OHS: a new link in supply chain management
By Charles Craig
Traditionally, manufacturers and distributors dealing with suppliers have been most interested in quality and price. But more and more, companies are incorporating greater expectations into supply chain management, a trend driven by multiple factors:
- a greater understanding of other contributors to effective supply chain management, such as health and safety performance
- the ability of information technology to collect and monitor an array of supply chain information
- a growing sense of ethical responsibility for their finished goods, often expressed in corporate ethics policies
- suppliers’ own corporate ethics
- suppliers’ desire to differentiate themselves in the marketplace
- increasingly sophisticated consumers applying their evolving ethics to purchasing decisions
Companies that choose to integrate health and safety into their supply chain can achieve considerable benefits beyond the satisfaction of improving health and safety. For instance:
- competitive advantage: in 2004, clothing retailer Gap launched an anti-sweatshop initiative using 90 inspectors to help achieve compliance among 3,000 suppliers. Instead of being perceived as part of the problem, Gap was praised for being part of the solution
- business continuity. The safer your suppliers, the less likely they are to experience downtime from injuries and mishaps, and disrupt your own production schedule. In a just-in-time world, lost time could mean lost sales
- consumer confidence. Transparency in the supply chain leads to trust and, by extension, customer loyalty
But can a company be reasonably held to account for the quality or ethics behind every nut and bolt it purchases?
“We buy from between 3,000 and 4,000 different manufacturers,” says Michael Horricks, director of supply chain management for Marks Supply, a wholesaler and distributor of plumbing, heating, ventilation and air conditioning supplies in Kitchener, ON. “In total, we probably buy from companies in 50 to 60 countries around the world. We don’t have people who could travel to every one of these companies and countries to verify that they’re meeting the health and safety requirements of their own countries, or the ethical health and safety standards we would expect a company in Canada to uphold.”
An alternative to direct inspections is having suppliers agree to a code of conduct. One such code has been produced by the Pharmaceutical Supply Chain Initiative (PSCI), representing major pharmaceutical companies. It identifies four traditional health and safety components: worker protection, process safety, emergency preparedness and response, and hazard information. It also goes further, incorporating fair treatment, child labour and young workers.
Buyers can enforce such codes by conducting strategic spot inspections, gathering company compliance information from third-party sources, or by investigating specific complaints they might receive on a supplier’s performance.
One employer’s approach
The City of Calgary, with 13,000 employees, packs considerable punch as a purchaser.
In January 2007, the city approved the Sustainable Environment and Ethical Procurement Policy (SEEPP), considered one of the most rigorous municipal supply chain evaluations in the world. The policy initially applies to the purchase of apparel, food, chemicals and custodial services, with an emphasis on social, economic and environmental sustainability. One of the stated goals of the program is to “reduce risk by promoting health and safety, and ensuring compliance with legislation.” Inherent in the policy is an understanding that the city may pay a premium in its contracts for choosing only suppliers that satisfy SEEPP, one of the reasons that government procurement policies may be more enlightened than those of industry, which is more accountable to the short-term demands of shareholders and the bottom line.
“Our purchasing policy requires ethical behaviour from our suppliers, and our supplier code of conduct lays out how we expect them to operate with respect to the environment and human rights and Fair Trade policies,” says Jim Nicholson, purchasing agent for the city. “Suppliers fill out a questionnaire that asks them a number of questions, and they’re held accountable for those answers… So while we don’t specify health and safety, the supplier has an ethical requirement to meet health and safety regulations, and could be disqualified as a supplier if anything negative came to our attention.”
How technology can help
Currently under development are sophisticated systems that will potentially be able to tell customers and end users almost anything about the product they’re purchasing.
“There’s more and more pressure to put the newest technology to work to make supply chains more visible,” says John Keogh, senior vice president of GS-1 EPCglobal Canada, part of a global organization promoting the development of worldwide standards to improve the efficiency and visibility of both supply and demand chains. “Part of it is understanding the breadth of what constitutes the supply chain,” he says. “It’s broader than some people think. In a previous position, my company was setting up benches and tools inside factories and we were using 3-D modeling software to make sure that the height of the bench and the size of the tools were appropriate to the average height of the people living in that country. That modeling software is part of the supply chain.”
Part of the development of a truly transparent supply chain may be linked to the establishment of standards to identify counterfeit products, he says. In addition to the economic loss suffered by legitimate manufacturers and retailers, these products can pose hazards if the manufacturers used substandard material or processes. Counterfeit goods may contain unexpected harmful chemicals not normally used in such products. Counterfeit lithium-ion battery packs for digital cameras, for example, may explode under certain circumstances. Counterfeit toys may be coated with paint containing lead.
An estimated $600 billion to $800 billion in counterfeit products are sold around the globe each year. What if each product had a globally recognized identifying number that was unique to the product as well as to each item manufactured, and could transmit that information through radio frequency to be read by a cell phone or similar device? “This is the type of system we’re promoting,” says Keogh. “Once you have that coding system in place, it can convey any amount of information about that product—where it came from, who made it, how it was shipped, how much carbon was produced in manufacturing it, expiry dates, WHMIS information, and information about the ethics and health and safety compliance of the company that made it.”
Keogh acknowledges that pursuing a high-tech ethical procurement policy may increase the need for due diligence and drive the price of goods higher, but believes a cultural shift is necessary so that more enlightened companies aren’t disadvantaged by an ethical stance. Keogh believes that, at some point, consumer demand will drive that type of accountability, noting that Fair Trade coffee and chocolate are often sold at prices consistently above traditional market value, yet maintain a healthy market share.
Horricks agrees that this is the direction in which supply chain management is headed. “This is also a perfect opportunity for third-party accreditation where organizations like IAPA can apply their own standards to the supply chain, certifying suppliers in much the same way as the Canadian Standards Association certifies products. If you don’t receive IAPA certification, as a supplier you may not be invited to the dance. The technology will make that possible.
“From a health and safety perspective,” continues Horricks, “there’s nothing but good news on the supply management front.”
Incorporating OHS into the supply chain
Health and safety is best incorporated into the supply chain when healthy and safe workplaces are perceived as a business advantage, rather than a mere cost of winning a contract, says Michael Abromeit, IAPA’s vice president, operations and marketing.
Abromeit notes that, in most cases when health and safety is considered a factor in the supply chain, it tends to focus only on regulatory compliance instead of, say, encouraging respect for workers and creating a work environment free from harassment. The challenge, then, is for companies to broaden their goals into overall corporate social responsibility practices that include personal health, mental health and the psychosocial environment.
To encourage health and safety throughout the supply chain, companies can
- help develop industry supply chain codes of conduct
- collaborate with non-traditional organizations and partners, such as government ministries and agencies, and business and community associations
- model the desired performance, and serve as a mentor to supply chain partners
- utilize non-traditional approaches, such as participatory initiatives, to encourage health and safety in the supply chain
- use its buying power as a tool of persuasion
While much of the effort to incorporate health and safety into supply chains involves ensuring that suppliers meet certain standards in a verifiable fashion, companies can also seamlessly build health and safety initiatives into their part of the supply chain.
Rather than deliver raw materials in large, heavy containers, suppliers can choose to split up deliveries into smaller containers that are easier for handlers to lift. In some cases, it might be safer to deliver a particular product in bulk, avoiding manual handling altogether. A featureless cardboard box containing a finished manufactured product could be fitted with handles to make it easier to move.
When a purchasing department changes the specifications of an order with an established supplier, a greater lead time can be offered to allow the supplier to incorporate changes into its health and safety regimen to accommodate the new specs.
Abromeit also encourages companies to look for opportunities to promote health and safety in the supply chain outside a narrow or local economic sphere. “The goal is to extend your influence beyond just one supply chain or economic sector,” he says.
Charles Craig is a freelance writer with an interest in workplace health and safety; email@example.com.
Achieving award-winning performance
By Robert Lee
Those few seconds in the spotlight, when a presenter hands an award to a recipient, are what often draws the most attention to an achievement. But what such moments can’t reveal is all the effort that led up to it.
This year, John Deere Welland Works and Honeywell Specialty Chemicals (Amherstburg) both met the criteria for IAPA’s best-in-class 2008 President’s Award, presented in April at Health and Safety Canada 2008, IAPA’s national conference and trade show.
IAPA launched the President’s Award, its highest honour, in 2007 to recognize firms that have achieved health and safety excellence and are committed to sharing their expertise with others.
John Deere’s turnaround
In 2007 John Deere Welland Works, which produces front loaders for agricultural and compact utility tractors, rotary cutters, and utility vehicles, hosted a Health and Safety Best Practice visit. Just a few years earlier, that same plant was an average safety performer among John Deere’s North American facilities.
While the safety department had management’s full commitment, it was seen as a separate entity that was not aligned well with operations. When he was hired, says health and safety director Shawn Finlay, “My job was to make sure safety was here to support the business.”
So his team got to work. Several initiatives were implemented to help raise safety awareness, drive accountability and reduce unsafe behaviour. For example:
- Dupont STOP (safety training observation program), which identifies workers who are performing safely and draws attention to what they’re doing in a positive manner
- a behaviour-based safety training program called ALERT
- continuous improvement teams, and
- other measures that promote safety loud and clear
Demonstrating an openness to learn from others, the department brought in co-op students from the University of Waterloo’s kinesiology program for four-month placements. The students segmented operations according to the ergonomic risks they posed, and developed a proactive musculoskeletal disorder prevention program. For instance, they redesigned fixtures to reduce or eliminate difficult or awkward manual tasks, and conducted ergonomic awareness training, advising participants on how to recognize and control awkward work positions. They even put magnets on sticks to reduce the need to bend down and pick up metal parts.
While the facility had already been tracking injuries, Finlay expanded these efforts by identifying root causes and taking corrective action. The company started to promote a positive safety culture by informing employees about its improving lost-time injury rates and safety program enhancements. Increasingly, safety was on everyone’s mind.
Finlay says the site now has such a rigorous housekeeping process that over the last four years it has helped to virtually eliminate injuries from physical hazards. The effort was part of the Deere Production System manufacturing strategy implementation, and helped establish a consistent, orderly factory environment. “Because everything has a place now,” he says. “Every tool has its place. Everything is properly labelled. We looked at sight lines, space in the work stations, removed unnecessary items that don’t add value to our product… “The result is pride in the workplace, as well as the discipline to maintain it and to continuously improve.”
Of the 46 John Deere plants globally, Welland’s safety record now ranks among the top 10.
Finlay says it couldn’t have happened without senior management’s commitment. Safety items are reviewed with the general manager every morning, discussed every day with business managers, and weekly with staff management. All levels of management participate in the STOP observation program, and the general manager routinely participates in accident investigations. “You’re not where you want to be if the safety person is running around doing everything. Everyone is now engaged, including workers, supervisors and senior management.”
“Safety is a never ending journey,” says general manager Donald De Bastiani. “There will always be aspects of our program that can be improved."
Honeywell: do or die
Honeywell produces some of industry’s most hazardous materials. Consequently, says Giovanni Grande, environmental safety manager of Honeywell’s Amherstburg, ON facility, Honeywell has always set a high standard for safety.
Plant manager Dean Palmer elaborates: “Within Honeywell’s specialty materials division, which includes Amherstburg, every manager at every level understands that health and safety has to be a fundamental part of how we operate. It is how we operate. If you can’t do that successfully, then you don’t have a license to operate.”
It’s not just about health and safety, says Palmer, it’s about business. “As the world’s leading producer of hydrofluoric acid, Honeywell has recognized that if you don’t take the measures to protect the health, safety and well-being of your workers at a very high level, you’re just not sure that you can operate effectively… There’s no grey area. If you’re not working safely, you’re not working successfully,” says Palmer.
Giovanni Grande explains how this plays out on a day-to-day basis: “the Amherstburg facility has created a healthy workplace culture where everyone is a step ahead of potential hazards. Workers talk about safety at the start of every shift. During the shift, if someone noticed a co-worker’s shoe was untied or saw a protruding piece of piping, he or she would alert workers affected, saying ‘Heads up, there’s a hazard here.’
“From a technical perspective, we had always had tight policies and procedures. But to get to zero and really drill down the things that need to be embedded in people’s psyche, you need to address the cultural aspects of health and safety.”
Central to the health and safety culture is Honeywell’s Structured Safety Process, which covers every conceivable aspect of health and safety from meetings and committees to contractor safety and emergency response. Management introduced the program in early 2006 as a means of involving all levels of the organization in safety performance.
A “what-if” drill is just one component of the new program. “We do it all the time,” says Grande. “We’ll look at a situation and say, what could go wrong with this? Or what if we lost power in the building? How would we get out of the building safely?” Nothing gets overlooked, not even those one-time tasks.
One of several achievements that impressed IAPA was how proactively Honeywell meets its personal protective equipment (PPE) needs. In 2000, Honeywell worked with two suppliers, Draeger Canada and Respirex Inc., to integrate an acid splash hood into a supplied air breathing system. In mid-2006 they further advanced it to work with an air-purifying respirator system that is not tethered, fully protects the eyes, and is sealed around the face. Honeywell also worked with Respirex Inc. to develop rubber pants and a rubber jacket for protection from live acids.
The Amherstburg plant also scored wellness points with IAPA. Besides employing a full-time occupational health nurse, the facility has an occupational health physician on site once a week. “We take care of workers as their family doctor would,” says Grande. For example, “the average employee’s age is 48, so we check the prostates, do blood work and run cholesterol tests.” Thanks to this regular monitoring, the medical department has diagnosed three individuals with elevated prostate specific antigens and two with elevated cholesterol in the past two years.
“There is an ethical and economic basis supporting our efforts in this area,” says Grande. “Our associates’ performance, alertness and safety at work is affected by many factors outside of work, and the better we understand and assist caring for them, the less likely that one of these conditions will become a factor in their working environment, thereby decreasing the risk of injury or illness.”
To companies that strive to create a healthy workplace, Grande offers this advice: “You can’t do everything at once. You need a well-defined and realistic plan, and you can’t deviate from that plan. If you do, then have a recovery position.”
This year’s two winning firms didn’t always have such solid health and safety programs but were committed to making it happen. Learn more about their health and safety performance in the August/September issue of Accident Prevention.
Is your safety program best in class? If not, it could still be on the right track. Find out what it takes to earn an IAPA achievement award.
Robert Lee is an independent journalist who specializes in industrial subjects.
ISO to release nanotechnologies safety report
This fall, International Standards Organization (ISO) Technical Committee 229 intends to publish a technical report on safe work practices involving nanotechnologies.
The report will identify current safe workplace practices in response to uncertainty over the health and safety implications of nanotechnologies, as well as the nanomaterials produced. “While the occupational risks associated with working with nanotechnologies have not yet been fully studied or identified,” says the ISO, “it is important to identify basic safe practices now and make them available to all interested parties.”
Nanotechnologies, techniques and processes involve manipulating matter at the molecular level. Nanomaterials or nanoparticles typically possess at least one physical dimension in the range of 1 to 100 nanometres (nm). By comparison, the diameter of a human hair is 100,000 nm.
Nanoparticles are not new. For example, they occur naturally in sea spray. What is new is the use of engineered nanomaterials, their growing evolution, and their use in a widening range of manufacturing processes and consumer products. By 2015, an estimated $1 trillion worth of products worldwide will incorporate nanotechnology.
The very properties that make nanomaterials so appealing may also present risks. For example:
- their physical and/or biological properties differ greatly from the same substance in bulk form, and so may pose different hazards
- their minute size may allow greater entry into organisms and across cellular membranes
- the high surface-area-to-volume ratio of nanomaterials can result in a greater number of reactive sites, thus increasing the potential for interaction
- the electronic properties of nanomaterials may interfere with normal cell function
Renzo Dalla Via, IAPA’s senior strategy advisor, technology, has been involved in development of the ISO technical report. “It sets down what we believe is the best current state of knowledge on how to safely use nanomaterials in the workplace.”
The report is the product of an international working group (WG). Technical Committee 229, which has members from 28 countries around the world, has four such groups, all responsible for producing nanotechnologies-related standards, specifications and technical reports:
- WG1 — terminology and nomenclature. “Using common terminology is incredibly important for the purposes of trade and legislation,” says Dalla Via. “Environment Canada, Health Canada, Industry Canada… are all on our Canadian mirror group. We also have members from industry, academia, NGOs like the Institut de recherche Robert-Sauvé en santé et en sécurité du travail (IRSST), IAPA, and other associations.” Members of these groups, because of their interest, expertise, or role, help to formulate Canadian positions on issues that go into the development of standards, specifications, and technical reports.
- WG2 — measurement and characterization, which is developing standards for measurement, characterization and testing methods.
- WG3 — health, safety and environmental aspects of nanotechnologies. The ISO notes that “there are high-priority, high-urgency needs for standard methods for toxicological screening, relative toxicity/hazard potential determination, establishing occupational exposure limits, etc. for nanoparticulates and other nanoscale materials; and protocols for inhalation testing, toxicology testing, safe handling, exposure determination and safe disposal of nanotubes.” Not all of these needs, such as exposure limits, are ISO responsibilities. Dalla Via chairs WG3’s Canadian mirror working group.
- WG4 — material specifications. The newest working group, its role is to develop standards, specifications and technical reports on materials specifications; for instance, the properties and characteristics associated with a specific nanomaterial. WG4 is expected to work closely with WG2 to ensure coordination of measurement, characterization and test methods.
Canadian experts call for Canadian research agenda
Canada should address possible health and environmental risks of nanomaterials by developing a strategic research agenda rather than new regulations, advises an expert panel on nanotechnology.
The recommendation appears in a detailed report, released in July, that was prepared for the federal minister of health. The minister had requested an assessment of “the state of knowledge with respect to existing nanomaterial properties and their health and environmental risks, which could underpin regulatory perspectives on needs for research, risk assessment and surveillance.”
We don’t know enough at present to assess and manage the potential risks of nanomaterials, says the report. It identifies key steps to help fill in existing knowledge gaps:
- develop interim terminology and classification to help regulators oversee an emerging group of nanomaterials and products, until international definitions and nomenclatures are devised
- develop new tools and standards, in conjunction with classification, to ensure that exposure to nanomaterials is consistently and reliably monitored
- revise current regulatory triggers to identify nanomaterials entering the market that may require regulatory oversight
- work collaboratively within Canada and internationally to address the diversity in material type and usage of nanomaterials, the scientific research required, and the increasing presence of traded products that contain nanomaterials
Some of these gaps will be filled by ISO and other national and international standards now in development, says Dalla Via. However, these standards depend on research conducted by governments and research organizations.
For more information
For an overview of the topic, read Engineered Nanotechnology in the Workplace, by Renzo Dalla Via, IAPA’s senior strategy advisor, technology. For a copy of Small is Different: A Science Perspective on the Regulatory Challenges of the Nanoscale, visit www.scienceadvice.ca.
Watch for more on the ISO technical report in an upcoming issue of Accident Prevention.
It's not just the blues: recognizing signs of depression
By Eric Hipple
Since his wife filed for divorce several months ago, Mike has lost a lot of weight; his suits hang off his once-bulky frame. Mike's face looks hollow and gaunt, and he's having trouble getting his work done.
Jessica keeps complaining of headaches and stomach aches. She has called in sick seven times over the last month. Today, when she returned from a two-hour lunch, you could have sworn you smelled alcohol on her breath.
Both Mike and Jessica are showing possible symptoms of depression, which costs businesses billions of dollars each year, mostly due to reduced productivity. But there’s more at risk than Mike's and Jessica's careers. Depression is one of the strongest risk factors for attempted suicide.
So how do you help a potentially depressed employee or coworker?
First, educate yourself about depression. Contrary to traditional thought, depression is not a personal failing; it is a clinically defined mental disorder that occurs when the brain's chemistry becomes unbalanced.
Fortunately, depression is highly treatable. Though each sufferer and situation is unique, some common depression risk factors and symptoms follow:
- recent loss — through death, divorce, separation, broken relationship, injury, loss of job, money, status, self-confidence, self-esteem, or loss of religious faith
- change in personality — sadness, withdrawal, irritability, anxiety, tiredness, indecisiveness, apathy, and loss of interest in friends, hobbies, or previously enjoyed activities
- change in behaviour — inability to concentrate on work or on routine tasks. Chronic tardiness or calling in sick, drug or alcohol abuse
- more physical complaints — headaches, back pain, stomach aches, etc.
- change in sleep patterns — complaints of insomnia, often with early waking or oversleeping, nightmares
- change in appearance and eating habits — noticeable weight gain or weight loss, picking at food or overeating, unkempt appearance
- low self-esteem — expressions of worthlessness, shame, overwhelming guilt, self-hatred
Warning flags for possible suicide include talking about dying or disappearing ("if I didn't wake up tomorrow, my family would be better off"), making specific plans for suicide, previous suicide attempts, giving away favourite things, making wills, arranging for the care of pets, extravagant spending, agitation, hyperactivity, and restlessness or lethargy.
So you see some symptoms. Now what?
- Approach the employee sensitively, informally and privately to establish the root of the problem. Remember, he or she may not be suffering from depression.
- Be approachable and ready to listen.
- If a work issue is causing the depression, use your managerial power to remedy situations that have caused the condition.
- If your company has an employee assistance program (EAP), remind the employee that it is a free resource. An EAP counsellor also can advise you how best to approach the employee.
- Keep an open mind and be flexible. Education is the best way to reduce the stigma associated with depression.
Referred to the EAP, the employee is now receiving treatment. What does this mean? How do you help?
Depending on the severity of the depression, treatment may include talk therapy and/or medication. During the employee's recovery, please keep the following in mind:
- antidepressants usually take a few weeks to take effect. Don't expect dramatic results right away
- the sufferer may need to switch medications and/or dosage levels several times to find the right fit for his or her unique brain chemistry. Be patient and aware that the person may be suffering some side effects while adjusting to the medication
- in severe cases, including those sufferers who attempt suicide, hospitalization may be required. The employee also may need to take a disability leave
- the employee may need a flexible work schedule as he or she recovers. In many cases, the structure and distractions of work can help the healing process
- work with the employee to determine the right amount of work as he or she heals
- be sensitive to the employee's right to privacy. Consult with an EAP practitioner about the best way to handle the situation with coworkers and/or clients
Despite mounting evidence that depression is a medical condition, just as diabetes and high blood pressure are, a stigma still surrounds mental illness. Employers and coworkers often feel uncomfortable broaching the subject with their colleagues. But for the sake of your business and for the employee in question, intervention often is necessary. Remember, silence can be deadly.
Eric Hipple is the author of Real Men Do Cry: A Quarterback's Inspiring Story of Tackling Depression and Surviving Suicide Loss. Former NFL quarterback of the Detroit Lions, Eric experienced a debilitating downward spiral after his 15-year-old son died of suicide. Bankrupt and jailed for drunk driving, Eric sought therapy for his own depression and was able to make an amazing comeback. Eric works with the University of Michigan Depression Center as an outreach coordinator, where he travels nationwide speaking to teens and adults about ways to recognize the signs of depression and risks for potential suicide. For information, visit his publisher at www.QoLpublishing.com.
How IAPA can help
- Free downloads on work-life balance, healthy workplaces, and psychosocial risks:
- Free downloads on workplace stress
- Healthy workplace consultation, training and programming. IAPA consultants can help your firm generate safety and performance advantages that result from achieving nationally recognized healthy workplace criteria. IAPA is an authorized provider of NQI Healthy Workplace courses and related materials, the NQI Progressive Excellence Program (NQI PEP) and related materials, and related services.
In the News
Ontario proposes new OEL limits
On July 18, the Ontario Ministry of Labour launched a 60-day consultation period on proposed changes to occupational exposure limits for 21 substances. Deadline for comments: September 18. Ontario currently has OELs for over 725 hazardous chemical substances, based on limits recommended by the American Conference of Governmental Industrial Hygienists (ACGIH).
OELs restrict a worker’s exposure to hazardous substances on the job. Proposed changes include the following.
- Adding OELs for two substances not previously listed in Ontario regulations:
- butenes, all isomers and Isobutene
- polyvinyl chloride (PVC)
- Consolidating the following four separate listings for aluminum and its compounds into one listing for aluminum metal and insoluble compounds:
- aluminum – powder
- alpha-alumina (total dust)
- aluminum, metal and oxide dust
- emery (total dust)
- Withdrawing the following three listings due to ACGIH’s determination of insufficient data to support the OEL:
- aluminum, alkyl derivatives of
- aluminum, water-soluble compounds of
- triphenyl amine
- Withdrawing separate exposure limits for welding fume:
- exposure to aluminum-containing fume will be regulated by the OEL for aluminum metal and insoluble compounds
- exposure to iron-containing fume will be regulated by the OEL for iron oxide
- exposure to welding fume not otherwise classified will be regulated as Particles (insoluble or poorly soluble) Not Otherwise Specified (PNOS)
- revised exposure limits or listings for another 11 substances
- The development of an OEL for a specific particle size fraction for seven substances previously regulated.
Copies of the proposal appear on the Ministry of Labour website, or are available by e-mailing the OEL Update Project at oelupdateproject@Ontario.ca.
Once the consultation closes on September 18, ministry staff will review stakeholder submissions and hold meetings with concerned stakeholders, as needed.