TECHNICAL CORNER - Q&A
Technical Corner appears in each issue of Facility Forum as an information exchange highlighting issues affecting facility operations.
VOLUME 17 Issue 1
Q: What are the parameters surrounding the “25-hours of required seat time” to obtain the Safe Ice Resurfacer Operator (SIRO) permit?
A: ORFA training programs ( specifically Safe Ice Resurfacer Operations) recommend that the practical component should be completed under the supervision of a skilled, seasoned operator. It is recommended that 25 full surface operations (ice maintenance or flooding) be completed while under supervision prior to a new operator performing solo. To ensure that both the employer and employee are meeting these legal obligations it is recommended that an “operating policy” and “operating procedure guidelines” be developed.
SIRO [Safe Ice Resurfacer Operations]
The ORFA sets a minimum of 25-hours of ice resurfacer seat time before a member who has taken the SIRO training workshop can apply for their operator permit – a good tool to help prove training has occurred. Drivers can use the ORFA standard of 20-minutes per flood – 5 minutes of set-up time, 10-minutes fl ood time, 5 minutes to dump and shutdown. This means that every 3 floods equal 1-hour of seat time. A driver can also use time in the seat for tasks such as general ice maintenance or ice in procedures using the resurfacer. The ORFA promotes the basic training requirements of the Occupational Health and Safety Act – we offer comprehensive theoretical training on many subjects – employers must then add the workplace specific component to complete the employee’s professional development process.
It is important to note that this minimum requirement does not supersede the need for the driver to express their confidence and competency in driving the equipment before being allowed to operate alone – some drivers may need more than 25-hours of seat time before applying. The intent of the requirement is to confirm that workplace specific training under the guidance of an in-house competent person has occurred. The supervisor who signs off on the SIRO permit application should ensure that the person making the application is capable and competent to operate the equipment prior to affixing their signature.
SAMPLE POLICY
The Town of Anywhere and its employees agree that prior to any employee operating an ice resurfacer they will have reviewed the manufacturer’s operating manual and completed 25 hours of one-on-one training with a competent skilled ice resurfacer operator. Prior to any employee operating an ice resurfacer solely and unsupervised they will openly express their full confidence in doing so. [Source: ORFA Safe Ice Resurfacer Operations]
Q: We recently installed a new playground structure in one of our parks. Since we have had very little snow, it is being used constantly. I imagine from a liability stand point we need to continue to monitor it when it is in use. What do you think?
A: There is a responsibility to ensure that all NEW playground installations meet current CSA Standards. An internal inspection should be conducted by a competent person as defined in the Occupational Health and Safety Act on a regular basis in accordance with the standard. Z614- 07 (Clause 11) Monthly versus Annual Inspection 2007 edition of the standard clearly states that 12 detailed monthly inspections can be bound together with a summary page and are acceptable en lieu of completing a separate annual comprehensive inspection on top of monthly inspection requirements. Many operators believe that as the snow begins to fall their obligations end – this is not true. It is not unusual to see play equipment that can be removed (swings, teetertotters) and then the remainder of the equipment wrapped in snow fence.
Last year, there was an incident when a girl with a developmental disability became trapped in a 12ft slide that was blocked with snow and ice at the bottom – the girl removed her boots and mitts and threw them out of the slide thinking that she could gain a better grip with her bare hands/feet – she was wrong. The parents of the girl became alarmed when she failed to return after a reasonable time and setout to retrace her known route. The young female recovered but the parents put the parks department on notice. Although this operation had a detailed year round inspection plan already in place, they now have a comprehensive inspection plan for its parks with slides based on weather reports.
Posting the park as closed does not resolve the issue. There is an invitation to play meaning that children are attracted to the area and there is specific obligation to ensure their safety. You have identified a potential hazard – now action must be taken. Now that’s good risk management.
Q: We struggle with understanding our obligations associated with annual worker WHMIS training – any direction on this issue?
A: This requirement has been misinterpreted by the industry since the first WHMIS courses were offered more than 20 years ago. First, there is nothing in the legislation that requires “ specific annual worker training in WHMIS be conducted”. What the OHSA says specific about WHMIS training and review is found under Regulation 860 of the Industrial Regulation Section 4, 6 & 7 - Worker Education. These sections merely support Section 25 of the Act that requires employers to provide training by giving direction to the employer in respect to their obligations to ensure a worker is informed of all hazardous information concerning “controlled products” that arrive or produced in the workplace; labels; MSDS; use, storage, handling and disposal of controlled products that a worker education as outlined in (1) is developed and implemented (3) and that the worker is able to use the information and train ing to protect their health and safety. This trying does not have an expiry date. It is as required which in many cases is more than annually.
The area specific to WHMIS that may cause some confusion is found under Section 42 of the OHSA - Instruction and Training. Under Subsection (1) it continues to support the need for training of workers using the following requirement “hazard chemical instruction and training as may be prescribed”; (2) such training shall be developed and implemented by the employer in consultation with the committee and/or health and safety representative (3) Review “an employer shall review, in consultation with the committee or health and safety representative the training and instruction provided to a worker therewith at least annually”. Section 25 sub-section (j) of the OHSA is more encompassing in respect to employers obligations to train; it states that “an employer shall: prepare and review at least annually a written occupational health and safety policy and develop and maintain a program to implant this plan” – this would include WHMIS as well as all other obligations in this regard.
This does not suggest that annual WHMIS training is no longer a requirement. In fact, we are concerned that some of our members are neither current nor in compliance with respect to WHMIS. There is a false sense of legislative security by putting workers through annual in-house training programs that simply repeat the core values of the WHMIS program. It is important to meet the basic minimum requirements of WHMIS that includes a second stage of “workplace specific training”. As a supervisor, ask yourself this: Currently, are you putting staff through an in-house WHMIS training program that lumps all municipal staff together? When they return, do you conduct additional training that may include specific MSDS overviews, chemical storage best practices etc.? Do you con duct any type of training when a new controlled chemical arrives on site? If you answered “no” to the two last questions you may want to review your existing WHMIS training program.
WHMIS training requires an internal commitment to a comprehensive training program that includes theory and “show and tell”. Anything less is a legal trip wire that may be triggered at any moment.
Q: Our Joint Health and Safety Committee (JHSC) is not very active with their workplace inspection requirements. Any advice on how to improve their attitude?
A: Any facility supervisor that relies on the operations JHSC to conduct workplace inspections is merely asking for trouble. The role of the JHSC in inspecting is in fact a check and balance that the supervisor is running a safe operation through a positive health and safety culture; this includes regular workplace inspections by the supervisor or their designate. The goal of the facility supervisory staff is to have the JHSC find nothing to report upon their visit. My conversations with health and safety professionals suggest that the MOL’s unwritten expectation is that supervisors should be conducting and logging in-house health and safety inspections weekly. Too many operations are shifting workplace health and safety obligations to the internal health and safety officer or JHSC. These individuals are merely tools to facilitate your commitment toward a safe and healthy workplace.
Inspections Reveal Lack of Good Risk Management Practices
At the recent Facility Operational Forum in Burlington Frank Cowan Co. Risk Manager Colin Kennedy presented an overview of reoccurring risk pressure points that he regularly encounters during his inspections. The message Colin sent to ORFA members is that the majority of legal claims they receive could be easily avoided with ongoing inspection and little actual capital investment. Although Colin’s full presentation was packed with good information, we have narrowed it down to these top 10 items.
#1 Outside Slips, Trips and Falls – usually caused by poor housekeeping or lack of maintenance. Facility staff accepts the current state of deterioration in outside areas such as walkways, paving stones and parking lots. Ongoing inspection and repair can significantly reduce the potential for legal action.
#2 Slips, Trips and Falls – usually caused by poor housekeeping or lack of maintenance. Facility staff accepts the current state of facility design as acceptable or out of their control. Such areas need serious consideration for improvement as part of a proactive risk reduction plan.
#3 Improper Fuel Storage – improper storage locations for fossil fuels being stored poor locations indoors and outdoors.
#4 Improper Propane Tank installation – many propane tanks found on ice resurfacing equipment are improperly installed. Ensuring that the locking pin is firmly in place will help ensure that the tank is in the correct position thus allowing its fail-safe mechanisms to function should the unit discharge.
#5 Inaccessible Fire Suppression Equipment – fire extinguishers are missing or are found in locations that are hidden from view or inaccessible.
#6 POOR Housekeeping – several areas are found cluttered and untidy creating an unsafe work area and fire hazard.
#7 POOR Fire Exit Operations – too many fire exits are being altered and poorly maintained.
#8 Unprotected Gas Supply Areas – several facilities have gas supply equipment that can be easily vandalized or is accessible to vehicle traffic; these areas need to be protected.
#9 Winter Park Inspections – many operations give up on inspecting and maintaining their parks during the winter months. Remember that if they are being used they need to be inspected and maintained.
#10 Standpipe Upkeep – a f ire system that does not work when required is not positive risk management. Facilities that experience ongoing theft of cover lids and other equipment often give up and fail to maintain their outside fire hose connection systems.
Colin’s presentation was well received by all present at the Annual Facility Operational Forum.
The ORFA is proud to call Frank Cowan Co. a partner in its efforts to reducing risks in facility operations. Contact the ORFA for a complete copy of the presentation with eye opening examples from municipal facilities in Ontario www.orfa.com email: info@orfa.com.
