Hazard Identification System

An important part of an organization's health and safety program is an effective hazard identification system that includes ways to mitigate the hazards.

If you are an employer with 20 or more employees in New Brunswick, the Occupational Health and Safety Act requires the following for hazard identification:

• Evaluation of the workplace to identify potential hazards.
• Procedures and schedules for inspections.
• Procedures for hazard reporting, and prompt follow-up and control of the hazards.

In addition, section 9(2)(a.1) requires all employers to “ensure that the place of employment is inspected at least once a month to identify any risks to the health and safety of employees”.

Furthermore, it is important to note that all employers and supervisors are required to inform their employees about any hazard associated with the use, handling, storage, disposal and transport of any tool, equipment, machine, device or biological, chemical or physical agent. This requirement can only be met if the workplace has identified all hazards that are present. The regulations also have similar requirements. For example, carrying out work:

• In a hot environment.
• Involving blasting operations.
• At elevation.
• Involving diving operations.
• While using hazardous products.
• In a logging operation.

These and many others must be analyzed for hazards to protect employees. It is important to check the regulations to determine if the activities being carried by your employees have hazard identification requirements.

The goals of a hazard identification system are:

• Identify hazards.
• Analyze or evaluate the risk associated with that hazard.
• Determine appropriate ways to eliminate or control the hazard.

While a co-ordinator or supervisor may be involved, it is critical that the people who do the work participate in this process – they know the work better than anyone else. While current New Brunswick legislation does not explicitly outline the steps for a hazard identification system, following these steps will help you accomplish this requirement:

1. List the most common and important tasks: List the tasks or jobs that are done in your workplace, including maintenance, repair, and cleaning. Common examples include lift and transfer of patients in nursing homes, operating a forklift in a warehouse and changing a tire on powered mobile equipment.
2. Review the full list of tasks and identify those that are “safety critical” tasks: Safety critical tasks are those with a higher risk of injury or damage. Look at your list and evaluate the risk associated with each task or job. You may use other information to help make these decisions, such as injury reports, inspection reports, incident investigations, “near miss” reports, employee reports, monitoring for biological, chemical and physical agents and experience with the task or job.
3. Break the safety critical tasks into steps: Watch how the task is done. Record the sequence of steps. Remind the employee that you are evaluating the job (not their performance) and ask for their input and feedback. This process is also known as a job safety analysis or job hazard analysis.
4. Identify potential hazards in each step: Using all of the information you have gathered, list the things that could go wrong with each job, what controls are already in place, what hazardous products are used, are there concerns such as temperature, noise or ergonomic conditions? Is the job done the same way by each person? Is it done the same way in each season?
5. Find ways to control or eliminate the hazards in each step. The main ways to control a hazard include:
   • Elimination (including substitution): remove the hazard from the workplace, or substitute (replace) hazardous materials or machines with less hazardous ones.
   • Engineering controls: includes designs or modifications to plants, equipment, ventilation systems, and processes that reduce the source of exposure.
   • Administrative controls: controls that alter the way the work is done, including timing of work, procedures and other rules, and work practices such as standards and operating procedures (including training, housekeeping, and equipment maintenance, and personal hygiene practices).
   • Personal protective equipment: equipment worn by individuals to reduce exposure, such as contact with chemicals or exposure to noise.

These methods are known as the “hierarchy of control” because they should be considered in the order presented (it is always best to try to eliminate the hazard first).

Hazard identification is an ongoing process. It needs to be done whenever your workplace introduces new processes, equipment, materials or tasks to ensure that the impact is fully understood and addressed.

OCCUPATIONAL HEALTH AND SAFETY ACT
S.N.B. 1983, c. O-0.2

DUTIES OF EMPLOYERS, OWNERS, CONTRACTORS, SUB-CONTRACTORS, SUPERVISORS, EMPLOYEES AND SUPPLIERS

Section 8.1

8.1 (1) Every employer with 20 or more employees regularly employed in the Province shall establish and implement a written health and safety program, in consultation with the committee or the health and safety representative, that includes provisions with respect to the following matters:

(a) the training and supervision of the employees in matters necessary to their health and safety;

(b) the preparation of written work procedures and codes of practice for the implementation of health and safety work practices, required by this Act, the regulations or by any order made in accordance with this Act;

(c) the identification of the types of work for which the work procedures are required at the places of employment of the employer;

(d) a hazard identification system that includes

(i) evaluation of the place of employment to identify potential hazards,

(ii) procedures and schedules for inspections, and

(iii) procedures for ensuring the reporting of hazards, prompt follow-up and control of the hazards;

(e) a system for the prompt investigation of hazardous occurrences to determine their causes and the actions needed to prevent recurrences;

(f) a record management system that includes reports of employee training, accident statistics, work procedures and health and safety inspections, maintenance, follow-up and investigations; and

(g) monitoring the implementation and effectiveness of the program.

(2) The employer shall review its health and safety program at least once each year, in consultation with the committee or the health and safety representative, and shall update the program as required.

(3) The employer shall make a copy of the program and all records available

(a) to the committee or the health and safety representative, and

(b) on request, to an employee at the place of employment or the Commission.

[S.N.B. 2013, c. 15, s. 3; 2024, c. 5, s. 1]

Section 9 Duties of employer

9. (1) Every employer shall

(a) take every reasonable precaution to ensure the health and safety of its employees;

(b) comply with this Act, the regulations and any order made in accordance with this Act or the regulations; and

(c) ensure that its employees comply with this Act, the regulations and any order made in accordance with this Act or the regulations.

(2) Without limiting the generality of the duties under subsection (1), every employer shall

(a) ensure that the necessary systems of work, tools, equipment, machines, devices and materials are maintained in good condition and are of minimum risk to health and safety when used as directed by the supplier or in accordance with the directions supplied by the supplier;

(a.1) ensure that the place of employment is inspected at least once a month to identify any risks to the health and safety of its employees;

(b) acquaint an employee with any hazard in connection with the use, handling, storage, disposal and transport of any tool, equipment, machine, device or biological, chemical or physical agent;

(c) provide the information that is necessary to ensure an employee’s health and safety;

(c.1) provide the instruction that is necessary to ensure an employee’s health and safety;

(c.2) provide the training that is necessary to ensure an employee’s health and safety;

(c.3) ensure that work at the place of employment is competently supervised and that supervisors have sufficient knowledge of all of the following with respect to matters that are within the scope of the supervisor’s duties:

(i) this Act and any regulations under this Act that apply to the place of employment;

(ii) any safety policy for the place of employment;

(iii) any health and safety program for the place of employment;

(iv) any health and safety procedures with respect to hazards in connection with the use, handling, storage, disposal and transport of any tool, equipment, machine, device or biological, chemical or physical agent by employees who work under the supervisor’s supervision and direction;

(v) any protective equipment required to ensure the health and safety of the employees who work under the supervisor’s supervision and direction; and

(vi) any other matters that are necessary to ensure the health and safety of the employees who work under the supervisor’s supervision and direction;

(c.4) ensure that work at the place of employment is sufficiently supervised;

(d) provide and maintain in good condition such protective equipment as is required by regulation and ensure that such equipment is used by an employee in the course of work;

(e) co-operate with a committee, where such a committee has been established, a health and safety representative, where such a representative has been elected or designated, and with any person responsible for the enforcement of this Act and the regulations.

(3) An employer shall develop a program for the inspection referred to in paragraph (2)(a.1) with the joint health and safety committee, if any, or the health and safety representative, if any, and shall share the results of each inspection with the committee or the health and safety representative.

[S.N.B. 2001, c. 35, s. 3; 2007, c. 12, s. 2; 2013, c. 15, s. 4; 2019, c. 38, s. 4; 2022, c. 32, s. 5]

Section 9.1 Duties of supervisors

9.1 (1) Every supervisor shall

(a) take every reasonable precaution to ensure the health and safety of the employees who work under the supervisor’s supervision and direction;

(b) comply with this Act, the regulations and any order made in accordance with this Act or the regulations;

(c) ensure that the employees under the supervisor’s supervision and direction comply with this Act, the regulations and any order made in accordance with this Act or the regulations; and

(d) co-operate with

(i) a committee, if a committee has been established,

(ii) a health and safety representative, if a representative has been elected or designated, and

(iii) any person responsible for the enforcement of this Act and the regulations.

(2) Without limiting the generality of the duties under subsection (1), every supervisor shall

(a) acquaint the employees under the supervisor’s supervision and direction with any hazard in connection with the use, handling, storage, disposal and transport of any tool, equipment, machine, device, or biological, chemical or physical agent;

(b) provide the information that is necessary to ensure the health and safety of the employees under the supervisor’s supervision and direction; and

(c) provide the instruction that is necessary to ensure the health and safety of the employees under the supervisor’s supervision and direction.

[S.N.B. 2019, c. 38, s. 5]