The necessity of I-CAB OHS assessments for an EPC organization arises from OHS legislation requiring any personnel in a leadership capacity to be competent and knowledgeable in the Act, Regulation, and Code as it relates to their work. Today’s businesses are being held to a more enforceable standard when it comes to ensuring representatives of the company are competent and knowledgeable in how the laws apply to their work. Whether you are a prime contractor, supplier, or service provider; it’s important that we understand how our decisions may affect the safety of the frontline worker. It’s easy to see the importance of frontline supervision having an understanding of health and safety legislation, but it’s sometimes more difficult to initially see how an engineering company/department, or supplier of materials being competent in the legislation would have an affect on a front line worker.
Large organizations such as energy or general contractors often fulfill the role of a prime contractor. As a prime contractor, legislation requires a system in place to ensure competency of our own workforce, and to ensure adherence to the legislation by our contractors, suppliers, and other service providers. EPC’s, sub-contractors, and suppliers all can have an impact on safety in the worksite, even when not on the worksite. Personnel participation is determined based on regulatory expectations for “leadership” with potential impact on the execution of work scope.
The term “professional engineer” is cited 134 times in various sections of the OH&S code. Engineers play a critical role in the safety for a project; from designing or calculating specifications on lifting lugs for a piece of equipment, and even the rise and run for a set of structural stairs. One could see how important it would be for an engineer to know the legislation as it pertains to a removable guardrail design. However, for everyone on the engineering side of an EPC to be in I-CAB assessments are not necessary. Engineers who should participate in I-CAB OHS assessments are those who are accountable for facility design aspects that are regulated by the OHS Code/CSA Standards. Examples include engineers designing facilities with safety items such as guardrails and staircases.
Leadership that is responsible for procuring goods, and services should be knowledgeable of their obligations under legislation. The equipment, tools, materials, and even PPE supplied to site, must meet legislative requirements. For example, deciding on what parts to order to meet regulatory requirements or what standards PPE must meet for the work being performed. Identifying contractors and suppliers that are able to provide goods and services that are compliant with health and safety legislation is foundational to safety performance at the worksite. Procurement personnel that should participate in I-CAB assessments are those who must procure safety related items such as PPE and other protective equipment that are regulated by the OHS Code/CSA Standards.
From a construction perspective, it’s much simpler to see the requirement for supervisors taking in I-CAB assessments as this part of the work scope has an obvious potential impact on the safety of any worksite. In this case field supervision and their managers have a direct impact on the safety of personnel and are expected to participate in the I-CAB OHS assessment program.
Who determines personnel participation?
The identification of the personnel who need to complete I-CAB assessments is best made by the individual employer. Prime contractors will only have the ability to audit/review this determination based on the role of the individual as it related to their scope of work. As a standard, most organizations are expected to have at least 10% of their leadership in operational roles complete an assessment, but this may vary between organizations.