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Transcript of Irs presentation4
W. A. L. K.
Workplace - Action - Learn - Knowledge
Internal Responsibility System
Introduction
Eric LeFort
Married with three Children
30 yrs + Reside in Whycocomagh NS
Graduate Algonquin College
15 years + Experiences in OHS
5 yrs + NS OHS Division Regulator
5 yrs + NS WCB Consultant
3 yrs + OHS Advisor in Industry
1.5 yrs + OHS Faculty Program, NSCC Marconi
CRSP, CSS Designation
NSCC CCEDP Candidate 7/7/21
Agenda
Accident Theory Model5 steps Accident AnalysisEffective Theory Model of IRS Defining IRSFirst for IRS in legislationEveryone's ResponsibilityWrap Up
7/7/21
Welcome
Eric LeFort , CRSP
Where does the “IRS” Come from?
Though the idea comes from the
Accident Model Theory, “The Ham
Royal Commission into Safety in the
Mines In Ontario”, which discussed
the IRS in its 1976 report, made this
idea much clearer and easier to
understand as it applies to OHS.
17/7/21
Eric LeFort , CRSP
Accident Theory Model
.
If the people in a managed system are
identified, and as you work through the
accident analysis, you can see the structure
of the IRS forming.
* In this example we have a domino model that
encompasses all the direct players of the IRS.
7/7/21
W. H. Heinrich's Domino Theory
2
Most modern accident theories take the
analysis away from the direct causes of
accidents and exposures to the root
problems in the management system.
Eric LeFort , CRSP
People and the IRS
If the people in a managed system are identified, as you work through the accident analysis, you can see the structure of the IRS forming.
7/7/21 3
IRS
5 Step Accident Causation Analysis
Eric LeFort , CRSP
Steps in cause analysis
1. Analyze the injury event to identify and describe the direct cause of injury.
Example:
Laceration to right forearm resulting from contact with rotating saw blade.
7/7/21 4
Click icon to add picture
IRS
Step 1 - Accident Causation Analysis
1
Eric LeFort , CRSP
Steps in cause analysis
2. Analyze events occurring just prior to the injury event to identify those conditions and behaviors that caused the injury (primary surface causes) for the accident.
Example:
Event x Unguarded saw blade. (condition or behavior? )
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Click icon to add picture
IRS
Step 2 - Accident Causation Analysis
2
Steps in cause analysis
3. Analyze conditions and behaviors to determine other specific conditions and behaviors (contributing surface causes) that contributed to the accident.
Example:
Supervisor not performing weekly area safety inspection. (condition or behavior? )
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Click icon to add picture
IRS
Step 3 - Accident Causation Analysis
3
3
Steps in cause analysis
7/7/21Eric LeFort , CRSP 7
Click icon to add picture
4. Analyze each contributing condition and behavior to determine if weaknesses in carrying out safety policies, programs, plan, processes, procedures and practices exist
Examples:
Safety inspections are being conducted inconsistently. (condition or behavior? )
IR
S
Step 4 - Accident Causation Analysis
4
Eric LeFort , CRSP
Steps in cause analysis
7/7/21 8
Click icon to add picture
5. Determine implementation flaws to determine the underlying design weaknesses.
Example:
Inspection policy does not clearly specify responsibility by name or position. (Condition or behavior?)
IRS
Step 5 - Accident Causation Analysis
5 Leadership
Eric LeFort , CRSP
Would you agree with this theory?
W. H. Heinrich's Domino Theory
"The occurrence of an injury invariably results from a completed sequence of factors, the last one of these being the accident itself. The accident in turn is invariably caused or permitted directly by the unsafe act of a person and/or a mechanical or physical hazard." (W.H. Heinrich)
7/7/21 9
Eric LeFort , CRSP 7/7/21
W. H. Heinrich's Domino Theory
10
Who can cause an accident?
Who can take steps to prevent accidents?
Who should be taking steps to prevent accidents and exposures?
Who should be responsible for health and safety in the organization?
Quiz yourselves on the Accident theory
Eric LeFort , CRSP
Did you get it right?
Who can cause an accident? Anyone
Who can take steps to prevent accidents? Anyone
Who should be taking steps to prevent accidents and exposures? Everyone
Who should be responsible for health and safety in the organization? Everyone
7/7/21 11
Eric LeFort , CRSP
Anything else which may influence the effectiveness of the IRS?
7/7/21 12
Eric LeFort , CRSP
Human Resources Theory
The human resources literature usually refers to "productivity" or "quality", but if you substitute the phrase "health and safety", we can see that the human element is by far the most important element of health and safety management.
137/7/21
Eric LeFort , CRSP
Management & Staff Engagement
It is absolutely clear that for an organization to perform optimally, it is the hearts and minds of the individual people throughout the organization that have to be engaged.
147/7/21
Eric LeFort , CRSP
I.R.S. Defined
I - Internal
R - Responsibility
S - System
7/7/21 15
It Is Not Rocket Science
Eric LeFort , CRSP
The IRS as a Structure
Commissions and acts aside, the IRS can be seen to arise from an understanding of how organizations work best.
The simple corporate model, shown on the the following Figure ,illustrates the flow of legitimate authority from the legal charter through to the operations people.
167/7/21
Eric LeFort , CRSP
Organizations and the IRS
There is, as we all know, enormous variation in workplaces and organizations.
To varying degrees, every organization has an IRS, no matter how stunted or deformed.
The process is to assess your current situation -- the health of your IRS -- and then move forward with improvements, with the true model of the IRS in mind.
177/7/21
Company Legal Charter
IRS is an Important Set of Ideas
The IRS is such an important set of ideas that it is properly the responsibility of the most senior people to see to it that the IRS is optimized.
Monitoring and fixing the IRS should be of high priority.
However, good leadership is the most important idea of all.
7/7/21Eric LeFort , CRSP 18
Eric LeFort , CRSP
IRS and OHSDr. Peter Strahlendorf
“The internal responsibility system, or IRS, is a system in which every individual is responsible for health and safety. It can be thought of as an organizational chart, with a clear set of statements about responsibility and authority for health and safety for each person within an organization -- no exceptions” .
197/7/21
Eric LeFort , CRSP
Got the correct understanding of the idea?
Should we conclude that the IRS is based on the law?
Should health and safety law be evaluated as to whether and to what degree it advances the IRS concept?
7/7/21 20
Eric LeFort , CRSP
IRS or Not!
Whether they call it the IRS or not, the best performers have found that a system of universal, but personal, responsibility is the most effective way to drive risk down.
The power of the IRS is that it captures the creativity, leadership, experience and knowledge of everyone in the organization.
7/7/21 21
Why Re-Invent The Wheel?
Eric LeFort , CRSP
Break Down - Plain Language Meaning of I.R.S
7/7/21 22
Eric LeFort , CRSP
The Internal
The “Internal" in the phrase “Internal Responsibility System" has more than one meaning.
First, the primary responsibility for health and safety is internal to the workplace.
The second meaning of “Internal" is that responsibility for health and safety is internal to the work, internal to the job.
237/7/21
Eric LeFort , CRSP
Responsibility
Refers to the personal duties of each person in the workplace.
These responsibilities exist on several levels.
There are responsibilities for each person spelled out in most health and safety legislation -- worker duties, supervisor duties, employer duties and so on.
There are responsibilities associated with each person's job description -- he or she is responsible for doing the job in such a way as to achieve a good outcome.
And there is the moral responsibility that each of us has to do the right thing.
A person who discharges all these duties is "taking responsibility" and, overwhelmingly, the most important element of the IRS is that everyone has personal responsibility.
247/7/21
System
Are the individual people.
The parts work together in relationships to further the purpose of the whole entity -- the system.
The purpose of the system is to drive risk down and keep up the pressure so that we can go for increasing lengths of time with zero injuries and illnesses.
As a true "system", the IRS comes with built-in self-monitoring devices that can readjust the system when part of it fails.
Work refusals, health and safety reps, and health and safety committees are among the more obvious self-correcting feedback loops.
As all parts of the system are inter-related and interdependent, damage to one part can affect another part in ways that may be indirect, but which can be very serious.
257/7/21Eric LeFort , CRSP
Eric LeFort , CRSP
Courts Definition
Adopted
Recommendations of the 1974 - 1976 Ontario “Ham Royal Commission”.
Report and inquiry of IRS / OHS “Responsibilities in a Mining Organization”.
7/7/21 26
Eric LeFort , CRSP
“Ham Royal Commission” Report defines IRS
Table setting out the
organizational structure
of a mining company.
7/7/21 27
Eric LeFort , CRSP
Organization Structure
Beside each layer of the structure was stated
Person's Role in Health and Safety President Vice-president Mine Manager Superintendent Supervisor Worker
7/7/21 28
Emphasis
Roles of the “worker auditor”
commonly known as the
“employee representative” and
the health and safety committee
were described as ways of
ensuring that the IRS worked well
within a any given organization.
The rights and responsibilities of
the “worker” or employees were
also discussed. 7/7/21Eric LeFort , CRSP 29
Eric LeFort , CRSP
OHS Act of Ontario - 1979
The Ontario health and safety legislation that came into effect in 1979 was based on Ham's vision of the IRS and how it could be monitored and fixed.
It is highly unlikely that we would be using the phrase "internal responsibility system" today were it not for the Ham Royal Commission.
7/7/21 30
Eric LeFort , CRSP
Where did this idea originally come from?
A requirement for a company to spell out its "organizational arrangements" - spelling out who was to be responsible for what aspects of health and safety in the organization.
7/7/21 31
Eric LeFort , CRSP
British legislation of 1974
Does the phrase on the previous slide come close to the meaning of the IRS as you know it?
7/7/21 32
Eric LeFort , CRSP
IRS Define “ Ontario MOL Study 2001”
“The IRS is a system, within an organization, where everyone has direct responsibility for health and safety as an essential part of his or her job.”“An individual does health and safety in a way that is compatible with the kind of work that person does.” Nothing left to chance !!!
7/7/21 33
Eric LeFort , CRSP
Westray Mine Inquiry
After the Westray Mine Explosion of 1992, which killed 26 Coal Miners, Nova Scotia re-wrote its OHS Act and based it on the IRS model as developed in the Ontario mining industry.
7/7/21 34
“Legal IRS” or “ Pre-Legal IRS”
When an act refers expressly to the IRS, as is the case in Nova Scotia, we would distinguish between the the "legal IRS" and the "pre-legal IRS".
Nova Scotia deserves much credit for being the first to have the nerve to put such a rich and subtle concept into their legislation in black and white terms.
7/7/21Eric LeFort , CRSP
35
NS OHS Act 1996
IRS Defined “The NS OHS Act”
s. 2 The foundation of this Act is the Internal Responsibility System which;
(a) is based on the principle that
(i) employers, contractors, constructors, employees and self-employed persons at a workplace, and
7/7/21Eric LeFort , CRSP 36
Eric LeFort , CRSP
NS IRS Definition Continued …
(ii) the owner of a workplace, a supplier of goods or provider of an occupational health or safety service to a workplace or an architect or professional engineer, all of whom can affect the health and safety of persons at the workplace, share the responsibility for the Health and Safety of persons at the workplace;
7/7/21 37
NS IRS Definition Continued
(b) assumes that the primary
responsibility for creating and
maintaining a safe and
healthy workplace should be
that of each of these parties,
to the extent of each party's
authority and ability to do so;
7/7/21Eric LeFort , CRSP 38
Eric LeFort , CRSP
NS IRS Definition Continued
(c) includes a framework for participation, transfer of information and refusal of unsafe work, all of which are necessary for the parties to carry out their responsibilities pursuant to this Act and the regulations; and
7/7/21 39
Right to Refuse
Right to Know
Right to complain
Right to Participate
Eric LeFort , CRSP
NS IRS Definition Continued
(d) is supplemented by the role of the
Occupational health and Safety Division
of the Department of Labour, which is
not to assume responsibility for creating
and maintaining safe and healthy
workplaces, but to establish and clarify
the responsibilities of the parties under
the law, and to support them in carrying
out their responsibilities and to
intervene appropriately when those
responsibilities are not carried out.
7/7/21 40
OHS Division Regulator
Support providing clarity
Something to Think about
What element does every job in every single workplace have?
1. Responsibility to perform certain tasks.
2. Authority to do certain things.
3. Accountability for the outcome.
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Eric LeFort , CRSP
Health and Safety
Add "health and safety" to each element and you have a world-class system that intergrades seamlessly into the chain of command.
7/7/21 42
Review
IRS
Everyone's Responsibility
7/7/21Eric LeFort , CRSP 43
Eric LeFort , CRSP
James Ham
James Ham got it right in 1976:
1. OHS should be integrated into production; it’s not a separate function.
2. Everyone should be doing OHS directly as part of his or her job.
7/7/21 44
Eric LeFort , CRSP
The IRS means that …
1. Responsibility for identifying hazards and solving OHS problems is _________ to the workplace.
Primary responsibility for OHS is not _________.
ie; on the shoulders of the NS OHS Division.
Key “Internal” “External”
7/7/21 45
The IRS means that …
2. OHS should not be an adversarial matter between ________ and employers.
3. Everyone has an _________ in avoiding workplace injury and illness.
Key “ Worker” “Interest”
7/7/21Eric LeFort , CRSP 46
The IRS means that …
7/7/21Eric LeFort , CRSP 47
4. Everyone in the workplace has _________ duties and rights regarding OHS.
5. Everyone is legally _________ as an individual, to participate in identifying hazards and in seeking to eliminate or control them.
Key “Legal” “Required”
The IRS means that …
6. Everyone is an "internal auditor" to see that the Act and regulations are _________ with.
7. The NS OHS Division Officer's job is not to be at __________ elbow to advise and to give commands.
Key “Complied” “Everyone's”
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Eric LeFort , CRSP
The IRS means that …
8. The Officer (External Responsibility System) only _____ in when the Internal Responsibility System is clearly not working , this when ______ are not taking their rights and responsibilities seriously.
Key “Steps” “People”
7/7/21 49
Eric LeFort , CRSP
Wrong IRS Description
“The IRS is a partnership between labour, industry and government to ensure a safe and healthy workplace.”
Refers to a tripartite policy-making process (e.g. the development of WHMIS)
but not the IRS.
7/7/21 50
Eric LeFort , CRSP
Wrong IRS Description
“The company/employer is responsible for OHS, not the government.”
Fails to raise the “corporate veil” and identify all
individuals as personally responsible.
7/7/21 51
Eric LeFort , CRSP
Wrong IRS Description
Labour and management co-manage OHS through the Committee. The Committee is the “IRS.”
The “labour relations” version of the IRS.
Missing personal contribution of individuals.
7/7/21 52
Eric LeFort , CRSP
Wrong IRS Description
“IRS” is a set of three rights:
1. To know about hazards
2. To refuse unsafe work
3. To participate (through committee)
Missing the main element - personal duties of everyone
7/7/21 53
Internal to the Job Description of Everyone
Everyone, no exception
Staff and line employees
Workers, supervisors, managers, officers and directors
Personal, individual responsibility
Do the kind of OHS work that fits with authority and control
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Eric LeFort , CRSP
Internal to Routine Decision-Making
OHS not an add-on, or an afterthought
OHS not a separate function
As you do your ordinary work you think about risk, hazards, controls and adjust your work accordingly
Easy to see with workers and supervisors
Hard to see with mid to senior managers and with staff positions
7/7/21 55
Eric LeFort , CRSP
IRS and Due Diligence
“Take every measure reasonable in the circumstances to improve processes you are involved in.”
For world class OHS performance, we must incorporate quality principles into OHS decision-making.
7/7/21 56
Proactive vs Reactive
A well functioning IRS System goes a long way to establishing Due Diligence and Ensuring for Total Quality within and Organization.
7/7/21Eric LeFort , CRSP 57
Eric LeFort , CRSP 7/7/21 58
Eric LeFort , CRSP 7/7/21 59