One of my clients recently had a WorkSafe BC inspection that took an unexpected dive into the topic of Bullying. It is my opinion that the Policy and Procedures statements I created address the topic well enough but speaking with WSB I have learned a bit more about the “newer” obligations they are implementing for coming inspections. It’s these obligations that we should speak about. I will reach into it a little bit here.
If you are using my Hiring Program, as I have always said, you are “minimally” covered, but you will be expected to do more than just having them in place and signed by new hires. Stated simply, the law requires you to have set policies and procedures in place and adopted by all staff and management. If you don’t have this already, do it. I would prefer you to call me of course, but regardless of how, do this. These hiring programs are easy to implement and until now have been good enough. I understand this may be changing.
As some of you may recall, when I’m training new clients in the use of my hiring program, I describe implementation as “swallowing hooks”. The challenge is that while using these programs for hiring and initial training are cost effective and relatively easy to implement, there are a few commitments you are obligated to make. It is these statements that your new staff are equally obligated to read and acknowledge during hiring. Here are a six sample statements your policies must include, in some form or another:
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- “Company” will make all reasonable effort to ensure its employees work in a healthy and safe environment that is free from bullying, harassment and violence.
- Any senior Manager or Supervisor of “Company”, in consultation with the Joint Health and Safety Committee and employees, are responsible for developing and publishing a Health and Safety Program […]
- All New employees shall receive adequate health and safety orientation and training prior to commencing work.
- This policy will be subject to ongoing review and evaluation, and modifications shall be made, (as deemed necessary) to […]
- “Company” is responsible for the effective implementation of and adherence to the policy, providing appropriate education and training […]
- If required “Company”, will conduct an individualized assessment of an employee’s ability to perform essential functions of their job while using any Medication. […]
This VERY short list is a sample of the “hooks” that a brewery *must* swallow to meet the obligations of Work Safe BC, Employment Standards and Human Rights. I have provided six of them here so that you have a reference for the next paragraphs.
Work Safe BC will be asking – How?
These six sample commitments must be made, and you will be asked: “How – are you going to do this?” I urge you to go back and look at each of those six bullets and ask yourself, what would you say or what would your management team say if an inspector asked – “How, do you do this?”