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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

PRIORITIES

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

E�ective Support for Workplaces

Addressing Occupational Disease

E�ective Financial and Non-Financial Motivators

Research Supporting System Improvement E�ective 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

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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 O�erings• 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

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• Measuring Outcomes (e.g. Decreased Injury & Illness Rates, Decreased Occupational Illness, E�ective 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 E�ectiveness o Translate Research into Products & Services

• Continuing Partnerships• Engaging the Right People• Tools & Messaging• Creating a Forum• Solid Internal Processes• Focus Groups

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Injuries, Illness & FatalitiesZERO WORK RELATED

IntroductionThe 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.

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SummaryIn addressing the Strategy paper, PSHSA identified several common themes that can help position the system for future success.

Develop a Renewed Focus on PurposeThe 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 SystemTogether, 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 PreventionThere 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.

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1 Addressing the Needs of Vulnerable Workers

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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 SystemThere 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 MediaIt 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.

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Strengthening the occupational health and safety of vulnerable workers can be facilitated through partnerships, education, collaboration and better communication.

PartnershipsIt 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 EducationSystem 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 MessagingWe 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 CommunicationFor 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

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2 Responding to Small Business Needs

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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 ModelThe 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 CaseSmall 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 ApproachBy 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 ResourcesPartners 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

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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 FocusIn 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 CaseUsing 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 ToolsSystem 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 ToolsThe 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.

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3 Assistance for High-Hazard Activities

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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

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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

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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 TrainersIt 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-TrainerRigorous 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 CompromisesOrganizations 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 QualityWhen 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 StandardsIn 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 ModelsMining and Forestry programs maintain strict training standards with mandatory training. Principles for implementation can be derived from their models.

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4 Integrated Planning & Service Delivery Model

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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 OutcomesWithin 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 PartnersOverlap 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 IntegrationThere 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 AnalysisPartners 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.

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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 UptakeTo 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 DeliveryAs 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 OutcomesThis 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 ServicesThe 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

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5 Expanding Capacity through InnovativePartnerships

What new partnerships could advance occupational health and safety?5a

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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 PartnershipsThere 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 OrganizationsRather 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 SectorThe 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 AssociationsSystem 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, LicensingSystem 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.

SponsorshipsSystem partners should consider joint sponsorships for conferences and trade shows to improve both value for money and coordination of messaging and marketing efforts.

Expand eConsultingIt 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 GrassrootsAs 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.

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6 Effective Support for Workplaces

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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 ResponsibilityCompliance 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 ComplianceIt 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 DisseminationCollaboration 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

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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 TechnologyThe 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 AssociationsThe 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 LibraryA 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 support6b

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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 PracticesA 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 OfferingsTo 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

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7 Addressing Occupational Disease

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What additional steps could the occupational health and safety system take to protect workers from occupational disease?7

Prior 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 DiseaseExposure 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 ReportingA 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 ExposuresSome 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 DataThere 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 CausesUpon 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.

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Form System Working GroupsWorking 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 AlignmentThere 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 SystemAdditional 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 ServicesResearch 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 ServicesWhere 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...

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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.

ParticipationCurrent 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 MotivationExperience 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

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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 StatusThe concept of achieving leadership status, as outlined in the i3consult model, can act as a non-financial motivator for firms and their peers.

Accreditation ProcessAnother 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 RecognitionWhen developing health and safety programs, providing participants certificates of recognition with approved vendor status, or similar motivation, should be considered.

Funding ApproachAnother motivator might entail utilizing a funding approach tied to leading and lagging indicators.

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9 Research Supporting System Improvement

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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 EmployersThe 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 SystemThere 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 CollectionWhen 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 EffectivenessResearch 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 ServicesOne 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 NetworksThis 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 SuggestionsAdditional, 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.

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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 GapsThe system should consider taking a bottom-up approach to research identification by surveying the needs of workplaces and working collaboratively with system partners.

PartnershipsPSHSA 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 PeopleWithin 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 MessagingPartners should provide the necessary knowledge tools and articulate the value and benefits of research to the system.

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What could be done to better implement research findings?9c

Creating a ForumSimilar 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 ProcessesBetter 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 GroupsThe 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 MarketPartners should look to reach out to the market to develop reciprocal relationships and improve understanding.

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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 ReportsThe development of a repository of reports can help standardize the way system partners receive information.

Common DefinitionsWhat 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 InformationFrequency rates cannot be calculated for Schedule 2 clients. As a result, outcome measurement can be challenging.

Ensuring Completeness of InformationIn 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.

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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 ProductsThe 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.

SurveysFor culture, surveys that are related to employee engagement often indicate health and safety performance.

Forms 6, 7 and 8For 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.

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AcknowledgementsThe 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.

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ReferencesFor 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/

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