B1. Occupational Health and Safety

Code 8.0

Worker potential for exposure to health and safety hazards (chemical, electrical and other energy sources, fire, vehicles, and fall hazards, etc.) shall be identified and assessed, mitigated using the Hierarchy of Controls. Where hazards cannot be adequately controlled by these means, workers shall be provided with appropriate, well-maintained, personal protective equipment, and educational materials about risks to them associated with these hazards. Gender-responsive measures shall be taken, such as not having pregnant women and nursing mothers in working conditions, which could be hazardous to them or their child and to provide reasonable accommodations for nursing mothers.

Elements to Demonstrate Compliance to RBA Code

Elements to Demonstrate Compliance to RBA Code are here below and also in the Health & Safety Checklist "B1 Occupational Health Safety: Pregnant and Nursing Mothers" later in this document.

1. Policy

Have a detailed, comprehensive documented occupational health and safety policy with elements including:

• a. All required permits, licenses, and test reports for occupational health and safety are in place and communicated timely to the government (if required).
• b. Occupational health & safety hazards are identified, assessed, and mitigated using the Hierarchy of Controls, which includes eliminating, substituting, and controlling through proper design, process and administrative controls, and appropriate Personal Protective Equipment (PPE) which is consistently and correctly used.
• c. Gender-responsive measures are taken to ensure pregnant women and nursing mothers are not in working conditions, which could be hazardous to them or their child, and provide reasonable accommodations for nursing mothers.

NOTE: All efforts must apply to all types of workers (direct, indirect, dispatched, young, interns, apprentices.

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. The facility keeps a registry or inventory of health and safety permits, licenses and certifications including their monitoring and reporting requirements, expiration dates, etc.
• b. Permits, licenses, and certifications are kept current and updated as necessary as operations changes occur.
• c. All health and safety violations have been remediated and are considered closed by the proper authorities.
• d. All government reporting is on time and correct.
• e. Assessments occur:
  • i. An adequate and effective risk assessment process is in place to identify the most significant actual and potential occupational health and safety risks, including specific risks of relevant demographics, such as gender and age, where the facility caused or contributed to adverse health and safety impacts for internal and external stakeholders (including applicable requirements).
  • ii. An adequate and effective process is implemented to eliminate or reduce worker safety hazards and determine proper PPE for specific job tasks and/or areas of the facility where it cannot be eliminated.
  • iii. A safety hazard assessment is performed for all machinery and equipment before purchase, installation and start up. Controls are implemented for the identified hazards.
  • iv. Hazards such as high noise, chemical use, heavy equipment use, awkward positions, work at heights, overhead hazards, etc. should all be evaluated.
  • v. Buildings are structurally sound and conform to local building code requirements.
  • vi. The risk assessment is updated when there is a Significant Change.

NOTE: Young workers, expectant and nursing mothers, others must be considered in a separate and unique category.

NOTE: Exposure to multiple chemicals can be either exposure to multiple chemicals by a single route or exposure to multiple chemicals by multiple routes. A route can be inhalation, ingestion, skin exposure, etc.

• f. Risks are addressed through the Hierarchy of Controls
  • i. Elimination
  • ii. Substitution
  • iii. Engineering controls
  • iv. Process and Administrative controls
  • v. Adequate and effective PPE
• g. Examples of areas to assess and steps are provided here; however, this is not comprehensive:
  • i. Stairways and elevated work areas are provided with appropriate guardrails and handrails.
  • ii. Aisles, stairways, and work areas are free of tripping hazards (stored materials, electrical cords, etc.).
  • iii. Health and safety education, both general and job-specific, is provided during initial orientation and on an ongoing basis.
  • iv. Precautions are taken to ensure safety in construction areas, including limiting vehicle speeds, scaffolding to prevent injury from falling objects and controls of electrical hazards.
  • v. In areas where powered industrial vehicles are used, pedestrian walkways are clearly delineated and physically separated, where possible, from vehicle operation areas.
  • vi. Electrical installations and wiring are regularly inspected and maintained to prevent electrical shock hazards (damaged cords and plugs, frayed wiring, missing protective barriers, etc.).
  • vii. Hazards are identified by appropriate signs, placards, and labels in the local language of workers.
  • viii. Energized parts are protected from accidental contact by enclosures and barriers.
  • ix. Operating procedures for equipment and machinery posing electrical hazards include electrical safety precautions.
  • x. Lockout/Tagout program is in place for work on equipment where stored energy (electrical, pneumatic, mechanical, etc.) or inadvertent start-up could injure workers.
  • xi. Confined spaces are identified, and hazards are evaluated before workers are allowed to enter. Hazard controls (e.g. mechanical ventilation, personal protective equipment, etc.) are implemented and maintained for the entire duration of the confined space work.
• h. Fire hazards are controlled:
  • i. Combustible storage is minimized and limited to areas with adequate fire detection and protection.
  • ii. Flammable and combustible materials are properly stored to prevent the accumulation of vapors.
  • iii. Ignition hazards (e.g. smoking, electrical sparks, open flames, etc.) are eliminated in areas where combustible and flammable materials are stored or used or if there is a flammable atmosphere.
  • iv. The facility controls the risks associated with fire hazards (e.g., replacing frayed electrical wiring, avoiding open flames, containing flammable vapors, etc.).
  • v. A hot work permit system is in place for welding, cutting, brazing, and similar activities.
• i. Only specially trained and licensed drivers are permitted to operate industrial powered vehicles.
• j. Workers are provided with appropriate fall protection for work in elevated work areas (e.g., roof work, heights, forklifts trucks, towers, etc.).
• k. PPE. Where hazards cannot be eliminated, there should be proper PPE requisition and renewal process. Adequate and effective notification and enforcement process for PPE use is in place including:
  • i. Worker training
  • ii. Signs and labels
  • iii. Regular enforcement by supervisors
  • iv. Work area inspections
  • v. PPE inspections and maintenance and renewal/replacement
• l. Gender-responsive measures for pregnant women and nursing mothers
  • i. General risk assessment of roles and areas must include potential hazards to expecting and nursing mothers. Those include but are not limited to these elements:
    1. Lifting/carrying heavy loads.
    2. Workstations and posture.
    3. Standing or sitting still for extended lengths of time.
    4. Exposure to infectious diseases
    5. Exposure to lead, organic mercury, other toxic chemicals, radioactive material.
    6. Work-related stress.
    7. Threat of violence in the workplace.
    8. Long working hours and/or night shifts.
    9. Extreme heat and/or noise
  • ii. When an expectant or nursing mother makes their situation known,
    1. A worker-specific risk assessment of the worker's job to assess risk to the mother and fetus.
    2. They must either be moved to a role that has been assessed and determined not to be hazardous to them or their children OR the hazardous elements of their role are removed.
    3. Health checks, if required by law, for pregnant workers and nursing mothers
  • iii. After the mother returns to work: a worker-specific post-natal risk assessment of the worker's job to assess risk to the mother and possible impacts on the baby through breastfeeding.
  • iv. Provide reasonable break time and location for a worker to express and store breast milk for nursing child.
    1. Location does not need to be a separate dedicated area.
    2. It cannot be a toilet stall or a bathroom.
    3. It must be private, secure, and close to the workspace.
    4. Clean, access to water and hygienic storage (e.g., a closed, clean cupboard)
    5. Refrigeration

NOTE: Workers have the freedom to refuse tasks that the worker believes to be hazardous without penalty or termination.

3. Controls & Monitoring

Controls & Monitoring should include:

• a. Steps to ensure tools, systems and processes are properly tested, calibrated, and otherwise maintained to demonstrate accuracy in measurement, indication, and recording.
• b. Site operations are reviewed for compliance with all monitoring, reporting and other permit requirements based on:
  • i. Internal monitoring and assessments
  • ii. Independent third-party assessments
  • iii. Regulatory agency reviews/inspections
• c. Ensure minimum monitoring is done including:
  • i. A daily safety inspection is performed for all industrial powered vehicles.
  • ii. PPE inspections by workers and staff

4. Records

Records are maintained including:

• a. All required occupational health and safety permits, licenses and test reports are in place and valid including:
  • i. Fire safety
  • ii. Industrial Hygiene permits and licenses (e.g., lasers, chemical)
  • iii. Building occupancy permits / use permits.
  • iv. Machine and industrial powered vehicles
  • v. Food, sanitation including drinking water, food sample testing.
  • vi. Housing includes rented apartments.
  • vii. Pressure vessel (e.g., boiler) permits
  • viii. Hoist / lift permits

NOTE: Some signage and information may be required by law to be posted in employee common / break/cafeteria locations.

• b. Professional certificates are maintained as required including:
  • i. Occupational health and safety (e.g., first responders, etc. where required).
  • ii. If nurses or doctors are employed or doctor/nurse services are used.
  • iii. Food worker/prep health tests
  • iv. Health and safety ERT members have the required qualifications/certifications.
• c. Accurate, complete, and up-to-date risk assessment reports
• d. Complete, and up-to-date internal and external stakeholder identification reports.
• e. Occupational Health / Injury and illness logs.
• f. Occupational health and safety testing reports are prepared, submitted as required, and retained including:
  • i. Industrial hygiene sampling data
  • ii. Drinking water sampling data
  • iii. Ventilation flow tests
  • iv. Injury and illness logs
  • v. Respiratory protection (fit tests, medical evaluations)
  • vi. Hearing conservation programs
  • vii. Notice of availability of medical records
  • viii. Fire safety equipment inspection, testing and maintenance data.
• g. All Occupational health and safety permits and licenses including:
  • i. Fire safety and emergency preparedness
  • ii. Occupational health professional licenses
• h. Emergency preparedness plans and data
• i. Occupational safety testing reports
• i. All industrial hygiene permits, licenses, and monitoring logs (e.g., exposures)
• j. Use permits.
• k. Industrial hygiene testing reports
• l. All machine (safety) permits and licenses and testing reports.
• m. Rented apartments shall be permitted by the local government.
• n. Food, sanitation and housing permits and licenses
• o. Canteen/kitchen workers have valid health certificates.
• p. If local regulations require facility health inspections or other tests or certificates, these are available and valid.

NOTE: All permits, licenses, certifications, and reporting data are posted as required by law in required or conspicuous locations

NOTE: Drinking water testing is not required if local water utility company can attest water meets World Health Organization (WHO) Guidelines for Drinking-water Quality or equivalent standard

5. Leading Practices

• a. Taking efforts, through communication, small group dialogue, other, to encourage expectant and nursing mothers to disclose their situation occur through communication and education.

6. Serious conditions that will result in a severe finding

• Not properly reporting occupational accidents, injuries, and illnesses to the governing agency as required by law; those that are deemed reportable by the authorities.
• Delay in mandatory government reporting in excess of 3 months from the due date.
• Workers wearing the wrong type of PPE or not at all WHEN there is an immediate risk to them.
• Not having PPE available for the ERT
• The ERT PPE is in poor condition, not working, insufficient, not visible nor easily accessible.
• Poor or improper use, handling or storing of hazardous substances (including waste) in a way that poses imminent harm or could lead to immediate risk to life, limb, or the facility.
• Having pregnant workers/nursing mothers in conditions that pose an immediate risk to them or their child.

1.0.0 (2024-01-01)

Changed

• Initial release for RBA Code of Conduct 8.0: Comprehensive criterion establishing requirements for identifying, assessing, and mitigating worker exposure to health and safety hazards using the Hierarchy of Controls.

• PPE compliance thresholds: Added quantitative thresholds for PPE compliance findings: >20% non-compliance = Priority, >5% = Major, >0% = Minor.

Added

• Gender-responsive OHS measures: Added explicit requirements for pregnant women and nursing mothers, including workplace accommodations and hazard exposure restrictions.

• Hierarchy of Controls framework: Formalized the five-tier Hierarchy of Controls (elimination, substitution, engineering, administrative, PPE) as the required approach for hazard mitigation.