You're satisfied with the way you've identified hazards related to specific jobs in your workplace. You've even assessed your hazards against legislated standards. You've trained your people on the hazard controls - repeatedly, thoroughly. Your Joint Health and Safety Committee, if your business is large enough to have one, meets regularly.
One day, a Ministry of Labour inspector knocks on your door. Should you be worried?
Yes, if you haven't documented everything you've done.
The Occupational Health and Safety Act (OHSA) takes the view that if your prevention activities weren't written down, they never happened.
When to "write it down" is the third of six critical steps to an effective health and safety program, designed by our trusted health and safety provider, Workplace Safety & Prevention Services (WSPS).
What is the "it" you need to write down? There are a few of them:
Your health and safety policy statement.
Your safety training: what it was for, who took part, and when.
Inspections and maintenance of equipment and personal protective equipment (e.g. harnesses and lanyards, or respirators).
Non-compliance with policies and procedures, or procedures that didn't work properly - and what you did about it.
Injuries and illnesses: the circumstances and what you did to prevent reoccurrence.
Where to find templates
"Don't reinvent if you don't need to," says Paul Mansfield, Account Manager at WSPS. "Look to see how other companies have done it. Start with an existing template and gradually customize it over time."
Scroll through WSPS Roadmap for Small Business to download helpful resources, at no cost; for example, an investigation report, with instructions, to help you identify incident information, cause analysis, controls, costs and action plans.
What gets in the way of documenting?
Why do small businesses sometimes miss the critical step of writing everything down (besides being chronically short of time)?
Some believe health and safety legislation doesn't apply to them. Owners who opt out of WSIB coverage may believe they can also opt out of the OHSA. That's not true: these are two separate pieces of legislation.
Also, they may have read in the Act that a workplace with five or fewer regular employees does not need a written health and safety policy. What they may have overlooked is the fine print, which indicates that if there's a critical injury or fatality, or even a visit from an MOL inspector, the business owner would still be required to demonstrate (i.e. document) that people are working safely, and that there's a disciplinary process ready to implement if they aren't. See section 6 of the OHSA: "Duties of Employers and Other Persons."
The good news is that documenting your health and safety activities doesn't need to be a ponderous process, and doesn’t require a formal binder full of perfectly formed sentences.
You're a small business, so document like one
Be true to what you are. As a small business, it makes sense for you to keep your health and safety processes simple and informal. Management walkabouts and a quick staff huddle followed by a handwritten memo to file, or a note in a log book: these strategies count when inspectors ask if you've been meeting your legal obligations.
"Many small business owners work out of a vehicle or live out of a briefcase," says Mansfield. "They don't have fully equipped offices, and they're keeping up with documentation at the dining room table in the evenings. What they need to know is two things. One, that their notes can be jotted down in point form. And two, that no matter how inconvenient or onerous, health and safety activities must be formalized in writing. There's simply no getting around it."
About your health and safety policy statement
One of the elements the OHSA requires you to write down (and post on your safety board) is your health and safety policy statement. It's easier than you think. Reflect on why health and safety is important to your business as you answer these three questions:
What is my health and safety promise?
How will we do it?
Who will do it?
Your policy statement does not need to be literature. It just needs to reflect your business and make sense. Check out how other companies have done it.
Let's make this easier
You deserve to be on the simplest, fastest path to a healthy, safe and productive workforce. Check out all six steps to an effective health and safety program in the "Roadmap," "How-To Guide," and other resources offered on the WSPS Small Business Safety Made Easy, and find out how to get it, do it, write it down, watch for it, report it, and find it.