8 ways for employers to ‘take every reasonable precaution’ during a pandemic

Occupational health and safety legislation says that employers and supervisors should “take every precaution reasonable in the circumstances for the protection of a worker.”

This is known as the general duty clause, but what it means in this uncertain period is a question many employers have been asking Workplace Safety & Prevention Services (WSPS).

WSPS Regional Community Coordinator Lori Shepherd cuts through any uncertainty with this simple approach: “It means applying the same risk management strategies to this hazard as we would to any other hazard.”

To help workplaces put this into practice during wave two of the coronavirus, Lori offers the following eight suggestions.

1. Identify and assess COVID-related hazards that may be present in your workplace. “We know the risk of contracting COVID-19 through close, prolonged personal contact can be very high,” says Shepherd. “What processes, procedures and tasks could put employees at risk? How many people could be exposed to the virus, and how likely are they to become infected? Have any COVID related changes implemented by your workplace introduced new hazards?”

2. Determine how best to control the hazards. Once you know the nature and extent of risk, it’s possible to explore control options. Apply the hierarchy of controls, starting with elimination. For instance, replace in-person meetings and conversations with virtual meetings and phone calls. For hazards that can’t be eliminated, determine how to control them. For instance:

• Install transparent barriers between workstations
• Change the alignment of workstations so that workers are at least two metres (six feet) apart in all directions and ideally don’t face each another
• Encourage workers to maintain clean workstations, tools and equipment; clean and disinfect tools and other equipment between shifts
• Employ signage and markings to promote physical distancing. (Find examples at wsps.ca/Information-Resources/Articles/Using-signage-to-improve-physical-distancing.aspx)
• Increase ventilation
• Stagger shifts and breaks
• Screen employees and visitors before they enter the workplace
• If masks or other personal protective equipment (PPE) are called for, ensure they also protect against COVID-19
• Clean or dispose of used PPE safely and in an environmentally friendly way

To help workplaces control hazards, WSPS, Ontario’s Ministry of Labour, Training, and Skills Development, and other prevention system partners have collaborated on over 100 sector-specific guidance documents. Each document includes a number of control options.

Find them at: covid19.wsps.ca/resources/sector-specific-health-safety-guidance

3. Develop a COVID-19 safety plan. Compile all of the steps necessary to protect workers from exposure to the coronavirus, as well as the procedures necessary to monitor worker exposure and their health.

Include steps to take in response to a suspected case of COVID-19 at work. Involve your joint health and safety committee or health and safety representative early on, and complement internal expertise with external expertise where needed. Once you have drafted a plan, discuss and share it with everyone at work.

4. Integrate local public health requirements for workplaces into your safety plan. Examples include wearing a mask or face covering, physically distancing at least two metres (six feet) apart, using proper hand hygiene, self-assessing for COVID-19 symptoms before entering the workplace, and staying home when feeling ill.

5. Document everything you do. This includes hazard assessments, controls, training, inspections, investigations, logs, checklists – so that if the need arises, you can demonstrate due diligence – that you have taken every precaution reasonable in the circumstances to protect your workers from COVID-19.

6. Review and update your COVID-19 hazard assessment and controls. A number of factors may prompt the need for a review:

• Significant changes or improvements to processes or tasks
• Challenges introduced by these changes
• Evolving information on COVID-19 and related hazards
• Changes to public health and other government requirements

7. Reinforce everyone’s role under the Internal Responsibility System. This is another staple of occupational health and safety legislation. Under the system, everyone in the workplace – employers, supervisors and workers – is responsible for their own safety and the safety of co-workers, and has specific roles and responsibilities.

8. If in doubt, err on the side of caution. Focus on controlling hazards, not just on compliance. Legislation and regulations set minimum performance requirements, which cannot guarantee a safe workplace. If you focus on compliance as a minimum, and not on taking every precaution reasonable, you may not be managing hazards effectively.

Helpful resources

In addition to the over 100 sector-specific guidance documents mentioned above, WSPS offers two more tools on its website. The Hazard Assessment Template was originally created for small businesses, and can help any size workplace identify and assess hazards and recommend controls.

The Post-Pandemic Business Playbook provides information and tools to help businesses adapt to the new operating environment. Sector-specific versions are also available.

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This article was prepared by Workplace Safety & Prevention Services (WSPS), which has helping Ontario businesses improve health and safety for over 100 years.

This article was originally published in the November/December issue of Manufacturing AUTOMATION.