In 1976, James Ham introduced us to the concept of the internal responsibility system (IRS) from his inquiry into fatalities in the mining industry. Since then, many organizations have successfully applied the IRS within their management systems. Others, however, are still struggling with its principles.
Ham’s Report of the Royal Commission on the Health and Safety of Workers in Mines was instrumental in identifying issues of responsibility and accountability within the management system in the mining industry. The information contained in the report eventually led to changes in legislation and worker rights in Canada.
The Royal Commission report recognized the value and function of various groups within an organization, such as the joint labour-management health and safety committee and the “worker-auditor.” It indicated the need for them to be more proactive in communicating concerns related to health and safety in the workplace. It also described the advisory role of the health and safety committee as an important resource to help a company respond to changing working conditions.
The following tasks will briefly describe how your health and safety committee can assist your organization in improving its safety management system and its IRS.
The first step is assessing the roles of each individual group within the line organization.
Management has the ultimate responsibility of identifying and addressing safety issues within the company. This is normally accomplished through: assigning, directing and managing the work; allocating appropriate resources; creating a safety culture; developing safety programs; enforcing safety rules; managing labour relations; and managing facilities and equipment.
In turn, the supervisors and workers are accountable to management for performing the work and for assisting management in resolving issues or concerns.
To maintain a healthy safety culture, it’s essential that the line organization’s IRS be founded on this breakdown of responsibilities.
Issues or problems with the IRS usually develop when the line organization is seen as encouraging “production over safety” and not dealing with safety problems. This leads to workers becoming disengaged and frustrated with the management system. It also leads to other groups, such as worker union representatives or the health and safety committee, trying to resolve the IRS issues instead of the line organization.
Evaluating the role of contributory groups that assist the line organization is the next step.
The Royal Commission report noted that an organization must rely on the support of contributory groups to assist, evaluate and recommend changes to its IRS. These groups assist the line organization with the IRS, without interfering with its function.
The contributory groups are divided into the external and internal sub-groups.
The external groups include the labour ministry, safety consultants, workplace safety and insurance boards and safety associations. They identify problems with the IRS and offer recommendations to the organization on how to address the problems. The external groups play a reactive role in addressing IRS issues or failures; but it is always preferable that your company’s issues be identified and corrected internally through the line organization.
The internal groups consist of the company’s corporate group, the workplace health and safety committee, the union and the organization’s safety professionals. The primary IRS role of these internal groups is to educate the line organization in implementing and maintaining their system. They also play an important, proactive role in monitoring and assisting the line organization should the IRS fail at the local level. These groups should be valued as internal auditors of your organization’s IRS and of the issues that may impact its function.
The functions of your health and safety committee should be considered.
Many of Canada’s health and safety committees are required by law and have specific duties assigned to them through provincial and/or federal legislation. These committees must fully understand their duties to best assist the line organization with the IRS.
Some of the basic committee functions include performing workplace inspections, participating in accident/incident investigations, identifying and advising management on how to address unresolved concerns, participating in the work refusals and work stoppages process, reviewing company safety policies and procedures, providing input into safety activities and initiatives, and establishing and maintaining communications with workers.
These should form the basis of the health and safety committee’s mandate or terms of reference. As a body independent from the line organization, an effective health and safety committee can identify potential safety issues affecting the company and recommend solutions. This then means that the committee can participate in the assessment and review of the line organization’s functional areas as well as the company’s IRS.
Once established, the responsibilities and accountabilities of the committee are used as a measurement tool to determine if the committee has achieved its mandate, without overstepping the boundaries of the IRS.
The role, responsibilities and accountabilities must be documented in the committee’s terms of reference and reviewed at least annually. This will ensure that members are familiar with the process and are not performing the line organization’s duties of assigning and directing the work.
The committee must refrain from any activities that are outside of its functions. Too often, it is unnecessarily dragged into line organization issues, such as labour relations, which can lead to loss of the committee’s credibility as a health and safety advisory group.
The committee, like the line organization, also has the same type of contributory groups to assist it.
The internal groups support the health and safety committee with its role as the internal “auditor” of the company’s IRS. These contributory groups must understand the committee’s role, and must be able to identify issues or concerns with respect to the committee’s IRS failures. They also provide valuable information to help the health and safety committee identify and report possible IRS problems within the company.
The external groups are essentially educators and advisors to the committee when it comes to dealing with the IRS. They are able to provide basic IRS information and guidelines when evaluating or assisting the committee during site visits.
Focus on the committee’s relationship and interaction with the line organization and the workers it represents. This is where the extra effort will pay off in maintaining and improving the company’s IRS.
The committee must not interfere with the company’s IRS since this would compromise the line organization’s duties to delegate responsibilities and authority to the groups or individuals performing the work.
The committee must be able to promote awareness of safety issues in the workplace. Identifying workplace hazards is normally performed during workplace inspections but can also come from employee concerns.
The development of corrective actions to deal with safety hazards or deficiencies is the responsibility of the line organization. The health and safety committee should, however, participate in the review and follow-up of these actions. Its input should reflect its assessment of safety issues or current working conditions, and should include suggestions for improvements.
The committee must be seen as a proactive safety auditor and contributor to the company’s safety management system, especially from the employee’s perspective. Having regular meetings and publishing minutes are not enough to fulfill this task. For the benefit of the workers it represents, the health and safety committee must actively pursue positive changes that will improve the company’s overall safety.
Possibility of failure
Prepare for the possibility that the line organization’s IRS will fail. James Ham was well aware of this possibility.
If the contributory groups, including the health and safety committee, are not able to assist in dealing with IRS failures, then it will be up to the worker, as a last resort, to address the situation.
Hence, the Royal Commission report was influential in the development of a worker’s safety rights: the right to refuse unsafe work, the right to know about hazards in the workplace and the right to participate in safety through worker representatives or the health and safety committee.
It is the line organization’s duty to make every attempt to address its IRS failures before employees feels compelled to invoke their safety rights.
The health and safety committee must play an active role in assisting the line organization with this task. Their advisory relationship with the line organization is essential for improving the company’s safety management system.
The need to foster and sustain this important relationship is critical for the company, its workers and a successful implementation of the IRS.
Guy Chenard, CRSP, C.E.T., is a safety professional with the Ontario Power Generation.