Collaboration and Partnerships Required
to Meet Mounting Regulatory
Requirements Around the Environment,
Health, Safety and Emergency
Management
Julia Lewis - Ryerson University
Gilles Morier - University of Ottawa
Grant McCaughey - University of Manitoba
Chris White - University of Guelph
CAUBO’s New
National EHS Committee
The mandate of the National Environmental
Health and Safety Committee is to identify
legislation or policy relating to Occupational
Health and Safety, Environmental Compliance
and Emergency Management and to provide
oversight and recommend best practices to
support prudent management decisions at
their institution.
Chair – Michael Histed (University of Ottawa)
Western Rep – Grant McCaughey (University of Manitoba)
Ontario Rep – Dan Langham (Queen’s University)
Quebec Rep – Sue Magor (Concordia University)
Eastern Rep – Dave Foley (InterUniversity Services Inc.)
The ‘Internal Responsibility’
Framework
Grant McCaughey, Director
Environmental Health and Safety Office
University of Manitoba
204-474-9290 Tel
E-mail: mccaugh@cc.umanitoba.ca
Web Page http://umanitoba.ca/admin/human_resources/ehso/
Here is a scenario to
think about ……….
►
►
►
Assume you are a Principal Investigator, responsible for 2
staff and 3 grad students.
You have been called by University Security Services and
advised that there has been an accident in area that you
are responsible for. One of the staff and 2 students have
been taken by ambulance to the Emergency Department.
The initial investigation indicates that there was an
explosion and fire.
Security Services also tells you that a safety and health
officer from the Department of Labour and a City
police officer have requested your presence for an
interview regarding the incident.
Are you Prepared ??
► Will
you be prepared to deal with the
authorities?
► Will you know and understand your
responsibilities?
► Will you be confident in your ability to show
that you have done your best to be duly
diligent in providing a safe and healthy
workplace?
Due Diligence
• Provincial H&S/Environmental Legislation
is fairly consistent across Canada.
• Offences under the legislation are
considered ‘strict liability’ offences. This
allows for the defence of due diligence.
• Due diligence is the level of judgment,
care, prudence, determination, and activity
that a person would reasonably be expected
to do under particular circumstances.
The Internal
Responsibility System
For OSH purposes, the IRS is based on the
principle that everyone at the workplace; the
employers, workers, contractors and self
employed persons, all share a responsibility for
the health and safety of persons at the workplace.
How can we ensure we have established programs
that provide for an all-inclusive participation of all
workplace participants ?
Provincial Safety & Health Laws
-Basic Worker Rights►right
to know about hazards
►right
to participate in safety activities
►right
to refuse dangerous work
How can we ensure we have established programs
to deliver on these basic rights ?
University Structure is
Unique (to say the least)
Corporation
University
Directors of Corp
BOG/PVP
Managers
Supervisors
Workers
Deans, Directors,
Dept Heads
PIs, Prof, Mgrs.
Workers
Students
CORPORATION
UNIVERSITY
Establishing Due Diligence ?
1.
2.
3.
4.
5.
6.
7.
Comply with Act/Regulatory
Requirements
Institute Safety and Health Controls
Undertake Inspections and Audits
Provide Training (Right to Know)
Allow Participation (H&S Committees)
Ensure adequate and proper Supervision
Reasonably foresee and protect
staff/students from hazards
Collaboration is Necessary!
► Need
to establish mechanisms to allow
collaboration to take place in order to meet due
diligence responsibilities, which include;
 Developing a comprehensive OSH Program that
identifies the responsibilities of all participants and clear
goals and objectives.
 Developing effective and consistent training programs
for staff/students.
 Developing effective communication systems to get the ‘
message’ out.
 Setting up effective systems to allow participation, i.e.
joint H&S Committees
How to Collaborate/Partner?
► Establish
a central Health and Safety
Committee, composed of all bargaining unit
reps, student rep, academics and
administrative staff. ( Statutory requirement
in most jurisdictions)
► Setup Local Area H&S Committees
(Faculty/Building/Area)
► Set up Topic/Hazard specific Committees to
deal with particular risks – i.e. Radiation,
Biohazards, Emergency Management, etc.
National Integrated
Risk Management
GOAL:
to enable calculated risk taking in support of
distinct research and learning mandates driving
innovation and organizational development
1.
2.
3.
Compelling External Context
Consistent Strategic Focus
Collaborative Approaches
Legislation – EH&S
Responsibility Summary
FEDERAL LEGISLATION
Statute
Biological and Toxic Weapons Convention Implementation Act
Canada Labour Code (Part II)
Chemical Management Plan – The Challenge
Chemical Weapons Convention Implementation Act
Criminal Code
Defence Production Act
Department of Health Act
Environmental Assessment Act
Environmental Protection Act
Export and Import Permits Act
Fisheries Act
Food Inspection Agency/Health of Animals Act
Hazardous Products Act
Navigable Waters Protection Act
Nuclear Safety and Control Act
Transportation of Dangerous Goods Act
Implications
on Research
Implications on
University Operations
and Infrastructure
Implications
on University
Administration
Legislation – EH&S
Responsibility Summary
INTERNATIONAL
LEGISLATION
Statute
Implications
of Research
Implications on
University Operations
and Infrastructure
Implications on
University
Administration
IATA (International Air Transport Association) TDG
IAEA (International Atomic Energy Agency)
National
US Military
The list is not exclusive and is intended as a guide to the types of
legislation that impact University operations
Compelling External
Context
► National
Comprehensive Liability
“Criminalization of health and Safety”
► Broad Risk Spectrum = “Broadened
Partnerships”
► Focus
on Best Practices in Sector
Defense = “ Need for Collaborative
Synergy“
…. building a responsive
foundation
Enabling Partnerships
Integrated Due Diligence
Community Wide Risk Management
O/EH&S, Security, Emergency Management,
Public Safety, Public Health, Regulatory Affairs
Consistent Strategic
Focus
… Critical success factors
Risk
Management
System
Internal
Responsibility
System
IRM
STRATEGY
System
Audit
Integration
and
Support
Collaborative Approaches
► Motivating
Internal Synergies
► Fostering External Partnerships
► Leveraging National Sector Specific
Influence
A naïve “risk management”
approach
►
How can different specialist teams work together to ensure
regulatory compliance and a safe workplace?
 Identifying and assessing is the first step
 Think about eliminating, controlling, or mitigating possible risks
 Think in terms of likelihood of occurrence and consequences if an
event does occur
 Prevention is better than correction or cure
 Insurance is good but not a panacea: Should be viewed as part of
a more comprehensive risk management strategy
►
Professors should be our partners: Moves us from a
“regulatory” to “client service” frame of mind
Research is integral part of
what we do
►
Integral to our raison d’être
►
Not a typical corporate environment :
 Professors have a freedom of action unknown in any other organizational
environment.
 Students are important research performers who are by definition
transitory and often, at least at the start, inexperienced.
►
We must, and do, delegate huge responsibilities to people with
tremendous independence.
►
The nature of the activities is a key contributor to exactly the type of
Environment, Health, Safety and Emergency Management issues we
must manage.
Partnering with the Research
Managers
► Our
environment:
 Volume, intensity and inter-disciplinarity of research is
increasing as universities take on a larger societal
research role
 The regulatory environment changes quickly,
continuously and occasionally in obscure ways
► Even
small changes can have big impacts
 Medically-oriented research is increasing relative to
others
► Use
of biohazardous materials, radioactive compounds, human
and animal subjects increasing faster than “rate of research
growth” would suggest
As a research manager, I care
about:
► Research
development and growth
► Good management
► Are we following the rules?
► Do we have the right policy / administrative
infrastructure?
► Can we keep up?
► Have I missed anything?
We can’t do it without the
experts!
►
We, research managers, rely on the collective wisdom and expertise of
the specialized teams
►
Becoming extremely difficult for institutions to know and to adapt
►
Becoming impossible for the researcher to know everything
►
We want you and your teams to be an integral part of our institutional
research management team
►
We want to work with you manage and mitigate risks, to educate, to
monitor and ensure compliance and, in general, to do the right thing
Different issues are managed
differently:
►
Ethics / Human Subjects  Project by Project
►
Animal Care  Project plus Procedures (within projects)
►
Radiation / Biohazards  Project plus Procedures (within
projects) plus Laboratory certification
►
Environment  Project plus Procedures (within projects)
plus Institutional capacity
►
Health and Safety  Institutional capacity then
Laboratory then Project
What we have in common:
► Data
 The need for information sharing, supported by
appropriate and shared systems, has never been
greater
 We all collect project-based data – would be a good
place to start!
► Clientele
 Expecting ease of use, consistency of approach, interservice coordination, tools and information
 How can we help them be successful?
What we have in common:
► Communications
needs:
 As educators, we should be thinking about :
► Ensuring
that our clientele has ready access to the information
they need to do things properly
► How each interaction with our clientele affords a pedagogical
opportunity.
 As communicators: We have important messages to
deliver to, and receive from, our clientele.
► Monitoring
/ Compliance Needs
 Coordinating processes as much as possible to minimize
duplication of effort and facilitate for our clients
In conclusion:
►
Promote much closer working relationship between risk management,
regulatory, and research management teams
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Good management all round mitigates risks
►
We need to work together
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To assure integrated management approach
To share information, communications opportunities
To wield influence
Ultimately, to better serve our research community: Professors, students,
trainees and employees
Mitigating risks helps us all be, and stay, successful
Collaboration and Partnerships Required
to Meet Mounting Regulatory
Requirements Around the Environment,
Health, Safety and Emergency
Management
Julia Lewis - Ryerson University
Gilles Morier - University of Ottawa
Grant McCaughey - University of Manitoba
Chris White - University of Guelph