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TABLE OF CONTENTS CHAPTER 1 - INTRODUCTION AND TABLE OF CONTENTS CHAPTER 1 INTRODUCTION CHAPTER 2 ORGANIZATION POLICY AND MANAGEMENT COMMITMENT CHAPTER 2 - ORGANIZATION POLICY AND MANAGEMENT COMMITMENT 1 10 11 11
2.1 HEALTH, SAFETY AND ENVIRONMENTAL VISION STELCO INC...................................................11 2.2 HEALTH AND SAFETY POLICY..........................................................................................................13 2.3 HEALTH AND SAFETY RESPONSIBILITIES..........................................................................................14 CHAPTER 3 - ORGANIZATION POLICY AND MANAGEMENT COMMITMENT 14
2.4 HEALTH AND SAFETY ACCOUNTABILITY.........................................................................................16 CHAPTER 4 - ORGANIZATION POLICY AND MANAGEMENT COMMITMENT CHAPTER 3 EMPLOYEE COMPETENCY CHAPTER 5 - EMPLOYEE COMPETENCY 16 20 20
3.1 NEW EMPLOYEE ORIENTATION........................................................................................................20 3.2 EMPLOYEE TRAINING, COMPETENCY, AND AUTHORIZATION........................................................22 CHAPTER 6 - EMPLOYEE COMPETENCY 22
3.6 SAFETY CONCERNS, COMPLAINTS AND WORK REFUSAL ...............................................................27 CHAPTER 10 - EMPLOYEE COMPETENCY 27
3.7 CONTACT PERSON TRAINING AND AUTHORIZATION......................................................................29 CHAPTER 11 - EMPLOYEE COMPETENCY CHAPTER 4 HEALTH MANAGEMENT CHAPTER 12 - HEALTH MANAGEMENT 29 30 30
4.1 HEALTH MANAGEMENT SYSTEMS....................................................................................................30 4.2 OCCUPATIONAL HEALTH PROGRAM................................................................................................31 CHAPTER 13 - HEALTH MANAGEMENT 31
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4.8 POTABLE WATER................................................................................................................................39 4.9 INDOOR AIR QUALITY........................................................................................................................40 CHAPTER 5 HAZARD IDENTIFICATION CHAPTER 19 - HAZARD IDENTIFICATION 41 41
5.1 HAZARD IDENTIFICATION AND ANALYSIS ........................................................................................41 CHAPTER 20 - HAZARD CONTROL CHAPTER 6 HAZARD CONTROL 44 44
6.1 HAZARD CONTROL SYSTEM..............................................................................................................44 6.1.1 ORGANIZATION OF PROCEDURES.....................................................................................................46 CHAPTER 21 - HAZARD CONTROL 46
6.2.1 WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM (WHMIS)....................................47 6.2.2 TRANSPORTATION OF DANGEROUS GOODS.....................................................................................48 CHAPTER 23 - HAZARD CONTROL 48
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6.3.1 HIGH VOLTAGE PERMITS..................................................................................................................52 6.3.2 GAS AND OXYGEN WORK PERMITS..................................................................................................53 CHAPTER 27 - HAZARD CONTROL 53
6.3.5 MAN BASKET AND AERIAL PLATFORM PERMITS..............................................................................56 CHAPTER 30 - HAZARD CONTROL 56
6.4.1 MODIFICATION TO CRANES AND MOBILE EQUIPMENT AND LIFTING EQUIPMENT...........................60 6.4.2 CRANE BOARDING AND SECURITY....................................................................................................62 CHAPTER 35 - HAZARD CONTROL 62
6.4.4 AUTHORIZATION OF CRANE AND MOBILE EQUIPMENT OPERATORS................................................64 CHAPTER 37 - HAZARD CONTROL 64
6.4.5 OPERATOR INSPECTION OF CRANES AND MOBILE EQUIPMENT........................................................65 CHAPTER 38 - HAZARD CONTROL 65
6.4.6 NON DESTRUCTIVE TESTING OF STRUCTURES, CRANES, MOBILE EQUIPMENT AND LIFTING EQUIPMENT.................................................................................................................................................66 6.5 CONTROL OF EQUIPMENT REQUIRED FOR SAFETY AND EMERGENCY RESPONSE........................68 CHAPTER 39 - HAZARD CONTROL 68
6.5.1 RESPIRATOR PROGRAM.....................................................................................................................68 6.5.2 FAILURE OR DISABLING OF SAFETY DEVICES AND ALARMS............................................................70 CHAPTER 40 - HAZARD CONTROL 70
6.5.4 WORKING AT HEIGHT &SAFETY BELTS AND HARNESSES................................................................72 CHAPTER 42 - HAZARD CONTROL 72
6.5.6 USE OF CELL PHONES.......................................................................................................................75 CHAPTER 44 - HAZARD CONTROL CHAPTER 45 - HAZARD CONTROL 75 76
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6.5.7 EMERGENCY LIGHTING.....................................................................................................................76 6.5.8 GAS TESTING EQUIPMENT.................................................................................................................77 CHAPTER 46 - HAZARD CONTROL 77
6.5.9 MANAGEMENT OF FIRE EXTINGUISHERS, STRETCHER STATIONS, EYE WASH STATIONS, SAFETY SHOWERS AND WATER JEL BLANKETS......................................................................................................78 CHAPTER 47 - HAZARD CONTROL 78
6.6.1 DESIGN AND MAINTENANCE OF EQUIPMENT....................................................................................79 6.6.2 CONSTRUCTION AND REPAIR GUIDELINES........................................................................................81 CHAPTER 49 - HAZARD CONTROL 81
6.6.7 PRESSURE VESSELS & PRESSURE RELIEF VALVES...........................................................................86 CHAPTER 54 - HAZARD CONTROL 86
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6.6.10 PIGEON CONTROL............................................................................................................................89 CHAPTER 57 - HAZARD CONTROL CHAPTER 7 REGULAR INSPECTIONS CHAPTER 58 - REGULAR INSPECTIONS 89 90 90
7.1 DEPARTMENT SAFETY INSPECTIONS...............................................................................................90 7.2 ALBERTA DEPARTMENT OF OCCUPATIONAL HEALTH AND SAFETY INSPECTIONS......................92 CHAPTER 59 - REGULAR INSPECTIONS 92
7.3 JOINT MANAGEMENT/UNION INSPECTIONS......................................................................................93 CHAPTER 60 - REGULAR INSPECTIONS CHAPTER 8 EMERGENCY RESPONSE CHAPTER 61 - EMERGENCY RESPONSE 93 94 94
8.1 EMERGENCY PROCEDURES ACTION PLAN DESCRIPTION............................................................94 8.2 EVACUATIONS....................................................................................................................................96 CHAPTER 62 - EMERGENCY RESPONSE 96
8.3 FIRST AID - SUPPLIES, FACILITIES AND SERVICE...........................................................................97 CHAPTER 63 - EMERGENCY RESPONSE 97
8 of 111 CHAPTER 64 - EMERGENCY RESPONSE CHAPTER 65 - INCIDENT INVESTIGATION CHAPTER 9 INCIDENT INVESTIGATION
9.1 INCIDENT, ACCIDENT, AND CONCERN INVESTIGATION..................................................................99 CHAPTER 10 PROGRAM ADMINISTRATION CHAPTER 66 - PROGRAM ADMINISTRATION 101 101
10.1 EFFECTIVE SAFETY COMMUNICATION.........................................................................................101 10.2 SAFETY PERFORMANCE MANAGEMENT........................................................................................102 CHAPTER 67 - PROGRAM ADMINISTRATION 102
10.6 SAFETY AUDITS...............................................................................................................................109 CHAPTER 71 - PROGRAM ADMINISTRATION CHAPTER 11 FACILITIES AND SERVICES CHAPTER 72 - FACILITIES AND SERVICES 109 110 110
11.1 VISITOR AND CONTRACTOR MANAGEMENT.................................................................................110 11.2 TOURS AND TOUR GUIDES.............................................................................................................111
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Chapter 1 Introduction
This Health and Safety Manual contains statements of safety policies and procedures to be followed by all employees of AltaSteel. It is to serve as a permanent reference and working guide for management, supervision, and employees in the day-to-day administration and compliance with safety policies, practices and procedures. The purpose of the manual is to increase understanding, eliminate the need for personal decisions on matters of safety policy and systems, and help to assure uniformity throughout our organization. It is the responsibility of supervision to administer these policies in a consistent and impartial manner. It is essential that employees not only understand the safety policies but also actively support and apply the safety policies, practices and procedures. This will ensure that our company can achieve productivity and performance objectives in a safe work environment, allowing us to challenge our competitors in terms of cost, efficiency and product quality. Policies, practices, and procedures in the field of health and safety are subject to modifications and further development in light of internal needs, and compliance with changing statutes and industry standards. Therefore, changes will occur periodically. All such changes will be recorded in the form of a Health and Safety Manual amending statement and issued to holders of the manual. All personnel can assist in keeping our Health and Safety Program up to date by notifying their immediate supervisor whenever problems are encountered, and to suggest improvements to the administration of safety policies. It is the responsibility of supervision to ensure that this manual is kept current, policies are understood by all employees, and that they are interpreted and administered uniformly and consistently. The safety information in this manual has been developed to comply with applicable Occupational Heath and Safety Act, Regulations and Code. Excerpts from the Act, Regulations and Code appear in the manual to emphasize and demonstrate specific points. Users are advised to refer to current editions of the Occupational Health and Safety Act, Regulations and Code before making any safety-related decisions to ensure that source information is current.
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Chapter 2 Organization Policy and Management Commitment 2.1 Health, Safety and Environmental Vision Stelco Inc.
The health and safety of our employees and protection of the environment are THE top priorities at Stelco. We are committed to continued leadership and excellence in the health and safety of employees and in protecting and enhancing the environments of the communities where we have operating facilities. We will continue to manage our business in a manner that leaves employees and our communities healthy and safe while producing quality products for our customers. We recognize this is a long term commitment which requires continual improvement to our practices as new understandings occur in health, safety and in environmental science, and as advances are made in technology. We will work toward this vision by: A) Employing safe technologies and operating procedures and by being prepared for emergencies including co-operation with government and other businesses where community action is needed. B) Developing internally or seeking out on a world-wide basis, the best available technology which is health, safety and environmentally compatible. C) Minimizing and striving to eliminate the release of substances that adversely affect the work environment or cause damage to the natural environment. D) Committing management resources, including a Health, Safety and Environment Committee of the Board of Directors, to ensure the implementation of our policies and procedures, and compliance with regulatory requirements. E) Conducting regular self-evaluations of health, safety and environmental performance at each facility. Risk evaluation techniques will be employed to prevent environmental incidents. F) Maintaining a system of pre-evaluation of capital appropriations to ensure compatibility with our Health, Safety and Environmental policies and procedures. G) Requiring all our people to share the responsibility of reporting and improving upon conditions that pose heath and safety risks or threaten the environment. H) Continually improving the education of our people in health, safety and environmental matters including joint programs with the Unions at our manufacturing sites. I) Making sustainable use of renewable natural resources, conserving non-renewable natural resources through efficient use and careful planning, and continuing to recycle products after use for the production of new steel. J) Minimizing the creation of waste and maximizing the reuse and recycling of materials. Disposing of all wastes will continue to be done through methods known to be safe and responsible. K) Investing in improved energy efficiency and conservation in our operations and making every effort to use environmentally safe and sustainable energy sources to meet our needs.
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In addition to protecting the health and safety of our employees and the environments of the communities where we have operating facilities, we believe that adherence to these principles will sustain the viability of our business, and enable us to continue to provide value to our employees, communities, customers and shareholders.
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2.2
AltaSteel Ltd. is committed to a Health and Safety Program that protects employees, property, other employees on our property, the general public, and the environment. Our goal is a healthy, injury free work place. By working together in all parts of the Health and Safety Program, we expect to achieve zero incidents, losses and injuries. Management sets an example and provides leadership in the Health and Safety Program. Management ensures that safe work practices are developed through hazard analysis and that these practices are followed. Management provides proper equipment and training including familiarizing all employees with the applicable requirements of the Occupation Health and Safety Act, Regulations and Code, and language in the Basic Agreement. The Joint Safety, Health and Environment Committee is recognized as a key component of the health and safety program. Employees at every level are accountable for and are recognized for health and safety performance. Active participation by everyone, every day in every job is expected. Employees are accountable for safe behavior including reporting all injuries and safety issues and participating in improving health and safety.
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2.3
Purpose: To define the responsibilities necessary to demonstrate a commitment from all that we will not compromise the health and safety of our employees, contractors, customers or community in the operation of AltaSteel and to demonstrate that Health and Safety is our first priority. Responsibilities: 1. The companys responsibilities are to: Establish a safety culture and expect all employees to work safely and efficiently. Insist on safe performance throughout operations by ensuring employees and contractors are competent and expected to do their work efficiently and safely. Have an effective Safety Program. Ensure the safety program and operations comply with regulatory requirements. Ensure employees and contractors know the operating companys expectations. Provide sufficient time for employees and contractors to do their jobs safely. 2. The contractors and subcontractors responsibilities are to: Support the companys safety culture and expect their employees to work safely and efficiently. Insist on safe performance throughout their operations by ensuring their employees are competent, and expected to work safely. Have effective safety programs. Ensure their employees and subcontractors meet the contractors and AltaSteels safety expectations. Ensure their programs and operations comply with contractual and regulatory requirements. Provide the time and resources required enabling employees and subcontractors to do their work safely and properly. 3. Visitors responsibilities are to: Follow the instructions of the site supervision or personal escort. Wear personal protective equipment when required. Never enter or move about the work site unescorted (walking or driving). Comply with the Employee Guided Tour Procedure Documentation and Records: Employee Guided Tour Procedure Related Procedures:
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15 of 111 Practice: 1. These responsibilities will be reviewed with new employees during the orientation process. 2. These responsibilities will be reviewed with all employees during annual safety reviews. 3. These responsibilities will be reviewed with contractors and contractor employees during their training. Table of Contents
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2.4
Purpose: To assign accountability for every action that contributes to health and safety, and to review those accountabilities on a regular basis. Responsibility: All employees at AltaSteel are responsible for being familiar with and carrying out the accountability for their position. Documentation and Records: Safety Performance Reviews Related Procedures: Practice: 1. President, Vice Presidents and Managers are accountable to: a. Provide a health and safety policy and commitment to safety. b. Provide leadership in the Health and Safety Program to progress towards and achieve zero injuries in the workplace. c. Monitor department safety performance and hold staff accountable for their individual safety performance. d. Meet responsibilities as defined in the Occupational Health and Safety Statutes and Regulations including providing familiarization to all employees. e. Ensure health and safety policies and language in the Basic Agreement are administered and enforced. f. Provide information, instruction and assistance to all supervisory staff to protect the health and safety of all employees. g. Provide ongoing safety education programs and first aid training as required. h. Communicate to all employees at least annually: i. The organizations commitment to health and safety. ii. Why health and safety is important and who it affects. i. Tour the worksite routinely to observe health and safety practices and behaviours. j. Set a good example by following the rules and policies. 2. The following items are monitored to evaluate accountability for the President and Managers: Accident frequency Accident severity Major violations O. H. & S. orders Audit results Recorded Safety Initiatives
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17 of 111 3. Day Supervisors are accountable to: a. Monitor safety performance of area and hold staff accountable for their individual safety performance. b. Ensure health and safety policies and language in the Basic Agreement are administered and enforced. c. Develop and maintain safety systems such as: Crane and mobile checklists Qualified operator lists Inspection tours Crew safety meetings Contractor safe work permits Cutting and welding permits Emergency response procedures Hazard analysis Safe work procedures WHMIS Modified work Accident and incident investigations Annual safety reviews. Provide information, training, instruction and assistance to supervisory staff to protect the health and safety of all employees. Meet responsibilities as defined in O. H. & S. Statutes and Regulations and provide necessary information on regulation to supervisory staff. Tour the worksite routinely to observe health and safety practices and behaviours. Set a good example by following the rules and policies. 4. The following items are monitored to evaluate Day Supervisory level accountability: Area accident frequency Area Accident Severity Major violations O. H. & S Orders Audit Results Logs of non-compliance with procedures and wearing of personal protective equipment Safety Meeting minutes and inspection reports Recorded Safety Initiatives Audits of safety system performance 5. Shift Supervisors are accountable to: a. Monitor safety performance of employees and hold them accountable for their individual safety performance.
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18 of 111 b. Know and apply company safety policies and relevant Occupation Health and Safety Statutes and Regulations, and language in the Basic Agreement. c. Ensure that all employees are educated to work in a safe and competent manner and that they use all protective devices and procedures required by the company and safety legislation. d. Advise all employees of any potential or actual dangers and how to isolate, prevent, or remove them. e. Record and investigate accidents and incidents that may have caused injury or damage. f. Carry out inspection tours as required. g. Correct physical conditions that are likely to cause accidents. h. Provide a good example to employees by always directing and performing work in a safe manner. i. Maintain a good housekeeping standard and assign definite responsibilities for housekeeping. j. Enforce all established safety regulations and work rules. k. Hold safety meetings with employees, record and issue minutes of those meetings, and correct health and safety concerns that were identified. l. Tour the worksite routinely to observe health and safety practices and behaviours. 6. The following items are monitored to evaluate Shift Supervisor accountability: Accident record of employees reporting to him/her Safety meeting minutes Inspection tour reports Logs of non-compliance with procedures and wearing personal protective equipment O. H. & S. orders Recorded Safety Initiatives 7. All employees are accountable for the following: a. Carry out work using safe behaviours that will not create a hazard to your health and safety or that of your fellow employee. b. Work with your supervisor to help create safe working conditions. c. Use all protective equipment and procedures required by the company or safety legislation. d. Set a good example by following work rules, procedures, and language in the Basic Agreement. e. Report and correct unsafe conditions. f. Report any accidents, incidents, near misses or unsafe acts to the area supervisor. g. Conduct inspections of your work area before starting work. h. Take defective tools out of service, and report equipment that is not functioning in the manner for which it is designed. i. Participate in the Health and Safety Program by making safety suggestions and providing your expertise. j. Refuse work that presents imminent danger. 8. The following items are used to monitor employee accountability:
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19 of 111 Personal accident Record Logs of non-compliance with procedures or wearing of personal protective equipment Attendance at safety meetings Recorded Safety Initiatives 9. These responsibilities will be reviewed with new employees during the orientation process. 10. These responsibilities will be reviewed with all employees during annual safety reviews. Table of Contents
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Purpose: To ensure that new employees at AltaSteel receive appropriate training and orientation when they begin working. Responsibility: It is the responsibility of the Human Resources Department to ensure that each new employee receives safety orientation before being placed on the job. The employees supervisor is responsible for ensuring that the new employee is paired up with an experienced employee for a number of days until the employee is able to work safely alone and for providing the necessary training prior to the employee starting work on his own. Documentation and Records: Job Training Requirements WHMIS Binders Due Diligence Training Material AltaSteel Health and Safety Manual Plant wide Safety Procedures Basic Agreement Related Procedures: Practice: 1. All newly hired employees are given a general safety orientation on their first day of employment. They spend their first morning in the Human Resources Department at which time they receive a copy of and review excerpts from the Employees Health and Safety Manual as well as Plant wide safety procedures. The orientation will emphasize real and potential hazards, safety requirements, first aid location(s), alarm systems, and emergency response procedures. 2. The employee will be scheduled to receive WHMIS training. 3. The principals of Due Diligence will be reviewed with the employee. 4. The Chairman of the Union Health and Safety Committee is provided time to reinforce the unions commitment to health and safety, and reinforce the new employees responsibility for health and safety. 5. A competent individual is assigned to arrange for the issuing of personal protective equipment and to provide specific training on its selection, care and use. The competent individual also provides a general plant tour. 6. The supervisor ensures that a new employee is paired up with an experienced employee until they achieve familiarity with the work area. 7. The new employee's supervisor ensures that the new employee is familiar with the job safety analysis developed for the work he/she will be performing. Health hazards such as noise,
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chemicals, radiation, harmful dusts, mists, or gases are to be identified. In addition, the supervisor ensures that the new employee is familiar with the safe work practices/procedures developed to control the real and potential hazards associated with the work being performed. This training is to occur before the new employee is allowed to proceed with the work. Table of Contents
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3.2
Purpose: To ensure a system is in place to provide new and existing employees with job specific training. This training is to be conducted: 1. At the time of hire. 2. When an employee is assigned new or different work. 3. When an employee is moved to a new site or location. Responsibility: Managers, Day Supervisors and Shift Supervisors are responsible for ensuring that employees receive job specific training. Documentation and Records: Organizational policies, practices and procedures. Job Safety Analysis to identify specific job hazards. Safety precautions. Job responsibilities. Regulatory requirements. Organizational enforcement policy. Employees right to know and refuse unsafe work. Employee Training Records. Due Diligence.principles Job training requirements Related Procedures: Practice: Job-Specific Training for Employees 1. Specific job training is to be provided to an employee when: The employee is newly hired The employee is an existing employee assigned new or different work The employee is an existing employee moved to a new site or location The requirements of the work being performed change and The employee requires the training in order to satisfactorily carry out the requirements of the work to be performed. 2. Job-specific employee training needs will be determined from:
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a. Specific internal requirements, b. The Occupational Health and Safety Statutes and Regulations c. Industry standards. d. Plant wide and department safety training requirements The respective operating departments will identify their specific needs to the Learning Coordinator, who will research the most practical and cost effective means of achieving the training and make recommendations. 3. Day & Shift Supervision will establish job training requirement lists for each job in order to ensure that the appropriate training content is covered. 4. Each employee receiving training will be required to demonstrate competence and mastery of the knowledge and/or skill associated with the training before being considered competent. 5. When demonstration of competence is evaluated via direct observation by the employees supervisor (or designate), the Supervisor or designate are required to sign off on the evaluation. 6. The respective departments will develop and maintain training records for all specific training provided for new and existing employees. Employees are required to acknowledge that they have received specific job training by signing-off on training records. Health and Safety/Assessment Training Records - Departmental. 1. A formal record will be created and maintained for each worker, indicating training: a. Date b. Subject matter c. Competent employee providing the direction/instruction d. Employee sign-off e. Supervisors signature 2. An employees record of training will be made available to the new supervisor when an employee is transferred from one department to another. 3. Records of any health assessments such as audiometric tests, pulmonary function tests, etc. are to be maintained by the medical department. 4. Employees who terminate employment will have their records forwarded to Human Resources. Related Procedures:
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3.3
Purpose: To provide Emergency Response training to all AltaSteel employees in situations which potentially involve: AltaSteel personnel. The public in the surrounding area. The environment or significant damage to the facilities. Responsibility: Managers in conjunction with the Supervisor Personnel and I. R. are responsible for implementing and maintaining this practice. Documentation and Records: Training records Plant wide safety procedures Evacuation Procedures Oxygen, Gas and Water schematic drawings Related Procedures: Section 8 Emergency Response Practice:
1. Day and Shift Supervision are responsible for indoctrinating their employees in the Management
"On Call" Practice, Emergency Action Plan, Emergency Procedures, Fire Fighting procedures and Evacuation procedures as part of the employees orientation. 2. Employees are to be given refresher training on the location and operation of the major shut off valves for gas, oxygen and water and evacuation gathering points via a tour on an annual basis or when locations or procedures change. 3. This information is to be recorded on the employees training record. Table of Contents
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3.4
Regulatory Requirements
Purpose: To ensure employees understand responsibility and accountability under regulatory requirements and that AltaSteel is in compliance. Responsibility: All employees are responsible for complying with government regulations. Vice Presidents, Managers, and supervisors are responsible for being familiar with regulatory requirements and communicating them to employees. The Supervisor Personnel and I.R. is responsible for monitoring regulations and communicating any changes to management. Documentation: Occupational Health and Safety Act The Regulations and Code under this Act Related Procedures: Practice: 1. Supervision is responsible for the health and safety of employees and is also responsible for making employees aware of their responsibilities and duties under the Act and applicable regulations. 2. Employee competency and training must meet the regulatory standards. 3. Regulations covering equipment and physical safeguards are primary performance standards that must be met. Table of Contents
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3.5
Purpose: To outline where there are specific medical requirements for certain jobs or tasks at AltaSteel. Responsibility: AltaSteel medical staff in co-operation with the Supervisor - Personnel and I.R. determine which jobs and tasks have specific medical requirements. AltaSteel medical staff will determine the nature of the requirements and advise management of those requirements. AltaSteel medical staff will schedule and perform the necessary testing, retain the medical records, and advise supervision of the status of employees who have been tested. Management and supervision will report any concerns about medical requirements on a job or task to AltaSteel medical staff so a determination can be made. Documentation and Records: Medical Records Job Training Requirements Authorized Operator Lists Related Procedures: Practice: 1. Operating supervision is to identify any jobs that may have medical requirements to AltaSteel medical staff. 2. AltaSteel medical staff will advise operating supervision that there are medical requirements for a job or task and organize testing of the individuals involved. 3. Operating supervision will include any medical requirements in the job training requirements and ensure that all employees performing the job are medically certified. 4. AltaSteel medical staff will be responsible for keeping medical records up to date, identifying time frames for any recurring medical testing, and notifying operating supervision and employees of the need for recurring medical testing.
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Chapter 10 -
Employee Competency
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3.6
Purpose: To ensure that a process is in place that can address safety concerns, complaints, or refusals to perform work expediently and in a timely manner. Responsibility: The respective supervisor holds the prime accountability for responding to the concern or complaint. The employee and safety representative play an integral role in developing, implementing, and applying the necessary control(s) to correct the substandard condition and to prevent recurrence. Documentation and Records: Occupational Health and Safety Act Workplace Procedures Related Procedures: Practice: 1. When a employee expresses a safety concern, it is incumbent upon the supervisor to develop an appropriate resolution to the concern or complaint. This practices recognizes that it is unusual for a employee to approach a supervisor and declare that he is exercising his right under the Occupation Health and Safety Act to refuse to perform a job because it is unsafe. More often, a safety concern is expressed in terms such as: a) I dont think that job is very safe. b) Im not sure about the safety of that job. c) Ive been told that job is not very safe. d) Im not sure that the procedure on that job is right. 2. The supervisors responsibility is to recognize the concern, then listen, and understand what the employee is saying. 3. If it is a concern or complaint that can be dealt with quickly and effectively, corrective action is taken to resolve the issue. If longer-term action is required, the employee and safety representative are involved in developing a plan for resolution and other employees advised of the issue, hazard and any interim procedures. 4. If it is a refusal to work, the supervisor first reviews with the employee and the safety representative the definition of a refusal to work under the Occupational Health and Safety Act as follows: No employee shall carry out work or operate any tool, appliance or equipment if, on probable and reasonable grounds, he believes that it will cause to exist an imminent danger to the health or safety of that employee or another employee. Where imminent danger means in relation to any occupation: a) a danger which is not normal for that occupation, or b) a danger under which a person engaged in that occupation would not normally carry out his work.
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Chapter 10 -
Employee Competency
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If the employee believes his concern satisfies the existence of imminent danger, the supervisor and safety representative jointly: c) investigate the concern as identified by the employee. d) prepare a written record of the employees concern. 5. One of the following situations may then occur: a) If the supervisor, union representative and employee agree, the situation is rectified immediately if possible. The recommended action taken to resolve the concern is recorded with the written record of the employees concern and a copy given to the employee. b) If the supervisor, union representative and employee agree, however, it is going to take some time to correct the situation; this is explained to the employee. The employee may agree to perform the work in an alternate manner until the situation is corrected. The recommended action to resolve the concern is recorded with the written record of the employees concern and a copy given to the employee. The supervisor/union representative will follow up to ensure the agreed to action is carried out. c) If the employee, the supervisor and the union representative are unable to reach agreement, or if the concern is beyond their technical knowledge, the Manager and a union member of the Joint Health, Safety and Environment Committee are contacted and involved in the resolution of the concern. 6. Should the concern remain unresolved, the employee is provided with a copy of the written record of his concern, the investigation and any action taken. If the employee continues to believe that imminent danger still exists, an officer of Alberta Labour is contacted and involved in the resolution discussions. 7. The Alberta Labour officer, upon investigation, prepares a written record of the employees complaint, the investigation and the action taken and gives the employee, supervision and union representatives, a copy of the record. 8. The decision of the officer may be appealed by the employee or the employer. 9. Once it is determined that a employee is refusing to work, the work in question can be assigned to another employee providing the employee so assigned is not exposed to imminent danger and is made aware of the specifics of the ongoing refusal. 10. Since some operations cannot simply be stopped and left unattended, consideration is given to ensure the safety of people and the protection of equipment. Therefore good judgment must be exercised when determining whether to continue the work or stop. Operations are maintained until it can be safely shut down on an emergency basis. Maintaining production is not a factor when considering whether to continue work or stop for safety reasons. 11. The following order should be used when attempting to obtain a Union Health and Safety Representative to be involved in the work refusal: a) a representative within the department on shift. b) a representative from another department on shift. c) a representative from off shift. 12. The supervisor advises subsequent crew(s) of the issue and its status if the concern is not resolved within the same shift. Table of Contents
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Chapter 11 -
Employee Competency
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3.7
Purpose: To ensure that people working as contact persons for contractors at AltaSteel are properly trained and authorized. Responsibility: The Supervisor Personnel and I.R. is responsible for providing training for contact persons and maintaining a record of authorized contact persons. Management and supervision is responsible for ensuring that only authorized contact persons perform this work. Documentation and Records: Training Records Authorized Contact Person List Related Procedures: Practice: 1. 2. 3. The Supervisor Personnel and I.R. will determine training requirements and time frames and organize training sessions. The Supervisor Personnel and I.R. will maintain a list of authorized contact persons and publish this to management and supervision. Managers and Supervisors will ensure the appropriate people are trained as contact persons and that only authorized contact persons are used.
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Chapter 12 -
Health Management
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Purpose: Health Management Systems are designed to detect chronic problems that may otherwise go undetected until they become severe, and to uncover worksite hazards that require corrective action. Responsibility: Supervision have the responsibility of identifying real and potential health hazards specific to the work being performed. The medical staff in cooperation with the Supervisor Personnel and I. R. are to keep abreast of health hazards that are being identified in similar industries, and develop and apply the necessary controls. Documentation and Records: Government Regulations for Silica, Asbestos, Noise, Metals, Total Particulate Medical Records MSDS program Test Results External Sources of Information Related Procedures: Practice: 1. Supervision is to identify real or potential health hazards to the Supervisor Personnel and I. R. 2. The Supervisor Personnel and I. R., in cooperation with the line operating area and the medical staff will develop the necessary strategies to monitor and control the health hazard. 3. External professionals may be required to identify and monitor specific problems. The Supervisor Personnel and I. R. will research the availability of these professionals and make recommendations to the respective stakeholders. 4. Records are to be developed and maintained regarding the testing, and effectiveness of the controls for any health hazard. 5. The medical staff will monitor health hazards that are identified in similar industries and develop and apply the necessary controls. Table of Contents
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4.2
Purpose: To ensure a system is in place to provide AltaSteel employees with an Occupational Health Program in compliance with Corporate Guidelines and Occupational Health and Safety Acts, Regulations and Code. Responsibility: The Medical Department is responsible for pre-employment medical examinations, emergency treatments for illness or accident, periodical medical examinations, medical counsel and health guidance for employees, supervision over sanitation and industrial hygiene. Documentation and Records: Audiograms Medical Examinations Injury Reports and Records WCB Forms and Records Related Procedures: Practice: 1. All injuries are to be reported to supervision no matter how slight. 2. All injuries reported to the first aid attendant or medical department are to be recorded. 3. Form P1036A "Request for Medical Service" will be completed for each employee treated. 4. Those people requiring additional medical treatment will be provided transportation to a MediCenter or hospital as conditions warrant. 5. The Nurse will train and supervise those individuals assigned to first aid duties. Table of Contents
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4.3
Purpose: The Industrial Hygiene Program requires the evaluation of chemical agents including toxic dusts, gases, mists, vapours, fumes and liquids, etc. Physical stresses include noise, vibration and extremes of temperatures, humidity and pressure, etc. Radiant energy includes ultra violet, infrared, ionizing and non-ionizing radiation. Responsibility: The Human Resources department is responsible for carrying out the evaluations required by Government Regulations and monitoring any changes in regulations or industry concerns. Technical direction and assistance will be provided by Engineering and Stelco Industrial Hygiene. The Human Resources department is responsible for carrying out evaluations deemed necessary by Operating or Engineering. Operating departments are responsible for monitoring operations for any areas of concern and following up to ensure the necessary testing is done and that appropriate engineering and administrative controls are put in place. Documentation and Records: Test Results Government Regulations for Silica, Asbestos, Noise, Metals, Total Particulate Medical Records Material Safety Data Sheet (MSDS) system Related Procedures: Practice: 1. Each department identifies potential occupational health hazards based on Government regulations and industry knowledge. 2. Evaluation of these hazards is done by the Human Resources Department through environmental monitoring which includes tests for ambient levels of dust, mists, gases, the analysis of noise and assessment of radiation levels. These tests provide a basis for determining whether Industrial Hygiene standards are being met. 3. Workplace conditions are to be reviewed at appropriate intervals, and all occupations tested as required. 4. The Human Resources Department will issues schedules outlining the type of testing to be done and the timing. 5. Monitoring is to be carried out where employees may be exposed to chemical agents or physical stress. Monitoring results will be posted in the workplace. 6. The main goal of this program is the preservation of health through control of exposure to these hazardous agents. 8. If exposure exceeds the "Occupational Exposure Limits" (OEL) studies are to be initiated as soon as possible to find methods of protecting employees. This includes engineering controls, personal protective devices or administrative controls. Table of Contents
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4.4
Purpose: To ensure a system is in place to provide AltaSteel employees with a hearing protection program in compliance with Occupational Health and Safety Acts, Regulations and Code and to ensure that hearing protection is worn as required. Responsibility: The Supervisor Personnel and I. R. will be responsible for coordinating the hearing protection program. Equipment will be specifically approved by the Canadian Safety Association (CSA). The Medical Department will be responsible for ongoing audiometric testing. Documentation and Records: Audiograms Medical Records Noise Study Reports Alberta Occupational Health & Safety Act and applicable regulations Related Procedures: Practice: 1. Engineering, Operations and Maintenance will consider methods of reducing noise at the source and along the path when equipment is be selected and repaired. 2. Engineering and the Supervisor Personnel and I. R. will organize and update noise studies in consultation with Industrial Hygiene, and notify the chairman of the Union Health, Safety, and Environment Committee. 3. The Supervisor Personnel and I. R. will review and assess the effectiveness of personal hearing protection. 4. Employees who are or may be required to wear hearing protection are to be medically examined and given regular audiometric hearing tests by the Medical Department. Employees will be informed of the results of the hearing tests and will be referred to an ear specialist for further testing should the results warrant it. 5. The Medical Department will review the importance of wearing hearing protection and its limitations and how to test for a satisfactory fit. 6. Hard hat mounted hearing protectors, replacement parts and earplugs will be obtained from Stores and must not be ordered directly from suppliers. Special requirements will be approved by the Supervisor Personnel and I. R.. 7. Each employee is responsible for ensuring that hearing protection is worn and the supervisor is responsible for ensuring compliance. 8. Hard hat mounted hearing protection (earmuffs) are to be maintained in good working order to ensure that a good seal around the ear is obtained. Employees are to regularly inspect the seals on earmuffs to check for signs of wear and check the integrity of the earmuff arm. Employees
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are to install new seals, liners and arms every 3 months or earlier when necessary. Earplugs can be cleaned as necessary and reused until replacement is warranted. 9. In excessively noise areas it is required that both earplugs and earmuffs be worn. 10. Day Supervision shall determine which areas or activities require hearing protection and ensure areas are properly signed. Table of Contents
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4.5
Medical Records
Purpose: To record the treatment of employees illnesses and injuries and to maintain a history of testing required by government regulation and company rules. Responsibility: The Medical Department is responsible for pre-employment medical examinations, emergency treatment for illness or accidents, periodical medical examinations, medical counseling and health guidance for employees in personal and industrial hygiene. Documentation and Records: Dockets X-rays Pulmonary Function Tests Audiograms Respirator Fit Testing records Mobile Equipment Operators Medicals Related procedures: Practice: 1. All medical records are confidential and may not be removed from the Medical Department. Employees have access to these records through the doctor who will discuss them with the individual employee at any time. 2. The company's medical authorities only give medical information to other parties with the employees signed consent. 3. Results of testing of employees as required by regulations will be provided to government. Table of Contents
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4.6
Purpose: To have a program in place that will allow an employee who is temporarily or partially disabled to function in the workplace for a limited duration of time until they are able to perform their normal job. Responsibility: Modified work will only be entertained when the employees attending physician authorizes this course of action. The AltaSteel Medical Department will decide if the employee is medically fit to perform modified work and identify the restriction. Supervision will decide if suitable work is available. Documentation and Records: Workers Compensation Board Guidelines Medical records Modified Work Policy Related Procedures: Practice: 1. Normally, written approval from the employees doctor listing the restrictions is required. 2. The Medical Department and the supervision will closely monitor the employees condition and progress. 3. Employees are to report their injuries to their supervisor and seek treatment at First Aid. If the employee chooses to seek additional medical treatment, he will be provided transportation to a medical centre or hospital and given a Modified Work form to be completed by the attending physician. 4. Supervision will: a) Review the completed Modified Work form and comply with the attending physician's instructions. b) Send the employee home if the physician indicates the employee should be off work. c) If the physician indicates modified work, the supervisor will make a decision if such work is available. If no work is available, the employee is to be sent home. d) Brief the employee if given a modified work assignment covering the following points: I. His welfare and performance will be monitored to ensure there is no aggravation of the injury. II. The company medical facilities are at his disposal. III. The Medical Department will approve his return to normal duties. IV. Modified work does not provide him special status outside his personal work assignment. V. In cases of work related injury, he is eligible for all Employees' Compensation benefits except wages.
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5. Employees placed on modified work on off shifts must be sent to the Medical Department as soon as possible for confirmation of the assignment. 6. Day Supervision is responsible for monitoring the progress of employees on modified work and weekly reporting findings to the Medical Department. 7. First Aid Attendants are to treat the injured and provide assistance to employees who require additional treatment at medical centres or a hospital. Modified work evaluation or assignments are not part of their responsibilities. 8. Medical Department will approve all modified work and monitor the employees progress while on the program, and authorize all employees return to regular duties. 9. The modified work policy detailed below will be followed. Definition "Modified Work" is defined as work assigned to an employee because of a temporary physical restriction which prevents performance of the full functions of the incumbent job. Based on this definition, an employee who cannot perform all of the major routine components of his or her job is considered to be on "modified work". In this circumstance, the Medical Department would categorize the employee as capable of returning to modified work and would detail any specific restrictions as to type of work. Modified Work Policy AltaSteel recognizes the benefits available to both the company and its employees by providing continuing employment that is modified to reflect temporary physical disability resulting from personal illness or injury occurring at home or at work. Therefore, provided legitimate and useful work is available throughout a scheduled shift, an employee will be provided the opportunity to maintain employment commensurate with his physical restrictions. Such employment will be provided on the same basis as specified in the Alberta Employees' Compensation Act, which reads as follows: "Where work is made available to a employee who is temporarily partially disabled and the Board is satisfied that the employee is medically and physically capable of doing the work and that considering all the circumstances, it is fair and just to expect the employee to accept the work. The suitability of a specific employment opportunity is determined by the company Medical Officer in consideration of the restrictions imposed by the temporary physical disability and in conjunction with the attending physician. This decision is not to be made by the employee or the supervisor.
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4.7
Employee Impairment
Purpose: To have a system in place to respond to concerns about an individual employees ability to perform work due to an impairment of his or her health. Responsibility: All employees have a responsibility to report concerns about their own or another employees ability to safely perform their work . Supervision is responsible for investigating any concerns about a employees ability to safely perform their job. Medical Staff will provide assessments of an employees ability when requested. Documentation and Records: Workplace procedures Related Procedures: Practice: 1. When a concern is raised about a employees ability to safely perform his job the supervisor will investigate and make an assessment. If necessary another supervisor or medical staff will be asked to assist. If there is doubt, the employee will not be allowed to perform the work until a medical assessment has been made. Employees with an ongoing record of concerns will be referred to the Medical department for assistance.
2. 3.
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4.8
Potable Water
Purpose: To ensure that potable water at AltaSteel is safe for consumption. Responsibility: The Manager Environment and Major Projects will ensure that regular sampling of potable water supplies is done to ensure it meets Provincial Regulatory requirements. AltaSteel Managers will ensure that potable water piping and containers in their area are maintained properly to prevent contamination. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures: Practice: 1. The Manager Environment and Major Projects is responsible for conducting regular sampling of potable water and test for compliance with Provincial Standards. Table of Contents
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4.9
Purpose: To ensure that the quality of the air in offices, pulpits, meeting rooms, etc. meets regulatory requirements. Responsibility: Managers will establish smoking policies that are in compliance with regulatory and local government requirements. Managers will respond to any concerns raised about indoor air quality. Documentation and Records: Smoking Policy Provincial Regulations Strathcona County Smoking Bylaws Related Procedures: Practice: 1. A smoking policy will be issued by the HR department. 2. Plant workplace air quality will be monitored as per the Industrial Hygiene program. Table of Contents
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Documentation and Records: Job Safety Analyses Hazard Analyses Occupational Health & Safety Statutes and Regulations Workplace Procedures
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Related Procedures: LIBRARY\PROCEDURES\PLANTWIDE\SAFETY 3.1 HAZARD IDENTIFICATION AND ASSESSMENT Practice: 1. Review current hazard analyses on an annual basis. 2. Conduct a hazard analysis when new equipment is added, or existing equipment is modified. 3. Conduct a hazard analysis when changes to the process are made or when new work is to be performed. 4. Hold pre-job/commissioning meetings to ensure that employees are aware of the hazards associated with performing the work. 5. Correct hazards that are identified and maintain records of those corrections. 6. Use the following approach for hazard analysis: i. Select the work, machinery, tools, equipment, and/or environment that poses a hazard. ii. Examine and discuss job with experienced supervisor and employee. iii. Seek professional assistance on matters that require specialized expertise. iv. Identify, locate, and read the regulations and/or industry standards that apply to the job. v. Locate all appropriate manufacturers recommendations. vi. Locate any existing administrative controls that are in place. vii. Review quality control, accident/incident investigation or other records that may provide a history. viii. Develop the hazard analysis. The analysis needs to identify controls for each of the hazard sources. Hazards having the greatest potential for injury need to be addressed first. ix. Use the following guidelines for hazard classification: Risk/hazard classification is a method of determining the likelihood of a hazard occurring and of its consequences. To be effective, it requires using sound judgment and experience, consulting with employees who may also be exposed to that hazard, looking over accident or incident reports, quality control records, and other information that may be available. Consider loss exposures that could cause problems but havent yet. Choose the most serious reasonably likely loss that could be expected to occur from an identified potential hazard. Use the rule of thumb that if it worries you, its likely enough. The system we use places hazards into three classifications: 1. High Hazard, 2. Medium Hazard, and 3. Low Hazard. High Hazard: Conditions or practices with the potential for permanent disability, loss of life or body part, and/or extensive loss of structure, equipment or material. With this type of hazard a course of action may require shutting down a piece of equipment.
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Medium Hazard: Conditions or practices with potential serious injury or property damage that is disruptive, but less severe than HIgh hazards. Example: Oily conditions in an aisle way. Broken rung on a ladder. Low Hazard: Conditions or practices with the potential for minor injury or illness or non-disruptive property damage. Example: Employee walking through plant without wearing safety glasses. Forklift operator not blowing horn before backing up.
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3. Employees are made familiar with safe work practices and procedures developed to control hazards before they start work. 4. Known hazards that can not be readily controlled must be brought to the attention of employees. 5. Safe work practices may not be limited to a specific task, but deal with a fairly wide range or work activities (e.g. using an overhead crane, entering a confined space, handling chemicals, and locking out equipment). They are especially useful in situations where employees perform a large number of tasks infrequently or where specific tasks are hard to proceduralize because of the way they are done varies greatly with the specific situation. 5. The following areas should be emphasized in developing safe work practices: a. Explain why the employee should comply with the Safe Work Practice. b. Point out the most probable sources of problems; the things to which special attention should be paid. c. Specify required clothing and equipment, the conditions under which it is required, and the reasons for its use. d. Emphasize proper use of special guards, barriers, switches, locks and emergency equipment. e. Reinforce the most important rules by including them in the Safe Work Practices. Keep them as short and simple as possible, and give the reason for the rules. f. Highlight the things that the employee can do to ensure efficient, safe, productive results. Keep the thou shall nots to a minimum. Work on the positives. g. Summarize the most important points.
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6.2
Hazardous Materials
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6.3
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Related Procedures: Practice: 1. All man basket and aerial platform operations require permits approved by the supervisor. 2. Aerial platform operators must be qualified as per AltaSteel procedures. 3. Man baskets may be used only on certain cranes at AltaSteel. See the Manager Maintenance and Engineering for details. Table of Contents
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Practice: 1. If required, a permit will be obtained before commencing any new electrical installations. 2. Annual permit(s) will be obtained as per provincial regulations. Table of Contents
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Practice: 1. All employees will follow the code of practice for confined spaces. 2. All confined spaces will be clearly identified. 3. All employees required to enter confined spaces must be properly trained and qualified. 4. The Supervisor Electrical and Mechanical will control the issue of entry permits and retain all permits issued in the past 2 years. 5. Gas Testers must be properly qualified, trained and authorized. Table of Contents
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Practice: 1. All Contractor work done at AltaSteel will be done in accordance with the Contractor Safe Work Procedure Manual including having a designated Contact Person for each job. 2. All Contact Persons must be trained and authorized. 3. Contractor Supervisors will be trained in the requirements of the Contractor Safe Work Procedure Manual and familiarized with the plant site. 4. Supervision and Maintenance and Engineering personnel will control the issue of Contractor Safe Work Permits and retain all permits issued in the past 2 years. Table of Contents
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6.4
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2. The Maintenance and Engineering Managers will retain the records of crane modification approvals. Table of Contents
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Practice: 1. Day Supervision will issue procedures for boarding of overhead cranes. These will be communicated to all persons who board the crane. 2. Day Supervision will issue procedures outlining the requirements for locking out cranes that are not in use. This includes methods of control for radio control boxes and pendants.
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Practice: 1. Day Supervision will issue procedures for operation of cranes and mobile equipment. 2. Day Supervision will issue requirements for cranes and mobile equipment when rentals are ordered. Table of Contents
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6.4.6 Non Destructive Testing of Structures, Cranes, Mobile Equipment and Lifting Equipment
Purpose: To ensure that structures, cranes, mobile equipment and lifting equipment are inspected regularly to avoid potential failures. Responsibility: The Engineering and Maintenance Managers are responsible for establishing the required inspection frequency and the type of inspection required for each piece of equipment and ensuring that it complies with Provincial Regulatory requirements. The Bar Mill Engineering and Maintenance Manager is responsible for implementing and carrying out the Non Destructive Testing program and providing feedback to equipment owners. Operations Managers and Supervisors are responsible for making equipment available for testing and providing the necessary assistance to the NDT Inspector to complete the testing. The NDT Inspector is responsible for performing crane and mobile equipment testing as per Engineering requirements and assessing the result of the testing. The Bar Mill Maintenance and Engineering Manager is responsible for scheduling and carrying out structural inspections of cranes, crane runways, crane cabs, buildings and other critical structures.
Documentation and Records: Workplace Procedures Provincial Regulations NDT Schedules and Reports Structural Inspection Schedules and Reports CMMS reports Related Procedures: ESM-MT-209.004Code of Practice for Lifting Equipment ESM-MT-209.012Temporary Lifting Lugs AS-BM-214.01A Inspections on Overhead Cranes AS-BM-218.01 Procedures and Policies AS-BM-218.04 Approved Department Equipment AltaSteel Safety Manual Module 6.4.1 Modification to Cranes, Mobile Equipment and Lifting Equipment
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Practice: 1. 2. 3. 4. 5. 6. The NDT Inspector will issue schedules of testing and regular reports of testing results. The AltaSteel civil engineer will schedule and carry out structural inspections of runways, crane cabs, buildings and other critical structures. Testing requirements must be authorized by Engineering and cannot be changed without Engineering approval. Any purchased cranes, mobile equipment, or lifting equipment will be examined by a qualified NDT Inspector prior to being put into service. Equipment put on hold by the NDT Inspector must not be used until released by the NDT Inspector or the Engineering and Maintenance Manager. Third party Structural inspection of cranes is to be done once every 3 years for the Scrap Crane, Charge Crane, Pouring Crane, Merchant Bar Crane and Rebar Runway Cranes. All other cranes are to be done every 5 years.
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6.5
Practice:
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1. In making a determination for the mandatory use of respiratory protective equipment the following shall be considered: a. The nature of any contaminant b. The concentration or likely concentration of any airborne contaminants c. The likely duration of the employees exposure d. The toxicity of the contaminant e. The partial pressure of oxygen f. The warning properties of the contaminants g. The need for emergency escape 2. Day Supervision shall maintain written procedures outlining which areas or activities require respirator use and what type of respirator is required. The HR department or Maintenance and Engineering department will provide technical assistance if required. 3. Employees will be responsible for the cleaning and maintenance of reusable respirators. 4. Each operating department is to train employees in the selection, care and use of the appropriate personal protective equipment, and enforce the developed controls. 5. Supervisors must assure that respirators are issued only for the purpose intended in accordance with this practice. 6. Employees who are or may be required to wear respirators are to be medically examined and fitted by the Medical Department. 7. Workers requiring respirators will be trained in their purpose including: a. Being informed of the airborne contaminant, including its properties and potential heath effects; b. Why the particular respiratory protective equipment was chosen and its limitations; c. How to put on and take off the respirator; d. Satisfactory fit procedure and requirements; e. This System description 8. Respirators are to be maintained in a clean and sanitary condition and stored in a manner to prevent their contamination. Respirators will be inspected before and after each use. 9. Respirators will be obtained from Stores and must not be ordered directly from suppliers. Special respirator requirements must be forwarded to the Supervisor Personnel and I.R. for evaluation of the most appropriate respirator, worksite evaluation, and respirator approval. Table of Contents
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2. Full body safety harnesses, complete with lanyards are to be used by workers to provide fall protection when it is possible to fall a vertical distance greater than 3.5 meters from a temporary work area or 1.2 meters from a permanent work area unless other fall protection safeguards, such as; a guardrail or a safety net is in place. 3. Safety belts and lanyards are to be used only as a restraining device, or tether, that will prevent workers from approaching a fall zone hazard area, such as; the edge of a roof, a crane, a platform, or another elevated structure. 4. Full body harnesses, complete with lifelines, are to be used by workers so they can be pulled to safety when there is a danger of drowning, entrapment or engulfment from any free flowing material. 5. The HR department will regularly (at least every 2 years) perform a plant wide inspection of belts and harness and communicate the results of the inspection. 6. Maintenance Supervision will maintain procedures outlining proper ladder use and how to work off ladders and scaffolding.
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7. When work at a height is done, involving several people such as; crane cable reeving, or crane overhauls, pre-job safety meetings are required. Table of Contents
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6.5.9 Management of Fire Extinguishers, Stretcher Stations, Eye Wash Stations, Safety Showers and Water Jel Blankets
Purpose: To ensure that this critical emergency response equipment is in place when needed and properly maintained and in compliance with provincial regulations. Responsibility: Managers are responsible for determining locations and quantities of each type of equipment. The HR department will provide technical advice on appropriate types and quantities of equipment. Day Supervision will implement regular inspections of this equipment in accordance with regulatory requirements. The HR department will implement annual inspections of this equipment utilizing outside expertise. Stores in conjunction with Purchasing and the HR department will establish a process for replacing spent fire extinguishers. Documentation and Records: Workplace Procedures Provincial Regulations Checklists Related Procedures:
Practice: 1. Managers will maintain a list of required equipment and locations and put in place procedures to maintain the equipment as well as identifying the locations with signs as required.
2. Day Supervision will develop an inspection checklist and ensure this is done weekly. Reports will
be submitted to Security who will summarize inspections done and report this back to the Managers.
3. Day Supervision will ensure spent fire extinguishers; used water gel blankets and stretcher
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6.6
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5. NDT Inspector and Maintenance and Engineering Departments are responsible for establishing preventative maintenance inspection schedules, conducting the inspections consistent with established checklists and scheduled frequencies, and maintaining records. The NDT inspector is responsible for advising operations, maintenance, and engineering when inspections are scheduled for cranes, lifting equipment, mobile equipment and hot metal equipment. 8. The Maintenance and Engineering Department in co-operation with the Supervisor Personnel and I. R. will interpret and communicate regulatory requirements. Table of Contents
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6.6.2
Purpose: To ensure that critical repair and new construction of safety related equipment such as stairs, ladders, utility lines, handrails, pulpits, crane cabs, etc. is performed according to consistent guidelines. Responsibility: The Maintenance and Engineering Department will establish guidelines for repair and new construction of safety related equipment. They will also be available for consultation if standards are not clear or unavailable. Day Supervision and Maintenance and Engineering Departments will ensure that repair and construction of safety related equipment is performed according to the guidelines. Documentation and Records: Workplace Procedures Provincial Regulations Construction and Repair Guidelines Related Procedures: Practice: 1. Engineering will establish guidelines and publicize them for all operating and maintenance management. 2. Engineering, operating and maintenance management will educate their people and contractors in the use of the guidelines and ensure that they are followed. Table of Contents
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Practice: 1. Safety lock issue will be controlled by security. 2. All employees will be issued personal safety locks when required. 3. Procedures for lockouts and reduction to a zero energy state must cover disconnecting and locking of electrical energy sources, blocking of any gravity or momentum energy source, bleeding of pressure from hydraulic or utility lines and testing to double check the lockout. 4. The HR department will establish a specific procedure for removing safety locks where the lock owner is not available. Except as outlined in the procedure locks shall only be removed by the owner. 5. All safety locks must be identified with the owners name or employee number. Table of Contents
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employees, contractors and others as required and ensure they are followed. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures:
Practice: 1. Procedures for restricted areas will cover roping off, entry authorization, signing & identification of area. 2. Permanently restricted areas must be signed with access restrictions clearly identified. Table of Contents
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6.6.5 Grinders
Purpose: To ensure fixed and hand held Grinder use at AltaSteel meets provincial regulatory requirements and AltaSteel procedures. Responsibility: Day Supervision are responsible for ensuring that grinders and grinder operating procedures comply with Provincial regulatory requirements. Purchasing and the requisitioner are responsible for ensuring that purchased grinders and grinding tools meet Regulatory requirements. Day Supervision are responsible for implementing a program of regular inspection of grinders. The HR Department will conduct regular plant wide inspections of grinders and publicize the results. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures:
Practice: 1. Procedures must cover requirements for RPM labeling, matching speed requirements of the stone and grinder, tool rest installation and adjustment, grinding on the side of abrasive wheels, PPE requirements, and inspection of stones.
2. Day Supervision are responsible for establishing training requirements for operation of both fixed
and hand held grinders. Operators must demonstrate an understanding of the procedure requirements and competence in the use of the equipment. 3. Only trained personnel may operate grinders. 4. All fixed grinders must have a face shield available.
5. Day Supervision will implement a program of regular inspections of grinders utilizing a checklist.
Completed checklists will be retained for 2 years. 6. The HR department will conduct an annual inspection of grinders utilizing outside expertise and report the inspection results to the Managers. Table of Contents
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Practice: 1. People who work in an isolated location on the plant site must establish regular communications with the security guard. 2. Where people are regularly working alone a written procedure will be developed. Table of Contents
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in their department. 2. The IGOR system will be used to trigger the required inspections of the pressure relief valves. 3. All purchases, leases, rentals or modifications of pressure vessels must be reviewed by engineering. Table of Contents
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Practice: 1. Winter boots will be provided to people regularly working outside. 2. Cool water will be made available to people working in extreme heat. Table of Contents
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6.6.9 Housekeeping
Purpose: To maintain housekeeping at an excellent level in order to minimize accidents, increase operational efficiency, minimize potential hazards, and promote pride in the workplace. Responsibility: Supervision are responsible for housekeeping in their area. Documentation and Records: Workplace Procedures Related Procedures:
Practice: 1. All work areas are to look professional and organized. 2. Supervision will organize housekeeping duties in their areas. 3. The AltaSteel Visitor Tour route is visible to visitors and customers. It must be kept in excellent condition.
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6.6.10
Pigeon Control
Purpose: To ensure that the pigeon population is controlled and minimize health concerns associated with pigeon droppings and carcasses. Responsibility: The Supervisor Personnel and IR will conduct a program of pigeon control utilizing the necessary outside resources. Documentation and Records: Workplace Procedures Related Procedures:
Practice: 1. Procedures will be established for safe disposal of pigeon carcasses. 2. Build-up of pigeon droppings will be vacuumed and disposed of using appropriate PPE and practices.
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Purpose: To ensure that a inspection system is in place to monitor hazard controls, identify safety rule violations, identify existing and potential hazards and reinforce and promote safe work practices and procedures. Responsibility: Managers are responsible for the implementation of regular planned/unplanned work site inspections for their respective departments. Department Joint H&S Meetings will review inspection performance at their monthly meetings. Documentation and Records: Health and Safety Inspection Reports AltaSteel Health and Safety Program AltaSteel Internal Standards for Health and Safety Occupational Health and Safety Statutes and Regulations Manufacturer Requirements Provincial and Federal Regulations Inspection Checklists Related Procedures:
Practice: 1. Department Worksite Safety Inspections are to be conducted on a monthly basis. 2. Worksite Inspection Report(s) are to identify substandard items, prioritize by hazard classification, identify who is responsible for making the corrections, set a projected date for the correction completion, and include a sign-off and date when the actual correction is made. 3, Supervisors hold the prime accountability for identifying the inspection team(s), for ensuring that work site inspections are being conducted on the scheduled frequencies, and for ensuring that the corrective actions are occurring. Inspection reports are to be forwarded to the respective Manager. Supervisors must immediately bring to the attention of the respective Manager any sub-standard item that is out of their immediate control and requires management involvement. 4. The inspection team(s) are to include employees. If a contractor/subcontractor is performing work on the site, then a representative(s) from the contractor/subcontractor are to be included in the planned work site inspection in the area where they are performing work. The inspection team(s) will, while conducting the inspection, look for items that are not in compliance with such items as practices and procedures, personal protective equipment policy, rules and regulations, safe hand tool usage and equipment operation. The team will also inspect other items such as guards, exit lights, fire extinguishers, emergency lighting, lighting, chains and hoists, emergency
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stop controls, warning signs, first aid supplies, electrical cords/wiring, housekeeping, aisles, work surfaces, and forklifts. The team will work towards developing a checklist. This will add continuity and ensure consistency in the inspection process. 5. Unplanned inspections can serve a useful purpose in determining health and safety performance. Respective area management has the responsibility for calling unplanned inspections. The same practice as identified in 2. above is to be followed in dealing with substandard items. 6. Worksite Inspection Reports are to be posted in the respective area(s). 7. Crew Safety Meetings, as part of their agenda, will review the substandard items found during inspections for the purpose of making employees aware of the substandard conditions and associated hazards. 8. Crew Health and Safety Committee(s) as part of their agenda, will review the progress of the identified substandard items. Exception Reporting is the process that is to be employed. Only items that are not successfully completed within the defined time parameters are to be reported to the Department Health and Safety Committee. 9. The respective Department Health and Safety Committee, as part of their agenda, will review the progress of the substandard items reported by exception and provide the necessary support. Any substandard items that cannot be resolved are to be reported to the Joint Health, Safety and Environment Committee. 10. Managers are accountable for monitoring the progress of all work site inspections conducted for their respective work area(s), summarizing the progress and forwarding this information to the respective stakeholders.
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7.2
Purpose: To comply with unscheduled inspections by the Occupational Health and Safety Officer which are done to ensure compliance with Occupational Health and Safety Regulations and Code. Responsibility: The Supervisor Personnel and I. R. is responsible for accompanying the Inspector on his tour of the plant. Documentation and Records: Occupational Health & Safety Inspector's Reports Occupational Health & Safety Inspection Notices Occupational Health & Safety Act, Regulations and Code Related Procedures: Practice: 1. The Department Manager(s) and the Vice President Administration will be notified that the Inspector is on site. 2. On off-hours the "On Call Manager" will be notified of the Inspector's presence. 3. The inspection notice will be signed for and posted. 4. Copies of the Inspection Notice will be circulated to all managers, and the chairman of the Union Joint Health and Safety Committee.
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7.3
Purpose: To ensure a system is in place whereby senior management and the union executive can actively participate in worksite inspections and demonstrate company commitment to the Health and Safety Program. Responsibility: The President in conjunction with the union co-chairman of the Joint Health, Safety, and Environment Committee are responsible for conducting worksite inspections. Documentation and Records: Safety Inspection Report. Previous inspections and pertinent information from Joint Health, Safety and Environment Committee reviews of departmental work site inspections. Sample Checklists Related Procedures: Practice: 1. Plant Safety Inspections are conducted to determine whether implemented controls are working. 2. The Joint Health, Safety and Environment Committee performs the Inspection quarterly. 3. Observed results are documented and a summary report is distributed to the respective departments for correction, and to the committee members. Table of Contents
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3. At AltaSteel, emergencies will be categorized into three main classifications generally as Level I, Level II, and Level III. a. Level I: Confined to a single managerial area, not likely to significantly affect other areas or the public. b. Level II: Involves two or more managerial areas but the effects of which can be confined to company property and do not immediately pose a significant hazard to the public. c. Level III: Involves any situation that could pose a significant hazard to the public and/or the environment. Would require activation of the Level III EMERGENCY ACTION PLAN. Our experience at AltaSteel has, to date, been confined to Level I Emergencies and, to a minor degree, Level II Emergencies. Fortunately, Level III Emergencies are rare occurrences. Therefore normal response will be to consider all emergencies in the initial stage as either Level I or Level II. In the event of escalation of an event to Level III the broad organizational plan in the Level III procedure is to be used. 4. Managers or the On Call Manager will determine when it is necessary to implement an emergency action plan. Table of Contents
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8.2
Evacuations
Emergency Evacuations Purpose: To ensure that procedures are in place for emergency evacuation of plant facilities. Responsibility: Managers are responsible for putting in place emergency evacuation procedures for their area. Documentation and Records: Workplace Procedures Evacuation Procedures Related Procedures: Practice: 1. Each manager will implement a written evacuation procedure for the areas required. 2. Procedures will outline a meeting place and head count requirements, communication plans and designated authorities.
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8.3
Purpose: To ensure that First Aid is available in compliance with Provincial Regulations. Responsibility: The HR Department is responsible for ensuring that Provincial Regulatory Requirements for First Aid Facilities and First Aider Coverage and Qualification are met. Managers are responsible for providing the facilities and personnel for First Aid. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures: Practice: 1. The HR department will provide First Aid training for First Aiders and monitor the number of qualified First Aiders to ensure regulatory requirements are met. 2. During normal operations First Aid will be administered from the First Aid Room in the Chem Lab building. During other periods a written notice outlining alternate First Aid response will be issued by the Nurse. 3. First Aid response will take precedence over any other duties of a First Aider. 4. The Nurse and the Supervisor Steelmaking Q.A.will implement a system to ensure First Aid supplies are properly maintained.
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8.4
Purpose: To conduct emergency response drills for emergencies that have the potential of occurring in the respective departments, and to analyze those drills to identify key learnings and areas of improvement. Responsibility: Mangers have the responsibility for identifying the potential types of emergencies that may occur in their areas and to schedule and hold an emergency drill(s) at least annually. The Supervisor Personnel and I. R. will provide assistance in evaluating the drills. Documentation & Records: Emergency Response Procedures and Action Plans Emergency Drill Reports
Related Procedures: Practice: 1. Supervision, in cooperation with safety representatives, are to identify the types of potential emergencies for their respective departments and work areas. 2. Emergency drills are to be conducted at a minimum of once per year. Where possible, emergency drills should be held on the back shifts. The Supervisor Personnel and I. R. will liaise with the operating areas to facilitate an emergency drill(s) for those areas in which employees work day shift only. 3. Supervision, the respective Union Health and Safety representative(s), and selected employee(s) are to analyze the drill and identify key learnings and areas for improvement. Review of the key learnings and areas for improvement is to be reviewed at the crew safety meetings. Information that may affect established emergency procedures is to be forwarded to the Supervisor Personnel and I. R. 4. The Supervisor Personnel and I. R. will initiate a review of the companys emergency response procedures on an annual basis to ensure that the procedures remain current.
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Purpose: To provide a uniform system for investigating incidents, accidents, and, concerns as well as health related incidents, and recording the information. Establishing cause and applying recommendations to prevent a recurrence and tracing the recommendations to their conclusion is a requirement. Responsibility: Employees are responsible for reporting all injuries, no matter how slight, to supervision. Employees are responsible for reporting all incidents which have potentially serious consequences to supervision. Supervisors are responsible for recording and investigating injuries, incidents, accidents and concerns. Managers are responsible for conducting investigations into serious accidents or incidents. Two members of the Joint Health, Safety and Environment Committee (one from the Union and one from management) are responsible for participating in investigations into incidents or accidents involving serious injury, cranes, mobile and lifting equipment.( Manager Environment and Major Project and Manager Maintenance and Engineering Bar Mill are considered members of the JHSC for the purposes of this clause). Definitions: Concern: Incident: Accident: Minor: Medical Aid: Lost Time: Serious Injury If an employee has a continuing, unsatisfied safety concern, it will be investigated. An unplanned event that could result in an injury or damage. An unplanned event that results in an injury or damage. Injury that does not require outside medical attention. Injury that is treated by a medical practitioner outside of work. Injury that causes the employee to miss time from work other than the day of the injury. as defined in the Occupational Health and Safety Act. This includes accidents that result in worker death or hospitalisation for more than two days, an unplanned or uncontrolled explosion, fire or flood that causes a serious injury or has the potential of causing a serious injury, or the collapse or upset of a crane, derrick or hoist or the collapse of failure of any component of a building or structure necessary for the structural integrity of the building or structure.
Documentation and Records: Request for Medical Service Supervisor's Accident & Employee's Compensation Report Employer's WCB Report Accident Investigation Recommendations Training Records Management On-Call Practice procedure
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Practice: 1. All injuries reported to supervision are to be recorded on the appropriate forms. 2. A supervisor's accident report will be completed on any incident/accident, consistent with following guidelines with respect to whom has the responsibility for conducting the investigation, before the end of the shift on which it occurred. 3. All those conducting investigations will be trained in Incident/Accident Investigation techniques. 4. Day Supervision will conduct medical aid injury investigations. Managers will make their respective comments and sign-off on the investigation. Investigations will be conducted at the earliest practical time and the reports completed in a timely manner. 5. Managers will conduct lost time accident investigations. The manager will make his/her comments and sign-off on the investigation. Investigations will be conducted at the earliest practical time and the reports completed in a timely manner. 6. The respective union safety representative(s) are to be included in all accident investigations as well as incident investigations where there is potential for serious injury. 7. An investigation report will include a clear description of the incident and circumstances, root cause(s), and recommendations to prevent recurrence. The report is to be concise and legible but does not have to be typewritten. 8. Where immediate action is required to resume work safely, such recommendations will include specific details on what will be done, and by whom. Supervisors have the prime accountability for communicating incident/accident investigation recommendations/requirements to all employees that may be affected. 9. The respective departments will put in place a system for ensuring that all incident/accident investigations are reviewed at all of their crew safety meetings. 10. The Supervisor Personnel and I. R. has the accountability for liaising with the departments and communicating all incidents/accidents that affect the site as a whole. 11. The medical department completes the Employers Report and sends to WCB within 72 hours. 12. When the injured employee sees a doctor the doctor completes a form and sends it to WCB within 48 hours of the injured employees visit. 13. For Medical Aid or Lost Time injuries, the injured employee completes a Employees Report of Injury Form and sends it to WCB as soon as possible. The medical department will assist the injured employee in completing this form if requested. 14. The Supervisor Personnel and I. R. will liaise with the respective department(s) to ensure the above reporting is occurring. Table of Contents
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c. Determine what action is required, if any, for the following year. d. Establish specific, measurable goals for the next year. e. Establish and maintain records of the respective reviews. 6. Vice Presidents and Managers will conduct regular safety observations on employees carrying out normal duties. The observation will be reviewed with the employee with an emphasis on positive aspects of the employees behaviour. 7. The observation will be documented and retained for 3 months. 8. Observations will be reviewed at the weekly managers meeting. Table of Contents
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8. Where possible, Union Health and Safety representatives are appointed. They report on situations or concerns that may affect department employees. 9. Minutes and attendance records will be kept of all safety meetings. 10. Managers will implement a follow-up system to ensure items raised at safety meetings and on inspection tours are dealt with. 11. Attendance records at these meetings will be reviewed periodically to ensure employee attendance is maintained. Table of Contents
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6. Presidents Award - Each Quarter the President will select an individual or group for special recognition for significant contribution to safety at AltaSteel. Nominations for this award will be submitted to the President by members of the Joint Health, Safety, and Environment Committee. Donations to the United Way in honor of an employee may be selected in lieu of merchandise. 7. This policy will be reviewed annually by management.
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