General principles
The University of Waterloo’s Health, Safety, Environment Management System (HSEMS) provides the framework to enable University compliance with health, safety and environment legislation. Specifically, it apprises members of the campus community of their duties and responsibilities with respect to these acts, UWaterloo’s relevant policies, and collateral procedural and reporting requirements.
The University’s HSEMS supports the management of Health, Safety and Environment (HSE) by ensuring:
- Maintenance and implementation of a policy on Health, Safety and Environment
- Compliance with HSE legislation
- Provision of centralized Health, Safety and Environment programs, standards, and services
- Guidance to faculty/department Health, Safety and Environment programs
- Monitoring and auditing of HSE
- Support for the activities of health and safety committees
The University has a general duty to "take every precaution reasonable in the circumstances for the protection of a worker" (OHSA) as well as a duty to put in place a proper system to prevent the occurrence of offences under the legislation and to take reasonable steps to ensure the effective operation of that system (Supreme Court of Canada).
- 1.1 - Policy 34: Health, safety and environment
- 1.2 - Internal responsibility system
- 1.3 - Management of change
- 2.0 - Roles and responsibilities
- 2.1 - University
- 2.2 - Audit committee
- 2.3 - Vice-president, Academic and Provost
- 2.4 - Secretary of the University
- 2.5 - Officers of the University
- 2.6 - Academic and academic support directors/chairs/heads
- 2.7 - Faculty/department health and safety coordinators/committees
- 2.8 - Researchers, faculty and supervisors
- 2.9 - Supervisors of contractors and sub-contractors
- 2.10 - Workers, students and other persons
- 2.11 - Safety Office
- Director of safety responsibilities
1.1 Policy 34: Health, Safety and Environment
Key to the HSEMS is UWaterloo Policy 34: Health, Safety and Environment, which states:
"The University of Waterloo strives to provide a safe, healthy work and educational environment for its students, employees, visitors and contractors. The University insists on compliance with legislative requirements and regulations contained in, but not limited to, the Occupational Health and Safety Act, the Workplace Safety and Insurance Act, the Fire Prevention and Protection Act and the Environmental Protection Act, and University of Waterloo policies and procedures."
1.2 Internal responsibility system
Each faculty member, staff member, student, visitor and contractor has the primary responsibility for their own safety and actions, and for others affected by their actions. Supervisors and all other persons in authority must provide for health and safety of those under their authority, including training in specific work tasks and must take necessary measures to comply with environmental requirements.
1.3 Management of change
Management of change is defined as a process to evaluate and manage any modifications to the design, control, or operations (including staffing) of a workplace activity, before any change is implemented.
Its purpose is to ensure that:
- No unintended hazards are introduced
- Risks are properly evaluated and minimized
- Update hazard analyses and controls, including standard operating procedures and training
As part of the process of identifying, monitoring, assessing and controlling risks and hazards in areas under their control, department directors/chairs/heads and supervisors must anticipate, prior to making any modification or introduction of new work methods, materials, processes, machinery or equipment in the workplace, the potential impact of the change on the health and safety of students, employees or other persons.
2. Roles and responsibilities
2.1 University
Directors and officers of UWaterloo are required to take all reasonable care to ensure University compliance with legislation and orders/requirements of HSE officials. For the purposes of HSE legislation and UWaterloo HSE Policy:
- Directors are members of Board of Governors
- Officers are the President and Vice-President, Academic & Provost and all direct reporting managers to the President and the Provost
2.2 Audit committee
The Board of Governors Audit Committee annually reviews UWaterloo’s report on compliance with HSE legislation. Additional reports may be presented to the Audit Committee where circumstances require the Audit Committee to carry out responsibilities pursuant to applicable legislation, on behalf of the Board of Governors.
2.3 Vice-President, Academic, & Provost
- Approves university policies and other actions necessary to comply with legislative requirements including OHSA, FPPA and EPA; and
- Responds to recommendations of a Joint Health and Safety Committee and Director of Safety.
2.4 Secretary of the University
- Oversees and supports the work of the Director of Safety with respect to design, implementation and maintenance of UWaterloo’s Health, Safety and Environment Program;
- Reviews and presents to the Board of Governors Audit Committee an annual report on HSE compliance;
- Establishes and maintains a procedure to identify legal requirements and periodically evaluate compliance with these requirements; and
- Reports to the President and/or Provost:
- Where there is not full and timely compliance with an order issued by the relevant Ministry or regulatory agency; or
- Any significant event which requires Board of Governors Audit Committee attention.
2.5 Officers of the University
Officers of the University, as defined in Section 2.1 are accountable to the Board of Governors for directing health, safety and environment activities within their areas and providing appropriate financial, human, and organizational resources to plan, implement, check, review, and correct the HSEMS. Specifically, this includes:
- Ensuring that UWaterloo’s Health, Safety and Environment Policy and Program is implemented; and
- Defining roles, assigning responsibilities, establishing accountability, delegating authority and ensuring that annual performance reviews address how subordinates have carried out their responsibilities for managing HSE.
- Maintaining a Senior Management Health and Safety Committee as appointed by the Vice-President, Academic, & Provost. The Committee is responsible for advising, at least annually, the Officers of the University on the overall health and safety performance of the University. The Committee shall identify and prioritize action plans, as well as new objectives and targets to facilitate continuous improvement of the HSE program.
- In performing its duties the Committee shall review:
- HSE performance to established objectives and targets;
- Periodic reports from Director of Safety on the HSE Program, which includes an assessment of faculty/departmental compliance with the HSEMS;
- Results of Safety Office department reviews and legal developments or other circumstances impacting overall risk management.
2.6 Academic and academic support directors/chairs/heads
Academic and academic support department directors/chairs/heads are accountable to the officers of the University and are given authority to exercise management functions. In carrying out HSE duties on behalf of the University, directors/chairs/heads are required to:
- Appoint competent supervisors
- Provide for information, instruction, supervision and training to enable students, faculty and staff to safely perform their tasks
- Establish and maintain measures to identify, monitor, assess and control risks and hazards according to the HSE Program; including Job Hazard Analysis, Standard Operating, Inspection and Incident Investigation Procedures
- Maintain appropriate records to demonstrate compliance with their duties and obligations
- Take corrective action, including discipline, where a member of the campus community is found or reported to be in an unsafe condition
- Review the Annual Faculty/Department Health, Safety and Environment Report (see 2.7 below) according to UWaterloo’s Health, Safety and Environment Program to ensure the faculty/department is meeting its obligations with respect to the HSEMS and submit to the Director of Safety
- Assisting the Director of Safety or designate with conducting a periodic comprehensive Health, Safety and Environment review.
2.7 Faculty/department Health and Safety coordinators/committees
Management may establish faculty/department health and safety coordinators/committees to co-ordinate health and safety activities and advise department directors/chairs/heads on health and safety matters on an ongoing basis. Such coordinators/committees should be designated person(s) who will communicate their findings to department directors/chairs/heads. In the absence of coordinators/committees, the department directors/chairs/heads assume these responsibilities. faculty/department health and safety coordinators/committees are responsible to their management for:
- Making recommendations concerning procedures and regulations addressing UWaterloo’s Health, Safety and Environment Program
- Completing the Annual Faculty/Department Health, Safety and Environment Report according to UWaterloo’s Health, Safety Environment Program
- Assisting with and/or conducting inspections and incident investigations in their area
- Ensuring that health and safety concerns are addressed by:
- Taking appropriate action as a co-ordinator/committee
- Referral to the appropriate department manager for action
- Referral to the Safety Office and/or a Joint Health and Safety Committee
2.8 Researchers, faculty and supervisors
Every person in a supervisory position is responsible to his/her line of authority for:
- Taking every reasonable precaution to protect and promote the health, safety and environment of those persons reporting directly and indirectly to them
- Ensuring that persons work in an appropriate manner, and with the equipment, protective devices, measures and procedures required
- Advising persons of the existence of potential or actual danger to their health or safety
- Fulfilling the requirements of the UWaterloo’s Health, Safety and Environment Program
- Ensuring that required job-specific training in areas and operations under their control is identified through hazard assessment and provided to all employees, and that records of training are maintained
- Promptly investigating and reporting all workplace incidents and taking any appropriate corrective action
- Ensuring their work area is inspected on a monthly basis
- Completing mandatory supervisory HSE training
2.9 Supervisors of contractors and sub-contractors
Any employee of the University who is responsible for hiring or overseeing a contractor or sub-contractor to perform work within the University must ensure that:
- Contract documents incorporate the applicable requirements under UWaterloo’s Health, Safety and Environment Policy and Program
- Relevant information relating to UWaterloo’s workplace hazards are communicated to the contractor
- Compliance with the UWaterloo’s Health and Safety Policy and Program is monitored and enforced
2.10 Workers, students and other persons
All persons on University premises, whether for monetary compensation or for educational or other purposes, are responsible for:
- Complying with HSE legislation and UWaterloo’s Health, Safety and Environment Policy and Program
- Using or wearing the appropriate equipment, protective devices or clothing
- Reporting promptly any hazardous condition or injury to his/her supervisor
- Refraining from any activity that may endanger the health and safety of themselves or of any other person
- Completing all training that applies to their job. Workers may be required to demonstrate their level of understanding of training through the completion of tests, quizzes and/or task observation
2.11 Safety Office
The Safety Office serves as a HSE resource to assist members of the University community in meeting their obligations to provide a safe, healthy work and educational environment. In particular, the Safety Office:
- Develops and reviews UWaterloo’s Health, Safety and Environment programs
- Provides advice, assists faculty/departmental health and safety co-ordinators/committees
- Administers, serves on or is a resource to UWaterloo’s HSE committees
- Monitors departmental and Joint Health and Safety Committee (JHSC) inspections
- Follows up on incidents as appropriate and monitors preventive and corrective actions
- Conducts periodic review of departmental HSE programs
- Acts a resource for the provision of training for all employees, and is responsible for determining training needs at least annually, providing training or train-the-trainer sessions as required, and retaining all HSE training records
The Director of Safety is responsible for:
- Directing the effective, efficient, and comprehensive delivery of assigned health, safety and environmental program services to support the achievement of the University’s strategic goals, facilitate successful endeavours by all members of the University community and ensure that persons accountable for University operations are informed of risks and compliance requirements
- Preparing reports on UWaterloo’s Health, Safety and Environment Program, which includes an assessment of faculty/departmental compliance with the HSEMS for the Senior Management Health and Safety Committee
- Duly informing officers and department directors/chairs/heads of their accountability and responsibility under the Occupational Health & Safety Act and regulations, Policy #34 and this management system
- Informing and advising the Secretary of the University on any instances where, pursuant to the legislation:
- Ministry or regulatory agency issues an order and there is not full compliance within the specified time
- Employee(s) refuse(s) to work for reason of danger to their health or safety
- Decision is taken to not implement a recommendation of a Joint Health and Safety Committee
- Circumstances require the Board of Governors Audit Committee to be informed so they may carry out responsibilities pursuant to applicable legislation, on behalf of the Board of Governors
Revision approved by the Vice President, Academic & Provost, June 20, 2013.