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Is it HR's job to manage OH&S?

(This is the second in a four-part series on OHS and the HR professional)

September 10 2013 - The simple fact is that, in many organizations, Occupational Health and Safety (OH&S) has become a Human Resources (HR) responsibility. In an era where corporate social responsibility has grown to come to include health and safety, how can HR fulfill its role in building an effective OH&S system?

Some organizations, which may have come late to the realization of the importance of OH&S, are defining it as an HR responsibility rather than creating a separate OH&S structure within the organization. The OHS field is vast and to effectively manage the risk within organizations, you need the expertise on board to do it! In this article we will be reviewing the OHS program administration requirements.

OHS Program Administration Requirements

By Heinrich Beukes, B-Tech, CRSP

HR professionals who find themselves responsible for health and safety need to know the basic administrative requirements for both legislative and regulatory compliance. A thorough understanding of what is required is also needed in order to effectively manage and operate an occupational health and safety management system.

Any OHS management system must be effectively administered to ensure that the program operates efficiently and has a permanent goal of continuous improvement. Several safety management systems standards such as OHSAS 18001, CSA Z1000 and OSSE require a formal approach to OHS program administration.

In addition, the WorkSafeBC Occupational Health & Safety Regulation (OHSR) Part 3.3 (f) requires "The maintenance of records and statistics, including reports of inspections and incident investigations, with provision for making this information available to the joint committee or worker health and safety representative."

Effective administration of the OHS program requires compliance with three fundamental components.

These are:

  1. Annual health and safety goals and objectives aligned with the organization's business plan
  2. A management process for health and safety documentation
    • Readily accessible OHS program manual
    • Date, version number and signature on all documentation
    • Tracking process to identify document changes and notify all users in organization
    • Scheduled review of OHS program
    • Legally required documentation present and/or retained for required period of time
  3. Annual evaluation of OHS management system to appraise effectiveness
    • Quarterly update to ensure regulatory changes are identified and communicated
    • Quarterly health and safety activity summary
    • Quarterly statistical report on incidents and analysis of information to identify trends
    • Appropriate corrective action based on identified trends
    • A process to ensure identified corrective action is implemented
OHS Record Keeping Requirements

The OHSR specifies retention period requirements for certain documentation but, for the majority of health and safety documentation it is left to the employer to determine how long to retain documents.

Examples of these requirements include:

  • First aid records are required by OHSR 3.19(2) to be retained for three years and, because they contain personal information, they must be kept confidential.
  • Joint Health and Safety Committee Minutes are required by the Workers Compensation Act, Part 3, Division 4, Section 137(2) (b) to be retained for two years from the date of the meeting.
  • In regards to hazardous substances, the OHSR 5.59(3) requires that investigation reports into symptoms of potential worker overexposure must be made available to workers and must be kept for a minimum of ten years.

The best way for an employer to establish a due diligence defence is proper documentation and record keeping. This can be effectively achieved by a well-structured and integrated OHS program administration system.

For further information on development or implementation your OH&S system, please contact your regional Safety Advisor via our web site,


Web sites:

FIOSA-MIOSA's OSSE Large Employer Audit tool:

Canadian Centre for Occupational Health and Safety - OH&S Answers:

WorkSafeBC OH&SR Part 3 Rights and Responsibilities

About the author

Heinrich Beukes

Heinrich Beukes CRSP, FIOSA-MIOSA Safety Alliance of BC
Director of Services and Resources

Heinrich was born and raised in South Africa. He obtained a National Diploma in Public Health in 1992 and a Bachelors degree in Environmental Health from the Cape Peninsula University of Technology in 1995.

He worked for one of the largest transportation companies in the world - Transnet Ltd. as a Risk Professional. He immigrated to Canada in 2001 and worked as a Regional Safety Consultant for the Ontario Safety Association for Community and Healthcare until 2006. He then accepted the position of Health and Safety Manager at the Molson Vancouver Brewery.

Heinrich has more than 15 years of experience in Safety Management, Occupational Hygiene and Environmental Management. He specializes in program auditing and safety management system development as well as program implementation. He has several national and international accreditations and holds a CRSP designation and is a CSSE member. He has written several published technical Health and Safety articles for the Healthcare Industry and worked on various provincial initiatives with the WSIB and the Ministry of Labour in Ontario.

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