Accident Prevention e-News
June 2009
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Volume 4/Issue 6/June 2009
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In this Issue:
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September enforcement blitz: hazardous materials
By Cyrus Gordon
 “I run a small paint manufacturing company in Kitchener, Ontario and we’ve just been inspected by the Ministry of Labour. The inspector noted that we use a lot of toluene and issued an order for us to set up a WHMIS program. If my employees take a WHMIS training course, will we be compliant?”
— a query received by IAPA’s Information Centre
IAPA’s Information Centre expects more inquiries about WHMIS—the Workplace Hazardous Materials Information System—in the days ahead. Hazardous materials will be the subject of a ministry enforcement blitz in September.
In an age where OHS management standards are a relatively new concept, it’s easy to forget that WHMIS, a standardized approach for managing workplace chemical hazards, has been a legislated requirement for over 20 years.
The purpose of WHMIS is to give employers and workers information about hazardous materials used in the workplace. Each province and territory across Canada has WHMIS requirements based on the federal Hazardous Products Act. Ontario’s WHMIS requirements are set out in the WHMIS Regulation (Reg. 860) under the Occupational Health and Safety Act.
In Ontario, all workplaces that may have a “controlled product” are required to implement a WHMIS program. Controlled products are hazardous and dangerous products, materials or substances identified by the Canadian federal Hazardous Products Act and its Controlled Products Regulations. So if your workplace uses these materials, WHMIS applies to you.
However, WHMIS is more than a regulatory obligation. IAPA Development Specialist Dina Meunier encourages employers to consider WHMIS as a valuable component of a chemical control program. It includes inventory, administrative and evaluation tools that enable a company to produce, use, store and dispose of chemicals safety and efficiently.
Soon, WHMIS will also help your company better compete in the international marketplace. More on this later.
Your WHMIS responsibilities
Under WHMIS, employers are responsible for delivering information about hazardous chemicals and other materials in three ways:
- ensuring containers of hazardous materials are properly labelled
- ensuring these labels are backed up with easily accessible material safety data sheets (MSDSs) containing additional hazard and precautionary information
- providing education programs for workers
So, in response to the inquiry we received, investing in WHMIS training for your employees would be a good first step in meeting responsibility #3. However, if you don’t already have a WHMIS program in place, IAPA Consultant and Occupational Hygiene Specialist Kimberly O’Connell urges you to first conduct a hazardous materials inventory in order to have a clear picture of which hazardous materials are present in the workplace and who’s exposed to them.
“Your ducks should be in order first before signing anyone up for WHMIS training,” explains O’Connell. Otherwise, you’re wasting resources and preventing trained workers from applying their new-found knowledge. “Besides,” says O’Connell, “the last thing a firm wants is to slap in place training that will highlight any issues of non-compliance.” Especially with an enforcement blitz ahead.
Hazardous materials inventory: assessing chemicals and identifying who’s at risk
The purpose of a hazard inventory is threefold:
- identify all hazardous materials in the workplace
- check whether proper controls and procedures are in place
- identify circumstances in which employees may be exposed to the hazardous materials
The more detailed the inventory, the better. Consider all materials used, produced and received in the workplace. Proper controls include the presence of proper MSDSs and labels, and procedures to ensure that labels and MSDSs are kept up to date.
Since inventories can be organized in a number of ways, IAPA has developed guidelines and checklists to help you assess your WHMIS needs (see “How IAPA can help”). “I often suggest conducting the inventory by department or work process,” explains O’Connell.
This approach identifies hazardous chemicals, as well as who must participate in WHMIS training. WHMIS requires employers to provide training for anyone
- who stores, handles, uses or disposes of the product
- who immediately supervises another worker performing the above duties
- whose health and safety could be at risk during storage, handling, use or disposal of a controlled product; during maintenance activities; or during emergencies and spills
Essentially, an employee doesn’t have to work directly with a hazardous material to be a candidate for mandatory WHMIS training. Just by working in a building that contains a hazardous material is enough. Exposure could occur at any time to any number of workers.
WHMIS is especially important for firms with young or new workers. “The timing of WHMIS training for new workers is critical,” says Dina Meunier. “You need to train them right away, not after they've had a month on the shop floor. If their job involves handling a hazardous material, even just one product, WHMIS training is required before they are asked to work with it.”
Developing your training program
Transforming the results of the hazardous materials inventory into a WHMIS training plan must be a collaborative approach. WHMIS requires employers to consult with the joint health and safety committee (JHSC) or health and safety representative when developing, implementing and reviewing a WHMIS education program. O’Connell recommends that employers go even further. “Involving supervisors is also of the upmost importance, as they’re very well versed in all the hazards in their work area.”
The hazards identified in the inventory will form the goals of your training program. Though each company will have its own WHMIS training needs, the WHMIS regulation identifies specific topics that must be covered in any training program. These include:
- labels and MSDSs — information required and the purpose and significance of the information
- procedures for the safe use, storage, handling and disposal of a controlled product
- procedures to follow where fugitive emissions are present
- procedures to follow in an emergency (e.g., spill or first aid) involving a controlled product
Selecting your WHMIS trainer
So now that you’ve identified your WHMIS training needs, who’s going to deliver the actual training program? The choice is yours. Because WHMIS is a performance-based system, the regulation contains no special qualifications for WHMIS trainers or specific requirements on how the training is to be delivered. Instead, training effectiveness is best measured by how well employees understand WHMIS concepts. The employer is, in the end, responsible for ensuring that employees are trained to a proper standard.
Generally, larger organizations have in-house WHMIS expertise and arrange for internal OHS staff, human resources staff, and joint health and safety committee members to deliver training. Smaller companies often use external service providers to deliver training, or use generic WHMIS training programs.
O’Connell recommends using tough criteria when selecting your WHMIS trainer. “They should bring a skill set that combines a knowledge of WHMIS legislative requirements and an understanding of the chemical hazards in your workplace,” she says.
A solid training background will also help ensure that WHMIS concepts are effectively conveyed to today’s diverse workforce. “WHMIS training doesn’t have to be complicated,” says O’Connell. “An effective trainer knows how to deliver a visually-driven, plain-language session that crosses ESL [English as a second language] and other boundaries.”
If you go ahead with an external training provider, watch out for “one-size-fits-all” solutions, because by nature they can’t accommodate specific needs. “Each workplace operates under unique circumstances, says O’Connell, “and an effective training program reflects this.
“For example,” continues O’Connell, “IAPA has a self-study DVD training package and new e-courses to support internal training programs. These courses cover the basic, core legislative pieces required for worker education, along with special responsibilities for managers and supervisors. Also, the DVD and e-learning formats mean that training can be delivered to workers from desktops.”
To supplement the generic WHMIS training, IAPA offers solutions to a company’s unique requirements. “We have a WHMIS ‘Train-the-Trainer’ course that allows internal staff to learn the facilitation skills to build custom programs for their company,” says O’Connell. “Also, our half-day WHMIS course is a brand-new, interactive, in-class facilitated session that allows consultants to answer specific questions. It can also be adapted for a customized in-plant session.” (See “How IAPA can help” for more on these and other training options.)
Evaluating your WHMIS training
Ensuring that employees understand and can apply WHMIS training is a legal requirement. “Evaluation of training is important,” says Meunier. “Too many companies conduct WHMIS training and don’t evaluate the knowledge of their employees or their ability to apply the information.”
Meunier recommends building an evaluation component right into the training course. This can be done by having participants complete an oral or written test.
“For compliance purposes,” says O’Connell, “make sure you record all aspects of the training, including names of the instructor, participants, course dates, material covered, and test results.”
Continuous evaluation and improvement are also needed. Review WHMIS training programs at least annually or more frequently if workplace conditions change (e.g., hiring new staff, introducing new chemicals) or if new information about a controlled product is released.
Enforcing WHMIS
The Ministry of Labour takes WHMIS violations seriously. Recent examples of fines against companies convicted for a failing to implement WHMIS include
- $50,000 against a small auto repair shop
- $65,000 against a company operating a chain of photocopying and printing outlets
The human cost for ignoring WHMIS is also high. The fine against the auto repair shop resulted from an incident where a welding torch ignited the fumes of a nearby container of lacquer thinner. The welder suffered serious burn injuries and spent 6 weeks in hospital.
According to the ministry, inspectors monitor WHMIS compliance during regular health and safety inspections, or during the investigation of related complaints, incidents or work refusals. Inspectors routinely check that
- controlled products are properly labelled or identified
- MSDSs are present in the workplace
- worker education programs have been carried out
For a violation of WHMIS provisions, the penalties on summary conviction are the same as the penalties for any other violation of the act or its regulations: a fine of up to $25,000 and/or a term of up to 12 months in jail.
The future of WHMIS
Canadian regulators are now exploring how to amend WHMIS so that it supports a planned new international standard for classifying chemicals—the Globally Harmonized System (GHS).
GHS was developed by the United Nations, ILO, OECD and other agencies to harmonize how chemicals are classified in different countries. Though similar to WHMIS in approach, GHS is more complex, having more hazard categories and fewer chemical exemptions.
Unlike WHMIS, GHS is currently a voluntary standard. However, countries that don’t adopt GHS will be at a disadvantage when conducting business internationally. Therefore, developing a solid WHMIS program today will make the move to GHS tomorrow a small step rather than a huge jump.
How IAPA can help
IAPA offers a number of options:
- classroom/on-site training courses
- WHMIS for Workers Self-Study Training Package (DVD format)
- WHMIS: Workplace Hazardous Materials Information System (1/2 day; also available on site)
- WHMIS: Train-the-Trainer (3 days)
- e-courses; one hour unless otherwise indicated
- WHMIS for Managers and Supervisors in Ontario
- WHMIS for Workers (ENG and FR versions)
- WHMIS Refresher (ENG and FR versions)
- WHMIS: Understanding MSDSs (ENG and FR versions; 1.5 hours)
- free downloads
- WHMIS General Information
- WHMIS Inventory Form
- WHMIS Training Requirements
- consulting services, including
- hazard assessment reports and recommendations
- development and delivery of awareness presentations on specific topics
- assistance in delivering systematic, written health and safety program procedures
- customized on-site training
Ladder safety for DIYers
 Any items on your to-do list involving ladders? Take steps so that you don’t join the surging numbers of other Do-It-Yourselfers visiting hospital emergency units with ladder injuries.
A US study reported recently in the American Journal of Preventive Medicine noted that, between 1990 and 2005, the number of nonfatal ladder injuries treated in emergency rooms—22,177,888—leapt by 50%. Three-quarters of the injured were male, and 97% of injuries occurred in what one researcher described as “non-occupational” settings.
If the injury involved a fracture, treatment may have included a lot more than just taking it easy. "Many of these fractures are very complex and require extensive surgery,” says a medical expert quoted in media coverage of the research. But that's only part of the problem, he says. “These fractures of hands, wrists, ankles and feet can require future surgeries, rehab and lifelong arthritis or chronic pain.”
A US National Institute for Occupational Safety and Health (NIOSH) study classifies ladder falls under three broad categories:
- incidents in which the wrong ladder was used to do a job
- incidents in which the ladder failed due to the physical condition of the ladder or its supporting surface
- incidents in which the ladder was improperly used
The following 14 suggestions can help you avoid falls in each of these categories. They’ve been drawn from a number of sources, including the Canadian Centre for Occupational Health and Safety (CCOHS), American Ladder Institute, and Manulife Financial.
Before you set up the ladder…
- ensure it suits the task at hand. If you’re using it around electricity, it must be made of wood or Fiberglas
- check the duty rating on the ladder’s safety label. The rating indicates the maximum weight load the ladder can safely hold. This rating corresponds to the total weight of the climber, plus the weight of all tools and gear the climber will bring onto the ladder. Can’t read the safety label? Can’t find it? Don’t use the ladder. It may be too old to be used safely
- select the right size. To determine the highest standing level required, measure the total height you would like to reach and subtract the climber’s height
- inspect it before use. Check for loose hinges or rungs, and clean off any foreign substances (e.g., mud, grease)
- check for obstacles, such as electrical wires and tree limbs
- avoid positioning the ladder near any door that is not properly locked, secured or guarded
Before you climb…
- stabilize the ladder. Ensure it always has 4-point contact with the working surface, and proportional pressure on each leg. Place it on a firm, level surface, never on ground that is uneven. If the working surface is slippery or unstable, tie or strap the ladder to the rear surface at the top and bottom. If these requirements are too restrictive, you’re probably using the wrong ladder
- always engage the ladder locks or braces before climbing the ladder
- wear-slip resistant shoes and ensure your hands and feet are dry
When you climb…
- always face the ladder when climbing up or down. Centre your body between the side rails. Maintain a firm grip and use both hands when climbing
- always maintain three points of contact with the ladder, e.g., with two feet and one hand
- centre your weight within the rails of the ladder
- avoid reaching at any time, since it can cause the ladder to topple over. Aim to keep your belt buckle within the side rails
- never use ladders in strong wind
When you’re finished…
- store ladders in sheltered, dry, well-ventilated areas to prevent weather damage, such as rust and warping
- support ladders horizontally on racks. To prevent sagging, support ladders every 2 meters. Do not hang ladders from rails or rungs
How IAPA can help
If your workplace contains machine-related hazards, consider these options.
- Download Ladders, a free 4-page guideline that discusses safe use of straight ladders and step ladders, what to include in a training program, proper maintenance, and relevant legislation. Provides an inspection checklist.
- Talk to a consultant. IAPA consultants have experience and knowledge regarding fall and other hazards, and can provide assessments or answers to your questions.
TDGA amendments to boost safety and security
 Changes to the federal Transportation of Dangerous Goods Act that received Royal Assent on May 14 will enhance safety and security in the transport of dangerous goods. An estimated 30,000,000 shipments of dangerous goods occur in Canada each year.
With a focus on prevention, the act assigns roles and responsibilities to shippers and carriers, and empowers inspectors to take immediate steps as needed in the event of an incident.
Among the changes, the amendments
- reinforce the existing Emergency Response Assistance Program, which requires shippers of dangerous goods to have emergency response assistance plans (ERAPs) in place. It would also allow Transport Canada to request that such plans be implemented in the event of a terrorist or other security incident
- enable Transport Canada to draft regulations requiring that dangerous goods be tracked during transport, and that incidents involving loss or theft be reported. The amendments would enable the use of security measures and interim orders, in accordance with the Public Safety Act and other legislation
- require security plans and training
- require security clearance for personnel working with dangerous goods
- amend the concept of importer to clarify who in Canada is subject to the act and its regulations with respect to importing dangerous goods
- harmonize the act with UN recommendations and classifications
The amendments were drafted following public consultation sessions that began in 2004, and were originally presented to Parliament in 2008 as Bill C-56. However, that bill died on the Order Paper with the dissolution of Parliament. Now that Parliament has passed the current amending act, Bill C-9, consultations will continue as Transport Canada begins drafting the necessary regulations.
ERAP refresher
Most duties under the act fall on the shipper:
- classifying the goods
- selecting and properly using the correct means of containment
- submitting an ERAP to Transport Canada
- preparing the shipping document, including information and ERAP numbers
- attaching safety marks
Detailed information required in an ERAP include:
- a list of the dangerous goods being transported
- a description of the shipper's emergency response capabilities
- a list of specialized equipment available for use at the emergency site
- a list of qualified persons available to advise and assist at the scene, and the communications systems expected to be used. The revised legislation would require that ERAPs also be submitted to cover security incidents
How IAPA can help
- Learn about your company’s TDGA responsibilities in IAPA’s new half-day course, Transportation of Dangerous Goods. Also available for on-site delivery.
- Train workplace parties to handle hazardous materials safely and responsibly in the workplace with these WHMIS (Workplace Hazardous Materials Information System) offerings:
6 heat stress questions
 Is heat stress a concern in your workplace, asks a new-for-2009 Heat Stress Awareness Guide. Created by members of the Occupational Health and Safety Council of Ontario (OHSCO), including IAPA, the guide posits these questions:
- Has anyone been affected by heat in your workplace?
- Are fans needed to keep workers cool?
- Is work done in direct sunlight?
- Are there heat-producing processes or equipment in the workplace?
- Do workers wear extra clothing/protective equipment that can make them hot (e.g., overalls, respirators, hard hats, etc.)?
- Have workers ever expressed concern?
Your obligation
Under section 25(2)(h) of the Occupational Health and Safety Act, employers have a duty to take every precaution reasonable in the circumstances for the protection of a worker. This includes developing policies and procedures to protect workers in hot environments due to hot processes or hot weather.
For compliance purposes, the Ministry of Labour recommends adopting the current threshold limit value (TLV) for heat stress and heat strain, published by the American Conference of Governmental Industrial Hygienists (ACGIH). These values are based on preventing the core temperatures of workers who are not acclimatized from rising above 38°C.
The longer you work in a hot environment, says the ministry, the better your body becomes at adjusting to the heat. This process is called “acclimatization.” If you are ill or away from work for a week or so you can lose your acclimatization. To become acclimatized, spend 20% of the first day in hot working conditions, and increase your time by 20% each subsequent day.
Heat stress control measures
The Ministry of Labour suggests the following measures to control exposure to heat stress.
1. Engineering controls
- reduce the physical demands of work task through mechanical assistance (e.g., hoists, lift–tables)
- control heat at its source with insulating and reflective barriers (e.g., insulate furnace walls)
- exhaust hot air and steam produced by operations
- reduce temperature and humidity through air cooling
- provide cool, shaded work areas
- provide air-conditioned rest areas
- increase air movement if temperature is less than 35°C (e.g., use fans)
2. Administrative controls
- assess the demands of all jobs and have monitoring and control strategies in place for hot days and hot workplaces
- increase the frequency and length of rest breaks
- schedule strenuous jobs for cooler times of the day
- provide cool drinking water near workers and remind them to drink a cup about every 20 minutes
- caution workers to avoid direct sunlight
- assign additional workers or slow down the pace of work
- make sure everyone is properly acclimatized
- train workers to recognize the signs and symptoms of heat stress and start a buddy system since people are not likely to notice their own symptoms
- encourage pregnant workers and workers with a medical condition to discuss working in the heat with their physicians
- ensure first aid responders and an emergency response plan are in place in the event of a heat related illness
- investigate any heat-related incidents
3. Personal protective equipment
- wear light summer clothing to allow free air movement and sweat evaporation
- when working outdoors, wear light-coloured clothing
- in a high radiant heat situation, reflective clothing may help
- for very hot environments, consider air, water or ice-cooled insulated clothing
- take extra caution, such as monitoring heat strain, when wearing vapour barrier clothing. It can greatly increase the amount of heat stress on the body
How IAPA can help
Learn more about managing heat stress by
1. downloading the three components of a heat stress toolkit, developed by the members of the Occupational Health and Safety Council of Ontario (OHSCO), including IAPA.
The toolkit provides strategies for
- recognizing the symptoms
- assessing the risk
- putting together an effective control program
In the toolkit you’ll find these tools:
2. talking to an IAPA consultant about creating, assessing or improving a heat stress management program
- Attend either of two half-day courses, Pandemic Planning: Is Your Business Ready, on June 23 and 25 in Mississauga and Burlington, respectively.
- Go to our Pandemic Planning page for a list of IAPA resources, including the two courses, a pandemic Q&A, free downloads, and the latest pandemic news
- Check out Diminishing Risks, from the May/June issue of Accident Prevention magazine, for a series of risk assessment tips.
In the News
“Tweet” tips for young workers
Employers of summer students have a new tool to help ensure their workers are well-informed. Students holding down summer jobs this year can add “WorkinSummer” to their twitter feeds.
Every week until Labour Day, Ontario’s Ministry of Labour will tweet tips about on-the-job health and safety and employment standards on this site, specially created for young workers. Each tweet poses a question and provides links to a section of the ministry’s website for the answer and related information. Learn more at www.twitter.com/WorkinSummer.
Global pandemic alert: now at 6 on a scale of 6
In a June 11 statement to the press, World Health Organization (WHO) Director-General Margaret Chan announced the WHO has raised the level of its the H1N1 influenza pandemic alert from phase 5 to phase 6.
This particular H1N1 strain is entirely new and contagious. It spreads easily from person to person, and from one country to another. WHO figures as of June 11 show nearly 30,000 confirmed cases have been reported in 74 countries. “Further spread,” said Chan, “is considered inevitable.”
Despite the virus’s rapid spread since it emerged in late April, Chan remarked that “no previous pandemic has been detected so early or watched so closely, in real-time, right at the very beginning... We have a head start. This places us in a strong position.”
The WHO believes that, based on current information, this pandemic may be of moderate severity. However, severity can vary, depending on many factors, from one country to another.
IAPA can help you reduce the health, safety and business continuity implications of a pandemic.
Melanoma: have you checked your skin?
We may be aware of melanoma—a skin cancer that can spread to the rest of the body—but half of us aren’t checking our skin often enough, according to a survey conducted in May for the Canadian Dermatology Association.
Almost 1,000 Canadians will die this year from melanoma, and 5,000 will be diagnosed with it. The lifetime risk of melanoma for Canadian men is now 1 in 74. For women, it’s 1 in 90. This risk has risen dramatically. For example, the lifetime risk of melanoma for Americans in the 1930s was 1 in 1,500.
Up to 70% of melanomas are first identified by patients themselves (53%) or close family members (17%). Early detection is crucial. It’s directly linked to a high survival rate of 90% for Canadians. However, survey results indicate that, when it comes to actually checking our skin, 55% of us don’t check often enough. Among this group, 24% never check their skin and 31% check “less often” than every couple of months.
As a guide, we should check our skin for signs of skin cancer once a month or every couple of months.
Who’s at greatest risk
For people aged 15 to 29, melanoma was the third most common cancer in young women, representing 11% of new cases. However, melanoma affects all genders and age groups.
Melanoma occurs most on men’s backs and women’s legs but can appear anywhere, including the arm, scalp or face. It can also occur on soles, palms and genitalia, inside the mouth, and underneath nails.
Some of us are at greater risk than others, regardless of age. Those at greatest risk have
- fair skin that burns and is unable to tan
- freckles
- red or blond hair
- many moles
- moles that are large or unusual in colour or shape
- a close family history of melanoma
- excessive ultraviolet exposure from the sun and/or sunbeds, especially if exposure begins in adolescence or young adulthood
- a history of severe sunburns
Many survey respondents were aware that lots of sunburns is a major risk factor (80%), However, only 42% knew that having many moles or large moles is a strong risk factor too. Even fewer (34%) recognized that having skin that freckles or is unable to tan, or red or blonde hair (30%) are also risk factors.
Protect yourself by
- assessing your personal risk
- knowing the early warning signs of melanoma, the ABCDEs.
- checking your skin, including hard-to-see areas such as the back
- limiting exposure to ultraviolet radiation by using sunscreen, wearing hats and clothing, and seeking out shade
What to look for
Mole warning signs—the ABCDEs—include the following. If you have a mole or growth with one or more of the ABCDEs, show it to your physician as soon as possible:
- asymmetry, which can be assessed by comparing one half of the growth to the other half. Unequal or asymmetric moles are suspicious
- border. If the mole's border is irregular, notched, scalloped, or indistinct, it is more likely to be cancerous (or precancerous)
- colour variation, (e.g., more than one colour or shade). Different shades of browns, blues, reds, whites, and blacks are all concerning
- diameter. Consider any mole that has a diameter larger than a pencil's eraser (> 6 mm) to be suspicious
- elevation. Look for moles that are elevated or raised from the skin
Change is also a concern. For example: changes
- in colour, especially multiple shades of dark brown or black; red, white and blue; or spreading of colour from the edge of the mole into surrounding skin
- in size, especially sudden or continuous enlargement
- in shape, especially development of irregular margins or borders
- in elevation, especially sudden elevation of a previously flat mole
- in the surface texture of a mole, especially scaliness, erosion, oozing, crusting, ulceration, or bleeding
- in the surrounding skin, especially redness, swelling, or new moles
- in sensation, especially itching, tenderness, or pain
If any mole or growth is changing, have it checked by a doctor.
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