1. Environmental Health & Safety: Research Compliance Reviews PI Health & Safety Responsibilities
August 28, 2018
Environmental Health & Safety: Research Compliance Reviews and PI Health & Safety Responsibilities
The presentation will include a very introduction to EHS and the services offered. An overview of the EHS Research Compliance Review process will be presented – it is through this process that we ensure that research activities comply with all appropriate federal & provincial legislation and university policies & procedures. The presentation will include a short review of an PI’s responsibilities  and obligations with respect to health & safety.
Pietro Gasparrini, CIH
Director, Environmental Health & Safety

2. Environmental Health & Safety
Environmental Health & Safety supports the academic, research and operational activities of the University and promotes a safe, healthy and sustainable campus environment by managing and coordinating programs and services that minimize health, safety, environmental and regulatory risks.
Prevention
Industrial Hygiene
Laboratory Safety
Sustainability
Who is EHS and what do we do?
Staff of 16:
13 safety professional and technicians & 3 Sustainability

3. Concordia’s Safety Policies
VPS-40 Environmental Health and Safety Policy
VPS-6 Policy on Working Outside The Hours of Operation or in Isolation
VPS-41 Policy on Personal Protective Equipment
VPS-42 Policy on Injury Reporting and Investigation
VPS-43 Return to Work & Temporary Work Assignment Policy
VPS-46 Radiation Safety Policy
VPS-47 Policy for the Management of Hazardous Materials
VPS-51 Laser Safety Policy
VPS-52 Biosafety Policy
VPS-54 Magnetic Field Safety Policy

4. Recent Regulatory Changes
Drone/UAV - Transport Canada (March 2017)
Control of Hazardous Energy Regulations (June 2016)
Transportation of Dangerous Goods (June 2015)
Human Pathogens and Toxins Act (Dec. 2015)
Workplace Hazardous Materials Information System - Hazardous Products Act & Regulations (Feb. 2015)
Lucky for us, regulations are constantly changing. It has been particularly busy the last couple of years. As a result, we revise our internal programs. When the regs change, they do impact us. The changes in the TDG regulations post the Lac Megnantic disaster requires much more information from labs disposing of hazardous waste – so much so that hazardous materials waste disposal training is now mandatory.
We try to keep up with research, which is not always that easy. A couple of years ago it was nanomaterials, which is still a challenge. Most recently we started worrying about UAV.
We make all attempts to know what is going on at the university, but that is extremely challenging. See us as a resource, if you are working in an area where there are no specific internal rules, let us know. Maybe we are not aware of your area of work…which is a potential problem. But, do not worry - sometimes, internal rules are not necessary. A good example is Controlled Substances – our internal procedure is, in a nutshell, let us know and we will help you with the paperwork.

5. Safety Programs - Research
Biosafety
Laboratory/Chemical Safety
Chemical Inventory
Nanomaterial Safety
Hazardous Waste Management
Transportation of Dangerous Goods
Controlled Goods
Controlled Substances
Laser Safety
Magnetic Field Safety
Radiation Safety
Control of Hazardous Energy
Machine Safety (Guarding)
Manuals:
Lab Safety
Biosafety
Radiation Safety
Laser Safety
SERVICES WE PROVIDE TO THE UNIVERSITY
EHS develop internal safety policy and procedures and;
Develop and manage risk-based safety programs
Involved in compliance reporting and;
Liaise with government agencies
Public Health Agency of Canada Canadian Nuclear Safety Commission
Commission de la santé et de la sécurité du travail (CSST) Ville de Montréal
Inspected by government agencies annually
1- We have risk-based safety programs:
2- Legislation changes constantly for example:
Transportation of Dangerous Goods (June 2015) Human Pathogens and Toxins Act (Dec. 2015)
Hazardous Products Act & Regulations (Feb. 2015) Workplace Hazardous Materials Information System (WHMIS )
3 - Before you panic, we keep up and update internal programs/manuals so you do not have to, but you need to read our communications. Newsletter in Fall 2017 and a new page dedicated to researchers.

6. Safety Rights & Responsibilities
Everyone has a basic right and responsibility to themselves and others to work in an environment which is safe
Everyone, no matter their position, is expected to take initiatives on health and safety issues and to work to solve problems and make continuous improvements in the workplace
Safety is a shared responsibility (VPS-40)
Now I would like to review with you health and safety responsibilities. Generally speaking, YES the responsibility is shared but employers/supervisors do have more responsibilities.

7. Supervisor’s responsibility
A Supervisor is any individual who has direct supervision of and responsibility for the activities of an employee or student
Must be able to demonstrate that you did everything reasonable to protect the health, safety and well-being of your staff and students - DUE DILIGENCE
Supervisors are personally liable and can be held criminally responsible (negligent) with regards to the safety of employees, students and visitors.
Supervisor’s Health & Safety Responsibilities Training – new required training (1.5 hours)
SGW October 16, 2018 & February 19, 2019
LOYOLA October 19, & February 22, 2019
As supervisor/employer you have added responsibilities. These responsibilities are partly due to provincial and federal legislations.
The objective of the Quebec Act is the elimination, at the source, of dangers to the health, safety and physical well-being of workers.
To accomplish this, the act identifies responsibilities of employer, supervisors and employees
At Concordia, who is the EMPLOYER? As the PI, you carry these responsibilities.
Where employee includes everyone under your supervision. The law sees volunteers as employees because they complete work that would otherwise be paid.
The supervisor’s main responsibility in neatly summarized in the following statement: The hardest part of demonstrating due diligence is in proving it. We provide tools to help you with that.
Our role is not to take your responsibility but we help you fulfill your role as supervisor.
When you do that overall risk is better managed university wide and compliance is improved.
At the federal level Criminal Code was amended as a result of the Westray Mine disaster that occurred in May, 2002, causing the death of 26 miners in N.S.
As a result, Canada has had one of the most strict criminal laws relating to workplace health and safety in the Western world.
The Canadian Criminal Code now includes a legal duty regarding health and safety.
217.1 “Everyone who undertakes, or has the authority, to direct how another person does work or performs a task is under a legal duty to take reasonable steps to prevent bodily harm to that person, or any other person, arising from that work or task.”
Act Respecting Occupational Health and Safety (L.R.Q., c. S-2.1)
Criminal Code of Canada

8. EHS Services & Support Safety Orientation & Training
Compliance Monitoring
Job Hazards Analysis
Exposure & Risk Assessments
NEW 3D Printer
SOP Reviews
Safety Awareness Campaigns
Our DB can be used to document orientations and training completed at the local level, as long as our form is used.
One-on-One Orientation
Understand your research/academic activities
Review of relevant safety policies
Internal & external permit requirements
Safety training requirements

9. Safety Orientation & Training
One-on-One Faculty/PI Orientation
Review of relevant safety policies
Internal & external permit requirements
Safety training requirements
Safety orientation checklists (handout)
Training
Legislated and University imposed safety training provided by EHS (handout)
Develop training upon request
Recordkeeping
Supervisor’s Training Report
One-on-One Orientation for PIs
Started in Approx. 15 to date.
Normally the Compliance Review is done simultaneously.

10.
Mention where/how they can register.

11. Compliance Monitoring
Inspections
EHS Research Compliance Reviews
Injury/Near-Miss investigations
If non-compliance is identified, then
Corrective action
Non-compliance escalation
Freezing of accounts
Closing of labs
EHS monitors compliance – we do this internally in order to keep our community safe…and to avoid issues when external agencies come to audit or inspect.
We have several mechanisms…
And when we find a non-compliance issue, we take action – we start with informing the responsible supervisor and, if that fails, escalate up line management…we can also freeze accounts and close labs. However, EHS closing labs or stopping work is NOT where we want to be.
If EHS needs to take action, it means that Supervisors have failed. EHS staff have stopped IITS contractors in the Hall building, ordered contractors and employees off our roofs, threatened to seize radioactive materials. In some instances, when non-compliance issues have been escalated management has taken action and that is the way it should be.

12. EHS Research Compliance Review
Research compliance review application forms completed by the PI (with assistance from EHS)
Verification of valid training of PI and team members
We have put in place mechanisms and created tools to help ensure compliance:
EHS Research Compliance Review
One-on-One Orientation
Orientation Checklist
Supervisor Training Reports
Let’s start with the EHS Research Compliance Review, a joint process with the Office of Research.
The main way we ensure compliance. BEFORE
SERVICE TO YOU!
2014 – 20 completed
2015 – 22 completed
Verification of internal & external permit requirements
Provided to the Office of Research
Required for release of funds

13. Safety Campaigns

15. Reporting injuries and near misses
Injuries and near-misses must be reported to:
Supervisor
EHS
Submit a completed Injury (Accident) / Incident/ Illness/ Hazard Report form to Environmental Health & Safety within 24 hours
Hazards and dangerous situations which you cannot correct must be reported immediately to the appropriate person/unit:
Facilities Service Centre (2400)
Security (3717)
EHS (4877)
Mention where this form can be found.

16. Questions? www.concordia.ca/ehs ehs@concordia.ca Contact EHS
(514) ext. 4877
SGW Office
1455 de Maisonneuve W.
GM-1000 Montreal, QC, H3G 1M8
Loyola Office
7141 Sherbrooke St. W.
PS-201 Montreal, QC, H4B 1R6
Finally, call us. We are there to help.