1. W. A. L. K. Internal Responsibility System Workplace - Action - Learn - Knowledge

2. 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

3. Agenda Accident Theory Model 5 steps Accident Analysis Effective Theory Model of IRS Defining IRS First for IRS in legislation Everyone's Responsibility Wrap Up 7/7/21 Welcome

4. Where does the “IRS” Come from? Though the ideacomes 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. 1 7/7/21 Eric LeFort , CRSP

5. Accident Theory Model . If thepeoplein a managed system areidentified,andas 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 Eric LeFort , CRSP 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.

6. People and the IRS If the people in a managed system areidentified,asyou work through the accident analysis, you can see the structure of the IRS forming. 7/7/21 Eric LeFort , CRSP 3 5 Step Accident Causation Analysis IRS

7. 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 Eric LeFort , CRSP 4 Step 1 - Accident Causation Analysis 1 IRS

8. 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? ) 7/7/21 Eric LeFort , CRSP 5 Step 2 - Accident Causation Analysis 2 IRS

9. 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? ) 7/7/21 Eric LeFort , CRSP 6 Step 3 - Accident Causation Analysis 3 IRS 3

10. Steps in cause analysis 7/7/21 Eric LeFort , CRSP 7 Step 4 - Accident Causation Analysis 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? ) 4 IRS

11. Steps in cause analysis 7/7/21 Eric LeFort , CRSP 8 Step 5 - Accident Causation Analysis 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 5Leadership

12. 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 Eric LeFort , CRSP 9

13. 7/7/21 Eric LeFort , CRSP Quiz yourselves on the Accident theory 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?

14. 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 Eric LeFort , CRSP 11

15. Anything else which may influence the effectiveness of the IRS? 7/7/21 Eric LeFort , CRSP 12

16. 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. 13 7/7/21 Eric LeFort , CRSP

17. Management & Staff Engagement It is absolutely clear that for an organization to perform optimally, it is the hearts and minds of the individualpeople throughout the organization that have to be engaged. 14 7/7/21 Eric LeFort , CRSP

18. I.R.S. Defined I - Internal R - Responsibility S - System 7/7/21 Eric LeFort , CRSP 15 It Is Not Rocket Science

19. 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. 16 7/7/21 Eric LeFort , CRSP

20. 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 yourcurrent situation -- the health ofyour IRS -- and then move forward with improvements, with the true model of the IRS in mind. 17 7/7/21 Eric LeFort , CRSP Company Legal Charter

21. IRS is an Important Set of Ideas The IRS is such an important set of ideas that it is properly the responsibilityof the most senior people to see to it that the IRS is optimized. Monitoring and fixing the IRS should be of high priority. However, goodleadershipis the most important idea of all. 7/7/21 Eric LeFort , CRSP 18

22. 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” . 19 7/7/21 Eric LeFort , CRSP

23. 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 Eric LeFort , CRSP 20

24. IRS or Not! Whether they call it the IRS or not, the best performers have found that a system of universal,but personal, responsibilityis 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 Eric LeFort , CRSP 21 Why Re-Invent The Wheel?

25. Break Down - Plain Language Meaning of I.R.S 7/7/21 Eric LeFort , CRSP 22

26. 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 tothe workplace. The second meaning of “Internal" is that responsibility for health and safety is internal tothe work, internal to the job. 23 7/7/21 Eric LeFort , CRSP

27. 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. 24 7/7/21 Eric LeFort , CRSP

28. 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 devicesthat 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, butwhich can be very serious. 25 7/7/21 Eric LeFort , CRSP

29. 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 Eric LeFort , CRSP 26

30. “Ham Royal Commission” Report defines IRS Table setting out the organizational structure of a mining company. 7/7/21 Eric LeFort , CRSP 27

31. 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 Eric LeFort , CRSP 28

32. 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. Therights and responsibilities of the “worker” or employees were also discussed. 7/7/21 Eric LeFort , CRSP 29

33. 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 Eric LeFort , CRSP 30

34. 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 Eric LeFort , CRSP 31

35. 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 Eric LeFort , CRSP 32

36. 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 Eric LeFort , CRSP 33

37. 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 Eric LeFort , CRSP 34

38. “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. 7/7/21 Eric LeFort , CRSP 35 NS OHS Act 1996

39. IRS Defined “The NS OHS Act” s. 2 The foundation of this Act is the Internal Responsibility System which; is based on the principle that (i) employers, contractors, constructors, employees and self-employed persons at a workplace, and 7/7/21 Eric LeFort , CRSP 36

40. NS IRS Definition Continued … 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 Eric LeFort , CRSP 37

41. NS IRS Definition Continued (b) assumes that the primary responsibility for creating and maintaining a safe and healthy workplaceshould be that of each of these parties, to the extent of each party's authority and ability to do so; 7/7/21 Eric LeFort , CRSP 38

42. NS IRS Definition Continued (c) includes a frameworkforparticipation, 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 Eric LeFort , CRSP 39 Right to Know Right to Participate Right to Refuse Right to complain

43. NS IRS Definition Continued 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 clarifythe responsibilitiesof 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. OHS Division Regulator Support providing clarity 7/7/21 40 Eric LeFort , CRSP

44. 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. 7/7/21 Eric LeFort , CRSP 41

45. 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 Eric LeFort , CRSP 42

46. Review IRS Everyone's Responsibility 7/7/21 Eric LeFort , CRSP 43

47. 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 Eric LeFort , CRSP 44

48. 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 Eric LeFort , CRSP 45

49. 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” 7/7/21 Eric LeFort , CRSP 46

50. The IRS means that … 7/7/21 Eric 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”

51. 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” 7/7/21 Eric LeFort , CRSP 48

52. 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 Eric LeFort , CRSP 49

53. 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 Eric LeFort , CRSP 50

54. 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 Eric LeFort , CRSP 51

55. Wrong IRS Description Labourand 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 Eric LeFort , CRSP 52

56. 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 Eric LeFort , CRSP 53

57. 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 7/7/21 Eric LeFort , CRSP 54

58. 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 Eric LeFort , CRSP 55

59. 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 Eric LeFort , CRSP 56

60. Proactive vs Reactive A well functioning IRS System goes a long way to establishing DueDiligence and Ensuring for Total Quality within and Organization. 7/7/21 Eric LeFort , CRSP 57

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