The City recognizes that in any move, relocation or major renovation, interactions with joint health and safety committees (JHSCs)/ health and safety representatives (H&S Reps) are of significant importance in ensuring hazards are addressed.
Moves, relocations and major renovations, from an occupational health and safety perspective, may have detrimental and/or beneficial effects:
- detrimental from the perspective that new hazards can be introduced into a workplace, either while the work is being performed or through the design of the workplace relative to the work to be performed
- beneficial from the perspective that previously-identified health and safety hazards can be designed out or addressed in the new or newly-renovated facility
Meaningful consultation with JHSCs/ H&S Reps prior to work being performed and prior to occupancy/re-occupancy provides the opportunity to effectively address and eliminate health and safety hazards.
Management is responsible for ensuring that move/relocation/renovation work is performed safely and for the health and safety of the new, newly-renovated and/or newly-occupied work area. JHSCs/H&S Reps, based on their knowledge of work performed, may wish to make recommendations to address or prevent health and safety hazards, for consideration by management during the move/relocation/major renovation process.
Moves of employees to new locations may necessitate changes to a division's JHSC/H&S Rep structure, as follows:
- For divisions that operate under multi-site JHSC Terms of Reference, representation from the new location on existing JHSCs must be considered, with JHSC Terms of Reference amended, as required
- For divisions that have JHSCs or H&S Reps at each work location, depending on the number of employees who work at the location, a new JHSC or H&S Rep will be needed
- Transfer of an existing JHSC/H&S Rep to the new location
There are several phases in the types of projects referenced above, including pre-planning, design, development of contract documentation, tendering, the actual renovation work, preparation for occupancy of newly constructed/renovated area and occupancy. [See Milestones in Capital Project Moves, relocations and Major renovations procedures]. The responsibilities that follow are intended to ensure JHSCs/H&S Reps are consulted during:
- Conceptual design (early planning stage)
- Actual design
- Performance of construction/renovation work
- Preparation for occupancy, followed by occupancy
Management of divisions where moves/relocations/major renovations are to be undertaken will:
- Consider the health and safety implications of the move/relocation/renovation, including:
- health and safety hazards associated with current operations that may be addressed through the move/relocation/renovation
- efforts needed during the move/relocation/renovation to ensure that new health and safety hazards are not introduced
- the impact of the move/relocation/renovation on the division’s joint health and safety committee structure (i.e. whether the move/relocation/renovation will result in the need for a new JHSC/H&S Rep or amendments to the division’s/location’s terms of reference for the structure and function of joint health and safety committees)
- Consult with the JHSC(s)/H&S Rep(s) that represent employees who will be impacted by the move/relocation/renovation at appropriate stages in the work, including the following:
- Notify the JHSC(s)/H&S Rep(s) of planned moves/relocations/major renovations, including during the pre-planning stage when this is feasible. This notification provides JHSCs/H&S Reps the opportunity to identify any major health and safety concerns they wish to see addressed as the project proceeds and to make recommendations to that effect, if needed.
- Consult with JHSCs/H&S Reps before design/contract documents are finalized, seeking feedback regarding health, safety or ergonomics of renovated or new work environment. This process will enable concerns raised by the JHSC and verified by management to be incorporated into contract documentation.
- Share with JHSCs the results of environmental assessments, if such assessments identify potential health and safety hazards (e.g. the presence of asbestos or other designated substances) that may impact employees during or following the move/relocation/major renovation.
- During construction/renovation work, follow up with project managers (and through project managers, with contractors) if JHSCs/H&S Reps identify health and safety hazards associated with the work being undertaken.
- Obtain information regarding deficiencies from project managers prior to employee occupancy/re-occupancy. Share information regarding health and safety deficiencies and planned actions to address these remaining deficiencies with JHSCs/H&S Reps. Recognizing the sensitivity of the deficiency document in the project management process, it is understood that it is the pertinent health and safety information, not the actual list, that will be shared.
- Arrange for a workplace inspection by a worker JHSC member/H&S Rep prior to occupancy/re-occupancy of the work area where construction/renovation work was conducted (by an experienced JHSC member/H&S Rep, or by a new JHSC member/ H&S Rep accompanied by an experienced JHSC member or Rep from another location).
- Share the workplace inspection report completed by the JHSC/H&S Rep with the project manager, where appropriate (i.e. where deficiencies are noted that need to be addressed as part of the scope of the project work).
- Advise JHSCs/H&S Reps when health and safety deficiencies, identified through deficiency reports or workplace inspection reports, are addressed.
- If the work may affect employees represented by several JHSCs/H&S Reps and there is a divisional health and safety committee, the consultation process may be expedited through interaction with that committee.
- If the move/relocation/major renovation results in a legal requirement for a new JHSC/H&S Rep, contact the applicable bargaining unit(s) as soon as the new occupants of the location have been identified. A request for JHSC worker member(s)/H&S Rep and assignment of management JHSC member(s) should be undertaken in a timely manner, such that the JHSC/H&S Rep is in place when the location becomes occupied/reoccupied.
- Introduce other health and safety elements, as required by health and safety legislation and City policy, at the occupancy stage (e.g. qualified first aiders, fire wardens, health and safety bulletin board set-up, etc) and advise JHSC/H&S Rep.
[Note: While the purpose of this policy is to identify expected interactions with JHSCs/H&S Reps during moves, staff relocations and major renovations, efforts to ensure information is shared with workers affected by these situations can also positively benefit health and safety. Actions such as posting of design drawings and orientation of employees to new or newly-renovated work areas are encouraged].
Project management staff (Facilities Management or other) will:
- Provide management of divisions where moves/relocations/major renovations are undertaken with the necessary information regarding health and safety matters to enable effective communication with JHSCs/H&S Reps, as outlined above.
JHSCs/H&S Reps will:
- Consider the information provided by management with respect to moves/relocations/major renovations and make recommendations, as needed.
- Review information regarding deficiencies provided by management.
- Undertake a workplace inspection of the new or newly-renovated space prior to re-occupancy.
- Complete a workplace inspection report and provide it to the supervisor of the work location. Identity the priority for correction of any noted deficiencies, based on the seriousness of the identified hazard and the potential for worker injury.
- Communicate with workers they represent, in response to concerns raised with them, while the move/relocation/major renovation is underway.
- Respect the confidentiality of the information being provided during the consultation process, where the need for such confidentiality is identified.
- Understand that there are often time pressures in moves/relocations/major renovations and consider information received in a timely manner.
Health and safety staff will:
- Based on knowledge and expertise, identify to management any health and safety hazards of which they are aware that should be addressed prior to, during and following move/relocation/major renovation work.
- Assist all workplace parties previously identified, as needed, in meeting responsibilities outlined in this policy.