Information

Introduction Russel Metals Inc. continually strives to provide leadership for employees through progressive health and safety practices. We accomplish this through education, training and awareness. The results of these initiatives have created an environment where all employees, supervisors and managers take accountability for their individual health and safety as well as the health and safety of co-workers, contractors, visitors and suppliers. This audit and its findings are based on the Ontario Occupational Health and Safety Act and Regulations, Canadian Labour Code, Canadian Centre of Occupational Health and Safety resources, WHMIS, Ontario Fire Code, Ontario Building Code, CSA Z462 Workplace Electrical Safety, CSA Z460 Control of Hazardous Energy, Canadian Electrical Code, CSA B244.1 Steel Storage Racks, CSA B167 Overhead Cranes, CSA B335-04 Lifting Devices, ANSI Z136-2000 Safe Operation of Lasers, CSA Z142 M90 Press and Brake Press Operation, CSA Z432 2004 Safeguarding of Machinery and all or any other regulations, standards or codes identified during the audit process. The implementation of this audit has been based on the Workplace Safety and Insurance Board Compliance Workwell Audit and the International Safety Rating System using the following: "D" Documentation - the auditor will review copies of the company safety program documentation. Documentation may include rules, procedures, inspection forms, incident reports, training records and meeting minutes. "O" Observation - Inspection. Observation informs the auditor about how well the safety program standards are bing implemented. Observations may include notice boards, labels, signs, work activity, machinery, operation, orderliness or use of personal protective equipment or clothing. "I" Interview - Workforce. The auditor will discuss the entire evaluation process with management and the workforce representative. During the site inspection, the auditor will interview workers to confirm safety practices and knowledge. Management terms such as senior manager, senior management, middle management, operation/branch/unit managers, front-line supervisors, Joint Health and Safety committee members or representatives and safety coordinator/manager will be established prior to the audit and used consistently throughout the audit. These terms will reflect the management position at the audited location only, and not management positions outside the audited facility. Should you have any questions regarding the content of the health and safety program, please contact Sharon Lee at 905-816-6172 or slee@russelmetals.com.

Facility Profile Facility Name: Address: Phone Number: Group: President: General Manager: Branch Manager: Plant Manager: Safety Manager: Date plant opened: Approximate Size: sq. ft. Approximate Number of Employees: Number of Shifts operating: Days per week: Product Description: Customers: Designations: (ISO etc.)

Designated Substances 1. Acrylonitrile - Ont. Reg. 835 2. Arsenic - Ont. Reg. 836 3. Asbestos - Ont. Reg. 278/05 4. Benzene - Ont. Reg. 839 5. Coke Oven Emissions - Ont. Reg. 840 6. Ethylene Oxide - Ont. Reg. 841 7. Isocyanates - Ont. Reg. 842 8. Lead - Ont. Reg. 843 9. Mercury - Ont. Reg. 844 10. Silica - Ont. Reg. 845 11. Vinyl Chloride - Ont. Reg. 846

Document Checklist One year of documentation will be required 1. Provide a facility map with the following information: Current layout of equipment/processes Location of all pits, tunnels, overhead cranes, forklifts, propane storage, AST's and UST's, including size, contents and installation date. 2. Copy of OH&S policy and procedures 3. Copy of Emergency Response Plan including emergency contact list and date of most recent evacuation drill documentation. 4. Copy of spill response plan. 5. OH&S training matrix, training records etc.. 6. Copies of all visits by property managers, compliance visits/orders, regulatory inspectors or visits, notice of violations, complaints etc. 7. Copies of previous OH&S Audits 8. Copy of most recent Action Plan. 9. Copies of preventative maintenance programs. 10. Copies of most recent monitoring, noise, air etc. 11. Copy of Job Hazard Analysis. 12. Copy of PPE assessment. 13. Copies of formal employee complaints, suggestions, etc. 14. Copies of contractors liability insurance certificates. 15. Copies of Health and Safety meeting minutes. 16. Copies of review and analysis of injury/illness. 17. Copy of certificate for Laser Safety Officer. 18. List of chemicals used in the facility. 19. LIst of all employees. 20. List of all contractors. 21. List of any changes since the last inspection, i.e. new equipment, removed equipment, process modifications etc. 22. Documentation and finds of self audit conducted.

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TAB 1 Profile Health and Safety policy Russel Metals Inc. continually strives to provide leadership for employees through progressive health and safety practices. We accomplish this through education, training and awareness. The results of these initiatives have created an environment where all employees, supervisors and managers take accountability for their individual health and safety as well as the health and safety of the co-workers, contractors and visitors. The Health and Safety Corporate Policy Manual is reviewed annually and will be updated where necessary. The Health and Safety policies posted on this page are applicable to all employees of Russel Metals Inc. Should you have any questions regarding the contents of the Health & Safety program, please contact Sharon Lee at 905-816-5172 or slee@russelmetals.com .

TAB 2 HSMS 1.0 Self Audit

  • HSMS 1.0 (a)<br>A self audit has been conducted by the branch at least three months prior to this formal audit.<br>The branch shall establish and maintain an annual audit program and procedures for periodic OH&S management system audits, to be carried out in order:<br>1. Determine the OH&S management system <br> (a) conforms to planned arrangements for OH&S management including the requirements of OHS applicable standards;<br> (b) has been properly implemented and maintained; and<br> (c) is effective in meeting the organization's policy and objectives.<br>2. Review the results of previous audits.<br>3. Provide information on the results of audits to the senior management team. The audit program including any schedule, shall be based on the results of risk assessments of the branch's activities, and the results previous audits. <br><br>The audit procedures shall cover the scope, frequency, methodologies and competences, as well as the responsibilities and requirements for conducting the audits and reporting results. Whenever possible, audits shall be conducted by personnel independent of those having direct responsibility for the activity being examined.<br>NOTE: the word independent does not necessarily mean external to the company.<br><br>SELF AUDIT SCORE: %<br>

  • HSMS 1.0 (b) <br>An audit action plan was developed and documented within 30 days of completion of the self-audit

  • HSMS 1.0 (c)<br>Previous corporate audit recommendations are closed and maintained?<br>Number completed and maintained #<br>Number of recommendations #<br>Percent completed %

  • HSMS 1.0 (d)<br>The materials needed for the audit completion are ready at the time of the audit?

  • HSMS 1.0 (e)<br>The last audit action plan submitted to Russel Metals Inc. Corporate Health and Safety Manager is within 30 days of the audit.<br>Section score reduced by 25% if the 30 day target is missed.

HSMS 4.15 Lost Time Accident Performance Index Only one point will be selected

  • HSMS 4.15 (a)<br>Reduced Lost time for the Past 3 years.<br>Facility has reduced their lost time accidents, for the last three or more calendar years, (including the audit year). If this element is "Yes", all other elements in 4.15 are to be scored "N/A"

  • HSMS 4.15 (b)<br>Reduced Lost time for the Past 2 years.<br>Facility has reduced their lost time accidents, for the last two calendar years, (including the audit year). If this element is "Yes", all other elements in 4.15 are to be scored "N/A"

  • HSMS 4.15 (c)<br>Reduced Lost time for the audit year.<br>Facility has reduced their lost time accidents, for the past 12 months. If this element is "Yes", all other elements in 4.15 are to be scored "N/A"

  • HSMS 4.15 (d)<br>The facility does not track lost time accidents. If this element is "Yes", all other elements in 4.15 are to be scored "N/A".

TAB 4 HSMS 1.1 The employer has defined, written standards and procedures in use for:

  • HSMS 1.1 (a)<br>Management commitment to the prevention of occupational illness and injury. OHSA 25 2(j)<br>The policy statement is a legislated requirement under the Occupational Health and Safety Act. THe auditor will confirm the following:<br>1. The policy statement shall include and address through continual improvement, the commitment by management for the prevention of occupational illness and injury, and to at least comply with current applicable OH&S legislation and with other requirements to which the branch subscribes. <br>2. The policy statement should include a statement addressing "the maintenance of a safe and healthy work environment", and that contractors meet or exceed the branch's safety requirements.<br>3. A statement of responsibility to implement and maintain a safe and health work environment.<br>4. A statement of responsibility of supervisors to ensure that safe and healthy work conditions are maintained in their assigned work area.<br>5. A statement of responsibility of workers to work in accordance with all legislated standards and employer safe work procedures/practices, report all unsafe and unhealthy conditions.<br>6. The copy must be posted in a common area and reviewed annually to ensure that it remains relevant and appropriate to the company.<br>7. The copy is signed by the President and CEO of the company, as well as the branch manager.

  • HSMS 1.1 (j) Distributed to employees<br>OSHA Part III Sec. 25-26<br>There are many different ways to distribute the policy statement, such as employee pay cheques, handbooks, training sessions, group or tail gate meetings. The health and safety policy should be comunicated and distributed annually to all employees.

  • HSMS 1.1 (k) Understood by employees<br>The auditor will randomly select employees to be interviewed to determine their understanding of the policy statement. The employees should know of the policy, locations posted, responsibilities, etc.

  • HSMS 1.4 (e) (1) Safety manuals<br>Safety manuals are available to all management and supervisory personnel. These employees are trained on the content and use of the manuals. The manual is reviewed annually with new or rvised dates.

TAB 5 HSMS 1.3 Posted Health and Safety material. The following documents are available at the workplace. Posters shall be in an area frequently vissted by employees (i.e. hallway, time clock, poster area of lunchroom). These posters listed are not defaced, or covered. The posters are up to date.

  • HSMS 1.3 (a) Occupational Health and Safety Act<br>The act must be posted in a high traffic area (worker entrance, time clock etc.) and accessible to all workers. The act and any explanatory material prepared by the Ministry must be readily available to employees, in printed or electronic form. The posted information must be both in English and the majority language of the workplace.

  • HSMS 1.3 (b)(c) Appropriate Regulation(s)<br>All other regulations that apply to the workplace must be posed in a high traffic area. The regulation must be readily available to employees in printed or electronic form.

  • HSMA 1.3 (d) 2.7 (d) Designated Substances<br>The applicable designated regulation must be posted in a high area (worker entrance, near time clock, bulletin board) and accessible to all workers in printed or electronic form. If applicable a written standard (exposure control plan) and procedures should be included. All employees who are likely to inhale, ingest and absorb are covered by the Regulation(s) and must be trained. The training identifies the hazards as well as proper hygiene practices and personal protective equipment requirements. The employees are aware of the designated substance(s) and the applicable regulations. If a control program is required then the employer must develop a training program for supervisors and workers on: the health effects; the measures and procedures required under the designated substance program; evaluate the training and maintain records of training.<br>

  • HSMS 1.3 (e); 2.7 (d) Material Safety Data Sheets (MSDS)<br>An inventory of all MSDS is available for all controlled products in the workplace and is no more than 3 years old. The MSDSs must be accessible to all workers. Every unexpired material safety data sheet is made available by the employer in the workplace in such a manner as to allow examination by the workers. MSDSs are available to all employees 24 hours per day. MSDS books contain a current list of chemicals used. The books are net, clean and easy to read. MSDS books are indexed so that a particular MSDS will be easy to find. WHMIS training for employees shall consist of: generic and workplace specific; process to review the training program; assign responsibility; established schedule; evaluation of the training and records of training.

  • HSMS 1.3 (g) First Aid Poster<br>The first aid station must contain the poster required by the WSIB. The employer shall at all time keep the poster posted in other conspicuous places. First aid regulations must be available at the first aid station and is adequately supplied to render first aid treatment.

  • HSMS 1.3 (f) (k) Occupational Health and Safety explanatory material.<br>This refers to the Guide of the Occupational Health and Safety Act. The guide must be posted in a high traffic area (worker entrance, near time clock, bulletin board) and must be readily available to employees. The employer shall make available regulations, standards and codes applicable to the facilities activities: (e.g. traffic control, laser, safety rules and transportation of dangerous goods). A copy of the regulations that apply to the workplace shall be in printed or electronic form. A risk assessment should be completed to ensure that all codes, regulations and standards are available.

  • HSMS 1.3 (i) Emergency Services and Numbers<br>Emergency numbers must be posted at primary telephones throughout the branch including the office area.Emergency numbers must include: 911 (if available); and the telephone numbers of fire, police, ambulance, OHSA Inspectors, utilities, poison control and internal contact numbers.

  • HSMS 1.3 (j) Reports<br>The employer shall post the following reports in a conspicuous and accessible workplace location; workplace health and safety inspections, JHSC meeting minutes; health and safety assessments / survey, OHSA inspector orders and reports, monthly safety statistics.

  • HSMS 1.3 (p) Safety rules<br>The facility has safety rules posted for; facilities general rules and equipment specific.

  • HSMS 1.3 (o) Emergency Evacuation Plan<br>The use of floor plans or workplace maps that clearly show the emergency escape routes and safe or refuge areas. These are posted throughout the facility. Floor plans are oriented correctly to their location.

TAB 6 Duties and Responsibilities. Health and Safety responsibilities are defined, written and communicated.

  • HSMS 1.2 (a)<br>Managers responsibilities and accountabilities.<br>Documentation outlining the legislated duties for facilities that incorporates their responsibilities as outlined in the Occupational Health and Safety Act. Documented evidence of responsibilities being formally communicated to managers is required. Measurable responsibilities are defined for management to ensure the performance of the following activities: workplace inspections, information sessions (safety talks, staff meetings, tail gate meetings), incident investigations, worker training, correcting substandard acts or conditions, commending worker and supervisor health and safety performance, appoint competent supervisors etc. Responsibilities being formally communicated to managers is required. Performance evaluations are required. The system must be formalized, measures each responsibility defined for 2.1 (a) and performed at least annually. Evidence that the system recognizes and commends accomplishments and contributions, identifies opportunities for improvement, and reinforces the employer's expectation that all managers maintain a healthy and safe operation should also be included and evaluated.

  • HSMS 2.7 (a) Applicable Legislation<br>The employer shall ensure employees receive training in the following: legislative health and safety responsibilities, policies and procedures, the right to refuse unsafe work, right to participate (JHSC and health and safety representative), early and safe return to work obligations and workplace violence and harassment policy etc. Records of training shall be reviewed and training records updated accordingly.

  • HSMS 1.2 (b) Supervisors responsibilities and accountabilities<br>Documentation outlining legislated duties for supervisors that incorporated their responsibilities as outlined in the Occupational Health and Safety Act. Documented efficient of responsibilities being formally communicated to all supervisors is required. Safety performance is specifically defined as measurable responsibilities and incorporated into each supervisor's written job description. Evidence that supervisors' are required to follow all health and safety rules. Evidence that supervisors do disciplinary action when safety infractions are made. Measurable responsibilities are defined for supervisors to ensure the performance of the following activities: workplace inspections, information sessions (safety talks, staff meetings, tail gate meetings), incident investigations, worker training, correcting substandard acts or conditions, commending worker health and safety performance etc. Responsibilities being formally communicated to supervisors is required. The standard should clearly describe what they are expected to do and how it should be done. Performance evaluations are required. The system must be formalized, measures each responsibility defined for 2.1 (c) and performed at least annually. Evidence that the system recognizes and commends accomplishments and contributions, identifies opportunities for improvement and reinforces the employer's expectation that all supervisors maintain a health and safe operation.

  • HSMS 2.7 (q) Supervisor Competency training relating to health and safety.<br>Certificates or other proof is acceptable. Training would entail accident investigation, health, safety and the law, hazard identification etc.

  • HSMS 1.2 (c) Workers<br>Documentation outlining legislated duties for employees that incorporates their responsibilities as outlined in the Occupation Health and Safety. Health and safety rules specific to the workplace must be communicated to all workers and supplied labour. Documented evidence of responsibilities being formally communicated to all is required. Supplied labour are individuals who are hired usually through a temporary employment agency. The facility must document duties for contract workers that include responsibilities. Documented evidence of responsibilities being formally communicated to all supplied labour by the facility and temporary agency is required. The system must be formalized and identify progressive discipline process and that the workers understand the consequences of health and safety violations.

  • HSMS 2.7 (f); 1.2 (d) New Worker Orientation<br>The employer shall ensure that training is provided to: newly hired workers, workers returning from an extended absence, workers hired on a contract basis, student workers and supplied labour workers. The employer shall assign responsibilities for orientation training and time frames for training. The components of the training shall include: health and safety policy, employee responsibilities and rules, standards/procedures for reporting injury/illness, hazards, emergency response, early and safe return to work, JHSC worker health and safety representative activities, refusal to work, workplace violence and harassment. A workplace tour is required which shall include: introduction to the JHSC worker/representative, emergency equipment, exits, first aid stations etc. The employer shall ensure that the training is evaluated and training records are maintained.

  • HSMS 2.7 (g) (h) Job Specific Orientation<br>Training is required for workers who are newly hired, returning from an extended absence, hired on a contract basis, students, from a supplied labour firm, transferred from one job to the other. The requirements of the training program shall be defined which includes: review of assigned job activities, operating instruction for equipment/process, hazards and controls, safe operating procedures/safe work instructions, a time frame for training and a qualified person to deliver the training. The program shall evaluate the training and maintain records of training.

  • HSMS 1.2 (e) Contractors/Subcontractors<br>The written standards must include responsibilities that addresses health and safety of workers, provide qualified workers for work performance, ensure all work performed is in accordance with governing legislation/regulation/industry standards. Evidence the the health and safety rules specific to the workplace and emergency response procedures have been formally communicated to all contractors and sub-contractors. The written standards must include responsibilities that address a formal system (e.g. performance rating system, contract incentives, removal from the workplace, audits, inspections etc.) Evidence to prove that it has been communicated to all contractor workers, consequences of unsafe behavior and a policy or procedure on violation is required.<br>BEST PRACTICE<br>Contractors are external service providers for maintenance, service or project contracts. The facility must document responsibilities for external service providers performing work at the facility. Documented evidence of responsibilities with the facility health and safety rules being formally communicated to all external service providers (contractors) is required.

  • HSMS 1..4 (o), (p); 1.2 (f)<br>Contractors/Subcontractors Activities<br>In order to ensure that contractors (external service providers) maintain a safe work environment while performing work for your facility, written standards and procedures should include but not be limited to: procedures for the selection of contractors (e.g. past safety performance, requesting and reviewing of safety program, policies, competencies of workers, responsibility of contractor's whole on the premises, actions to ensure the contractor understands the hazards at the workplace, actions to ensure contractor's know and understand the facilities policy and procedures etc.) Is a safety orientation given to each contractor before starting work? Contractors inform the facility about chemicals that may be used in the workplace.

  • HSMS 1.4 (p)(1)<br>Certificates of Insurance<br>BEST PRACTICE<br>Insurance certificates are up to date with one for each contractor on site and contain appropriate coverage amounts for auto and general liability.

  • HSMS 1.2 (h) <br>General Public<br>BEST PRACTICE:<br>The facility should have documented responsibilities to ensure safety of the general public and or customers. This element may be applicable if: <br> The public attends tours of the facility<br> Retail areas<br> Service counters<br> Pick-up and receiving from members of the general public.<br>The responsibilities for the general public should be communicated to all staff.

  • HSMS 2.7 (m) (1-3) <br>Personal Protective Equipment<br>Equipment specific training is required for: proper fit, inspection, maintenance and replacement, equipment use and limitations. The program shall define the time frames for training completion, assigned responsibilities for training delivery. The program shall evaluate the training and maintain records of training. An analysis should be completed to capture all PPE required.

  • HSMS 2.7 (r) <br>Other<br>Other training may include: pesticide use, transportation of dangerous goods, traffic control etc. The program shall indicate time frames for completion, assigned responsibilities for training delivery, evaluation of the training and maintain records of training.

TAB 7 Electrical Safety

  • HSMS 2.6 (a)<br>Electrical cords, plugs and sockets are in good condition<br>Electrical cords and plugs appear to be in good condition, are not over-loaded, do not have exposed contacts or conductors, do not have pig-tailed connections, do not have splits or repaired with tape.

  • HSMS 2.6 (b)<br>Electrical extension cords.<br>Extension cords are not used for permanent wiring.

  • HSMS 2.6 (c)<br>Electrical hand tools<br>Electrical hand tools are regularly inspected, maintained and in good working order.

  • HSMS 2.6 (d) (g)<br>Cord-connected electric equipment and portable tools.<br>Cord-connected electric equipment, electric hand and portable power tools must have proper grounding or double insulation protection. (CFGI) are used when in wet locations or outdoors, portable electrical tools are protected with ground fault circuit interrupters. A process is in place to investigate and correct any ground fault.<br>

  • HSMS 2.6 (e)<br>Insulating material and conducts are certified.<br>All electrical equipment, insulating material and conductors must be certified by the CSA or Electrical Safety Authority in the area of jurisdiction.

  • HSMS 2.6 (f) Entrances to electrical rooms<br>Entrances to rooms or enclosures containing exposed, live electrical components has a sign warning of the danger and prohibiting unauthorized entry.

  • HSMS 2.6 (h)<br>Power Lines<br>If applicable, a procedure is in place and communicated (e.g. signage) to ensure clearance is maintained from live power lines in accordance with OSHA<br>

  • HSMS 2.6 (i)<br>Electrical Safety Training<br>Identified employees receive electrical safety training at regular intervals. Employee's are trained in safe work practices, procedures and other requirements necessary for the safety. <br>(Millwright)

  • HSMS 2.6 (j)<br>Infrared Inspections<br>As a minimum, transformers and buses scanned annually with infrared thermometers. Results documented.

  • HSMS 3.4 (q)<br>Electrical maintenance logs<br>Logs (electronic or hardcopy) electrical maintenance is maintained in accordance with the Electrical Safety Code.

TAB 8 Emergency Planning

  • HSMS 1.4 (w)<br>Workplace Violence<br>This is a legislative requirement.<br>The facility must implement a program, policy and procedure outlining the responsibilities of all employees as well as: completing a risk analysis and identifying situations that are associated with identified risks, provide all interested parties with a copy of the results of the risk analysis, include the risk associated with domestic violence, establish and maintain procedures related to the identified OH&S risks, provide a worker with information and instruction on the program, policy and procedure and when to call for assistance.

  • HSMS 4.13 (a) <br>Fire Extinguishers<br>Employees should not be allowed to use fire extinguishers if they have not been trained. The emergency plan should include instructions to employees. Employees have been trained and training is current.

  • HSMS 4.13 (b)<br>Emergency equipment<br>Is the fire equipment easy to access and not blocked? Are fire extinguishers hung on hooks in their proper place and are not left on floor? Are fire extinguishers located throughout the facility and the location is marked with an easy to read identification (pole painted red, large sign)? A review of other types of emergency equipment will take place to ensure it is available at the workplace (e.g. eyewash stations, deluge showers, fire alarms, sprinkler systems, carbon monoxide alarms, etc.)

  • HSMS 4.13 (c) Fire extinguishers inspected<br>Fire extinguishers are checked and documented at the source on a monthly basis.

  • HSMS 4.13 (d)<br>Hydrostatic Testing<br>Fire equipment must have hydrostatic testing documented every 12 years and must have a label that identifies the last testing.

  • HSMS 4.13 (e)<br>Sprinkler systems<br>Sprinkler systems are checked and documented annually. All valves are locked in the open position. No storage is allowed around the sprinkler system.

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