Imported and Manufactured Food Program Inspection Manual
Chapter 3: Occupational Safety and Health
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Chapter 3 of the Inspection Manual covers safety and health matters related to delivery of inspection duties. This chapter also provides information on employee rights as they relate to occupational safety and health, and aims to increase awareness on prevention of accidents and hazardous occurrences related to inspection activities. The latter section of this chapter provides information on general safety guidelines for Inspectors.
The bulk of the sections of this chapter have been derived directly from the CFIA's Occupational Safety and Health (OSH) website.
3.1 Rights of Employees
The Canada Labour Code - Part II is intended to prevent accidents and injury related to employment. The Code is based on three fundamental rights of employees:
The right to know
Inspectors have the right to be informed of known or foreseeable hazards in the workplace and to be provided with the information, instruction, training and supervision necessary to protect their health and safety.
The right to participate
Through the Regional, Area and local OSH workplace committees and representatives - (Internal access only), inspectors have the right, and the responsibility, to participate in identifying and recommending corrective and preventive measures regarding job-related health and safety concerns.
The right to refuse dangerous work
An employee, at work, has the right to refuse dangerous work, if he or she has reasonable cause to believe that:
- a condition exists at work that presents a danger to himself or herself;
- the use or operation of a machine or thing presents a danger to the employee or a co-worker; or
- the performance of an activity constitutes a danger to the employee or to another employee.
Section 128 (1), 129 and 130 of the Canada Labour Code – Part II describes the inspectors right to refuse dangerous work in detail.
3.2 Duties of Employees
Section 126 (1) of the Canada Labour Code - Part II outlines the duties of employees with respect to occupational health and safety. In summary, employees should:
- use any safety materials, equipment, devices and clothing that are intended for the employee's protection and furnished to the employee by the employer
- follow prescribed procedures with respect to the health and safety of employees
- take all reasonable and necessary precautions to ensure the health and safety of themselves, other employees and any person likely to be affected by the employee's acts or omissions
- comply with all instructions from the employer concerning health and safety
- cooperate with the policy and work place committees or the health and safety representative
- report to the employer any circumstance in a work place that is likely to be hazardous to the health or safety of the employee
- report every accident or other occurrence arising in the course of or in connection with the employee's work that has caused injury to the employee or to any other person
- comply with oral or written direction of a health and safety officer
- report any situation that the employee believes to be a contravention the Code
3.3 Duties of the Employer
Section 125 (1) of the Canada Labour Code - Part II outlines the duties of employers with respect to occupational health and safety. In summary, employers should:
- investigate, record and report in the manner and to the authorities as prescribed all accidents, occupational diseases and other hazardous occurrences known to the employer
- post at a place accessible to every employee and at every place directed by a health and safety officer
- a copy of the Code
- a statement of the employer's general policy concerning the health and safety at work of employees, and
- any other printed material related to health and safety that may be directed by a health and safety officer
- keep and maintain in prescribed form and manner prescribed health and safety records
- first-aid facilities and health services
- sanitary and personal facilities
- potable water
- ensure that the vehicles and mobile equipment used by the employees in the course of their employment meet prescribed standards
- provide every person granted access to the work place with prescribed safety materials, equipment, devices and clothing
- ensure that the levels of ventilation, lighting, temperature, humidity, sound and vibration are in accordance with prescribed standards
- comply with prescribed standards relating to fire safety and emergency measures
- ensure that employees have safe entry to, exit from and occupancy of the work place
- provide each employee with the information, instruction, training and supervision necessary to ensure their health and safety at work
- ensure that each employee is made aware of every known or foreseeable health or safety hazard in the area where the employee works
- ensure that the work place, work spaces and procedures meet prescribed ergonomic standards
- comply with every oral or written direction given to the employer by an appeals officer or a health and safety officer concerning the health and safety of employees
- ensure that employees who have supervisory or managerial responsibilities are adequately trained in health and safety and are informed of the responsibilities they have under the Code
- respond, as soon as possible, to reports made by employees
- develop health and safety policies
- ensure that the work place committee or the health and safety representative inspects each month all or part of the work place, so that every part of the work place is inspected at least once each year
- when necessary, develop, implement and monitor a program for the provision of personal protective equipment, clothing, devices or materials
3.4 Preventing Accidents/Hazardous Occurrences
- 3.4.1 Job Hazard Analysis
- 3.4.2 Personal Protective Equipment (PPE) and Clothing
The Canada Labour Code - Part II and its Regulations, and CFIA occupational safety and health (OSH) policies, directives, and guidelines provide directional advice in preventing accidents, injury and occupation-related illness.
3.4.1 Job Hazard Analysis
A Job Hazard Analysis (JHA) is a process of identifying potential hazards related to a job for the purpose of reducing or eliminating hazards, developing safe work practices and implementing control measures.
Human Resources Skills Development Canada (HRSDC) is currently developing regulations to provide inspectors with directional advice on JHAs.
3.4.2 Personal Protective Equipment (PPE) and Clothing
The use of Personal Protective Equipment (PPE) is an important component in accident prevention and inspectors should use PPE or wear protective clothing when it is not possible to eliminate a health or safety hazard at their work site. Inspectors should consult their supervisor to find out what types of PPE is required for a specific inspection activity.
188.8.131.52 General Requirements for PPE
All personal protective equipment must:
- provide effective protection,
- not create a hazard itself,
- be regularly inspected and tested by a qualified person, and
- be kept in a clean and sanitary condition.
A "qualified person" means, a person who, because of his or her knowledge, training and experience, is qualified to perform that duty safely and properly.
Annex 1 provides a list of personal protective equipment, materials and clothing provided by the CFIA to Inspectors conducting food safety inspections.
Ergonomics is the study of designing equipment and devices that fit the human body and its movements. The main purpose of using ergonomic equipment is to prevent musculoskeletal problems resulting in aching, numbness, tingling, weakness or pain usually in the fingers, wrists, arms, shoulders, neck, back and feet. Other concerns include fatigue, headache and eye strain. These problems are common among employees working in an office, a laboratory, and in slaughter environments.
The main causes of these injuries are:
- Sitting or standing in a stationary position for extended periods of time, poor body alignment, excessive reaching or twisting.
- Repetitive motion such as mousing, keyboarding, or inspecting samples for extended periods of time.
- Force or Pressure:
- Sitting for extended periods of time, handling knives, lifting objects (especially when lifting outside of neutral position).
- Poor workstation design:
- Improper positioning of the monitor, keyboard or mouse, rack and table height, incorrect lighting, poor layout of tools and accessories on the working surface, and poor design of tools and equipment.
- Work Habits:
- Working for long periods without breaks or stretching, or using poor lifting techniques.
Inspectors should report any symptoms to their supervisor and should take time to examine their work station design to see if improvements can be made.
3.5.1 Safe Work Practices – Office Environment
Listed below are some tips to follow in order to maximize comfort when working in an office environment
- Stretch or change your position every half hour.
- Maintain good posture.
- Blink often and look into the distance.
- Adjust your armrests to support your forearms.
- Position the keyboard and mouse beside each other, allowing for your wrist and forearm to be straight.
- Keep the monitor at arm's distance and placed so that your eyes can sweep the screen without head movement.
- Reduce glare that you see on your monitor.
- Keep ambient lighting low and use task lighting for work surface or document.
- Adjust your chair to support your lower and upper back and most of your thigh.
- Avoid resting your wrist.
- Use a headset if you are on the phone regularly.
- Use hotkeys (such as control S for Save).
- Organize your workstation efficiently to avoid twisting, bending, or reaching.
- Have your glasses set appropriately for computer distance.
3.5.2 Precautionary Measures for Safe Lifting
If you lift or carry more than 10 kg, you must be trained in safe lifting and must follow safe work procedures. Here are some guidelines:
- Size up the load and get help or equipment when necessary.
- Check to see if the movement pathway is clear.
- Get a firm footing with feet apart for a stable base close to the load.
- Bend your knees.
- Tighten abdominal muscles to support your spine.
- Keep the load close to your body.
- Keep your back straight and avoid twisting.
- Lift with your legs.
3.6 Hazardous Substances
- 3.6.1 Workplace Hazardous Materials Information System
Inspectors may sometimes work in an environment where there may be a risk of exposure to hazardous materials. The inspectors must have the appropriate level of Workplace Hazardous Materials Information System (WHMIS) training if they are exposed to hazardous substances.
3.6.1 Workplace Hazardous Materials Information System
The Workplace Hazardous Materials Information System (WHMIS) is Canada's hazard communication standard. The key elements of the system are cautionary labelling of containers of WHMIS "controlled products", the provision of Material Safety Data Sheets - (Internal access only) (MSDSs) and worker education programs.
The employer is responsible for ensuring that controlled products are properly labelled and that inspectors are provided with appropriate MSDSs and any required training if they are expected to be exposed to hazardous substances.
WHMIS covers any product, material or substance found in the classes listed in Schedule II of the Hazardous Products Act. It includes compressed gas, flammable, combustible, oxidizing, corrosive, bio-hazardous and dangerous materials and materials causing toxic and corrosive effects.
184.108.40.206 Material Safety Data Sheets
Before undertaking any task or while performing these tasks, inspectors should be aware of all risks of exposure to hazardous materials. Always review the Material Safety Data Sheets before using or handling new products or chemicals in the workplace or at an establishment. The potential dangers may include:
- explosion hazards
- fire hazards,
- incompatibility hazards,
- toxic hazards,
- dangers of bio-hazardous and infectious substances,
- corrosive hazards,
- radiation hazards,
- unknown substances.
The degree of severity for exposure to any hazardous material varies with:
- the substances or materials involved,
- the length of exposure,
- the route of entry into the body,
- the individual's health and physical condition,
- the length of time before treatment is administered,
- whether the correct first-aid measures are taken,
- environmental considerations (e.g. humidity, temperature).
220.127.116.11 General Preventative Measures
Listed below are some general precautions to take when dealing with hazardous substances:
- Look for labelling, placarding or any other symbol that indicates presence of hazardous wastes and that can identify the material belonging to one of the 9 classes; symbols or words that indicate the contents are from a lab; signs of corrosion or leakage; and swelling or bulging of the container.
- Keep all handling to a minimum.
- Preventive Guidelines
- Follow the preventive guidelines of the 8 classes of dangerous goods.
- Wear personal protective equipment as prescribed by the Job Hazard Analysis
- Skin Contact
- Never allow direct skin contact with the surfaces of containers or their contents.
- Precision Tools
- Use precision tools to open and sample hazardous substances
3.7 Reporting Accidents and Hazardous Occurrences
- 3.7.1 Responsibilities
- 3.7.2 Reporting
Under the Canada Labour Code - Part II, inspectors are required to report every accident in the course of work that has or is likely to cause an injury to the employer.
Guidelines were developed to ensure reporting and recording consistency and to gather information for trends analysis. They contain:
- explanations about the responsibilities of employees, supervisors and managers;
- information about applicable forms, such as the Hazardous Occurrence Investigation Report - (Internal access only) ; and
- details on what to report – the different categories of incidents, such as near misses, minor injuries, recurrences – and how to send the information.
18.104.22.168 Employee's Responsibilities
Employees have a responsibility to take all reasonable and necessary precautions (use and maintenance of Personal Protective Equipment, safe work and hygiene practices) to ensure their health and safety and that of anyone else who may be affected by their work or activities:
- by reporting to the manager/supervisor any accident even if they seem minor;
- by reporting to the manager/supervisor any thing or circumstance that is likely to be hazardous to employees or any other person in the work place;
- by reporting to the manager/supervisor, all work related accidents, occupational diseases or other hazardous occurrences that have caused injury to the employee or any other person.
22.214.171.124 Manager's/Supervisor's Responsibilities
Managers/supervisors must be thoroughly aware of all applicable legislation, regulations and departmental policies. Occupational safety and health issues should be considered in all activities they carry out.
When notified of a hazardous occurrence, managers/supervisors must:
- determine the severity and type of occurrence;
- ensure that the situation is contained and that no further hazard exists;
- ensure that appropriate treatment (first aid and/or medical care) is provided, as required;
- ensure that the affected area is left undisturbed for investigation purposes;
- notify a member of the OSH committee or the OSH representative;
- advise the Director(s) responsible for the affected employee(s);
- advise the Area OSH Advisor;
- advise the National Laboratory Safety Coordinator (NLSC) if the accident/hazardous occurrence occurred in a lab;
- ensure that the situation is promptly and properly investigated and the Hazardous Occurrence Investigation Report completed; and
- ensure that corrective actions, follow-up and record-keeping are completed.
126.96.36.199 OSH Committee's/Representative's Responsibilities
- Participate in the accident/hazardous occurrence investigations and reporting;
- Monitor implementation of recommendations;
- Review and keep records on accidents/hazardous occurrences and recommend corrective measures to avoid reoccurrence.
188.8.131.52 What to Report
Employees and employers are required to promptly report:
- all injuries incurred in the workplace that require first aid or medical treatment;
- any disease or illness contracted or incurred in the course of employment; and
- all hazards, near misses, events or situations that may jeopardize the safety and health of employees and outsiders.
184.108.40.206 When to Report
All accidents, hazardous occurrences or occupational diseases should be reported promptly to the manager/ supervisor, as soon as possible and/or upon becoming aware that a hazardous condition may be work-related.
220.127.116.11 How to report
The manager/supervisor must complete The Hazardous Occurrence Investigation Report (HOIR)
3.8 Inspector Safety
- 3.8.1 Safe Work Practices
- 3.8.2 Personal Safety and Protection
- 3.8.3 Emergency Preparedness
- 3.8.4 Road Safety
3.8.1 Safe Work Practices
All inspection staff must be aware of the potential hazards present in their immediate work environment. When unsafe conditions or situations are identified at third-party premises during the course of an inspection, they must be corrected first before continuing inspection activities. Safe work practices should always be observed by inspectors when performing their tasks to avoid or reduce the risk of injury or harm.
Inspectors always have the right to refuse to perform an inspection for occupational safety and health reasons. If they have doubts about their safety or a co-worker's safety, they must notify their supervisor and identify safety issues. Safety issues must be addressed and resolved before inspectors can carry out their activities.
3.8.2 Personal Safety and Protection
Personal safety of Inspectors is paramount, and should not be taken for granted. The following are some information on Inspector's personal safety and protection related to inspection activities.
18.104.22.168 Personal Protective Equipment
PPE should always be used/worn to prevent accidents and to protect the inspector from hazardous conditions. See Section 3.4.2 for more information on PPE.
22.214.171.124 Dealing with Aggressive Persons
Inspectors are tasked to enforce the regulations as necessary. In carrying out their activities, they have to deal directly with the parties that the Agency regulates – manufacturers, importers, legal agents, etc. Sometimes, conflict may arise between inspectors and the management or representative of a company. When such situations arise, inspectors have a responsibility to report the incident to their supervisor and Security Services.
Listed below are a few guidelines on dealing with hostile or defensive clients:
- Properly prepare to conduct an inspection. Wear clean, comfortable, suitable clothing and practical shoes which allow you to leave the premises quickly, if necessary.
- Always wear your identity badge or carry it with you.
- The supervisor should inform employees about regulated parties who are known to be aggressive or hostile. By the same token, inspectors should report to their supervisor any regulated party that have shown him or her any form of aggressive or threatening behaviour during an inspection.
- Inspectors should work in pairs or teams in potentially high-risk situations.
- Arrange to meet with regulated parties in a safe location.
- Carry only the items that are strictly necessary (basic kit).
- Remain vigilant and take note of the layout of the premises during your first visit.
- When dealing with an emotional or aggressive person, remain calm and focused on objective while negotiating a resolution.
- If you receive physical resistance or threat, disengage from the confrontation, get to safety, and inform your supervisor immediately.
126.96.36.199 Slip and Fall Prevention
The risk of slipping, tripping and falling can be reduced by:
- wearing CSA-approved protective footwear;
- keeping footwear tread in good condition; and
- following safe work practices.
Inspectors must not climb on skids, equipment or materials. Further, inspectors must not stand on platforms being hoisted by a lift truck or on the lift truck forks. They must always ask a company representative for assistance when obtaining samples or items beyond their reach.
3.8.3 Emergency Preparedness
During inspections, inspectors should be aware of the company's emergency plan or procedures. If such a plan does not exist, inspectors should ask the company management to establish an interim evacuation plan in case of an emergency. Be aware of the emergency exits in your immediate work area, and ensure that these exits are unlocked and unobstructed.
In the event of an emergency (e.g., fire) where evacuation of the building is necessary, the following guidelines should be followed:
- Calmly proceed to the nearest exit. Do not use elevators. Use handrails in stairways.
- Move away from the building quickly, and watch for falling debris and other hazards.
- Follow instructions from the company's emergency personnel.
- Never re-enter the building until the company's emergency personnel has given instructions that it is safe to do so.
3.8.4 Road Safety
Inspectors are sometimes required to travel long distances or through heavy traffic to get to an establishment. The establishment may be located in a remote area, and driving on country or back roads through rural or sparsely populated areas may be necessary. In any event, whether driving long or short distances, inspectors should always exercise and observe road safety.
Before driving a fleet vehicle for duty travel, make sure it is maintained according to the CFIA Fleet Policy:
- Perform a quick vehicle safety check (tires, lights, windshield wiper fluid, etc.)
- Check for any fluid leaks (e.g., brake fluid, oil or gasoline).
Inspectors are recommended to complete a Defensive Driving Course to enhance driving skills and gain knowledge on road safety.
188.8.131.52 Winter Driving
Winter driving is a challenge not only to novices but also for experienced drivers. Factors that affect driving in winter include: shorter daylight, poor or limited visibility during white-outs or with blowing snow, poor road conditions due to snow accumulation on roads, and cold temperatures. Some winter driving tips are listed below:
- Check local weather and road conditions before leaving.
- If possible, tell someone where you are going and when you expect to arrive.
- Plan properly and allow yourself extra time for travel.
- Bring a map and be prepared to take an alternative route.
- Dress properly – wear warm clothing.
- Clear the vehicle completely of snow so that you can see and be seen.
- Wait until the windows are defrosted before you start driving.
- Always keep the gas tank at least half full, and add gasoline antifreeze to every second tank.
- Top up antifreeze, transmission, brake and windshield-washer fluids.
- Use a matching set of all-season or snow tires that meet standards.
- Make sure that tire valves are equipped with caps to keep out snow and ice.
- Bring a charged cell phone, and a cell phone charger, as appropriate.
- Stick to the main roads whenever possible.
- Stay alert, slow down, be aware and follow road signs and driving speed limits. Watch out for black ice.
- Drive with low-beam headlamps on.
In the event that the vehicle gets stuck in snow, do not panic. Stay with the vehicle for safety and warmth. Call for help using a cellular phone if you are in an area with cellular phone service. Otherwise, draw attention to the vehicle using emergency flashers, flares or a "Call Police" sign.
184.108.40.206 Emergency Kits
Emergency situations are often unforeseeable. Therefore, inspectors should always be prepared in the event an emergency situation is encountered. Having essential supplies can provide some safety and comfort. Before venturing out to conduct an inspection, especially during inclement weather, always check that the vehicle, be it a fleet or personal vehicle, is equipped with an emergency kit.
220.127.116.11 In Case of an Accident
In the unlikely event of a vehicular accident, the following guidelines should be followed:
- Remain on the scene.
- Turn on your four-way flashers and set out safety triangles to prevent further damage as necessary.
- Call the police.
- Obtain the following information: name, address, telephone number and drivers' license number of the other driver(s) involved; make, model and license plate number of the vehicles, and the name of the insurance company; names and addresses of the witnesses; name of the police officer dispatched to the scene, his/her badge number and unit.
- Take note of the time, location, date, weather conditions and light.
- Do not admit guilt.
- Notify your supervisor.
- Fill out an accident report form.
Scales of Entitlement
Personal Protective Equipment, Materials and Clothing
- COSH Regulations = Canada Occupational Safety and Health Regulations
- CSA = Canadian Standards Association
- NJC Directive = National Joint Council Directive
- NIOSH = National Institute of Occupational Safety and Health
- ANSI = American National Standards Institute
- PPE & Clothing = Personal and Protective Equipment and Clothing Directive Part XII (NJC)
Note: This document is provided as a guide to assist managers in the provision of personal protective equipment, materials and clothing. This guideline does not preclude management from taking into account unique situations and thereby providing acceptable alternate items. This document will be updated, modified and amended as required with changes in standards, regulations, directives and as dictated through job hazard analysis (JHA). In determining the requirements for PPE, in addition to this guide, managers should refer to relevant standards, regulations and directives listed. Contact Area OSH Advisors for assistance in selecting appropriate PPE or acceptable alternate items.
II. Inspections In Processing Plants, Manufactured Plants, Egg Stations, Storage (Fish Inspection, Meat Hygiene, Food Safety, Fair Labelling Practices, Dairy Products, Eggs, Honey, Fresh Fruits and Vegetables, Processed Products)
|Item||Freq. of Repl.||COSH Reg.||CSA Std.||TBS/NJC|
|1. CSA Approved Rubber Boots (Steel toe)||As required||Part XII (12.5(1)(2))||CAN/CSA-Z195-02 & Z195.1-02 Protective Footwear||Paragraphs 12.9,12.10,12.11PPE & Clothing||Provided. Check tread regularly Fish inspection: includes sanitary zone boots|
|2. CSA Approved Leather Boots (Steel toe and/or Steel sole) and Rubber Overboots||As required||Part XII (12.5(1)(2))||CAN/CSA-Z195-02 & Z195.1-02 Protective Footwear||Paragraphs 12.9,12.10,12.11PPE & Clothing||Provided. Fish inspection: includes sanitary zone boots|
|3. Freezer Coat / Insulated Vest||As required||Part XII (12.9)||Paragraphs 12.4,12.6 PPE & Clothing||Pooled clothing|
|4. Protective gloves||As required||Part XII (12.9)||Paragraphs 12.3 Appendix PPE & Clothing||Leather / Rubber / Insulated / Cotton Provided|
|5. Disposable Gloves||As required||Part XII (12.9)||Paragraphs 12.3 PPE & Clothing||Provided|
|6. CSA Approved Hearing Protection||As required||Part VII (7.7(1))||Z94-2-02 Hearing Protection||Appendix Noise Control and Hearing Conservation||Provided|
|7. Lab Coats/Long-Short Coat/Vest/ Coveralls/ Insulated Coveralls||As required||Part XII (12.9)||Paragraph 12.3PPE & Clothing||Pooled. Insulated coveralls only for work in cold storage for extended periods.|
|8. CSA Approved Headwear||As required||Part XII (12.4)||CAN/CSAZ94.1-05 Industrial protective Headwear - Performance, selection, care and use||Paragraph 12.7PPE & Clothing||Provided|
|9. Hair / Beard Net||As required||Part XII(12.12)||Appendix PPE & Clothing||Provided|
|10. Half face-piece air purifying respirator, disposable||As required||Part XII (12.7)||Must be in NIOSH Certified Equipment List||Paragraph 12.3PPE & Clothing||Provided|
|11. CSA Approved Eye Protection||As required||Part XII (12.6)||Z94.3-02 & Z94.3-1-02 Industrial Eye & Face Protection||Paragraph 12.8PPE & Clothing||Provided|
|12. CSA Approved Flashlight||As required||Part XII (12.1)||Paragraph 12.1PPE & Clothing||Provided|
|13. Rubber Pants/Jacket/Apron||As required||Part XII (12.9)||Paragraph 12.3PPE & Clothing||Provided - For pickled / salted fish inspection|
|14. Raincoat or Rain suit||As required||Part XII (12.9)||Paragraph 12.3PPE & Clothing||Provided - For Fish Inspection only.|
|15. Parkas/Pants/ Exterior Footwear/Ski glasses||As required||Part XII (12.9)||Paragraphs 12.4, 12.6 PPE & Clothing||Pooled - For Coastal Labrador inspections - Arctic Wear. For other programs than fish, winter parkas/coats should be provided only to staff working outside or in hazardous weather condition.|
|16. Felt Boots - Long Underwear - Mittens - Socks - Tuque||As required||Part XII (12.9)||Paragraph 12.4PPE & Clothing||Individual - For Coastal Labrador inspections - Arctic wear|
|17. Fall Protection Systems||As required||Part XII(12.10)||
Safety Belts and Lanyards
Z259.2-M1979 Fall Arresting Devices, Personnel Lowering Devices and Life Lines
Z259.3-M1978 Lineman's Body Belt and Lineman's Safety Strap.
|Paragraph 12.3PPE & Clothing||
Fall Arrest Kit
The fall-arresting system must respect the CSA/ANSI standards for all items - i.e. harness, lines, safety hooks, belts and rope grabs.
Provided, only if required.
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