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PSHSA’s response and recommendations to the questions posed in the Ministry of Labour’s discussion
paper highlight ways in which Ontario’s Health and Safety System can be renewed.
Enhanced Service
Delivery
THEMES
P
R
I
O
R
I
T
I
E
S
Support for Those
Who are Most in Need
Meeting Changing Individual
and Organizational Needs
THEMES
Addressing the Needs
of Vulnerable Workers
Responding to Small
Business Needs
Assistance for High
Hazard Activities
Integrated Planning and
Service Delivery
Expanding Capacity through
Innovative Partnerships
Effective Support for
Workplaces
Addressing Occupational
Disease
Effective Financial and
Non-Financial Motivators
Research Supporting System Improvement Effective Means for Measuring Performance
• Partnerships In and Beyond Ontario’s H&S System
• Use a Combination of Digital & Traditional Media
• Coordinated Messaging Across the System
• Employer Education on Vulnerable Worker Rights
• Revisit the Economic Model
• Create a Strong Business Case
• Embed Research in Approach
• Develop Small Business-Specific Resources
• Create a Common Focus
• Enhanced Use of Online Tools
• Streamline Service Delivery
• Link Funding to Outcomes
• Review Shared Services
• Collaborate but Maintain Sectoral Specificity
• Facilitate Research Uptake
• Leverage Existing Partnerships
• Form New Partnerships
o Cross-jurisdictional
o Private Sector
o Across OPS & BPS
o Labour & Trade Associations
1
2
3
• Revisit the Economic Model
• Create a Strong Business Case
• Embed Research in Approach
• Develop Small Business-Specific Resources
• Create a Common Focus
• Enhanced Use of Online Tools
• Form System Working Groups
• System Collaboration & Alignment
• Form Partnerships Beyond the System
• Integrate New Research in Products/Services
• Develop & Market New Products/Services
• Enhance & Customize Current Products/Services
• Shift Culture to Embrace Collective Responsibility
• Clear Definition of Compliance
• Integrated Product Development/Dissemination
• Enhanced Use of Technology/Multi-Format Offerings
• Development of a Resource Library
• Better Sharing of Best Practices
• Multi-Staged Motivation (Financial Rebates
as well as Information and Services)
• Leadership Status
• Accreditation Process
• Certificate of Recognition
• Funding Approach
4
5
6
7
8
• Measuring Outcomes (e.g. Decreased Injury &
Illness Rates, Decreased Occupational Illness,
Effective H&S Training Programs, Positive
Workplace Culture and Psychologically Safe
and Healthy Workplaces)
• Develop a Repository of Reports
• Define Measures
• Schedule 2 FTE Information
• Ensuring Completeness of Information
(Forms 6,7 and 8)
• Leading Indicators (e.g. Training, Risk
Assessment and Organizational Culture) &
Lagging Indicators (e.g. WSIB Composite,
Non-occupational/Insurer Data, Human
Resources Data)
• Surveys (e.g. Employee Engagement)
• Strategic Objectives:
o Understand Needs & Gaps
o Research Alignment & Improve
Data Collection
o Expand Research Networks
o Evaluate H&S Program
Effectiveness
o Translate Research into
Products & Services
• Continuing Partnerships
• Engaging the Right People
• Tools & Messaging
• Creating a Forum
• Solid Internal Processes
• Focus Groups
9 10
Injuries, Illness & Fatalities
ZERO WORK RELATED
Introduction
The Ministry of Labour (MOL), through the Chief
Prevention Office (CPO), is seeking feedback regarding
Ontario’s first Integrated Occupational Health and Safety
Strategy. The discussion document, “An Integrated
Occupational Health and Safety Strategy for Ontario”,
outlines the vision and three strategic themes for the
system, and poses questions to stakeholders around ten
priorities.
This is an exciting time for Ontario and we appreciate
the opportunity to contribute to the future direction of
health and safety in the province. As an integral part
of Ontario’s Health and Safety System, Public Services
Health & Safety Association (PSHSA) is pleased to
submit our response to the Strategy paper.
To ensure that our response was representative, our
approach involved a consultative process. The draft was
sent to our own staff and management as well as the
organization’s broader stakeholders, including members
of our advisory councils and board of directors, for the
purpose of gathering feedback.
PSHSA serves over 9,500 organizations and 1.2 million
workers across the province’s public service sector.
We work closely with Ontario education and culture,
community and healthcare, municipal and provincial
government, emergency services, and First Nations,
offering consulting, training and resources to reduce
workplace risks and prevent occupational injuries,
illnesses and fatalities.
Working in regional teams, our consultants have
valuable expertise in common workplace issues such
as musculoskeletal disorders (MSD), slips, trips and
falls, workplace violence, and due diligence. Putting
this experience to work, we help organizations identify
workplace hazards, develop effective policies and
procedures and provide the right tools to address their
unique health and safety needs. With a long history
of regional, sectoral and industry expertise, we are
well positioned to offer constructive feedback on an
integrated health and safety strategy for Ontario.
When it comes to health and safety, Ontario faces a
number of challenges. Both Ontario’s Health and Safety
System and workplaces continue to experience times of
constraint. Furthermore, today’s workplaces remain in a
time of transition. They continue to experience sectoral
and labour adjustments, economic changes and fiscal
constraints, continued technological innovation and
adoption, an aging workforce, and social shifts. There are
new priority areas to address, however stresses, such as
the current economic climate, may lead firms to rethink
their investments in health and safety, citing a lack of
time and money. The system must reply collectively to
provide answers to these challenges and demonstrate
the benefits that prevention investments yield.
Ontario’s Health and Safety System has accomplished
a lot throughout its history. As the system continues
to evolve, we will continue to lead the way in our
prevention activities and are glad to offer our support
and assistance in any way. There is still a lot to be done
and we look forward to working together towards
building a stronger, more innovative and renewed Health
and Safety System.
3
Summary
In addressing the Strategy paper, PSHSA
identified several common themes that can help
position the system for future success.
Develop a Renewed Focus on Purpose
The prevention system must instigate a mindset
shift where all employers and workers know,
understand and demonstrate the importance of
occupational health and safety. System partners
must continue to focus on the end outcome –
zero injuries and illness. And new stakeholders
– labour and employer groups, associations,
community groups, all level of government –
must be engaged to act as advocates for health
and safety.
Coordinate and Collaborate as a System
Together, the prevention partners must build
a stronger culture of collaboration as well as
expand and leverage relationships for the benefit
of the Health and Safety System and Ontario
workers and employers. A collaborative approach
will assist Health and Safety Associations (HSAs)
and other system partners in maximizing our
funding and resources by ensuring the greatest
return on investment.
Collaboration and coordination can achieve many
things. It can help minimize repetition among
the products, training and services developed
and delivered by system partners, while still
maintaining the sector specificity needed by
workers and workplaces. Partners should seek
to avoid duplication in their activities by looking
for mutually beneficial opportunities to work
together and ensure the system is operating
efficiently and moving prevention forward.
Secondly, collaboration helps to avoid crossover
between sectors by system partners. This can be
done by finding new ways to work together to
ensure clients are properly directed through the
system and to the appropriate HSA (e.g. through
referrals, shared services). This will also improve
the collective ability to measure the effectiveness
of prevention programs.
System partners should work together to create
a common message, and look to utilize multiple
methods of reaching workers and employers
to optimize its reach and maximize the
effectiveness of awareness campaigns. Examples
of this include forming the aforementioned
partnerships and enhancing and expanding use
of social media.
The system must look to collaborate with those
outside of the current structure and expand
partnerships. For example, connecting to workers
and workplaces through partnerships with
provincial ministries, federal departments and
agencies and research organizations should be
encouraged.
In addition, the system must also understand
that health and safety efforts are not confined
just to those identified as stakeholders in the
introduction of the discussion paper. There are
service providers who can be better integrated
into the fold. Currently there are a number of
private health and safety providers offering
training and other services, but who are not
included in the overall business model. One
suggestion may be for PSHSA to be a solution
provider, developing sustainable and outcome-
based content for private organizations to
deliver.
Where possible, system partners should also look
to coordinate research efforts as well as ensure
there is sustained knowledge transfer and uptake
in the programs and service delivery.
Underlying coordination and collaboration is the
need to put in place the mechanisms to support
collaboration across the system. For example,
there should be incentives and conditions in
place which encourage partnerships.
Eliminate Barriers to Prevention
There are opportunities for the Health and
Safety System to think differently about the way
it optimizes its reach and improves prevention
effectiveness. These include, but are not limited
to, the following recommendations.
Rather than remaining insular, the system should
look externally, across Canada and beyond, to
identify best practices, streamline delivery and
increase efficiency.
The system should consider reviewing and
realigning the funding model to align with
economic realities as well as the needs of
workers, employers and the system itself, and to
encourage cooperation. This includes reviewing
and aligning the partners differing business
models, and thinking strategically as a collective.
This will also be supported though developing a
shared understanding of system issues between
partners, including an improved and common
view of the provincial market as well as the social
and economic landscape.
Similarly, measurement of the impact and
effectiveness of solutions and services provided
should be carried out across the system.
The report expands on these recommendations
and seeks to inspire a renewal of Ontario’s Health
and Safety System.
4
1 Addressing the Needs
of Vulnerable Workers
5
How can the voice of the vulnerable worker be brought into the occupational
health and safety discussion to better understand their needs?
1a
For our organization, it is important to first address the definition of vulnerable workers. Many public service workers only fit loosely into the
provided categories. Regarding factors that contribute to worker vulnerability, an additional consideration is that lack of training does not necessarily
mean there is no education available for a group of workers. For some public sector workers, education is largely unregulated. For example, personal
support workers can receive the same certificate by taking a 10 month college program or a private weekend course.
It is integral that the voice of vulnerable workers be brought into the occupational health and safety discussion so that we, as a system, can better
understand their needs. The best way to do this is to reach out and engage these workers. The approach should consider both the modes of
communication as well as the points of connection.
Connecting Through Partnerships Beyond Ontario’s Health and Safety System
There are many touch points where workers and potential workers need or choose to go for information. By partnering with these organizations,
system partners can not only connect vulnerable workers to valuable health and safety education and resources, but listen and receive input from
them as well. Reaching vulnerable workers can be aided through relationships with community centres and associations, various government entities,
and employer and labour associations.
Developing relationships with local and regional community-based centres and associations, such as religious and medical centres, can help provide
access to vulnerable groups. A variety of formal and informal associations, both known and unknown, exist in every community. Efforts should be
made to identify these groups and reach out to them.
Further, many of PSHSA’s clients work in public services and are funded through various government entities. It may be beneficial to collaborate with
other ministries as many clients and vulnerable workers have already formed relationships with them.
Lastly, several vulnerable workers, and the workplaces that employ them, are represented by various industry associations. By partnering with
employer and labour associations, the system will be able to better connect with vulnerable groups.
Utilizing Online, Social and Mobile Media
It has been suggested that the system provide a venue that vulnerable workers can relate to, such as a communications portal, hotline, mobile
application or social media channel. This will not only provide vulnerable workers with support by delivering on-demand advice and resources, it will
act as a venue for open discussion and learning as well. This will complement the system’s more traditional approaches.
6
Strengthening the occupational health and safety of vulnerable
workers can be facilitated through partnerships, education,
collaboration and better communication.
Partnerships
It is understood that introducing workers to the basic rights and
contacts for health and safety can lend to positive awareness
efforts. Citizenship and Immigration Canada is often the first point
of contact for entrants into the country, as the office coordinates
work permits for new immigrants, refugees, protected persons and
permanent residents seeking to legally work in Canada. Similarly,
visa offices, employment and job-training centres, and settlement
centres, which provide basic skills training, ESL/FSL training and
employment support, can act as other effective channels for
reaching vulnerable workers.
Another important partnership involves education institutes and
related provincial ministries (e.g. Ministry of Education, Ministry
of Training, Colleges and Universities). By adding health and
safety programming into university, college and training college
curriculums, we are able to access those who will eventually enter
the workforce. Likewise, reaching out to grade school levels can
help build awareness as well as the foundational elements of a
health and safety culture among young students; this is sure to
have long-felt impacts.
Lastly, the system should look to connect and form partnerships
with labour and employer associations to help educate the
workers that these associations represent on the significance of
occupational health and safety.
Employer Education
System partners should work together to educate employers
about vulnerable workers, who they are and what they need. This
includes communicating the importance of worker orientation and
job-specific training.
Coordinated Messaging
We must work as a system, collaborating and coordinating with
the other Health and Safety Associations (HSAs) to ensure the
prevention approach is reinforced. PSHSA can support outreach
efforts through providing information, tools and guidance, such as
eLearning and eConsulting, and acting as a resource for vulnerable
workers when required.
Multimodal Communication
For vulnerable workers, emphasis should be placed on
communicating in targeted ways. In this case, it is providing
information in multiple languages, modes and literacy levels.
Recognizing the diversity of the province, the system must make
a collective effort to translate materials into various languages
in a way that is cost-effective. This will help improve access to
information.
How can we strengthen the occupational health and safety of vulnerable
workers?
1b
7
2 Responding to Small
Business Needs
8
As with other priority groups, there are a number of considerations specific to understanding and meeting small business health and
safety needs, including: employers’ limited time and resources, the perception that small businesses are at minimal risk, and the need for
adaptable and on-demand products and services. The following recommendations can help small businesses and their workers achieve
safe and healthy workplaces.
Revisiting the Economic Model
The Health and Safety System’s economic model currently favours those industries and clients that are able to pay, rather than those who
cannot. There is a lack of focus on small businesses as they are unable to support or sustain an investment in health and safety. To help
address this concern, the system must look at ways that the current economic model can better include small business and encourage
emphasis on providing the tools and solutions they require.
Creating a Strong Business Case
Small business owners can get caught up in the bottom line and other pressures of business ownership, often losing sight of the bigger
picture. The system should work together to communicate a strong business case for health and safety. This involves framing the
message to clearly demonstrate the benefits associated with an investment in health and safety versus the costs of injuries and illness. It
should also state that, contrary to popular perception, the laws apply to small businesses as well.
Embedding Research in Approach
By incorporating research in the design and creation of new products and services, the system is able to provide perspective on small
business needs as well as what approaches will be effective in improving health and safety programs.
Developing Small Business-specific Resources
Partners can look to put together information kits that are adapted to the needs of small business. These can be distributed in multiple
formats through a variety of channels, including partnerships with other ministries.
PSHSA offers a free, downloadable Small Business Resource Guide detailing the ten steps toward building an effective health and safety
program. Furthermore, PSHSA’s eConsulting approach, which utilizes technology to provide just-in-time professional advice and services,
will assist small business clients with their immediate needs.
What can help small businesses and their workers
have safe and healthy workplaces?
2a
9
How can the occupational health and safety system partners
work with established networks to identify the needs of small
businesses and better understand how to address them?
2b
There are numerous established networks and associations to which small businesses are directed for purposes such as business
registration, tax filing or access to resources. These include: business groups, publicly funded centres (e.g. Business Help Centres),
associations (e.g. Canadian Federation of Independent Businesses, Chamber of Commerce) and provincial ministries (e.g. Ministry
of Economic Development). In working with these established networks, system partners are better able to identify and address
the needs of small business using the following approaches.
Create a Common Focus
In terms of how to work with these networks, system partners should first consider creating a common focus. The system should
look to develop a common message as well as a quick and easy connection to the system which clearly outlines where to go.
Promote the Business Case
Using a variety of networks, all system partners should do their part to communicate the message to small businesses about the
significant costs of injury and illness, and the benefits of preventing such.
Enhanced Use of Online Tools
System partners should consider enhancing and expanding the use of online and social tools to identify and address the needs of
small businesses. It may be impractical for owners, managers or staff to take a day for offsite training. Easy to use websites, social
media, videos, eLearning and just-in-time information can help facilitate increased health and safety knowledge and awareness.
Increase Availability of Tools
The system should seek to form strategic partnerships with new network partners. These partners can act as connection points to
small businesses and ensure the approach is appropriate for their sectors. The system should also look to leverage and enhance
existing tools, such as the Ministry of Labour hotline.
10
3 Assistance for High-
Hazard Activities
11
High-Hazard Activities: Those activities where the worker is regularly exposed to potential sources of serious harm or serious health effects (e.g.
working at heights, near and around heavy equipment, underground, or with hazardous substances).
When defining high-hazard activities, the system must consider the following:
•	 Activities where workers are exposed to uncontrolled conditions.
•	 Activities where workers are exposed to unknowns and unseen dangers (e.g. chemical exposure, exposures to conditions that may lead to
occupational disease).
•	 Activities for which protocols and standards of practice are in place, and injuries and illnesses have been prevented, but where the hazard has not
been eliminated.
•	 Activities which are preventable, but have high claims rates, though typically lack market appeal or research focus (e.g. noise, chemical exposures).
For high-hazard activities, it is vital to address the concerns ahead of time through risk assessment, and to be cognizant of all the potential individuals
who may be exposed to identified hazards through the work they are engaged in.
How do you define high-hazard activities? For example, would the definition
be based more on the seriousness of the potential injury or illness, or the
potential frequency of injury or illness? Would it be based on other criteria?
3a
12
Our organization feels that there are some high-hazard activities that should have more rigorous training, compliance and enforcement. These include:
confined space entry, working at heights, traffic control, trenching operations, heavy equipment operation, utility work, use of equipment and chemicals
in shops, work in labs and maintenance rooms, exposures to medical compounds (e.g. antineoplastics), social and community services (e.g. where there
is exposure to violence), work on energized systems (e.g. electrical, pneumatic, pressurized), and emergency rescue situations.
Please note that the development of rigorous standards is not only required for high-hazard training programs; they are necessary for qualifying trainers
and training providers as well.
What high-hazard activities should be subject to more rigorous training
standards, assurance of compliance or ministry enforcement?
3b
13
What concerns and challenges do you see for the Ministry of Labour in
implementing industry-wide training on specific tasks that have been
defined as high-hazard?
3c
Experience of Trainers
It is critical that health and safety is a focus of high hazard
training programs. Trainers must be strong facilitators so that
they are able to clearly communicate the risks and ensure there
is uptake of the message. Similarly, high-hazard activities require
more than general knowledge. Instructors must have a deep
understanding of best practices, gained through education or
prior experience, in order to properly address questions and
concerns that fall outside of the curriculum.
Considerations for Train-the-Trainer
Rigorous Train-the-Trainer standards need to be developed for
high-hazard activities. Prerequisites must be defined for trainers
requesting high-hazard Train-the-Trainer programs and a process
must be developed for managing this.
In addition, a system to manage the delivery of updates (e.g.
legislation changes, new best practices, refresher programs) for
those who have completed Train-the-Trainer programs should
also be considered. This would ensure that those who have
completed Train-the-Trainer programs are always delivering
the most current information, regardless of when they took the
course. If partners are going to offer Train-the-Trainer programs,
they must have the capacity to sustain them over time.
Potential Compromises
Organizations may choose alternative methods of training
delivery due to the following compromises. It is important that
we develop solutions as a system to mitigate these compromises.
The prevention system cannot support the notion that any
training is better than no training – the risks are too great.
First, organizations may be limited by financial constraints. This
can lead to decisions to seek alternative methods of health and
safety training and services. However, these alternatives may
not be current or up to standards. Second, many organizations
today feel pressure due to time constraints. As a result of heavy
workloads, organizations may opt for lesser training programs.
This is a particular concern for small businesses.
To cope with concerns and challenges when implementing
industry-wide training on high-hazard tasks, we recommend the
following for consideration.
Monitor Training Quality
When implementing standards, it is vital to designate trainers
only when all steps are complete, and build in the structures
to monitor the quality of training. A risk assessment should be
conducted to demonstrate the impact of doing otherwise.
Shift Towards Global Standards
In the past, there has been little made-in-Canada material
for emergency services training. However, Canada and other
jurisdictions are currently moving towards implementing global
standards and then adjusting for local applicable legislation (e.g.
National Fire Protection Association standards).
Drawing from Exemplary Models
Mining and Forestry programs maintain strict training standards
with mandatory training. Principles for implementation can be
derived from their models.
14
4 Integrated Planning &
Service Delivery Model
15
What are the highest priority gaps in occupational health and
safety system service delivery that needs to be addressed?
4a
Within the system, there are opportunities to address current
gaps and continue to improve prevention service delivery.
The challenges outlined herein are reflective of the current
environment; PSHSA would like to continue to find ways to
collaborate and address these.
Differing Business Models
System partners have distinct business models, including
pricing and, in some cases, services. This sends an
inconsistent message to clients and may hinder some
collaborative efforts.
Funding Not Aligned to Address Shifts in Needs and
Outcomes
Within the system, there are a number of self-imposed
barriers stemming from funding which is not linked to
outcomes, nor reallocated for sectoral structures, labour
shifts and economic realities.
Repetition Among Partners
Overlap exists between the back-end service delivery of
organizations funded through the same channels. There is
also repetition among products, training and other services
provided and developed by system partners, as well as
organizations outside of the publicly funded sphere. The
HSAs need to focus on maximizing funding by ensuring
the greatest return on investment. For example, as a
large and diverse province, there is a need for Ontario to
provide health and safety products in multiple languages.
Product translation may be an area where it makes sense to
coordinate.
In addition to products and services, there is currently
crossover in the sectors and clients that the system partners
serve. As a result, it is difficult to measure effectiveness.
System partners are unable to ascertain whether or not
our respective programs are truly effective. Moreover,
performance metrics are not accurately reflective of one
another’s work.
Inconsistent Research Integration
There are many examples where translating research
findings into products and services has positively impacted
prevention activities. There needs to be a level of consistency
and efficiency, as well as a better approach to facilitate this.
Similarly, there is a need for research outcomes to be linked
to funding.
No Standards for Data Analysis
Partners in the Health and Safety System have access to
the same information sourced from the WSIB EIW. However,
partners may extract and analyze it in various ways, often
leading to different approaches to address needs. Outcomes
are met, but there are no controls over ways to measure
comparative efficiencies.
16
detailing how partners should work
together.
Identify Areas of Sectoral Specificity
There is a need to ensure that sectoral
partners, including those in research,
adapt products and services to meet the
distinct needs of sectors as necessary,
such as hazard identification and control,
and in shaping messages to the particular
audiences. Since our sector specific
knowledge and expertise is what separates
the HSAs from private consultants, system
partners should continue to maintain
sector identity in our service offerings, yet
look for opportunities to collaborate where
it makes sense.
Facilitating Research Uptake
To improve prevention activities, the
system should provide the means to
enable the inclusion of research findings
into the products and services of system
partners.
There are a number of ways the system
partners and other organizations can align
to overcome these obstacles and improve
service delivery.
Streamline Service Delivery
As a system, we must develop a business
plan that works for everyone. This can
be done by learning from each other’s
business models, and jointly agreeing to
one which is used consistently across the
system.
Link Funding to Outcomes
This will continue to focus partner
activities on delivering health and safety
improvements. Consideration should be
made regarding allocation of funding to
where the needs exist, whether based on
priority groups and proportion held by a
system partner, market size, and so forth.
Review Shared Services
The system must work together to develop
a common definition for shared services.
Having expertise in this area, PSHSA is
willing to lead a committee or project team
to look into this further.
System partners must work together
to identify where there are unexplored
opportunities to collaborate that will
benefit the system by leveraging resources
and reducing duplication. System partners
need to find new ways to work together
to ensure clients are properly directed
through the system and to the appropriate
HSA (e.g. through referrals, shared
services). In addition, by maintaining
sectoral specificity in the clients and
sectors with which we do business, system
partners will have a better understanding
of the effectiveness of their programs.
For example, the system can create
branding and marketing guidelines that
support the overall goal of consistent
messaging. This will ensure the client gets
the right help at the right time. This relates
to the idea of establishing expectations
How can we align system partners and other organizations to improve
service delivery? Can you provide examples?
4b
17
18
5 Expanding Capacity
through Innovative
Partnerships
What new partnerships could advance occupational health and
safety?
5a
19
First and foremost, it is important to note
that it is not only new partnerships that can
advance occupational health and safety; existing
partnerships can also be leveraged. The system
should consider the following:
•	 Refocus on outcomes (lives saved) across
the province and beyond.
•	 Look to define and describe measures
and outcomes in the same way across the
system.
•	 Coordinate shared messages throughout the
system.
•	 Remove artificial barriers and continue to
work toward collaborative delivery and
aligned business models.
•	 Identify where gaps exist and mutually
beneficial relationships can be struck.
•	 Improve the internal capacities of the
HSAs and other partners to deliver on the
prevention mandate.
•	 While the HSAs can each address the needs
of our sectors, we must work together to
move forward collectively as a system.
With that said, opportunities remain to look
across the country and beyond to identify
new, innovative partnerships that can expand
capacity and advance health and safety. Our
recommendations are as follows.
Cross-Jurisdictional Partnerships
There is potential to look across Canada at all
levels and identify opportunities to share best
practices, products, tools and information, and
to coordinate service delivery, messaging to and
engagement of workers and employers.
First, the Health and Safety System must look to
other provinces, at the ministry level and beyond,
to discuss practices and principles, identify
priority areas and see where collaboration
between provinces and federal government can
collectively address health and safety.
Second, the system should look for opportunities
to connect with other provincial associations
at the system partner level across Canada and
abroad (e.g. prevention organizations with similar
mandates) to learn about best practices, to
inventory products that are easily adaptable to
Ontario workers and employers, and, likewise,
to share Ontario’s best practices and health and
safety tools. For instance, entire programs may
be shared where only a few modules referencing
legislation will require substitution. Results
include: efficiencies, the reallocation of funding
to unaddressed areas, better products and
services, and improved responsiveness to needs
and priorities.
Third, the system should look to find ways to
draw upon research bodies, both basic and
applied, across the country that are uncovering
or addressing common hazards, solutions and
the like.
Partnerships with Private Sector
Organizations
Rather than remaining insular, the system should
look externally to identify what can be learned
from best practices. This includes looking at
successful private sector firms to share their
stories with our clients.
Partnerships Across Ontario and the
Broader Public Sector
The system should add health and safety into
the broader conversation and coordinate efforts
to reach priority groups, such as small business
and workers employed in high-hazard activities.
Examples of such include aligning content
provider channels.
The system should consider partnerships
with other ministries as well. For instance,
partners can look for opportunities to embed
occupational health and safety awareness into
educational curriculums for trades.
Partnerships with Labour and Trade
Associations
System partners should seek to build reciprocal
relationships with labour and trade associations
so that the needs of those represented by these
associations are included in the prevention
conversation and effective programs and
improved market penetration can be achieved.
This is also a mechanism to identify influential
individuals and organizations who can act as
advocates for prevention across the province.
There is a mutual opportunity here for marketing,
revenue generation and free intelligence.
In addition, to meet the needs of workers
represented by these associations, this can
further ensure sector specificity in products and
services.
What innovative approaches
could expand the reach of
current occupational health and
safety efforts?5b
Broadening our reach is integral to achieving our common mission. The
following suggestions outline potential approaches that can contribute to the
expansion of our current occupational health and safety efforts.
Develop a Referral System
There is a need to incentivize the system to encourage collaboration. There
may be an opportunity to develop a system to facilitate referrals between
the HSAs that will guide employers and workers to the areas they can be
best served. Similarly, the possibility of developing a system-wide Learning
Management System (LMS) for eLearning has been raised.
Co-branding, Licensing
System partners should work together to co-brand or license products where
opportunities exist. Partnering with external service providers and those who
provide prevention services independently can expand and enhance these
opportunities.
Sponsorships
System partners should consider joint sponsorships for conferences and trade
shows to improve both value for money and coordination of messaging and
marketing efforts.
Expand eConsulting
It is ideal to implement multiple modes to transmit the message and enable
clients to connect. This includes using social media to complement traditional
approaches and reach out to groups not previously engaged.
Reach Out to Grassroots
As a collective, the system should look to identify those who have influence in
communities, sectors/industries, or regions, and educate and empower those
individuals to become advocates.
20
6 Effective Support
for Workplaces
2121
The Internal Responsibility System (IRS) is the foundation of all prevention programs,
and prevention system partners have generally developed a good mix of products and
services. There are some ways, however, that can enhance an organization’s ability to
become self-reliant in achieving compliance. These include:
Shifting the Culture to Embrace Collective Responsibility
Compliance is often misinterpreted as the responsibility of the organization’s Joint
Health and Safety Committee (JHSC) or health and safety representative. It is integral
to communicate that health and safety is the responsibility of everyone, including
employees, supervisors and managers, executives, and the boards of directors. This can
be achieved by building on existing models and reshaping products and services.
Employees Participating in Change (EPIC) is an active engagement approach and
strategy used by PSHSA consultants to teach organizations about the tools available to
them, and to aid in changing their workplace culture and attitudes toward business and
health and safety. We are working to build on the Employees Participating portion for all
levels.
The customization of existing products and messaging to all levels within an
organization, including the executive and board of directors, can lend to increased self-
reliance among organizations.
Partnerships with MOL to Define Compliance
It is recommended that the system form a partnership to develop specific guidelines on
implementing an IRS and provide clear guidelines on what compliance means. This may
include clear and consistent communication as to what inspectors may look for or ask
when reaching out to organizations as well as the translation of legislation or regulations
into the language of the client.
Integrated System Approach to Product Development and Dissemination
Collaboration and coordination across the prevention system yields better outcomes
and achieves process efficiencies. PSHSA is a strong supporter of finding new ways
to work together, and is currently working as part of the broader system team on the
development of worker and supervisor training.
What products and services could help
your workplace to become
self-reliant in achieving compliance with
the Occupational Health and Safety Act
and regulations?
6a
22
We have a number of recommendations for improving access to health
and safety products and services, including enhanced use of technology,
partnerships with provincial associations and the development of a
resource library.
Enhanced Use of Technology
The system should look to supplement traditional products and services
with e-products. Examples of this include: eConsulting, multimedia and
online access. Via web and social media, eConsulting provides easy
access to improve responsiveness and provide on-demand information.
Multimedia, such as audio, video, images and infographics, are short,
focused and shareable forms of content which address particular questions
or issues. Online access to products and services ensures that information
and answers can be found at the touch of a button.
Partnerships with Provincial Associations
The purpose of connecting with provincial associations, whose members
are owners and operators of organizations, is three-fold. First, by
reaching out through shared platforms (such as eLearning) or association
membership lists, the system is able to connect with leaders and decision
makers who can guide health and safety programs in their organizations.
Second, connecting with provincial associations will assist in reaching a
broader group of workers and employers. Third, this can assist with market
intelligence. By gaining a better understanding of organizations’ health and
safety needs, partners are able to improve methods of access as well as
product and service offerings.
Developing a Resource Library
A resource library would make available a central repository of products or
tools to maintain consistent messaging and information. These tools can be
provided to workers and employers when needed.
What could improve access to
products and services for those
workplaces that need support
6b
23
When it comes to the IRS, it is important to support Ontario workplaces
as best we can. The following recommendations can assist workplaces in
strengthening their IRS.
Better Sharing of Best Practices
A process or mechanism should be developed to identify best practices.
This should entail the collection, consolidation and sharing of knowledge
regarding what works well for organizations in different sectors, of
different sizes, or with similar challenges, regarding IRSs. Clients with
robust training programs or health and safety resources should be
encouraged to share.
Multi-Format Offerings
To help workplaces strengthen their IRS, the system can provide products
and services in a number of formats, such as traditional learning offerings,
blended learning offerings, distance education and eLearning, to
address the diverse needs of various workplaces. For example, for small
businesses with limited resources and strict time-constraints, eLearning
provides a health and safety representative the opportunity to learn their
responsibilities without sacrificing a day for offsite training.
What assistance could the system
provide to help workplaces
strengthen their Internal
Responsibility System (IRS)?6C
24
7	Addressing
Occupational Disease
25
What additional steps could the occupational health and safety
system take to protect workers from occupational disease?
7Prior to delving into additional steps for protecting workers, it is important to review the unique challenges and considerations
that apply to occupational disease.
Prolonged Development of Illness and Disease
Exposure to chemical or physical hazards may induce adverse health effects instantly, while others may take time to manifest.
Since the effects are not always felt immediately, precautions are sometimes ignored or taken less seriously. Delay in the onset of
symptoms or disease makes it challenging to communicate the importance of taking proactive preventative measures. Exploring
the potential of early detection and screening would help address this concern. Similar to this, we should remain cognizant
not only of the physical illnesses, but of the hazardous situations that can lead to mental illnesses as well. For example, first
responders are exposed to situations that can lead to post traumatic stress disorders. The effects of mental illness may also
develop or last over time.
Barriers to Reporting
A system challenge, individuals affected by occupational illness and disease may not report exposures for various reasons. This
can lead to long-term exposure and, consequently, long-term impacts.
Broad Exposures
Some occupations involve frequent contact with hazardous materials or other disease-causing agents, but these workers are not
considered a priority (e.g. contact with patients receiving chemotherapy, teachers in shops and labs, and water treatment and
wastewater workers).
Challenges Obtaining Data
There is a need for better statistical data regarding occupational disease. It is difficult to obtain adequate data from WSIB or
elsewhere to identify trends, and so forth. Exploring other data sources may help address this concern.
Propensity to Respond to Key Incidents, Not Key Causes
Upon diagnosis of occupational disease, organizations tend to focus on the most recent incident or exposure. However, since
disease can take time to manifest, there must be a focus on all potential causes.
To put this topic in perspective, of the numerous causes of occupational illness and disease, examples for PSHSA include: noise
exposure, exposure to solvents, antineoplastics, infectious agents, asbestos, diesel exhaust, shift work and biological hazards (e.g.
mould, bacteria, exotoxins/endotoxins). The following steps can be taken to protect workers from occupational disease.
26
Form System Working Groups
Working groups involving Health and Safety System partners
have shown to yield positive outcomes. For example, PSHSA
took part in an occupational disease working group focused
on mould exposure, heat stress and noise spanning all sectors
which resulted in a series of tools to address the issues.
PSHSA recommends and supports new working groups
tasked to address other cross-sectoral issues and suggests
revisiting data and statistics available to support such a
group.
System Collaboration and Alignment
There are a number of areas for collaboration within the
system. Partners should collaborate around key issues,
such as occupational hygiene and shift work. Awareness
campaigns can be coordinated around certain topics. PSHSA
will take initiative to develop new posters, training, etc.
In addition, we will continue working with the Centre for
Research Expertise in Occupational Disease.
Form Partnerships beyond the System
Additional stakeholders should be engaged in the
conversation about occupational disease so they too can
become part of the solution. This can be facilitated, first,
by providing awareness. By reaching out to the medical
community, we can share legislative updates and extend
invitations to information sessions (e.g. OMA, Public Health
Ontario, medical schools).
Second, partnerships can assist with the gaining of important
insights. In working with high-risk trade groups, perhaps
through focus groups or other mechanisms, we are able to
learn effective approaches to address high risk exposures to
such things as noise, solvents and cancer causing agents.
Third, system partners should look to form partnerships
with other ministries for a broader impact. Similar to other
health and safety programs, we should look to work with
trade schools to add occupational health and safety into
the curriculum. This will help to inform students of the
importance of taking precautions prior to the development of
symptoms.
Integration of New Research in Products and Services
Research is instrumental to understanding issues, whether
related to occupational disease and illness or in the broader
health and safety context. Organizations such as the
Centre for Research and Occupational Disease (CRE-OD)
and the Centre of Research Expertise for the Prevention
of Musculoskeletal Disorders (CRE-MSD) provide valuable
insights.
Opportunities for the prevention system may involve
identifying where there may be a higher susceptibility for
workers to develop occupational diseases, and looking
at multiple segmentations to be more effective in our
prevention activities. Another opportunity may involve the
launch of a focus group tasked to identify groups that have
a higher likelihood of exposure. In addition, system partners
should always look to work collaboratively with scientists and
product specialists to translate research results into practical
and meaningful products.
Enhance and Customize Current Products and
Services
Where applicable, the system should look into enhancing
and customizing current products and services. This would
involve investigating other modes of training and service
delivery to increase engagement and uptake of information.
Other suggestions include gearing training to particular
groups and equipping health and safety consultants with
checklists and surveillance tools for high-risk exposures.
Develop and Market New Products and Services
The system partners should consider developing system-wide
marketing campaigns to shed light on the long-term effects
of exposures and to support any specialized training and
services.
Continued...
27
28
8	Effective Financial
and Non-Financial
Motivators
The Ministry of Labour has laid out a very practical approach to arrive at revised prevention-based programs focused on outcomes. All programs should
encourage workplaces with higher injury rates to improve their health and safety programs and consequently decrease injuries to become top performers.
All programs should also increase the number of cases that demonstrate return in both dollars and safety as a result of participation and investment.
PSHSA has participated in previous WSIB programs, such as:
•	 Safe Communities Incentive Program (SCIP): The program creates awareness and helps firms develop health and safety programs with rebates for
participation in training, planning, policy development and self assessment.
•	 Safety Groups: Member firms that are involved in this program share experiences, access resources and work towards implementing a comprehensive
health and safety program that will reduce WSIB premiums. Safety Groups offer a financial incentive in the form of rebates if measures are achieved.
•	 Workwell: The program involves on-site evaluations for firms with higher comparative health and safety risks in their workplace. These evaluations can
reduce risks and incidents, improve morale, and grant rebates or decrease premiums for improvements in experience records.
Highlighted below are areas for consideration when conducting the program review and evaluating the suitability of motivators.
Participation
Current programs exclude Schedule 2 employers as well as those workplaces that do not pay into WSIB. Unlike Schedule 1 firms who pay premiums,
Schedule 2 employers reimburse WSIB for claims paid to their workers in addition to an administration fee. Therefore, considerations need to be made
when designing and implementing financial-based motivators or incentive programs. PSHSA is particularly familiar with this as we serve a high proportion
of Schedule 2 firms in particular sectors.
Multi-Staged Motivation
Experience has taught us that the motivators for companies, in terms of engagement in prevention, can shift over time. This has been seen through a
number of programs in which PSHSA has participated. Safety Groups are a good example. Our clients were initially drawn to the program because of the
financial rebates they receive. However, according to feedback provided by members, we learned that continued participation in the program is not due
to the financial rewards, but because of the information, products and consulting services they receive both from PSHSA and other client members which
enable them to make health and safety improvements in their organizations.
PSHSA recommends pursuing a combined approach, where financial motivators are advertised to draw clients into the Health and Safety System and its
programs, and support is provided once they are there. A continuum of involvement could be used to engage both small and larger businesses where the
initial focus is on core health and safety elements. Supporting firms to develop robust health and safety programs and to become leaders in health and
safety may be a positive motivator. PSHSA’s i3consult model encourages and supports organizations to continue to make improvements in their internal
systems.
How could prevention programs utilize motivators (positive and negative)
to improve occupational health and safety performance in the workplace?
8a
29
Other than financial, are there other motivators that will attract a
company’s participation in health and safety programs?
How could a non-financial incentive program attract participants
and assist in motivating better performance?8b
The following are suggestions for non-financial motivators to attract participation in health and safety programs.
Leadership Status
The concept of achieving leadership status, as outlined in the i3consult model, can act as a non-financial motivator for firms and
their peers.
Accreditation Process
Another motivator could be a health and safety accreditation process with a recognition mechanism for successful candidates.
Health and safety accreditation should be linked to other business accreditation programs (e.g. ISO, Accreditation Canada).
Certificate of Recognition
When developing health and safety programs, providing participants certificates of recognition with approved vendor status, or
similar motivation, should be considered.
Funding Approach
Another motivator might entail utilizing a funding approach tied to leading and lagging indicators.
30
9	Research Supporting
System Improvement
31
What should be the strategic objectives of occupational
health and safety research in Ontario?
9a
PSHSA sees tremendous value in conducting
basic and applied research to better
understand the characteristics of our clients
and their health and safety needs. In addition, it
is important to study the barriers and enablers
to creating and sustaining healthy and safe
workplaces. Further to focusing on the high
priority areas within the prevention system,
including vulnerable workers, high-hazard
activities and small business, we believe a
number of other strategic objectives should be
considered to advance occupational health and
safety research in Ontario.
Understand the Needs of Ontario Workers
and Employers
The research system should seek to understand
the market and gain a deep understanding of
the needs of those within the market.
Align Research with Health and Safety
System
There are two components to this objective.
First, the system should look to create a central
research repository. With numerous, relevant
research projects taking place, it would be
helpful to have one central repository of
information. From this, gaps as well as new
research opportunities can be identified.
Second, the HSAs should make better use
of system partnerships. This would involve
sustaining and improving relationships and
connections across the system to ensure there
is sharing of research between organizations
and partners to achieve efficiencies. The system
must also ensure we are reallocating the
resources to new research.
Improve Data Collection
When possible, the system should utilize
technology to improve the collection of data
(e.g. implementing a standardized and up-to-
date database).
Evaluate Health and Safety Program
Effectiveness
Research needs to focus on evaluating and
validating the health and safety programs and
tools that are used in the prevention system by
system partners.
Effectively Translate Research into
Products and Services
One way to disseminate knowledge and
research findings is through the products and
training programs the partners deliver. By
incorporating relevant and current research
into products, the system is able to assist with
knowledge implementation.
Expand and Enhance Research Networks
This will involve looking beyond Ontario and
perhaps Canada, and removing jurisdictional
silos where they may exist, to understand and
coordinate research efforts so that the system
can realize efficiencies and improvements
in injury and illness prevention. An example
of bringing this all together locally may
be coordinating a conference focused on
occupational health and safety that is global in
scope, yet hosted at home in Ontario.
Research Suggestions
Additional, more specific examples of
occupational health and safety topics that we
believe should be the focus of future research
include: workplace psychological health and
safety, the role and the impact of a JHSC
or health and safety representative in the
workplace, leading practices within our sector
clients related to a particular health and safety
issue, effective ways to engage clients in health
and safety, and validated tools and strategies
aimed at advancing health and safety within
organizations.
32
How can we best align research with the occupational
health and safety needs of the workplace?
9b
Reflecting on the proposed strategic objectives, the system can align research with workplaces’ health and safety needs through
the following.
Understanding Needs and Gaps
The system should consider taking a bottom-up approach to research identification by surveying the needs of workplaces and
working collaboratively with system partners.
Partnerships
PSHSA is part of the Health and Safety Association Liaison Committee that meets on a quarterly basis with representatives from
the HSAs, MOL, Institute for Work and Health (IWH) and other research partners. This serves as an opportunity to exchange ideas,
report on current projects and brainstorm strategies to improve the way we do business.
Engaging the Right People
Within the system, there are people who specialize in knowledge translation and advocate and champion research. There is
an opportunity to connect with staff within organizations who believe in research, are motivated to see it succeed and use the
research in their health and safety programs. Larger organizations often have human resources dedicated to knowledge and
research acquisition. Hence, partners can work with these individuals to expand our networks. It is equally important to engage
advocates and specialists at the right time along the program and product development continuum.
Tools and Messaging
Partners should provide the necessary knowledge tools and articulate the value and benefits of research to the system.
33
What could be done to better
implement research findings?
9c
Creating a Forum
Similar to the Healthy Work Environment portal, which is receiving positive
feedback, the system should consider creating a central searchable reference
for organizations involved in research. This would assist in identifying gaps,
refocusing efforts and reducing duplication.
Solid Internal Processes
Better distribution of research findings across the system should be a priority. In
addition, the development of system-wide processes for synchronizing the way
that partners gather, appraise and incorporate research knowledge into products
and services should be considered.
Holding Focus Groups
The system should also consider connecting with specific groups for the purposes
of raising awareness about research, identifying the needs, validating the
necessary tools and outlining where gaps among products and services exist.
Penetrating the Market
Partners should look to reach out to the market to develop reciprocal relationships
and improve understanding.
34
35
10 Effective Means
for Measuring
Performance
What are the right outcomes to measure that would result
in a common vision of success for the occupational health
and safety system?
10a
The system should measure the following outcomes: decreased injury rates, decreased illness rates, decreased occupational
illness, effective health and safety training programs, positive workplace culture and psychologically safe and healthy workplaces.
In order to properly measure these outcomes, overall improvements and positive changes must be made to the WSIB information.
In addition, there must be improvements to non-occupational statistics and other information in terms of availability and
application.
The data feeding into many of these measures will come from the WSIB EIW system. Recognizing areas for improvement in
the way the system is structured is important to measuring and understanding outcomes. We recommend the following for
consideration.
Develop a Repository of Reports
The development of a repository of reports can help standardize the way system partners receive information.
Common Definitions
What is included in the data may differ from system partners’ definitions. For example, small business in WSIB data is measured
as less than 20 FTE, whereas MOL considers less than 50 applicable. A shared understanding and shared definitions will further
ensure consistency across the system. Also, the system should look to develop similar approaches to identifying root causes of
injuries and illnesses. This can lead to better prevention efforts.
Schedule 2 FTE Information
Frequency rates cannot be calculated for Schedule 2 clients. As a result, outcome measurement can be challenging.
Ensuring Completeness of Information
In the Health and Safety system, data comes from various injury and illness reporting forms, including: Form 6 (workers report),
Form 7 (employers report) and Form 8 (health professionals report). WSIB and MOL can employ mechanisms, such as imposing a
fine for incomplete forms to improve completeness of data.
Additional information may also be required. For instance, the idea of proximate cause should be considered when discussing
outcomes as well as leading and lagging indicators. An injury or illness may occur in the workplace, but an additional event,
either inside or outside of the workplace, may have played a more significant role in causing the actual injury or illness. Additional
variables such as economic and psychosocial factors should also be considered.
36
What leading indicators does your organization use
and what methods are used to measure them?
10b
PSHSA recognizes the importance of using both leading and
lagging indicators to measure the performance of organizational
health and safety and the effectiveness of programs.
Recommendations regarding particular outcomes were informed
by our participation in projects, such as the IWH Ontario Leading
Indicators Project (OLIP), the IWH Organizational Performance
Metric (OPM) and the Ministry of Health and Long-Term Care
(MOHLTC) Indicators Project.
Our indicators are used at an organization level to benchmark
and better understand system performance as a whole. The
recommended indicators, both leading and lagging, and the
outcomes they are associated with are as follows:
•	 Training (leading): staff training and professional
development, manager and supervisor training.
•	 Risk assessment and organizational culture (leading): risk
assessment and management, employee engagement
climate.
•	 WSIB composite (lagging): injury, illness, occupational
disease and fatality rates.
•	 Non-occupational/insurer data (lagging): data around the
use of pharmaceutical drugs by employees.
•	 Health human resources (lagging): absenteeism, turnover.
To better identify what safety components need to be in place,
partners may want to look to develop and adopt preventative
best practices that outline the necessary components to
measuring a safe and healthy workplace (e.g. training, CEO buy-
in).
The following outline just some of the possible means for
measuring the above indicators.
Adopting Available Products
The means to measure health and safety indicators can be
drawn from Accreditation Canada’s Worklife Pulse tool. This
organization offers two tools: a general tool for staff and another
which measures physicians’ quality of worklife.
Surveys
For culture, surveys that are related to employee engagement
often indicate health and safety performance.
Forms 6, 7 and 8
For lagging indicators, the WSIB collects information via
Forms 6, 7 and 8. MOL has the power to enforce use and, in
collaboration with other members of the Health and Safety
System, agreement on the required data.
In addition to giving consideration to organizational injury and
illness data, preventive measures used by organizations should
also be evaluated. More specifically, there should be a systematic
evaluation of the health and safety programs developed and
delivered by the prevention system partners. To truly understand
the effectiveness of programs and prevention efforts, there
must be the ability to distinguish which intervention lead to
improvement in indicators, be it company effort or HSA effort.
Additionally, there should be a better understanding of what
happens outside of the workplace that may contribute to injuries
and illnesses on the job, or which may improve indicators.
Some areas of consideration include: a better understanding of
labour and demographic changes and their impacts on injuries
and illnesses and the development of shared definitions and
methodology for indentifying proximate cause.
37
Acknowledgements
The development of this response was a collaborative effort. We’d like to thank our staff,
advisory council members and Board of Directors for their input and participation in the
process and for ensuring the document is reflective of the reality of the sectors we serve and
the Health and Safety System as a whole.
38
References
For more information on Public Services Health & Safety Association,
please visit PSHSA.ca.
Information on programs and projects referenced within this response
are as follow:
•	 PSHSA’s Healthy Work Environment Portal: http://www.
healthyworkenvironments.ca/
•	 Healthy and Safe Healthcare Workplace Indicators Project: http://
www.healthyworkenvironments.ca/Resources_Indicator_Project.
htm
•	 Small Business Resource Manual: http://pshsa.ca/2013/02/01/
health-and-safety-for-small-business-resource-book/
39

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Renewing Ontario's Health & Safety System: Inspiration for the Province's First Integrated Occupational Health and Safety Strategy

  • 1.
  • 2. P:P: P: P: P: P: P: P: P: P: PSHSA’s response and recommendations to the questions posed in the Ministry of Labour’s discussion paper highlight ways in which Ontario’s Health and Safety System can be renewed. Enhanced Service Delivery THEMES P R I O R I T I E S Support for Those Who are Most in Need Meeting Changing Individual and Organizational Needs THEMES Addressing the Needs of Vulnerable Workers Responding to Small Business Needs Assistance for High Hazard Activities Integrated Planning and Service Delivery Expanding Capacity through Innovative Partnerships Effective Support for Workplaces Addressing Occupational Disease Effective Financial and Non-Financial Motivators Research Supporting System Improvement Effective Means for Measuring Performance • Partnerships In and Beyond Ontario’s H&S System • Use a Combination of Digital & Traditional Media • Coordinated Messaging Across the System • Employer Education on Vulnerable Worker Rights • Revisit the Economic Model • Create a Strong Business Case • Embed Research in Approach • Develop Small Business-Specific Resources • Create a Common Focus • Enhanced Use of Online Tools • Streamline Service Delivery • Link Funding to Outcomes • Review Shared Services • Collaborate but Maintain Sectoral Specificity • Facilitate Research Uptake • Leverage Existing Partnerships • Form New Partnerships o Cross-jurisdictional o Private Sector o Across OPS & BPS o Labour & Trade Associations 1 2 3 • Revisit the Economic Model • Create a Strong Business Case • Embed Research in Approach • Develop Small Business-Specific Resources • Create a Common Focus • Enhanced Use of Online Tools • Form System Working Groups • System Collaboration & Alignment • Form Partnerships Beyond the System • Integrate New Research in Products/Services • Develop & Market New Products/Services • Enhance & Customize Current Products/Services • Shift Culture to Embrace Collective Responsibility • Clear Definition of Compliance • Integrated Product Development/Dissemination • Enhanced Use of Technology/Multi-Format Offerings • Development of a Resource Library • Better Sharing of Best Practices • Multi-Staged Motivation (Financial Rebates as well as Information and Services) • Leadership Status • Accreditation Process • Certificate of Recognition • Funding Approach 4 5 6 7 8 • Measuring Outcomes (e.g. Decreased Injury & Illness Rates, Decreased Occupational Illness, Effective H&S Training Programs, Positive Workplace Culture and Psychologically Safe and Healthy Workplaces) • Develop a Repository of Reports • Define Measures • Schedule 2 FTE Information • Ensuring Completeness of Information (Forms 6,7 and 8) • Leading Indicators (e.g. Training, Risk Assessment and Organizational Culture) & Lagging Indicators (e.g. WSIB Composite, Non-occupational/Insurer Data, Human Resources Data) • Surveys (e.g. Employee Engagement) • Strategic Objectives: o Understand Needs & Gaps o Research Alignment & Improve Data Collection o Expand Research Networks o Evaluate H&S Program Effectiveness o Translate Research into Products & Services • Continuing Partnerships • Engaging the Right People • Tools & Messaging • Creating a Forum • Solid Internal Processes • Focus Groups 9 10 Injuries, Illness & Fatalities ZERO WORK RELATED
  • 3. Introduction The Ministry of Labour (MOL), through the Chief Prevention Office (CPO), is seeking feedback regarding Ontario’s first Integrated Occupational Health and Safety Strategy. The discussion document, “An Integrated Occupational Health and Safety Strategy for Ontario”, outlines the vision and three strategic themes for the system, and poses questions to stakeholders around ten priorities. This is an exciting time for Ontario and we appreciate the opportunity to contribute to the future direction of health and safety in the province. As an integral part of Ontario’s Health and Safety System, Public Services Health & Safety Association (PSHSA) is pleased to submit our response to the Strategy paper. To ensure that our response was representative, our approach involved a consultative process. The draft was sent to our own staff and management as well as the organization’s broader stakeholders, including members of our advisory councils and board of directors, for the purpose of gathering feedback. PSHSA serves over 9,500 organizations and 1.2 million workers across the province’s public service sector. We work closely with Ontario education and culture, community and healthcare, municipal and provincial government, emergency services, and First Nations, offering consulting, training and resources to reduce workplace risks and prevent occupational injuries, illnesses and fatalities. Working in regional teams, our consultants have valuable expertise in common workplace issues such as musculoskeletal disorders (MSD), slips, trips and falls, workplace violence, and due diligence. Putting this experience to work, we help organizations identify workplace hazards, develop effective policies and procedures and provide the right tools to address their unique health and safety needs. With a long history of regional, sectoral and industry expertise, we are well positioned to offer constructive feedback on an integrated health and safety strategy for Ontario. When it comes to health and safety, Ontario faces a number of challenges. Both Ontario’s Health and Safety System and workplaces continue to experience times of constraint. Furthermore, today’s workplaces remain in a time of transition. They continue to experience sectoral and labour adjustments, economic changes and fiscal constraints, continued technological innovation and adoption, an aging workforce, and social shifts. There are new priority areas to address, however stresses, such as the current economic climate, may lead firms to rethink their investments in health and safety, citing a lack of time and money. The system must reply collectively to provide answers to these challenges and demonstrate the benefits that prevention investments yield. Ontario’s Health and Safety System has accomplished a lot throughout its history. As the system continues to evolve, we will continue to lead the way in our prevention activities and are glad to offer our support and assistance in any way. There is still a lot to be done and we look forward to working together towards building a stronger, more innovative and renewed Health and Safety System. 3
  • 4. Summary In addressing the Strategy paper, PSHSA identified several common themes that can help position the system for future success. Develop a Renewed Focus on Purpose The prevention system must instigate a mindset shift where all employers and workers know, understand and demonstrate the importance of occupational health and safety. System partners must continue to focus on the end outcome – zero injuries and illness. And new stakeholders – labour and employer groups, associations, community groups, all level of government – must be engaged to act as advocates for health and safety. Coordinate and Collaborate as a System Together, the prevention partners must build a stronger culture of collaboration as well as expand and leverage relationships for the benefit of the Health and Safety System and Ontario workers and employers. A collaborative approach will assist Health and Safety Associations (HSAs) and other system partners in maximizing our funding and resources by ensuring the greatest return on investment. Collaboration and coordination can achieve many things. It can help minimize repetition among the products, training and services developed and delivered by system partners, while still maintaining the sector specificity needed by workers and workplaces. Partners should seek to avoid duplication in their activities by looking for mutually beneficial opportunities to work together and ensure the system is operating efficiently and moving prevention forward. Secondly, collaboration helps to avoid crossover between sectors by system partners. This can be done by finding new ways to work together to ensure clients are properly directed through the system and to the appropriate HSA (e.g. through referrals, shared services). This will also improve the collective ability to measure the effectiveness of prevention programs. System partners should work together to create a common message, and look to utilize multiple methods of reaching workers and employers to optimize its reach and maximize the effectiveness of awareness campaigns. Examples of this include forming the aforementioned partnerships and enhancing and expanding use of social media. The system must look to collaborate with those outside of the current structure and expand partnerships. For example, connecting to workers and workplaces through partnerships with provincial ministries, federal departments and agencies and research organizations should be encouraged. In addition, the system must also understand that health and safety efforts are not confined just to those identified as stakeholders in the introduction of the discussion paper. There are service providers who can be better integrated into the fold. Currently there are a number of private health and safety providers offering training and other services, but who are not included in the overall business model. One suggestion may be for PSHSA to be a solution provider, developing sustainable and outcome- based content for private organizations to deliver. Where possible, system partners should also look to coordinate research efforts as well as ensure there is sustained knowledge transfer and uptake in the programs and service delivery. Underlying coordination and collaboration is the need to put in place the mechanisms to support collaboration across the system. For example, there should be incentives and conditions in place which encourage partnerships. Eliminate Barriers to Prevention There are opportunities for the Health and Safety System to think differently about the way it optimizes its reach and improves prevention effectiveness. These include, but are not limited to, the following recommendations. Rather than remaining insular, the system should look externally, across Canada and beyond, to identify best practices, streamline delivery and increase efficiency. The system should consider reviewing and realigning the funding model to align with economic realities as well as the needs of workers, employers and the system itself, and to encourage cooperation. This includes reviewing and aligning the partners differing business models, and thinking strategically as a collective. This will also be supported though developing a shared understanding of system issues between partners, including an improved and common view of the provincial market as well as the social and economic landscape. Similarly, measurement of the impact and effectiveness of solutions and services provided should be carried out across the system. The report expands on these recommendations and seeks to inspire a renewal of Ontario’s Health and Safety System. 4
  • 5. 1 Addressing the Needs of Vulnerable Workers 5
  • 6. How can the voice of the vulnerable worker be brought into the occupational health and safety discussion to better understand their needs? 1a For our organization, it is important to first address the definition of vulnerable workers. Many public service workers only fit loosely into the provided categories. Regarding factors that contribute to worker vulnerability, an additional consideration is that lack of training does not necessarily mean there is no education available for a group of workers. For some public sector workers, education is largely unregulated. For example, personal support workers can receive the same certificate by taking a 10 month college program or a private weekend course. It is integral that the voice of vulnerable workers be brought into the occupational health and safety discussion so that we, as a system, can better understand their needs. The best way to do this is to reach out and engage these workers. The approach should consider both the modes of communication as well as the points of connection. Connecting Through Partnerships Beyond Ontario’s Health and Safety System There are many touch points where workers and potential workers need or choose to go for information. By partnering with these organizations, system partners can not only connect vulnerable workers to valuable health and safety education and resources, but listen and receive input from them as well. Reaching vulnerable workers can be aided through relationships with community centres and associations, various government entities, and employer and labour associations. Developing relationships with local and regional community-based centres and associations, such as religious and medical centres, can help provide access to vulnerable groups. A variety of formal and informal associations, both known and unknown, exist in every community. Efforts should be made to identify these groups and reach out to them. Further, many of PSHSA’s clients work in public services and are funded through various government entities. It may be beneficial to collaborate with other ministries as many clients and vulnerable workers have already formed relationships with them. Lastly, several vulnerable workers, and the workplaces that employ them, are represented by various industry associations. By partnering with employer and labour associations, the system will be able to better connect with vulnerable groups. Utilizing Online, Social and Mobile Media It has been suggested that the system provide a venue that vulnerable workers can relate to, such as a communications portal, hotline, mobile application or social media channel. This will not only provide vulnerable workers with support by delivering on-demand advice and resources, it will act as a venue for open discussion and learning as well. This will complement the system’s more traditional approaches. 6
  • 7. Strengthening the occupational health and safety of vulnerable workers can be facilitated through partnerships, education, collaboration and better communication. Partnerships It is understood that introducing workers to the basic rights and contacts for health and safety can lend to positive awareness efforts. Citizenship and Immigration Canada is often the first point of contact for entrants into the country, as the office coordinates work permits for new immigrants, refugees, protected persons and permanent residents seeking to legally work in Canada. Similarly, visa offices, employment and job-training centres, and settlement centres, which provide basic skills training, ESL/FSL training and employment support, can act as other effective channels for reaching vulnerable workers. Another important partnership involves education institutes and related provincial ministries (e.g. Ministry of Education, Ministry of Training, Colleges and Universities). By adding health and safety programming into university, college and training college curriculums, we are able to access those who will eventually enter the workforce. Likewise, reaching out to grade school levels can help build awareness as well as the foundational elements of a health and safety culture among young students; this is sure to have long-felt impacts. Lastly, the system should look to connect and form partnerships with labour and employer associations to help educate the workers that these associations represent on the significance of occupational health and safety. Employer Education System partners should work together to educate employers about vulnerable workers, who they are and what they need. This includes communicating the importance of worker orientation and job-specific training. Coordinated Messaging We must work as a system, collaborating and coordinating with the other Health and Safety Associations (HSAs) to ensure the prevention approach is reinforced. PSHSA can support outreach efforts through providing information, tools and guidance, such as eLearning and eConsulting, and acting as a resource for vulnerable workers when required. Multimodal Communication For vulnerable workers, emphasis should be placed on communicating in targeted ways. In this case, it is providing information in multiple languages, modes and literacy levels. Recognizing the diversity of the province, the system must make a collective effort to translate materials into various languages in a way that is cost-effective. This will help improve access to information. How can we strengthen the occupational health and safety of vulnerable workers? 1b 7
  • 8. 2 Responding to Small Business Needs 8
  • 9. As with other priority groups, there are a number of considerations specific to understanding and meeting small business health and safety needs, including: employers’ limited time and resources, the perception that small businesses are at minimal risk, and the need for adaptable and on-demand products and services. The following recommendations can help small businesses and their workers achieve safe and healthy workplaces. Revisiting the Economic Model The Health and Safety System’s economic model currently favours those industries and clients that are able to pay, rather than those who cannot. There is a lack of focus on small businesses as they are unable to support or sustain an investment in health and safety. To help address this concern, the system must look at ways that the current economic model can better include small business and encourage emphasis on providing the tools and solutions they require. Creating a Strong Business Case Small business owners can get caught up in the bottom line and other pressures of business ownership, often losing sight of the bigger picture. The system should work together to communicate a strong business case for health and safety. This involves framing the message to clearly demonstrate the benefits associated with an investment in health and safety versus the costs of injuries and illness. It should also state that, contrary to popular perception, the laws apply to small businesses as well. Embedding Research in Approach By incorporating research in the design and creation of new products and services, the system is able to provide perspective on small business needs as well as what approaches will be effective in improving health and safety programs. Developing Small Business-specific Resources Partners can look to put together information kits that are adapted to the needs of small business. These can be distributed in multiple formats through a variety of channels, including partnerships with other ministries. PSHSA offers a free, downloadable Small Business Resource Guide detailing the ten steps toward building an effective health and safety program. Furthermore, PSHSA’s eConsulting approach, which utilizes technology to provide just-in-time professional advice and services, will assist small business clients with their immediate needs. What can help small businesses and their workers have safe and healthy workplaces? 2a 9
  • 10. How can the occupational health and safety system partners work with established networks to identify the needs of small businesses and better understand how to address them? 2b There are numerous established networks and associations to which small businesses are directed for purposes such as business registration, tax filing or access to resources. These include: business groups, publicly funded centres (e.g. Business Help Centres), associations (e.g. Canadian Federation of Independent Businesses, Chamber of Commerce) and provincial ministries (e.g. Ministry of Economic Development). In working with these established networks, system partners are better able to identify and address the needs of small business using the following approaches. Create a Common Focus In terms of how to work with these networks, system partners should first consider creating a common focus. The system should look to develop a common message as well as a quick and easy connection to the system which clearly outlines where to go. Promote the Business Case Using a variety of networks, all system partners should do their part to communicate the message to small businesses about the significant costs of injury and illness, and the benefits of preventing such. Enhanced Use of Online Tools System partners should consider enhancing and expanding the use of online and social tools to identify and address the needs of small businesses. It may be impractical for owners, managers or staff to take a day for offsite training. Easy to use websites, social media, videos, eLearning and just-in-time information can help facilitate increased health and safety knowledge and awareness. Increase Availability of Tools The system should seek to form strategic partnerships with new network partners. These partners can act as connection points to small businesses and ensure the approach is appropriate for their sectors. The system should also look to leverage and enhance existing tools, such as the Ministry of Labour hotline. 10
  • 11. 3 Assistance for High- Hazard Activities 11
  • 12. High-Hazard Activities: Those activities where the worker is regularly exposed to potential sources of serious harm or serious health effects (e.g. working at heights, near and around heavy equipment, underground, or with hazardous substances). When defining high-hazard activities, the system must consider the following: • Activities where workers are exposed to uncontrolled conditions. • Activities where workers are exposed to unknowns and unseen dangers (e.g. chemical exposure, exposures to conditions that may lead to occupational disease). • Activities for which protocols and standards of practice are in place, and injuries and illnesses have been prevented, but where the hazard has not been eliminated. • Activities which are preventable, but have high claims rates, though typically lack market appeal or research focus (e.g. noise, chemical exposures). For high-hazard activities, it is vital to address the concerns ahead of time through risk assessment, and to be cognizant of all the potential individuals who may be exposed to identified hazards through the work they are engaged in. How do you define high-hazard activities? For example, would the definition be based more on the seriousness of the potential injury or illness, or the potential frequency of injury or illness? Would it be based on other criteria? 3a 12
  • 13. Our organization feels that there are some high-hazard activities that should have more rigorous training, compliance and enforcement. These include: confined space entry, working at heights, traffic control, trenching operations, heavy equipment operation, utility work, use of equipment and chemicals in shops, work in labs and maintenance rooms, exposures to medical compounds (e.g. antineoplastics), social and community services (e.g. where there is exposure to violence), work on energized systems (e.g. electrical, pneumatic, pressurized), and emergency rescue situations. Please note that the development of rigorous standards is not only required for high-hazard training programs; they are necessary for qualifying trainers and training providers as well. What high-hazard activities should be subject to more rigorous training standards, assurance of compliance or ministry enforcement? 3b 13
  • 14. What concerns and challenges do you see for the Ministry of Labour in implementing industry-wide training on specific tasks that have been defined as high-hazard? 3c Experience of Trainers It is critical that health and safety is a focus of high hazard training programs. Trainers must be strong facilitators so that they are able to clearly communicate the risks and ensure there is uptake of the message. Similarly, high-hazard activities require more than general knowledge. Instructors must have a deep understanding of best practices, gained through education or prior experience, in order to properly address questions and concerns that fall outside of the curriculum. Considerations for Train-the-Trainer Rigorous Train-the-Trainer standards need to be developed for high-hazard activities. Prerequisites must be defined for trainers requesting high-hazard Train-the-Trainer programs and a process must be developed for managing this. In addition, a system to manage the delivery of updates (e.g. legislation changes, new best practices, refresher programs) for those who have completed Train-the-Trainer programs should also be considered. This would ensure that those who have completed Train-the-Trainer programs are always delivering the most current information, regardless of when they took the course. If partners are going to offer Train-the-Trainer programs, they must have the capacity to sustain them over time. Potential Compromises Organizations may choose alternative methods of training delivery due to the following compromises. It is important that we develop solutions as a system to mitigate these compromises. The prevention system cannot support the notion that any training is better than no training – the risks are too great. First, organizations may be limited by financial constraints. This can lead to decisions to seek alternative methods of health and safety training and services. However, these alternatives may not be current or up to standards. Second, many organizations today feel pressure due to time constraints. As a result of heavy workloads, organizations may opt for lesser training programs. This is a particular concern for small businesses. To cope with concerns and challenges when implementing industry-wide training on high-hazard tasks, we recommend the following for consideration. Monitor Training Quality When implementing standards, it is vital to designate trainers only when all steps are complete, and build in the structures to monitor the quality of training. A risk assessment should be conducted to demonstrate the impact of doing otherwise. Shift Towards Global Standards In the past, there has been little made-in-Canada material for emergency services training. However, Canada and other jurisdictions are currently moving towards implementing global standards and then adjusting for local applicable legislation (e.g. National Fire Protection Association standards). Drawing from Exemplary Models Mining and Forestry programs maintain strict training standards with mandatory training. Principles for implementation can be derived from their models. 14
  • 15. 4 Integrated Planning & Service Delivery Model 15
  • 16. What are the highest priority gaps in occupational health and safety system service delivery that needs to be addressed? 4a Within the system, there are opportunities to address current gaps and continue to improve prevention service delivery. The challenges outlined herein are reflective of the current environment; PSHSA would like to continue to find ways to collaborate and address these. Differing Business Models System partners have distinct business models, including pricing and, in some cases, services. This sends an inconsistent message to clients and may hinder some collaborative efforts. Funding Not Aligned to Address Shifts in Needs and Outcomes Within the system, there are a number of self-imposed barriers stemming from funding which is not linked to outcomes, nor reallocated for sectoral structures, labour shifts and economic realities. Repetition Among Partners Overlap exists between the back-end service delivery of organizations funded through the same channels. There is also repetition among products, training and other services provided and developed by system partners, as well as organizations outside of the publicly funded sphere. The HSAs need to focus on maximizing funding by ensuring the greatest return on investment. For example, as a large and diverse province, there is a need for Ontario to provide health and safety products in multiple languages. Product translation may be an area where it makes sense to coordinate. In addition to products and services, there is currently crossover in the sectors and clients that the system partners serve. As a result, it is difficult to measure effectiveness. System partners are unable to ascertain whether or not our respective programs are truly effective. Moreover, performance metrics are not accurately reflective of one another’s work. Inconsistent Research Integration There are many examples where translating research findings into products and services has positively impacted prevention activities. There needs to be a level of consistency and efficiency, as well as a better approach to facilitate this. Similarly, there is a need for research outcomes to be linked to funding. No Standards for Data Analysis Partners in the Health and Safety System have access to the same information sourced from the WSIB EIW. However, partners may extract and analyze it in various ways, often leading to different approaches to address needs. Outcomes are met, but there are no controls over ways to measure comparative efficiencies. 16
  • 17. detailing how partners should work together. Identify Areas of Sectoral Specificity There is a need to ensure that sectoral partners, including those in research, adapt products and services to meet the distinct needs of sectors as necessary, such as hazard identification and control, and in shaping messages to the particular audiences. Since our sector specific knowledge and expertise is what separates the HSAs from private consultants, system partners should continue to maintain sector identity in our service offerings, yet look for opportunities to collaborate where it makes sense. Facilitating Research Uptake To improve prevention activities, the system should provide the means to enable the inclusion of research findings into the products and services of system partners. There are a number of ways the system partners and other organizations can align to overcome these obstacles and improve service delivery. Streamline Service Delivery As a system, we must develop a business plan that works for everyone. This can be done by learning from each other’s business models, and jointly agreeing to one which is used consistently across the system. Link Funding to Outcomes This will continue to focus partner activities on delivering health and safety improvements. Consideration should be made regarding allocation of funding to where the needs exist, whether based on priority groups and proportion held by a system partner, market size, and so forth. Review Shared Services The system must work together to develop a common definition for shared services. Having expertise in this area, PSHSA is willing to lead a committee or project team to look into this further. System partners must work together to identify where there are unexplored opportunities to collaborate that will benefit the system by leveraging resources and reducing duplication. System partners need to find new ways to work together to ensure clients are properly directed through the system and to the appropriate HSA (e.g. through referrals, shared services). In addition, by maintaining sectoral specificity in the clients and sectors with which we do business, system partners will have a better understanding of the effectiveness of their programs. For example, the system can create branding and marketing guidelines that support the overall goal of consistent messaging. This will ensure the client gets the right help at the right time. This relates to the idea of establishing expectations How can we align system partners and other organizations to improve service delivery? Can you provide examples? 4b 17
  • 18. 18 5 Expanding Capacity through Innovative Partnerships
  • 19. What new partnerships could advance occupational health and safety? 5a 19 First and foremost, it is important to note that it is not only new partnerships that can advance occupational health and safety; existing partnerships can also be leveraged. The system should consider the following: • Refocus on outcomes (lives saved) across the province and beyond. • Look to define and describe measures and outcomes in the same way across the system. • Coordinate shared messages throughout the system. • Remove artificial barriers and continue to work toward collaborative delivery and aligned business models. • Identify where gaps exist and mutually beneficial relationships can be struck. • Improve the internal capacities of the HSAs and other partners to deliver on the prevention mandate. • While the HSAs can each address the needs of our sectors, we must work together to move forward collectively as a system. With that said, opportunities remain to look across the country and beyond to identify new, innovative partnerships that can expand capacity and advance health and safety. Our recommendations are as follows. Cross-Jurisdictional Partnerships There is potential to look across Canada at all levels and identify opportunities to share best practices, products, tools and information, and to coordinate service delivery, messaging to and engagement of workers and employers. First, the Health and Safety System must look to other provinces, at the ministry level and beyond, to discuss practices and principles, identify priority areas and see where collaboration between provinces and federal government can collectively address health and safety. Second, the system should look for opportunities to connect with other provincial associations at the system partner level across Canada and abroad (e.g. prevention organizations with similar mandates) to learn about best practices, to inventory products that are easily adaptable to Ontario workers and employers, and, likewise, to share Ontario’s best practices and health and safety tools. For instance, entire programs may be shared where only a few modules referencing legislation will require substitution. Results include: efficiencies, the reallocation of funding to unaddressed areas, better products and services, and improved responsiveness to needs and priorities. Third, the system should look to find ways to draw upon research bodies, both basic and applied, across the country that are uncovering or addressing common hazards, solutions and the like. Partnerships with Private Sector Organizations Rather than remaining insular, the system should look externally to identify what can be learned from best practices. This includes looking at successful private sector firms to share their stories with our clients. Partnerships Across Ontario and the Broader Public Sector The system should add health and safety into the broader conversation and coordinate efforts to reach priority groups, such as small business and workers employed in high-hazard activities. Examples of such include aligning content provider channels. The system should consider partnerships with other ministries as well. For instance, partners can look for opportunities to embed occupational health and safety awareness into educational curriculums for trades. Partnerships with Labour and Trade Associations System partners should seek to build reciprocal relationships with labour and trade associations so that the needs of those represented by these associations are included in the prevention conversation and effective programs and improved market penetration can be achieved. This is also a mechanism to identify influential individuals and organizations who can act as advocates for prevention across the province. There is a mutual opportunity here for marketing, revenue generation and free intelligence. In addition, to meet the needs of workers represented by these associations, this can further ensure sector specificity in products and services.
  • 20. What innovative approaches could expand the reach of current occupational health and safety efforts?5b Broadening our reach is integral to achieving our common mission. The following suggestions outline potential approaches that can contribute to the expansion of our current occupational health and safety efforts. Develop a Referral System There is a need to incentivize the system to encourage collaboration. There may be an opportunity to develop a system to facilitate referrals between the HSAs that will guide employers and workers to the areas they can be best served. Similarly, the possibility of developing a system-wide Learning Management System (LMS) for eLearning has been raised. Co-branding, Licensing System partners should work together to co-brand or license products where opportunities exist. Partnering with external service providers and those who provide prevention services independently can expand and enhance these opportunities. Sponsorships System partners should consider joint sponsorships for conferences and trade shows to improve both value for money and coordination of messaging and marketing efforts. Expand eConsulting It is ideal to implement multiple modes to transmit the message and enable clients to connect. This includes using social media to complement traditional approaches and reach out to groups not previously engaged. Reach Out to Grassroots As a collective, the system should look to identify those who have influence in communities, sectors/industries, or regions, and educate and empower those individuals to become advocates. 20
  • 21. 6 Effective Support for Workplaces 2121
  • 22. The Internal Responsibility System (IRS) is the foundation of all prevention programs, and prevention system partners have generally developed a good mix of products and services. There are some ways, however, that can enhance an organization’s ability to become self-reliant in achieving compliance. These include: Shifting the Culture to Embrace Collective Responsibility Compliance is often misinterpreted as the responsibility of the organization’s Joint Health and Safety Committee (JHSC) or health and safety representative. It is integral to communicate that health and safety is the responsibility of everyone, including employees, supervisors and managers, executives, and the boards of directors. This can be achieved by building on existing models and reshaping products and services. Employees Participating in Change (EPIC) is an active engagement approach and strategy used by PSHSA consultants to teach organizations about the tools available to them, and to aid in changing their workplace culture and attitudes toward business and health and safety. We are working to build on the Employees Participating portion for all levels. The customization of existing products and messaging to all levels within an organization, including the executive and board of directors, can lend to increased self- reliance among organizations. Partnerships with MOL to Define Compliance It is recommended that the system form a partnership to develop specific guidelines on implementing an IRS and provide clear guidelines on what compliance means. This may include clear and consistent communication as to what inspectors may look for or ask when reaching out to organizations as well as the translation of legislation or regulations into the language of the client. Integrated System Approach to Product Development and Dissemination Collaboration and coordination across the prevention system yields better outcomes and achieves process efficiencies. PSHSA is a strong supporter of finding new ways to work together, and is currently working as part of the broader system team on the development of worker and supervisor training. What products and services could help your workplace to become self-reliant in achieving compliance with the Occupational Health and Safety Act and regulations? 6a 22
  • 23. We have a number of recommendations for improving access to health and safety products and services, including enhanced use of technology, partnerships with provincial associations and the development of a resource library. Enhanced Use of Technology The system should look to supplement traditional products and services with e-products. Examples of this include: eConsulting, multimedia and online access. Via web and social media, eConsulting provides easy access to improve responsiveness and provide on-demand information. Multimedia, such as audio, video, images and infographics, are short, focused and shareable forms of content which address particular questions or issues. Online access to products and services ensures that information and answers can be found at the touch of a button. Partnerships with Provincial Associations The purpose of connecting with provincial associations, whose members are owners and operators of organizations, is three-fold. First, by reaching out through shared platforms (such as eLearning) or association membership lists, the system is able to connect with leaders and decision makers who can guide health and safety programs in their organizations. Second, connecting with provincial associations will assist in reaching a broader group of workers and employers. Third, this can assist with market intelligence. By gaining a better understanding of organizations’ health and safety needs, partners are able to improve methods of access as well as product and service offerings. Developing a Resource Library A resource library would make available a central repository of products or tools to maintain consistent messaging and information. These tools can be provided to workers and employers when needed. What could improve access to products and services for those workplaces that need support 6b 23
  • 24. When it comes to the IRS, it is important to support Ontario workplaces as best we can. The following recommendations can assist workplaces in strengthening their IRS. Better Sharing of Best Practices A process or mechanism should be developed to identify best practices. This should entail the collection, consolidation and sharing of knowledge regarding what works well for organizations in different sectors, of different sizes, or with similar challenges, regarding IRSs. Clients with robust training programs or health and safety resources should be encouraged to share. Multi-Format Offerings To help workplaces strengthen their IRS, the system can provide products and services in a number of formats, such as traditional learning offerings, blended learning offerings, distance education and eLearning, to address the diverse needs of various workplaces. For example, for small businesses with limited resources and strict time-constraints, eLearning provides a health and safety representative the opportunity to learn their responsibilities without sacrificing a day for offsite training. What assistance could the system provide to help workplaces strengthen their Internal Responsibility System (IRS)?6C 24
  • 26. What additional steps could the occupational health and safety system take to protect workers from occupational disease? 7Prior to delving into additional steps for protecting workers, it is important to review the unique challenges and considerations that apply to occupational disease. Prolonged Development of Illness and Disease Exposure to chemical or physical hazards may induce adverse health effects instantly, while others may take time to manifest. Since the effects are not always felt immediately, precautions are sometimes ignored or taken less seriously. Delay in the onset of symptoms or disease makes it challenging to communicate the importance of taking proactive preventative measures. Exploring the potential of early detection and screening would help address this concern. Similar to this, we should remain cognizant not only of the physical illnesses, but of the hazardous situations that can lead to mental illnesses as well. For example, first responders are exposed to situations that can lead to post traumatic stress disorders. The effects of mental illness may also develop or last over time. Barriers to Reporting A system challenge, individuals affected by occupational illness and disease may not report exposures for various reasons. This can lead to long-term exposure and, consequently, long-term impacts. Broad Exposures Some occupations involve frequent contact with hazardous materials or other disease-causing agents, but these workers are not considered a priority (e.g. contact with patients receiving chemotherapy, teachers in shops and labs, and water treatment and wastewater workers). Challenges Obtaining Data There is a need for better statistical data regarding occupational disease. It is difficult to obtain adequate data from WSIB or elsewhere to identify trends, and so forth. Exploring other data sources may help address this concern. Propensity to Respond to Key Incidents, Not Key Causes Upon diagnosis of occupational disease, organizations tend to focus on the most recent incident or exposure. However, since disease can take time to manifest, there must be a focus on all potential causes. To put this topic in perspective, of the numerous causes of occupational illness and disease, examples for PSHSA include: noise exposure, exposure to solvents, antineoplastics, infectious agents, asbestos, diesel exhaust, shift work and biological hazards (e.g. mould, bacteria, exotoxins/endotoxins). The following steps can be taken to protect workers from occupational disease. 26
  • 27. Form System Working Groups Working groups involving Health and Safety System partners have shown to yield positive outcomes. For example, PSHSA took part in an occupational disease working group focused on mould exposure, heat stress and noise spanning all sectors which resulted in a series of tools to address the issues. PSHSA recommends and supports new working groups tasked to address other cross-sectoral issues and suggests revisiting data and statistics available to support such a group. System Collaboration and Alignment There are a number of areas for collaboration within the system. Partners should collaborate around key issues, such as occupational hygiene and shift work. Awareness campaigns can be coordinated around certain topics. PSHSA will take initiative to develop new posters, training, etc. In addition, we will continue working with the Centre for Research Expertise in Occupational Disease. Form Partnerships beyond the System Additional stakeholders should be engaged in the conversation about occupational disease so they too can become part of the solution. This can be facilitated, first, by providing awareness. By reaching out to the medical community, we can share legislative updates and extend invitations to information sessions (e.g. OMA, Public Health Ontario, medical schools). Second, partnerships can assist with the gaining of important insights. In working with high-risk trade groups, perhaps through focus groups or other mechanisms, we are able to learn effective approaches to address high risk exposures to such things as noise, solvents and cancer causing agents. Third, system partners should look to form partnerships with other ministries for a broader impact. Similar to other health and safety programs, we should look to work with trade schools to add occupational health and safety into the curriculum. This will help to inform students of the importance of taking precautions prior to the development of symptoms. Integration of New Research in Products and Services Research is instrumental to understanding issues, whether related to occupational disease and illness or in the broader health and safety context. Organizations such as the Centre for Research and Occupational Disease (CRE-OD) and the Centre of Research Expertise for the Prevention of Musculoskeletal Disorders (CRE-MSD) provide valuable insights. Opportunities for the prevention system may involve identifying where there may be a higher susceptibility for workers to develop occupational diseases, and looking at multiple segmentations to be more effective in our prevention activities. Another opportunity may involve the launch of a focus group tasked to identify groups that have a higher likelihood of exposure. In addition, system partners should always look to work collaboratively with scientists and product specialists to translate research results into practical and meaningful products. Enhance and Customize Current Products and Services Where applicable, the system should look into enhancing and customizing current products and services. This would involve investigating other modes of training and service delivery to increase engagement and uptake of information. Other suggestions include gearing training to particular groups and equipping health and safety consultants with checklists and surveillance tools for high-risk exposures. Develop and Market New Products and Services The system partners should consider developing system-wide marketing campaigns to shed light on the long-term effects of exposures and to support any specialized training and services. Continued... 27
  • 29. The Ministry of Labour has laid out a very practical approach to arrive at revised prevention-based programs focused on outcomes. All programs should encourage workplaces with higher injury rates to improve their health and safety programs and consequently decrease injuries to become top performers. All programs should also increase the number of cases that demonstrate return in both dollars and safety as a result of participation and investment. PSHSA has participated in previous WSIB programs, such as: • Safe Communities Incentive Program (SCIP): The program creates awareness and helps firms develop health and safety programs with rebates for participation in training, planning, policy development and self assessment. • Safety Groups: Member firms that are involved in this program share experiences, access resources and work towards implementing a comprehensive health and safety program that will reduce WSIB premiums. Safety Groups offer a financial incentive in the form of rebates if measures are achieved. • Workwell: The program involves on-site evaluations for firms with higher comparative health and safety risks in their workplace. These evaluations can reduce risks and incidents, improve morale, and grant rebates or decrease premiums for improvements in experience records. Highlighted below are areas for consideration when conducting the program review and evaluating the suitability of motivators. Participation Current programs exclude Schedule 2 employers as well as those workplaces that do not pay into WSIB. Unlike Schedule 1 firms who pay premiums, Schedule 2 employers reimburse WSIB for claims paid to their workers in addition to an administration fee. Therefore, considerations need to be made when designing and implementing financial-based motivators or incentive programs. PSHSA is particularly familiar with this as we serve a high proportion of Schedule 2 firms in particular sectors. Multi-Staged Motivation Experience has taught us that the motivators for companies, in terms of engagement in prevention, can shift over time. This has been seen through a number of programs in which PSHSA has participated. Safety Groups are a good example. Our clients were initially drawn to the program because of the financial rebates they receive. However, according to feedback provided by members, we learned that continued participation in the program is not due to the financial rewards, but because of the information, products and consulting services they receive both from PSHSA and other client members which enable them to make health and safety improvements in their organizations. PSHSA recommends pursuing a combined approach, where financial motivators are advertised to draw clients into the Health and Safety System and its programs, and support is provided once they are there. A continuum of involvement could be used to engage both small and larger businesses where the initial focus is on core health and safety elements. Supporting firms to develop robust health and safety programs and to become leaders in health and safety may be a positive motivator. PSHSA’s i3consult model encourages and supports organizations to continue to make improvements in their internal systems. How could prevention programs utilize motivators (positive and negative) to improve occupational health and safety performance in the workplace? 8a 29
  • 30. Other than financial, are there other motivators that will attract a company’s participation in health and safety programs? How could a non-financial incentive program attract participants and assist in motivating better performance?8b The following are suggestions for non-financial motivators to attract participation in health and safety programs. Leadership Status The concept of achieving leadership status, as outlined in the i3consult model, can act as a non-financial motivator for firms and their peers. Accreditation Process Another motivator could be a health and safety accreditation process with a recognition mechanism for successful candidates. Health and safety accreditation should be linked to other business accreditation programs (e.g. ISO, Accreditation Canada). Certificate of Recognition When developing health and safety programs, providing participants certificates of recognition with approved vendor status, or similar motivation, should be considered. Funding Approach Another motivator might entail utilizing a funding approach tied to leading and lagging indicators. 30
  • 32. What should be the strategic objectives of occupational health and safety research in Ontario? 9a PSHSA sees tremendous value in conducting basic and applied research to better understand the characteristics of our clients and their health and safety needs. In addition, it is important to study the barriers and enablers to creating and sustaining healthy and safe workplaces. Further to focusing on the high priority areas within the prevention system, including vulnerable workers, high-hazard activities and small business, we believe a number of other strategic objectives should be considered to advance occupational health and safety research in Ontario. Understand the Needs of Ontario Workers and Employers The research system should seek to understand the market and gain a deep understanding of the needs of those within the market. Align Research with Health and Safety System There are two components to this objective. First, the system should look to create a central research repository. With numerous, relevant research projects taking place, it would be helpful to have one central repository of information. From this, gaps as well as new research opportunities can be identified. Second, the HSAs should make better use of system partnerships. This would involve sustaining and improving relationships and connections across the system to ensure there is sharing of research between organizations and partners to achieve efficiencies. The system must also ensure we are reallocating the resources to new research. Improve Data Collection When possible, the system should utilize technology to improve the collection of data (e.g. implementing a standardized and up-to- date database). Evaluate Health and Safety Program Effectiveness Research needs to focus on evaluating and validating the health and safety programs and tools that are used in the prevention system by system partners. Effectively Translate Research into Products and Services One way to disseminate knowledge and research findings is through the products and training programs the partners deliver. By incorporating relevant and current research into products, the system is able to assist with knowledge implementation. Expand and Enhance Research Networks This will involve looking beyond Ontario and perhaps Canada, and removing jurisdictional silos where they may exist, to understand and coordinate research efforts so that the system can realize efficiencies and improvements in injury and illness prevention. An example of bringing this all together locally may be coordinating a conference focused on occupational health and safety that is global in scope, yet hosted at home in Ontario. Research Suggestions Additional, more specific examples of occupational health and safety topics that we believe should be the focus of future research include: workplace psychological health and safety, the role and the impact of a JHSC or health and safety representative in the workplace, leading practices within our sector clients related to a particular health and safety issue, effective ways to engage clients in health and safety, and validated tools and strategies aimed at advancing health and safety within organizations. 32
  • 33. How can we best align research with the occupational health and safety needs of the workplace? 9b Reflecting on the proposed strategic objectives, the system can align research with workplaces’ health and safety needs through the following. Understanding Needs and Gaps The system should consider taking a bottom-up approach to research identification by surveying the needs of workplaces and working collaboratively with system partners. Partnerships PSHSA is part of the Health and Safety Association Liaison Committee that meets on a quarterly basis with representatives from the HSAs, MOL, Institute for Work and Health (IWH) and other research partners. This serves as an opportunity to exchange ideas, report on current projects and brainstorm strategies to improve the way we do business. Engaging the Right People Within the system, there are people who specialize in knowledge translation and advocate and champion research. There is an opportunity to connect with staff within organizations who believe in research, are motivated to see it succeed and use the research in their health and safety programs. Larger organizations often have human resources dedicated to knowledge and research acquisition. Hence, partners can work with these individuals to expand our networks. It is equally important to engage advocates and specialists at the right time along the program and product development continuum. Tools and Messaging Partners should provide the necessary knowledge tools and articulate the value and benefits of research to the system. 33
  • 34. What could be done to better implement research findings? 9c Creating a Forum Similar to the Healthy Work Environment portal, which is receiving positive feedback, the system should consider creating a central searchable reference for organizations involved in research. This would assist in identifying gaps, refocusing efforts and reducing duplication. Solid Internal Processes Better distribution of research findings across the system should be a priority. In addition, the development of system-wide processes for synchronizing the way that partners gather, appraise and incorporate research knowledge into products and services should be considered. Holding Focus Groups The system should also consider connecting with specific groups for the purposes of raising awareness about research, identifying the needs, validating the necessary tools and outlining where gaps among products and services exist. Penetrating the Market Partners should look to reach out to the market to develop reciprocal relationships and improve understanding. 34
  • 35. 35 10 Effective Means for Measuring Performance
  • 36. What are the right outcomes to measure that would result in a common vision of success for the occupational health and safety system? 10a The system should measure the following outcomes: decreased injury rates, decreased illness rates, decreased occupational illness, effective health and safety training programs, positive workplace culture and psychologically safe and healthy workplaces. In order to properly measure these outcomes, overall improvements and positive changes must be made to the WSIB information. In addition, there must be improvements to non-occupational statistics and other information in terms of availability and application. The data feeding into many of these measures will come from the WSIB EIW system. Recognizing areas for improvement in the way the system is structured is important to measuring and understanding outcomes. We recommend the following for consideration. Develop a Repository of Reports The development of a repository of reports can help standardize the way system partners receive information. Common Definitions What is included in the data may differ from system partners’ definitions. For example, small business in WSIB data is measured as less than 20 FTE, whereas MOL considers less than 50 applicable. A shared understanding and shared definitions will further ensure consistency across the system. Also, the system should look to develop similar approaches to identifying root causes of injuries and illnesses. This can lead to better prevention efforts. Schedule 2 FTE Information Frequency rates cannot be calculated for Schedule 2 clients. As a result, outcome measurement can be challenging. Ensuring Completeness of Information In the Health and Safety system, data comes from various injury and illness reporting forms, including: Form 6 (workers report), Form 7 (employers report) and Form 8 (health professionals report). WSIB and MOL can employ mechanisms, such as imposing a fine for incomplete forms to improve completeness of data. Additional information may also be required. For instance, the idea of proximate cause should be considered when discussing outcomes as well as leading and lagging indicators. An injury or illness may occur in the workplace, but an additional event, either inside or outside of the workplace, may have played a more significant role in causing the actual injury or illness. Additional variables such as economic and psychosocial factors should also be considered. 36
  • 37. What leading indicators does your organization use and what methods are used to measure them? 10b PSHSA recognizes the importance of using both leading and lagging indicators to measure the performance of organizational health and safety and the effectiveness of programs. Recommendations regarding particular outcomes were informed by our participation in projects, such as the IWH Ontario Leading Indicators Project (OLIP), the IWH Organizational Performance Metric (OPM) and the Ministry of Health and Long-Term Care (MOHLTC) Indicators Project. Our indicators are used at an organization level to benchmark and better understand system performance as a whole. The recommended indicators, both leading and lagging, and the outcomes they are associated with are as follows: • Training (leading): staff training and professional development, manager and supervisor training. • Risk assessment and organizational culture (leading): risk assessment and management, employee engagement climate. • WSIB composite (lagging): injury, illness, occupational disease and fatality rates. • Non-occupational/insurer data (lagging): data around the use of pharmaceutical drugs by employees. • Health human resources (lagging): absenteeism, turnover. To better identify what safety components need to be in place, partners may want to look to develop and adopt preventative best practices that outline the necessary components to measuring a safe and healthy workplace (e.g. training, CEO buy- in). The following outline just some of the possible means for measuring the above indicators. Adopting Available Products The means to measure health and safety indicators can be drawn from Accreditation Canada’s Worklife Pulse tool. This organization offers two tools: a general tool for staff and another which measures physicians’ quality of worklife. Surveys For culture, surveys that are related to employee engagement often indicate health and safety performance. Forms 6, 7 and 8 For lagging indicators, the WSIB collects information via Forms 6, 7 and 8. MOL has the power to enforce use and, in collaboration with other members of the Health and Safety System, agreement on the required data. In addition to giving consideration to organizational injury and illness data, preventive measures used by organizations should also be evaluated. More specifically, there should be a systematic evaluation of the health and safety programs developed and delivered by the prevention system partners. To truly understand the effectiveness of programs and prevention efforts, there must be the ability to distinguish which intervention lead to improvement in indicators, be it company effort or HSA effort. Additionally, there should be a better understanding of what happens outside of the workplace that may contribute to injuries and illnesses on the job, or which may improve indicators. Some areas of consideration include: a better understanding of labour and demographic changes and their impacts on injuries and illnesses and the development of shared definitions and methodology for indentifying proximate cause. 37
  • 38. Acknowledgements The development of this response was a collaborative effort. We’d like to thank our staff, advisory council members and Board of Directors for their input and participation in the process and for ensuring the document is reflective of the reality of the sectors we serve and the Health and Safety System as a whole. 38
  • 39. References For more information on Public Services Health & Safety Association, please visit PSHSA.ca. Information on programs and projects referenced within this response are as follow: • PSHSA’s Healthy Work Environment Portal: http://www. healthyworkenvironments.ca/ • Healthy and Safe Healthcare Workplace Indicators Project: http:// www.healthyworkenvironments.ca/Resources_Indicator_Project. htm • Small Business Resource Manual: http://pshsa.ca/2013/02/01/ health-and-safety-for-small-business-resource-book/ 39