Working
Alone Legislation:
Amendment
to the Alberta Occupational Health and Safety Act
Overview:
An amendment
to the Alberta Occupational Health and Safety Regulations
(AR448/83) comes into full force on April 30, 2001. This
amendment is designed to ensure that adequate measures are
taken to protect workers who are working alone. It requires
employers to achieve this by:
- assessing
all work areas for potential safety hazards
- take
measures to eliminate or reduce these hazards
- have
an effective communication system available for the worker
to summon help in case of an accident or emergency.
This
requires that everyone who supervises people who may have
to work alone in an office, vehicle, lab, shop or field
site must assess the hazards and develop guidelines to reduce
the risks associated with that work. This legislation does
not forbid people from working by themselves.
Background:
The
Occupational Health and Safety Act is intended to set standards
to protect the health and safety of employees in Alberta.
Employers have responsibilities are expected to set up safe
work practices and also to ensure that these practices are
followed. Workers are also expected to cooperate and follow
the rules designed to promote health and safety at the workplace.
This is the act that requires WHMIS training for workers
to inform them of all the hazards they may encounter while
doing their job. The amendment was developed, at least
partly, as a result of the death of a convenience-store
worker after a robbery in Calgary. However, it has application
for many different kinds of job situations.
Definitions
and Interpretations:
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A worker
is considered as working alone if the
individual is working by his/herself such that assistance
is not readily available should some injury, illness or
emergency arise.
Alone is interpreted as being out of visual [and presumably
voice] contact with another person for more than a few seconds.
The
OH&S Act refers to workers, not just employees,
this means that volunteers (unpaid workers) are also covered
by the legislation.
The
act covers students in laboratories of technical
schools and universities and students engaged in on-the-job
work experience programs.
Students
who are not volunteers or paid for some service are considered
to be self-employed. As such, they have a responsibility
for complying with the Act but educational institutions
like a university are viewed as a prime contractor
with responsibility for the worksite that houses all the
self-employed students (although the details for responsibility
are not altogether clear with respect to students, it is
obvious that the University has some accountibility for
ensuring student safety).
The
Act does not apply to:
- students
enrolled in elementary schools
- students
working in a classroom or computer lab
- students
participating in extra curricular activities
- farmers
and ranchers
- workers
working in their own private dwelling
- domestic
workers (nannies, housekeepers)
- federal
government workers and workers in federally-regulated
industries (banks, television, radio broadcasting).
What
needs to be done if people you supervise are working alone:
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- Conduct
a hazard assessment of the area and work procedures to
identify hazards and try to eliminate them. If you cannot
eliminate the hazards, then try to minimize or control
them.
- Make
sure there is an effective means of communication available
to the worker in case help is needed.
- Ensure
that all workers are trained and educated in how they
are to do their work safely.
You
should also consider an assessment of work in areas like
offices or reading rooms where no 'hazardous activities'
are conducted. In these instances, matters of personal security
are likely most important. You could advise someone that
you expect to return be a certain time so that they might
check on you if you are late. This would be much more important
if a person had a medical condition that predisposed them
to become incapacitated (e.g. epilepsy). Workers and supervisiors
need to assess the risk of injury for the individuals in
all areas, even those where 'activity' risks are considered
minimal.
1. Hazard
Assessment
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- in
cooperation with the workers, review all aspects of the
work that might be done and anticipate the kinds of hazards
that might arise. You are looking for risks of occupational
injury as well as potential for personal injury from a
violent attack.
- review
records of past incidents to help identify potential problems
- identify
what can be done to eliminate or minimize the hazards.
- the
assessment should be written and dated. It should be
reviewed and updated as needed.
- you
need a hazard assessment for each different set of conditions.
If you have 10 offices with similar activities in each,
then one assessment should cover all. However, if money,
tobacco and drugs are stored in one of the offices, that
would require a different review.
This
might include restricting certain activities until another
person is present. This is exactly the same as prohibiting
certain activities if workers are not properly trained or
if they do not have the appropriate safety equipment (a
fume-hood for distilling benzene or a safety harness and
rope if you are climbing 30 meters up a tree). Some examples
of activities that could result in severe personal injury
and which should not be attempted without a backup could
include things like: distilling phenol, entering into a
confined space or one where the atmosphere might be dangerous
(a deep metal tank where rusting can deplete the oxygen
level), getting close to an animal carcass that has recently
been killed (whatever killed it may be close by). Any such
activities should be explicitly mentioned in your hazard
assessment. It is up to the supervisor in consultation
with the workers to identify such situations. The standard
that will be applied if a problem arises will
be by comparing your hazard assessment to others of a similar
nature. If other people have identified five hazards in
a situation very similar to yours and have taken measures
to avoid them while you have not, you will probably be found
lacking in discharging your responsibility to help protect
workers and could be charged under the Occupational Health
and Safety Act.
Besides
injury from personal actions, consider hazards that might
arise from other aspects of the work. Are you exposed to
personal attack by animals (bears, dogs, elk) including
humans? Do you have to travel to remote locations and
meet with clients you do not know in their office? You
might control risk of personal injury for indoor work by
requiring doors be kept shut and locked if you are alone.
You might suggest (or require) workers use the services
of the Safe Walk program if they are leaving the campus
after dark. Adding a check-in and check-out routine may
be warranted to know if someone is overdue whether in travel
to a worksite or leaving an office to return home.
2. Effective
Communication:
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In case
someone needs help, they need access to a means of communication.
This does not mean everyone must be issued a cellular phone
or radio although these may be a good idea in some situations.
Within the department there are telephones in many rooms
and most of the pay phones have quick dial buttons to Campus
security and 911. Undergraduate students should be made
aware of where telephones are located and who to call (Campus
Security knows their way around campus while a 911 operator
will want your street address; call for help at the university
first). If nothing else is available, a tripped fire alarm
will bring assistance.
Field
workers present a bigger problem with regard to communication.
Cell phones may not work where you are located and you may
be out of radio contact. In this case, a check-out check-in
system might be used. A log book is kept in a base camp
and people sign out before they leave indicating route,
destination, activity and estimated return time. When they
return they check back in. The log must be examined at
regular intervals and procedures should have been outlined
in case a search has to be mounted. In some cases, a check
in routine might be used even if an electronic means of
communication is available. If someone is doing highly
dangerous work like felling trees or crawling through sewers,
they might have hourly contacts with someone. The frequency
of contact will depend on the nature of the hazard. Even
without electronic communication, regular contact could
be achieved using flash lights or flags if for instance,
people were working on opposite sides of a lake.
Look at a sample
guidline that might be used for a teaching or research
laboratory (a Word2000 document that you can customize).
The
process of conducting a hazard assessment and seeking measures
to reduce the risks will take some time. Except in simple
situations, the assessment will need to be reviewed and
updated as conditions change or after talking to colleagues
doing similar work. It is hoped that everyone in our department
will start now to develop these procedures and hopefully
we can share ideas.
Some
examples to help you get started:
Please
note, these are intended to get you thinking about some
scenarios that could occur. The particulars for your situation
may dictate a different response.
1.
A graduate student working in a chemical laboratory:
Activity:
|
Potential
hazard:
|
Efforts
to minimize hazard:
|
diluting
a strong acid (HCl)
|
chemical
burn to skin, eyes, inhaling vapours
|
-
work in a fumehood,
-
wear protective clothing (lab coat,
goggles, gloves);
-
knows where spill kit is located;
knows who to call for help because emergency phone
numbers are posted in the lab - OK
|
handling
concentrated hydrofluoric acid
|
death
has occurred from spilling only 250 mL on the skin
|
prohibited
if alone find a partner to back you up during
the procedure; no partner - no procedure.
|
connect
a regulator to a tank of hydrogen
|
fire
or explosion if the tank is damaged due to a fall
|
person
is experienced in procedure; knows how to test for
leaks OK
|
"
|
"
|
person
has never done it before or even seen it done- prohibited
until supervision is available
|
testing
a new stain on a piece of tissue
|
possible
mutagen or carcinogen
|
person
has never done it before or even seen it done; person
is aware of the hazards of carcinogens and is using
appropriate protection and procedures - OK
|
2.
An undergraduate student working in a chemical laboratory:
Similar
to the graduate student but consider the individuals may
have much less experience and may not be familiar with the
building or who to contact in an emergency. More activities
may be restricted because of their inexperience.
-
post
a list of activities that are permitted and those that
are not. You may not identify everything that should
not be attempted but work within the framework of what
the student has previously experienced in the lab.
They may have used an ultra centrifuge during their
lab but are not allowed to run it without supervision.
-
post
a map of where telephones, first aid kit, fire extinguishers,
fire alarm pull stations and safety showers are located.
(N.B. do not advise anyone to use a fire extinguisher
unless they have some experience. They are not firefighters
and the appropriate response is to leave the room, shut
the door and summon help).
-
provide
a list of phone number to call: a teaching assistant,
lab coordinator, lab supervisor, safety officer, campus
security, campus control centre. Use a large font to
make it easier to read in an emergency.
-
try
to have students work in pairs if they have to come
in at odd hours.
-
make
sure they know to keep the door shut and locked when
they are alone.
3.
Anyone working in an office on campus:
Occupational
injury would not normally be anticipated for this situation.
However a person could still trip and become injured.
The potential risk here is that they are alone and may be
subject to personal attack. The door should be kept shut
and locked at all times. If there is a glass door or window,
consider working out of public view. Post the numbers for
Campus Security or Safe Walk on campus. Have people check
in and out with someone when they arrive and when they leave
to go home.
4.
Field research away form a remote base camp:
Activity:
|
Hazard:
|
Efforts
to minimize hazard:
|
bird
survey conducted on the ground
|
none
other than usual hazards of walking in the woods
|
-
radio available: check in with someone every 4 hours
-
carry a personal first aid kit
-
carry appropriate clothing, whistle,
water, map.
-
maybe carry bear spray
|
"
|
"
|
as
above but no radio: OK if you use
a check-out and in log book stored in base camp.
log is checked several times a day for overdue workers
|
retrieving
eggs from nest in trees that require you to climb
4 meters up
|
fall
|
wear
helmet, use harness and rope where appropriate, have
a worker on the ground while in the tree - OK
|
"
|
"
|
as
in previous but no worker available on ground prohibited
|
obtain
a hair sample from a recently deceased moose
|
predator
may be close by and may defend the carcass
|
prohibited
if no backup worker with you. Might even be prohibited
unless the backup is trained in handling firearms
and is carrying a weapon
|
travel
to worksite on an ATV (All Terrain Vehicle)
|
tip
over, fall from seat, run into bushes
|
driver
trained in operation of vehicle;
is
wearing suitable boots and protective clothing (long
pants, jacket and helmet) - OK
|
"
|
"
|
as
previous but no helmet around - prohibited
|
When
you are trying to judge the likelihood and severity of a
hazard, consider the factors that are uncontrolled variables:
could there be a bear in the area? if you are climbing a
tree, footing may be a problem even with appropriate equipment
so thats why you need a backup worker.
All
supervisors need to begin a hazard assessment of any situations
where workers may have to work alone. You need to identify
potential hazards and consider means to reduce or eliminate
the risks. I suggest a point form approach to the assessment
and the guidelines as long as everything can be made clear.
Most of these assessments will include preparing a list
of emergency contacts (telephone numbers), how to contact
help, and locations of safety equipment and other resources.
The assessment must be written and the information communicated
to all workers.
Sources
for further information:
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1. Working
alone guidelines and sample templates from the University
of Alberta Office of Environmental Health and Safety (look
on their policies
web page).
2. Working Alone Safely A Guide for Employers and Employees.
Alberta Human Resources and Employment. 2000. ( workingalone.pdf)
3. Albertas Occupational Health and Safety Regulations.
An Explanation of the General Safety Amendment Regulation.
The Working Alone Amendment II edition. December
2000 (WA 00202). This looks better than the guide.
Go to the Government of Alberta Working
Alone web page to find these two documents.
Please
contact me if you would like me to review your assessment.
Barry
McCashin
CW315A (x2399)
barry.mccashin@ualberta.ca
BGMcC
April 06, 2001
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