implement and follow public health orders, guidance and recommendations in the Re-Open Saskatchewan plan.

Reduce the hazard of person-to-person transmission by implementing controls

To reduce the risk of the virus spreading, implement protocols to protect against identified hazards. Whenever possible, use the protocols that offer the highest levels of protection. This may mean you need to incorporate controls from various levels to address all of the hazards in your workplace.

First level of protection: Elimination

Use policies and procedures to follow the public health orders. Limit the number of people in your workplace at any one time and ensure physical distancing wherever possible. Rearrange workspaces or reschedule work tasks to ensure that workers are two metres apart from one another and from customers.

Checklist

  • We have established and posted occupancy limits for our workplace, including break rooms, meeting rooms, washrooms, elevators, photocopy spaces, storage rooms, etc.
  • We have considered work from home arrangements, virtual meetings, rescheduling tasks and limiting the number of customers or visitors in the workplace.
  • We have implemented measures to keep workers at least two metres apart wherever possible.

Second level of protection: Engineering controls

If you cannot maintain physical distancing, install barriers and partitions to separate people.

Checklist

  • We have installed barriers in situations where workers can’t keep two metres distance from coworkers, customers or others.
  • We have included barrier cleaning in our cleaning protocols.
  • We have installed the barriers so that they do not introduce other hazards to the workers (for example, barriers installed inside a vehicle don’t affect the safe operation of the vehicle).
Third level of protection: Administrative controls

Establish rules and guidelines, such as posted occupancy for shared spaces, a designated delivery area and one-way doors or walkways, to keep people physically separated.

Checklist

  • We have identified rules and guidelines for how workers must conduct themselves.
  • We have policies and procedures for handwashing.
  • Our workplace has enough handwashing facilities/stations for all staff.
  • We have reviewed the information and protocols for cleaning and disinfecting surfaces and shared spaces (washrooms, doorknobs, light switches, etc.).
  • We have sufficient cleaning materials and staff have been trained to use them. The chemical product labels are visible on the cleaning solutions.
  • We have removed unnecessary tools and equipment to simplify cleaning processes (coffee makers, shared utensils, etc.).
  • We have clearly communicated the rules and guidelines to workers through a combination of training and signage.
Fourth level of protection: Personal protective equipment

If the first three levels of protection are not enough to control the hazard, consider the use of personal protective equipment (PPE). Ensure workers are using PPE appropriately.

Non-medical masks or face coverings are not PPE. If they are used in a workplace setting, be aware of their limitations. The provincial government has guidelines on the use of non-medical masks or face coverings.

Checklist

  • We have reviewed information on how to use the PPE provided.
  • We understand the limitations that PPE has in providing protection and how they need to be used in combination with other control measures.
  • We have trained employees on how to use PPE.
Employers must conduct a hazard assessment with their OHC or occupational health and safety representative to ensure that any control measures implemented do not introduce new hazards for workers in a workplace setting.
  1. Step three: Develop policies

Develop the necessary policies to manage your workplace, including policies around who can be at the workplace, how to address illness that arises at the workplace and how to keep the workers safe in adjusted working conditions.

Having a policy around what an investigation looks like when a worker tests positive for COVID-19 is also recommended.

Checklist

  • Our workplace policies ensure that workers and others showing symptoms of COVID-19 are prohibited from entering the workplace.
  • Our policies prohibit anyone who is required to self-isolate from entering the workplace.
  • Our policies address visitors coming to the workplace.
  • We have an investigation policy for work-related COVID-19 exposure incidents that protects the confidentiality of the exposed worker.
Conducting a hazard assessment and developing a safety plan
  • We have a working alone policy (if needed).
  • We have a work from home policy (if needed).
  • We have strategies and training to address the risk of violence that may arise as individuals adapt to restrictions or modifications to the workplace.
  • Our workplace has policies around what to do if workers believe that they have been exposed to COVID-19.
Our policy to address workers who start to feel ill at work includes:
  • Directions for sick workers to report to first aid if applicable, even with mild symptoms.
  • Directions for sick workers to wash or sanitize their hands, be provided with a mask and isolated.
  • Directions for sick workers to go straight home and call the Saskatchewan HealthLine at 811 for further guidance. If the worker is severely ill, call 911.
  • Clean and disinfect any surfaces that an ill worker has come into contact with.
  1. Step four: Develop communications plans and training

You must ensure that everyone entering the workplace, including workers from other employers, know how to keep themselves, and those around them, safe while at your workplace. This plan must be in writing and available to workers.

Checklist

  • We have a training plan to ensure everyone is trained on our policies and procedures, including identifying limitations of infection control measures.
  • All workers have received the policies for staying home when ill.
  • We have posted signage at the workplace, including occupancy limits and effective hygiene practices.
  • We have posted signage at the main entrance indicating who is restricted from entering the premises, including visitors and workers who have symptoms.
  • Supervisors have been trained on monitoring workers and the workplace to ensure policies and procedures are being followed.
  1. Step five: Monitor your workplace and update plans as necessary

As you continue to operate your business, things may change. You may identify new areas of concern or need to address a process that isn’t working. Involve your employees and OHC or occupational health and safety representatives in reviewing and updating policies and processes.

Checklist

  • We have a plan in place to monitor hazards.
  • We make changes to policies and procedures as necessary.
  • Workers know who to go to with health and safety concerns.
  • we involve employees and OHCs or occupational health and safety representatives.
  • policies include escalations to address individuals who may not be following procedures.
  1. Step six: Assess and address hazards after resuming operation

If your business has not been operating during the COVID-19 pandemic, you may need to manage the hazards associated with resuming or reopening your business.

Checklist

  • We have a training plan for new staff.
  • We have a training plan for staff taking on new responsibilities.
  • We have a training plan around changes to our business and how we operate.
  • We have reviewed the startup requirements for equipment, machinery and vehicles that have been out of use for any period of time.
  • We have identified a safe process for cleaning systems and lines of production that have been out of use.