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Guidelines Part 3

Guidelines Part 3 Contents

Guidelines Part 3 - Occupational health and safety programs

G3.1 Occupational health and safety program

Issued March 30, 2004; Revised October 26, 2005; Revised May 17, 2006; Editorial Revision February 1, 2008

Regulatory excerpt
Section 3.1 of the OHS Regulation ("Regulation") states:

3.1 (1) An occupational health and safety program as outlined in section 3.3 must be initiated and maintained

(a) by each employer that has

(i) a workforce of 20 or more workers, and

(ii) at least one workplace that is determined under section 3.16 (2) (b) to create a moderate or high risk of injury, or

(b) by each employer that has a workforce of 50 or more workers.

(1.1) If subsection (1) (a) or (b) applies to the employer, the occupational health and safety program applies to the whole of the employer's operations.

(2) Despite subsection (1) an occupational health and safety program may be required in any workplace when, in the opinion of an officer, such a program is necessary.

Purpose of guideline
The purpose of this guideline is to provide criteria for counting workers in an employer's workforce for considering whether an occupational health and safety ("OHS") program is required under section 3.1(1), provide WorkSafeBC prevention officers with factors to consider when exercising their discretion under section 3.1(2); and, discuss benefits of OHS programs.

Criteria for counting workers for the purpose of section 3.1(1)
In determining the number of workers for the purpose of section 3.1(1), the following workers should be considered part of the employer's workforce, regardless of how they or their employers define their status:

Workers employed for more than one month
Workers who are employed for less than one month, but have worked for the employer periodically.

Note: Other sections of the Regulation and Workers Compensation Act ("Act") also have requirements that relate to the number of workers. For criteria for counting workers for other requirements, see also

OHS Guideline G3.16
Prevention Manual Policy Item D4-125-1: Joint Committees - When a Committee is Required

Considerations for prevention officers when exercising their discretion under section 3.1(2)
In addition to those employers who are required to initiate and maintain an OHS program under section 3.1(1), some other types of employers should also initiate and maintain health and safety programs. Section 3.1(2) provides that an OHS program may be required in any workplace when, in the opinion of a prevention officer, such a program is necessary.

A prevention officer who encounters a situation where all of the following conditions are present should consider requiring the employer to initiate and maintain an OHS program pursuant to section 3.1(2) of the Regulation:

The employer has a workforce of less than 20 workers
Those workers are exposed to high risks
An OHS program is essential to the health and safety of workers.

In deciding whether to require an OHS program in the above situation, the prevention officer should consider whether such a program could be effectively initiated and maintained by the employer for each workplace where work is being performed for the benefit of that employer.

Benefits of an OHS program for all workplaces
Even though an employer may not be required to initiate and maintain an OHS program, OHS programs can provide a number benefits. For example, OHS programs enable an employer to control its occupational health and safety risks, improve health and safety performance, communicate its health and safety commitments and policies to staff, and provide a framework for attaining its health and safety goals and objectives. Further, OHS programs assist with implementation by delineating roles, responsibilities, and accountability for tasks, including checking and corrective action as the program evolves. A properly implemented OHS program can be expected to reduce injuries and the associated costs of disability and lost production hours.

G3.1-2 Farm labour contractors and growers - Responsibilities and OHS programs

Issued July 5, 2007; Editorial Revision February 1, 2008

Regulatory excerpt
Responsibilities for worker health and safety are established by the Workers Compensation Act ("Act") and the OHS Regulation ("Regulation"). Farm labour contractors are considered to be the employers of the farm workers they provide to agricultural operations. As such they have responsibilities under the Act, for example in section 115. They also have responsibilities under the Regulation, for example for occupational health and safety programs under section 3.1.

Section 115 of the Act states:

115 General duties of employers

Every employer must:

(a) ensure the health and safety of
(i) all workers working for that employer, and
(ii) any other workers present at a workplace at which that employer's work is being carried out, and

(b) comply with this Part, the regulations and any applicable orders.

(2) Without limiting subsection (1), an employer must

(a) remedy any workplace conditions that are hazardous to the health or safety of the employer's workers,

(b) ensure that the employer's workers
(i) are made aware of all known or reasonably foreseeable health or safety hazards to which they are likely to be exposed by their work,
(ii) comply with this Part, the regulations and any applicable orders, and
(iii) are made aware of their rights and duties under this Part and the regulations,

(c) establish occupational health and safety policies and programs in accordance with the regulations,

(d) provide and maintain in good condition protective equipment, devices and clothing as required by regulation and ensure that these are used by the employer's workers,

(e) provide to the employer's workers the information, instruction, training and supervision necessary to ensure the health and safety of those workers in carrying out their work and to ensure the health and safety of other workers at the workplace,

(f) make a copy of this Act and the regulations readily available for review by the employer's workers and, at each workplace where workers of the employer are regularly employed, post and keep posted a notice advising where the copy is available for review,

(g) consult and cooperate with the joint committees and worker health and safety representatives for workplaces of the employer, and

(h) cooperate with the Board, officers of the Board and any other person carrying out a duty under this Part or the regulations.

Section 3.1 of the Regulation states

3.1 When program required

(1) An occupational health and safety program as outlined in section 3.3 must be initiated and maintained

(a) by each employer that has
(i) a workforce of 20 or more workers, and
(ii) at least one workplace that is determined under section 3.16 (2) (b) to create a moderate or high risk of injury, or

(b) by each employer that has a workforce of 50 or more workers.

(1.1) If subsection (1)(a) or (b) applies to the employer, the occupational health and safety program applies to the whole of the employer's operations.

(2) Despite subsection (1) an occupational health and safety program may be required in any workplace when, in the opinion of an officer, such a program is necessary.

Purpose of guideline
The purpose of this guideline is to

Provide background information on farm labour contractors (FLCs) and their role as employers of farm workers
Describe circumstances in which the contractor has an obligation to establish a formal occupational health and safety program, and lists the elements that would typically be covered in the programs
Describe circumstances in which informal programs are required, and what they would include
Discuss the occupational health and safety responsibilities of growers who use contractors to provide services of farm workers in their operations
Provide five examples of how the responsibilities of FLCs apply to the protection of farm workers, in comparison to the responsibilities of the grower: worker transport vehicles, personal protective equipment, first aid, protection from hazardous materials, and training

Farm labour contractors and their responsibilities as employers
Farm labour contractors are licensed under the Employment Standards Act. Lists of licensed FLCs are maintained by the Employment Standards Branch at http://www.labour.gov.bc.ca/esb/agriculture/flclist.htm, along with information on the crops serviced and the number of workers for which the FLCs are bonded. In April 2007, about 100 FLCs were listed, bonded for approximately 6,900 workers.

Most FLCs provide services to the vegetable, berry, nursery, and greenhouse sectors, but some deal in other sectors such as poultry, tree fruits, and vineyards. Most are based in the Lower Mainland and Fraser Valley, but a number operate elsewhere, particularly in the Okanagan region.

FLCs are considered employers because of the nature of their contractual arrangements with farm workers. As such they have all the responsibilities of employers under the Act and the Regulation.

When do requirements for formal OHS programs apply?
OHS Guideline G3.1 (Occupational health and safety program) provides detailed information on the application of section 3.1 of the Regulation. It discusses how to count workers for the purposes of determining whether a formal occupational health and safety (OHS) program is required, and outlines considerations that will be used by WorkSafeBC prevention officers when exercising their discretion to require a formal OHS program under section 3.2 of the Regulation. A brief summary of the main points from the guideline is provided below.

Workers are included in the count if they are employed for more than a month. In addition they are included if they have currently worked for less than a month but have previously worked periodically for the employer. As noted in section 3.1(1.1) of the Regulation the count of workers covers all the operations of the employer. This is particularly important to an FLC who provides workers to a number of different farming operations. The count is to include all workers who work for the FLC, not just to those assigned to a particular farming operation.

As noted in section 3.1(1) of the Regulation, if an employer employs workers in at least one moderate or high risk operation there must be a formal OHS program if the total workforce in all operations is 20 workers or more. For all other situations there must be at least 50 workers in the count before a formal OHS program is required. (Most FLCs are bonded for workforces of 20 or more workers and are likely to be involved in at least one moderate risk operation.)

The hazard rating for a farm labour contractor is based on the hazard rating for the farming operations to which the FLC provides the workers. Unless a hazard assessment demonstrates otherwise, most of the operations typically serviced by FLCs are moderate risk. Examples include: berry farms, greenhouse operations, vegetable farms, and orchards. In any case where an FLC provides workers to at least one moderate risk operation, the FLC must provide a formal OHS program for all their workers if they have a total workforce of 20 or more workers, regardless of whether the FLC's other workers are engaged in low risk work.

Under section 3.1(2) of the Regulation a prevention officer may require a formal OHS program even if it is not required under section 3.1(1). This may apply where the workforce is less than 20 workers, but the workers are exposed to high risk and it is considered that an OHS program is essential to the health and safety of workers.

(Note that for a grower, the obligations to provide a formal OHS program will also apply at the workplace(s) operated by the grower, depending on the level of risk in the workplace(s) and the total number of workers working in the workplace(s) for the periods of time outlined above.)

What do formal OHS programs include?
Under section 3.3 of the Regulation (Contents of program) the occupational health and safety program must be designed to prevent injuries and occupational diseases, and must include at least the following elements:

A statement of the employer's aims, and of the responsibilities of the employer, supervisors, and workers.

Provision for regular inspection of premises, equipment, work methods, and work practices, at appropriate intervals, to ensure that prompt action is undertaken to correct any hazardous conditions found.

Appropriate written instructions, available for reference by all workers, to supplement the Regulation.

Provision for the prompt investigation of incidents to determine the action necessary to prevent their recurrence.

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, as applicable and, on request, to a prevention officer, the union representing the workers at the workplace or, if there is no union, the workers at the workplace.

Provision by the employer for the instruction and supervision of workers in the safe performance of their work.

Provision for holding periodic management meetings for the purpose of reviewing health and safety activities and incident trends, and for the determination of necessary courses of action.

An effective program will

Identify hazards in the workplace
Control the hazards and eliminate or minimize the potential for workplace injuries or illness
Be monitored to ensure the program meets its goals and WorkSafeBC requirements under the Act and Regulation

To achieve these objectives the program may need to include additional elements.

What are the requirements for less formal OHS programs in small operations?
These requirements are established by section 3.2 of the Regulation. Such programs must be implemented in all workplaces where formal OHS programs are not required.

The employer has the following three basic responsibilities when implementing and maintaining a less formal program:

Hold regular monthly meetings with workers for discussion of health and safety matters
Ensure meetings deal with correction of unsafe conditions and practices and the maintenance of cooperative interest in the health and safety of the workforce
Maintain a record of the meetings and the matters discussed. This does not mean that formal minutes have to be kept. It is sufficient that a record is kept of when meetings were held, who attended, and the general nature of what was discussed. The record should mention any specific concerns raised by persons attending, and it must be available for inspection by prevention officers

Responsibilities of growers in relation to FLCs
FLCs provide contract labour services to growers. Growers who receive their services also have responsibilities for those workers, typically as employers under section 115(1)(a)(i) & (ii) of the Act and the provisions of the Regulation.

Under section 115 of the Act the grower is responsible for the health and safety of all workers at the grower's workplace, including those of any other employer. Also, depending on the situation, growers may have responsibilities as prime contractors or owners under sections 118 and 119 of the Act respectively.

A prime contractor must

Ensure that the activities of employers, workers, and other persons at the workplace relating to occupational health and safety are coordinated
Do everything that is reasonably practicable to establish and maintain a system or process in the workplace that will ensure compliance with Part 3 of the Act and the Regulation

An owner must

Provide and maintain the owner's land and premises that are being used as a workplace in a manner that ensures the health and safety of persons at or near the workplace
Give to the employer or prime contractor at the workplace the information known to the owner that is necessary to identify and eliminate or control hazards to the health or safety of persons at the workplace
Comply with Part 3 of the Act, the Regulation, and any applicable orders

(Note: Under section 106 of the Act an owner includes not only a person who owns land outright, but also one who is a tenant, lessee, or occupier of the land or premises.)

Examples of the application of OHS requirements to FLCs and growers
The following examples will assist with an understanding of the application of occupational health and safety requirements to FLCs, and growers who contract for their services.

1. Worker transport vehicles: These are typically owned and operated by FLCs. As such FLCs are responsible for all aspects of safety of the vehicle including condition, maintenance, operation, and use. Requirements apply under provisions such as Part 17 (Worker transportation) of the Regulation, and those under the Motor Vehicle Act.

Growers who contract with FLCs are expected to exercise an oversight function when the vehicle arrives on site. Should they observe any faulty condition of the vehicle or unsafe operation they should draw it to the attention of the FLC to ensure it is corrected. In addition, as owners, the growers have a responsibility to make sure that the site is safe, including any roadway to be used by the worker transport vehicle operated by the FLC.

2. Personal protective equipment (PPE): Part 8 (Personal Protective Clothing and Equipment) of the Regulation provides the applicable requirements. Section 8.2 outlines the obligations of workers and employers. Generally, workers are expected to provide clothing for protection against the natural elements such as weather, and general purpose work gloves, footwear, and safety headgear if needed. However, the Regulation also recognizes that an employer may provide any or all of these items.

An employer must provide any other PPE required for the protection of workers. This might include protective gloves, clothing, or respirators if workers may be exposed to pesticides or other harmful materials, and hearing protection if workers will be working near noisy equipment. Typically, the grower controls the circumstances where workers may be at risk on the worksite and would have the expertise on appropriate PPE. In such cases, the grower would have a primary responsibility for provision of such equipment, but the FLC shares in that responsibility.

3. First aid: Under the requirements for first aid in Part 3 (Rights and Responsibilities) of the Regulation, the FLC is responsible for the provision of first aid for farm workers in their employ. First aid equipment must be provided on worker transport vehicles as required by section 17.10 (Vehicle design), as well as appropriate fire extinguishers. Typically the equipment required will be a Level 1 first aid kit, except where a very small number of workers are transported, in which case a basic kit may be sufficient.

Once workers have been transported to a worksite, the hazard assessment is likely to change, as many agricultural worksites are at least moderate risk. First aid for the FLC's workers would have to be adjusted accordingly. In addition, if the grower employs workers other than those provided by the FLC, then the first aid for the site needs to take account of the total number of workers on site.

As previously mentioned, the grower typically has employer responsibilities on site for workers provided by the farm labour contractor. If in a particular situation the grower is a prime contractor (refer to section 118 of the Act), then section 3.20 of the Regulation requires the grower to do everything that is reasonably practicable to establish and maintain the necessary first aid capability on the site. Unless there is an unusual circumstance, such as a short term situation in which the FLC provides more workers than was originally requested, it will be considered practicable for the grower to provide first aid that covers all workers on site.

4. Protection from hazardous materials: Typically workers employed by FLCs carry out activities such as pruning, thinning, and harvesting. In most cases, if there are hazardous materials present in a workplace, then they are likely to be under the control of the grower.

Under their responsibilities as both owners and employers, growers are required to maintain a safe site, and ensure that FLCs are given the information needed to ensure the safety of the FLC's workers.

Information requirements on hazardous materials are covered primarily in Part 5 (Chemical and Biological Substances) of the Regulation. Most substances to which a worker might be exposed in an agricultural operation (such as many pesticides, corrosive cleaning agents, and fertilizers) are covered by the Workplace Hazardous Materials Information System (WHMIS), which is addressed in sections 5.3 to 5.19. For hazardous substances not covered by WHMIS, such as decomposition gases from silos and manure pits, section 5.2 will apply. Other provisions in Part 5 cover issues such as storage, exposure limits, ventilation, and hazardous wastes.

Part 6 (Substance Specific Requirements) of the Regulation covers requirements for specific groups of substances; for example, pesticides. Among other things, the employer must ensure that pesticides are stored and used safely, are applied by a qualified person, that restricted entry intervals are established after application of a pesticide and appropriate warning signs are posted, and that proper hygiene facilities are provided. In most cases these measures will be the responsibility of the grower.

Restricted entry intervals prohibit entry by a worker into an area in which pesticides are applied unless a worker is properly protected before he/she enters the area. Workers must be protected both before and after the expiry of the entry intervals. The party that controls the use of pesticides on site, typically the grower, has responsibilities to protect workers under these provisions. In addition they have the responsibility to communicate to the FLC all information needed to ensure the safety of the FLC's workers. Depending on the arrangements made between the grower and the FLC, one or both of the parties will be responsible for providing necessary information to workers, and any necessary personal protective equipment that is not the responsibility of the worker under section 8.2 of the Regulation.

5. Training: Under section 115(2) of the Act, an employer has the responsibility to ensure workers are made aware of all known or reasonably foreseeable hazards, as well as their rights and duties under the Act and Regulation, and are provided with the information, instruction, training, and supervision to ensure their health and safety. A number of specific training requirements are covered in the Regulation. Three examples are provided below.

5.1 Orientation: Effective July 26, 2007 under sections 3.22 to 3.25 of the Regulation all young and new workers must receive orientation and training specific to the workplace. New workers include workers who are relocated to a new workplace if the hazards in that workplace are different from the hazards in their previous workplace. These provisions will have substantial application to FLCs in the agriculture sector given that their workers are often assigned to new workplaces. Again, responsibilities may be shared between the grower and FLC on how the various specified training and orientation elements are addressed. It may, for example, be reasonable to expect that the FLC take the lead on providing generic instruction on topics that are not site-specific, with the grower taking responsibility for site specific topics. Records must be kept of the orientation and training provided.

5.2 WHMIS: For hazardous substances covered by WHMIS, the worker must receive the education and training required by sections 5.6 and 5.7 of the Regulation. Section 5.6 deals with general (generic) requirements to ensure workers know among other things the elements of the WHMIS program, and the content required on labels and material safety data sheets (MSDS). Section 5.7 addresses site-specific requirements for training in the safe procedures for controlled products in the workplace.

Again, the FLC and grower may, depending on the arrangements between them, share in the responsibilities for both generic instruction and site-specific training. It may be a typical scenario for the FLC to ensure generic instruction is given, and the grower to cover site-specific training. In the final analysis, the worker must be able to answer the following four questions:

What are the hazards of the materials to which I may be exposed?
How am I protected from those hazards?
What do I do in the event of an emergency?
Where do I get more detailed information?

5.3 Forklifts and other on-site equipment: Typically any such equipment is under the control of the grower. Therefore, it will be the grower who has the basic responsibility to ensure workers are trained in the use of the equipment should they be required to operate it, and in the safe procedures to follow for workers who are working in the vicinity of the equipment. The FLC has a responsibility to ensure that adequate training has been provided.

5.4 FLC vehicles: The FLC is responsible for instruction of workers in the use of FLC vehicles used for transporting farm workers to and from the grower's operation. This would include, for example, instruction for the operator in the requirements of the pre-shift vehicle inspection, and for the operator and workers being transported, instruction in the proper procedures to follow in the vehicle, such as the procedures for the transport of materials and tools, and the use of seat belts.

G3.2 "Less formal" occupational health and safety (OHS) programs

Issued October 26, 2005; Revised May 17, 2006; Editorial Revision February 1, 2008

Regulatory excerpt
Section 3.1 of the OHS Regulation ("Regulation") states:

3.1 (1) An occupational health and safety program as outlined in section 3.3 must be initiated and maintained

(a) by each employer that has

(i) a workforce of 20 or more workers, and

(ii) at least one workplace that is determined under section 3.16 (2) (b) to create a moderate or high risk of injury, or

(b) by each employer that has a workforce of 50 or more workers.

(1.1) If subsection (1) (a) or (b) applies to the employer, the occupational health and safety program applies to the whole of the employer's operations.

(2) Despite subsection (1) an occupational health and safety program may be required in any workplace when, in the opinion of an officer, such a program is necessary.

Section 3.2 of the Regulation states:

In any operation where the workforce is less than that referred to in section 3.1(1) the employer must

(a) initiate and maintain a less formal program based on regular monthly meetings with workers for discussion of health and safety matters,

(b) ensure that meetings are directed to matters concerning the correction of unsafe conditions and practices and the maintenance of cooperative interest in the health and safety of the workforce, and

(c) maintain a record of the meetings and the matters discussed.

Purpose of guideline
The purpose of this guideline is to highlight situations where employers are required to implement a "less formal program" under section 3.2, rather than an OHS program under section 3.1, but are still required to implement joint committees under the Workers Compensation Act ("Act"). The guideline also discusses requirements for less formal programs under section 3.2.

OHS programs, less formal programs, and joint committees
Under section 3.2 of the Regulation, less formal programs are required in any operation where the workforce is less than that referred to in section 3.1(1). Note that even where an OHS program under sections 3.1 and 3.3 is not required, an employer may be required to establish and maintain a joint committee under section 125 of the Act.

For example, consider the following situation:

Number of workers	30
Risk level	Low
OHS Program required under section 3.1(1)?	No
Joint Committee required under section 125(a) of the Act?	Yes

In this situation, the employer must meet the requirements of section 3.2 of the Regulation and the requirements in the Act for joint committees.

Requirement for less formal programs
Section 3.2(a) requires that the employer or a person delegated by the employer calls, at least once a month, a meeting of workers present at that time. The employer's obligation under section 3.2(c) to maintain a "record of the meetings" does not mean that formal minutes have to be kept. It is sufficient that a record is kept of when meetings were held, who attended and the general nature of what was discussed. The record should mention any specific concerns raised by persons attending. The record must be available for inspection by prevention officers.

Guidelines Part 3 - Correction of unsafe conditions

G3.11 Emergency circumstances

Issued August 1, 1999

An officer encountering a situation presenting an immediate danger must act in accordance with section 3.11 of the OHS Regulation with respect to his or her personal safety, and ensure the employer complies with section 3.11 while correcting the unsafe condition.

Normally an officer will refrain from direct involvement in correcting the unsafe condition. If necessary to render assistance, the officer will proceed with caution and within his or her qualifications. The officer must immediately attempt to notify his or her manager.

An officer receiving an inquiry regarding immediate danger to the public will refer the parties concerned to the appropriate authority. If it is not clear who the appropriate authority is, the parties should be referred to the police or fire department responsible for the area where the reported immediate danger exists.

Guidelines Part 3 - Refusal of unsafe work

G3.12 Refusal of unsafe work

Issued August 1, 1999

An officer investigating a situation under section 3.12(5) of the OHS Regulation will:

(1) Interview the worker or workers refusing to work and the employer's representative to obtain all available information regarding the situation.

(2) Inspect the site of the reported hazard.

(3) Issue an inspection report specific to the site or subject of the reported hazard. If an undue hazard exists, the officer will issue a "stop work" order under section 187, 190 or 191 of the Workers Compensation Act, depending on the nature and seriousness of the hazard. If no immediate danger or undue hazard is observed, the body of the inspection report will note "An investigation of a work refusal under section 3.12 has not identified an undue hazard."

(4) Discuss with the worker(s) refusing to work and the employer's representative the results of the investigation and ensure both understand the procedure for resolving work refusals under section 3.12. The officer will advise the parties of the requirement of section 3.13 of the OHS Regulation that "A worker must not be subject to discriminatory action as defined in section 150 of Part 3 of the Workers Compensation Act because the worker has acted in compliance with section 3.12 or an order made by an officer".

(5) If a violation is observed at the employer's operation in an area separate from the site or subject of the refusal to work, or is observed at the site or subject of the reported hazard but the violation is not considered an immediate danger or an undue hazard, the officer will issue the orders on a separate inspection report.

Guidelines Part 3 - Occupational first aid

G3.14 to G3.20 First aid guidelines for employers

Issued March 30, 2004; ; Revised November 1, 2004; Editorial Revision February 1, 2008

The first aid guidelines cover the following:

Information regarding WCB Standard OFA1: Certification of Occupational First Aid Attendants - see OHS Guideline G3.14
The employer's responsibility for providing first aid services and transportation to medical aid - see OHS Guideline G3.16
Conducting an assessment to determine the level of first aid service required in the workplace - see OHS Guideline G3.16
First aid procedures - see OHS Guideline G3.17
Implementing an early defibrillation program in the workplace - see OHS Guideline G3.17(1)-1
Communications with the first aid attendant and to obtain assistance - see OHS Guideline G3.18(1)
Availability of the first aid attendant - see OHS Guideline G3.18(2)
Acceptable first aid records - see OHS Guideline G3.19
Multiple employer workplaces - see OHS Guideline G3.20

The following supplementary materials support these guidelines:

Assigned Hazard Rating List
Types of First Aid Attendants and Training Programs
First Aid Kits: Recommended Minimum Contents
First Aid Facilities: Recommended Minimum Criteria
Emergency Vehicles and Equipment

If you wish to print all the first aid guidelines with supplementary materials, these are available in PDF format on the WCB web site:
www2.worksafebc.com/PDFs/firstaid/First_aid_guidelines.pdf (175 KB)

In addition, you may wish to print the first aid assessment flow chart:
www2.worksafebc.com/PDFs/firstaid/First_aid_assessment_flowchart.pdf (56 KB)
and the first aid assessment worksheet:
www2.worksafebc.com/PDFs/firstaid/First_aid_assessment_worksheet.pdf (101 KB)

G3.14 First aid attendant certification, qualifications and general responsibilities

Issued November 1, 2004

Section 3.14 of the OHS Regulation states:

...
"first aid attendant" means a person who holds a valid first aid certificate issued by the Board or by a person recognized by the Board and who is designated as a first aid attendant by the employer;
...

In order to clarify the definition of "first aid attendant" under section 3.14 of the OHS Regulation, qualifications of attendants under section 3.15 of the OHS Regulation, and responsibilities of attendants under section 3.21 of the OHS Regulation, the Board issued WCB Standard OFA1: Certification of Occupational First Aid Attendants.

This standard explains how a person becomes certified to act as an attendant in the workplace, the terms and conditions of certification, the general responsibilities of the attendant in the workplace, and the disciplinary actions the WCB may take if an attendant does not meet his or her responsibilities.

The standard is located at:
www2.worksafebc.com/Publications/OHSRegulation/WCBStandards.asp?ReportID=33295

G3.16 First aid assessment

Issued March 30, 2004; Revised February 1, 2008

Regulatory excerpt
Section 3.16 of the OHS Regulation ("Regulation") states:

(1) The employer must provide for each workplace such equipment, supplies, facilities, first aid attendants and services as are adequate and appropriate for

(a) promptly rendering first aid to workers if they suffer an injury at work, and

(b) transporting injured workers to medical treatment.

(1.1) The type and quantity of equipment, supplies, facilities, first aid attendants and services referred to in subsection (1) must be no less than is required by Schedule 3-A.

(1.2) The quality, maintenance and use of equipment, facilities and methods of transportation referred to in this section must be acceptable to the Board.

(2) For the purpose of complying with subsection (1), the employer must conduct an assessment of the circumstances of the workplace, including

(a) the number of workers who may require first aid at any time,

(b) the nature and extent of the risks and hazards in the workplace, including whether or not the workplace as a whole creates a low, moderate or high risk of injury,

(c) the types of injuries likely to occur,

(d) any barriers to first aid being provided to an injured worker, and

(e) the time that may be required to obtain transportation and to transport an injured worker to medical treatment.

(3) The employer must review the assessment under subsection (2)

(a) within 12 months after the previous assessment or review, and

(b) whenever a significant change affecting the assessment occurs in the employer's operations.

(4) First aid equipment, supplies and facilities must be kept clean, dry and ready for use, and be readily accessible at any time a worker works in the workplace.

Purpose of guideline
The purpose of this guideline is to set out a step-by-step method for employers to follow when conducting an assessment of the workplace to determine an adequate and appropriate level of first aid coverage. These steps cover the requirements listed in section 3.16(2) and (3). The steps are designed to help employers determine which table applies to their workplace and what the required levels of first aid service mean. (See Schedule 3-A Minimum Levels of First Aid Tables 1-6 ("Schedule 3-A") in the Regulation.) Also see, at the end of these Guidelines: First Aid Kits: Recommended Contents, First Aid Facilities: Recommended Criteria, and Emergency Vehicles and Equipment).

Most employers will not need all the information provided in this guideline. A flow chart and worksheet are available to help you do the first aid assessment for your workplace. Where you may need additional information as you work through the flow chart, the chart refers to the appropriate part of the first aid guidelines. These guidelines are also available in PDF: http://www2.worksafebc.com/PDFs/firstaid/First_aid_guidelines.pdf

Employer's responsibility to conduct an assessment
Schedule 3-A in the Regulation specifies mandatory minimum levels of first aid, including what type of first aid kits, facilities, and equipment are required. Schedule 3-A does not specify required contents or criteria for the first aid kits, facilities and equipment. The content and criteria of first aid kits, facilities and equipment should be based on the assessment performed under section 3.16(2). This recognizes that persons working in the workplace will generally have a greater awareness of its circumstances and needs than WorkSafeBC. Employers are expected to exercise good judgment in performing the assessment.

Once employers have identified the required minimum levels of first aid in Schedule 3-A, they should consult the appropriate table in First Aid Kits: Recommended Minimum Contents, First Aid Facilities: Recommended Minimum Criteria, and Emergency Vehicles and Equipment, found at the end of this guideline. Typically, employers would be expected to approximate the recommendations in the appropriate tables. However, after conducting an assessment, the employer may legitimately conclude that the nature of the necessary first aid kit, facility or equipment is different from that which is recommended in the appropriate table. If the recommendations in the tables are not followed, employers are expected to demonstrate that the assessment was conducted diligently and led to a reasonable conclusion about the content or nature of first aid kit, facility and equipment required at the workplace. If their assessment results in levels different from those suggested in the tables, given the circumstances at the workplace, the employer is expected to explain and provide a rationale for the differences. An assessment must not result in levels lower than the mandatory minimums required by Schedule 3-A.

If workers of two or more employers are working at the same workplace at the same time, the prime contractor is responsible for conducting the assessment and providing the first aid services identified by the assessment. See OHS Guideline G3.20.

Conducting the assessment

Step 1:
Identify the workplace.
First identify the workplace for which first aid is required. As a result of this step, you may determine that you have more than one workplace. An assessment of the first aid requirements for each workplace must be done.

Is the workplace at one location only?
For most workplaces with one location, there is one workplace. However, if there is more than one location or if there are lodgings, there may be more than one workplace.

Consider the factors in the following table to see if they apply to your workplace. In any situation, the factors may point to different conclusions. It is then necessary to weigh those factors indicating one workplace against those indicating separate workplaces. After considering all the factors, you should choose the option that provides the greatest level of first aid service.

Location factors

Factor No.	Factor	Indication of one workplace	Indication of separate workplaces
1	Location or locations are under the control of one employer.	Yes
2	Location leased by one employer is part of a larger property which may be leased to others		Yes
3	Locations controlled by one employer are separated by locations controlled by other employers.		Generally yes, but depends on circumstances. See 6.
4	Locations of one employer are more than 20 minutes apart from each other.		Yes
5	A public roadway separates locations of one employer from each other in an urban area.		Yes
6	Locations of one employer are 20 minutes or less from each other in a rural area.	Yes
7	Though adjoining, locations of one employer are separated by physical barriers.		Yes
8	Though controlled by one employer, the locations are under separate administrative structures.		Yes

Lodgings
Lodgings at or near the workplace, generally within 20 minutes, should be considered part of the workplace. First aid service should be based on the total workforce present at the place of work and in the lodgings at any time. This does not apply to a company town or to motels or hotels where workers have lodgings in a nearby town.

The employer providing lodgings may allow other employers on the site to accommodate their workers there. The employer providing the lodgings is responsible for ensuring that first aid service is provided for all workers in the lodgings, unless other arrangements are made.

Lodgings that are not at or near the workplace may be considered a separate workplace. The level of first aid service must be determined by conducting an assessment based on the number of workers in the lodgings. This includes workers such as cooks and cleaners who perform their daily work there as well as others who work elsewhere but spend free time there.

The employer may be able to provide the required first aid services for the lodgings and the workplace by moving the same first aid personnel and equipment from one place to the other as the workers move.

Multiple employer workplaces
See OHS Guideline G3.20 for more information on multiple employer workplaces where there is a prime contractor.

At the end of Step 1
An assessment is required for each workplace identified in Step 1. If you are using the worksheet provided on the web site, fill in a separate sheet for each workplace since the requirements may be different.

Step 2:
Determine the hazard rating as low (L), moderate (M), or high (H).
The workplace can be assigned an overall rating that indicates the nature and extent of the risks and hazards in the workplace. The step-by-step approach in this guideline uses three levels of hazard rating: low, moderate, and high.

(a) Is my industry listed in the Assigned Hazard Rating List?
To assist in the assessment, WorkSafeBC has assigned ratings of low, moderate, and high to various industries in an "Assigned Hazard Rating List." The list reflects the previous Schedule 7 in Part 33 (prior to March 30, 2004). The new designations correspond to former hazard ratings:

C in Schedule 7 = Low (L)
B in Schedule 7 = Moderate (M)
A in Schedule 7 = High (H)

If your industry is not in the "Assigned Hazard Rating List," it is probably because there is a wide variation in the industry as to the job functions, work processes, or tools and equipment. You can calculate a hazard rating using the adjustment calculation in (d) of this step, or you may call WorkSafeBC at 604-276-3100 or toll-free at 1-888-621-7233 and talk to an officer who can help you with this part of the assessment.

(b) Are the job functions, work processes, and tools used in my workplace typical of the industry?
You need to determine if the assigned rating is appropriate and make a rating adjustment if the circumstances warrant it. The overall workplace rating is based on typical job functions, which are designated as low risk or high risk. There is no moderate level for job functions, but the percentage of workers doing high-risk job functions and the amount of time they spend doing those job functions determines whether a workplace has an overall hazard rating of moderate or high.

Generally, to determine the level of risk of a job function, you should analyze the work conducted at the workplace to identify:

The following lists will help you determine whether your workplace has typical low-risk or high-risk job functions.

Typical low-risk job functions

Typical high-risk job functions

5.1.1

Regulation

If you decide that your workplace is not typical of the industry and that the assigned hazard rating is not appropriate, you can assess your level of risk and hazards in another way. See Step 2(d) below.

(c) Consider the type of injuries likely to occur, by looking at past incidents, near-misses, and injuries. Are these typical for this hazard rating?
The evaluation of types of injuries that can potentially occur is important, as varying levels of first aid attendants and supplies are required to promptly render first aid for varying types of injuries. For example, if a first aid attendant may need to move a person on a spine board, the workplace requires a Level 3 attendant or a Level 1 or 2 attendant with a Transportation Endorsement. If you want to know what the different levels of first aid courses cover, you can find this on the first aid web site under "Certification and Training": http://www2.worksafebc.com/Topics/FirstAid/FAQ.asp

Look at past first aid records, incident reports, and WorkSafeBC time-loss claims history to see the type of injuries that have occurred in the past. You may be able to get information on typical injury trends from an industry association or WorkSafeBC.

If the hazard rating from the "Assigned Hazard Rating List" is appropriate, use that rating (L, M, or H) in Step 3. Or you may decide to use a higher hazard rating. If you have determined the appropriate hazard rating, you do not need to do the hazard rating adjustment in Step 2(d), which follows. Record this hazard rating on your worksheet.

(d) Do I want to calculate a different rating, more specific to my workplace?
Instead of using the table, you have the option of determining the hazard level using generally accepted principles and methods. The method in this guideline is one acceptable way to calculate an adjustment and is similar to methods used in other jurisdictions. WorkSafeBC officers may ask to see a written assessment or an explanation of your calculation of hazard rating.

Hazard rating adjustment
The following factors are considered when determining the overall hazard rating of the workplace:

low-risk

high-risk

The calculations will use the extent of individual worker exposures to establish the overall workplace rating as low, moderate, or high. These ratings determine the appropriate level of first aid service.

Calculating the extent of exposure to high-risk job functions follows these principles:

A rating could be adjusted up or down as a result of the calculations. Here is the method for adjusting between low and moderate

low

moderate

either

30% or more of the workers have individual total exposures of greater than 20% to a high-risk job function, or
50% or more of the workers have individual total exposures of greater than 10% to a high-risk job function

moderate

down

low

both

70% or more of the workers have individual total exposures of 20% or less to a high-risk job function, and
50% or more of the workers have individual total exposures of 10% or less to a high-risk job function

Here is the method for adjusting between moderate and high

moderate

high

either

30% or more of the workers have individual total exposures of greater than 75% to a high-risk job function, or
50% or more of the workers have individual total exposures of greater than 50% to a high-risk job function

high

down

moderate

both

70% or more of the workers have individual total exposures of 75% or less to a high-risk job function, and
50% or more of the workers have individual total exposures of 50% or less to a high-risk job function

It is expected that every workplace will have low-risk job functions. Therefore, it is generally expected that employers will start by assuming the workplace has a low hazard rating and will then move to a moderate or high rating if required. Adjustments are calculated from one level to the next, so it is a two-step process to go from low to moderate to high.

Example
To use the above calculations, you will need to identify the job functions for each worker (or for each group of workers doing the same job functions). Find out what percentage of time is spent doing each job function; you will need the percentage of time doing high-risk job functions for the calculations.

For example, in a lumber yard/retail hardware store, there are nine workers. Three workers do the same job. Each spends:

Therefore, each of these three workers has an individual total exposure of 15% to high-risk job functions (obtained by adding 5% + 10%). The result is that 33% of the workforce has individual total exposures of 15%.

The remaining six workers do sales and office work, all spending 100% of their time in low-risk job functions. They have no exposure to high-risk job functions.

Although a lumber yard is listed as moderate in the "Assigned Hazard Rating List," this particular lumber yard has lower-than-expected exposures to high-risk job functions. When the adjustment calculation is applied, the moderate hazard rating is adjusted down to a low hazard rating because both of the following conditions apply:

At the end of Step 2
Record your hazard rating (L, M, or H) on the worksheet and use it in the next step.

Step 3:
Consider surface travel time to hospital.
Tables 1-6 in "Schedule 3-A: Minimum Levels of First Aid" in the Regulation have different levels of first aid service that are based on how long it takes to transport an injured person to a hospital and the number of workers per shift.

The definition of "hospital" for the purpose of the assessment is "a hospital or diagnostic and treatment centre that has an emergency department or resuscitation area and a physician on duty, or immediately available on call, during the hours when workers might need these services."

(a) Does it take more than 20 minutes to travel to hospital (by road or water) during working hours?
The calculation of time is based on the normal time to safely transport an injured worker on a stretcher by land or water, having consideration for the weather, road conditions, traffic patterns, and other factors that may affect travel and are likely to prevail during working hours.

Check that the hospital or treatment facility

Facilities with the designation hospital, health care centre, clinic, diagnostic and treatment centre, first aid post, and diagnostic facility offer different levels of patient care and various hours of operation. Some of these facilities have B.C. Ambulance bypass protocols in place. Bypass protocols are put in place if the local clinics or hospitals are unable to receive trauma patients during certain hours. The same "bypass" rules may apply to accepting the employer's emergency transportation vehicle or industrial ambulance.

As a result of the hours of service at the nearest treatment facility, you may find that the hospital for the day shift is closer than the hospital available for the night shift, and therefore a different table with different required first aid services would be used for the different shifts.

At the end of Step 3
On the worksheet, record the distance from hospital and the table for your workplace

Step 4:
Determine the number of workers on a shift.
For each workplace, the assessment must include the number of workers who may require first aid at any given time. The term "workers" includes managers and supervisors.

(a) Are all the workers at one location during the shift?
If yes, this is the number of workers (including managers and supervisors) to count.

If there are workers who are dispatched from a central workplace or workers in lodgings, they may need to be included in the first aid requirements for the central workplace. You can use the following method to count these workers.

Dispatched workers
Include dispatched workers within 20 minutes' surface travel time from the central workplace

It is required that dispatched workers who work alone and travel more than 20 minutes from the central workplace carry their own first aid personal kit. See "First Aid Kits: Recommended Minimum Contents."

Workers in lodgings provided by the employer

(b) How many workers per shift are there?
Count the number of workers for each shift. Use the table you identified in Step 3 and find the number of workers per shift in Column 1.

At the end of Step 4
You have now determined which row in your table to use for each shift. The next step will take you through the remaining columns corresponding to the row you have just identified for the number of workers on a shift in your workplace. If there is more than one shift with different requirements, complete the information for each shift.

Step 5:
Find the required first aid services for your workplace.
Step 5 looks at the required level of first aid coverage needed for your workplace by looking at each column of the row you selected in your table in the previous step. Keep in mind the type of injuries that could potentially occur in your workplace - see Step 2(c). This will help you decide whether the required minimum service is adequate and appropriate for your workplace.

(a) Look at Column 2 of your table from Step 3. What supplies, equipment, and facilities are needed?
Column 1 lists the following:

The level of first aid kit required, and its recommended contents (see "First Aid Kits: Recommended Minimum Contents")
Emergency transportation vehicle (ETV) equipment and industrial ambulance equipment, if required (see "Emergency Vehicles and Equipment")
Dressing station or first aid room and equipment, if required (see "First Aid Facilities: Recommended Minimum Criteria")

(b) Is this adequate for the type of injuries expected and the distance to medical treatment?
Consider the past need for first aid services and the type of injuries that are likely to occur in your workplace. If necessary upgrade the facility from that given in the table. See Step 5(f) below for examples.

(c) Look at column 3 of your table. What level of first aid attendant is needed?
Column 3 lists the level of first aid attendant and the number of attendants if more than one is required for your workplace. For information on the levels of first aid certification, see "Types of First Aid Attendants and Training Programs."

(d) Is this adequate for the type of injuries expected and the distance to medical treatment?
Consider the past need for first aid services and the type of injuries that are likely to occur in your workplace. If necessary, upgrade the level or number of attendants from that given in the table. See Step 5(f) below for examples.

(e) Look at Column 4 of your table. What transportation is needed?
Column 4 lists whether an emergency vehicle is required. For recommendations on ETVs and industrial ambulances (and on a mobile treatment centre as an alternative), see "Emergency Vehicles and Equipment."

(f) Are there any barriers to reaching medical treatment?
This question helps you consider whether there is any potential delay in transporting an injured worker to medical treatment. These include the ambulance response time and remote locations.

Consider the factors that affect the response time of the ambulance service

Regularly recurring temporary obstructions or barriers, such as railway lines used on a daily basis with railcars blocking access at some point in the day
Temporary obstructions or barriers of an isolated nature, such as long-term road closure
Permanent obstructions or barriers on the access road, such as cross ditching

If an ambulance is not able to access the workplace, appropriate upgrading includes replacing a Level 2 attendant with a Level 3 attendant and supplying ETV equipment to facilitate preparing a patient for transport. See "Emergency Vehicles and Equipment" for more information on ETVs. The ETV should be appropriate for the terrain to be traversed and the injured or ill worker's condition. The situations for upgrading are listed in the tables in Column 5 (Other Considerations).

Keep in mind the types of potential injuries you identified in Step 2(c). Make sure that the level of attendant and the supplies and equipment are sufficient to deal with any identified delays in reaching medical treatment.

At the end of Step 5
You have determined the first aid services appropriate for your workplace. Add this information to the worksheet. First aid services must meet or exceed the minimum levels required in Schedule 3A.

Step 6:
Review your assessment.
The first aid assessment must be reviewed annually or whenever a significant change in operations occurs. Keep written records of the results of your review.

G3.17 Developing and implementing first aid procedures

Issued March 30, 2004

Section 3.17 of the Occupational Health and Safety Regulation states:

(1) The employer must keep up-to-date written procedures for providing first aid at the worksite including

(a) the equipment, supplies, facilities, first aid attendants and services available,

(b) the location of, and how to call for, first aid,

(c) how the first aid attendant is to respond to a call for first aid,

(d) the authority of the first aid attendant over the treatment of injured workers and the responsibility of the employer to report injuries to the board,

(e) who is to call for transportation for the injured worker, and the method of transportation and calling, and

(f) prearranged routes in and out of the workplace and to medical treatment.

(2) The employer must post the procedures conspicuously in suitable locations throughout the workplace or, if posting is not practicable, the employer must adopt other measures to ensure that the information is effectively communicated to workers.

(3) The first aid attendant and all other persons authorized to call for transportation for injured workers must be trained in the procedures.

There are samples of written first aid procedures for reference on the first aid web site under "Forms and Records": http://www2.worksafebc.com/Topics/FirstAid/FAQ.asp

Drills
To ensure the effectiveness of the employer's first aid service, a drill should be held at least once each year to test:

Workers' awareness of the way to summon first aid, the effectiveness of the communication system, and the ability of the first aid attendant to respond to being summoned
The capacity of the first aid service to treat injuries or illnesses of the type likely to occur in the workplace

Maintaining the system
The employer should assign personnel to manage the first aid service at the workplace. That person's duties should include ensuring that the required attendants, supplies, facilities, and equipment are always available. This would include ensuring that attendants are replaced when they are absent or leave the employ of the employer and that supplies are replenished as they are used.

G3.17(1)-1 Implementing an early defibrillation program in the workplace

Issued September 30, 2004

Section 3.17(1) of the Occupational Health and Safety Regulation states:

The employer must keep up-to-date written procedures for providing first aid at the worksite including

(a) the equipment, supplies, facilities, first aid attendants and services available,

(b) the location of, and how to call for, first aid,

(c) how the first aid attendant is to respond to a call for first aid,

(d) the authority of the first aid attendant over the treatment of injured workers and the responsibility of the employer to report injuries to the Board,

(e) who is to call for transportation for the injured worker, and the method of transportation and calling, and

(f) prearranged routes in and out of the workplace and to medical treatment.

An early defibrillation program in the workplace has three main elements: an automated external defibrillator (AED) that meets acceptable technical standards, oversight by a medical director, and training of first aid attendants and other authorized persons in the use of the AED. These will be supplemented by written procedures.

This guideline sets out technical standards for AEDs, the role of the medical director, training standards for the designated first aid attendant and other authorized persons, and the requirements for written procedures.

An early defibrillation program is not specifically required by the OHS Regulation, but if one is established, then the AED is considered to be first aid equipment, and its use is governed by relevant provisions in the OHS Regulation, particularly section 3.17(1). AED training is not included in WCB occupational first aid course curriculum; therefore, additional training will be required in order for this equipment to be used at the worksite.

Section 3.17(1)(a) requires employers to keep up-to-date written procedures for providing first aid at the worksite including the equipment, supplies, facilities, first aid attendants and services available. If the employer chooses to implement an early defibrillation program the written procedures must outline the program according to this guideline and describe how the equipment will be integrated into the first aid response for that worksite.

The early defibrillation program should be integrated with the employer's emergency first aid response plan.

Because the introduction of an early defibrillation program has potential consequences for the health and safety of workers, it is expected that the employer will consult with the joint occupational health and safety committee, or worker health and safety representative, as applicable, on proposals to introduce the use of AED equipment.

Early Defibrillation Devices - technical standards

These devices (termed automated external defibrillators or AEDs) should meet three minimum criteria to be acceptable for use in the workplace in BC. They should be:

Currently licensed for use as an external defibrillator in Canada by Health Canada (see Health Canada, Medical Devices Bureau of the Therapeutic Products Directorate (www.mdall.ca),
Automated (semi-automatic) in operation (the only type licensed for use at this time in Canada), and
Capable of storing both electrocardiographic and AED event data.

AED Medical Director

Where an early defibrillation program exists in the workplace, the program should be under the direction of an AED Medical Director. The Medical Director will:

Be a physician licensed to practice medicine in British Columbia by the College of Physicians and Surgeons of British Columbia,
Be familiar with early defibrillation clinical and technical issues,
Be responsible for the security and management of patient clinical information including any electronic data from an AED unit, and
Provide a letter of confirmation to the employer, confirming he or she is the AED Medical Director for that site's early defibrillation program.

The employer at a workplace with an early defibrillation program will make the letter of confirmation from the AED Medical Director available on request of a Board officer, as required under section 179(3) of the Workers Compensation Act.

Training standards for early defibrillation responders

The AED Medical Director will set out in writing, for the employer, the expected criteria to which the early defibrillation responders must be trained.
It is expected that these criteria will meet or exceed the early defibrillation standards of the Heart and Stroke Foundation of Canada and that recertification in early defibrillation will occur yearly.
Among other things, section 115(2)(e) of the Workers Compensation Act requires that the employer provide the information, instruction and training to workers necessary to ensuring the health and safety of other workers at the workplace. For those workers who will use AEDs this includes information and instruction necessary for the safe use of the equipment. Also, section 3.17(3) of the OHS Regulation requires first aid attendants and other persons authorized to call for transportation of injured workers to be trained in these procedures.
The employer is responsible for maintaining records of early defibrillation training and certification for each early defibrillation responder at the worksite. The employer will make these records available on request of a Board officer.

Designated first aid attendant & other authorized persons
Where an early defibrillation program exists in the workplace, the designated first aid attendant is in charge of the emergency first aid care of the patient, including the delivery of early defibrillation until the patient is transferred to a higher medical authority.

This does not preclude other trained individuals in the workplace from administering first aid, cardiopulmonary resuscitation or early defibrillation in the absence of or while awaiting the arrival of the designated attendant.

Written procedures

Written procedures are required by section 3.17(1) of the OHS Regulation and must include any procedures or protocols associated with the employer's early defibrillation program, including the means of designating workers who are authorized to use AEDs, a list of persons so authorized, and the means of use of equipment.
The procedures and protocols should be sanctioned by the AED Medical Director.
The procedure and protocols should also address:
(a) The assurance of ongoing clinical support for early defibrillation responders.
(b) Integration of the use of AEDs within the organization's written procedures for providing first aid.
(c) Clinical documentation (written and/or electronic) of an event where early defibrillation was deployed, including security of and maintenance of this documentation, which is required by section 3.19 of the OHS Regulation
(d) The storage, inspection, and maintenance of AED equipment (See section 3.17(1)(a)).

G3.18(1) Communications

Issued March 30, 2004

Section 3.18(1) of the Occupational Health and Safety Regulation states:

(1) The employer must provide an effective means for

(a) communication between the first aid attendant and the workers served, and

(b) the first aid attendant to call for assistance.

This guideline suggests suitable means of communication between the first aid attendant and workers.

There is an "effective means" of communication if workers throughout the workplace know how to alert the first aid attendant that service is required. That system could consist of a whistle, siren, series of lights, pager, two-way radios, or portable phones that the first aid attendant would see or hear and that would enable the attendant to know where to respond.

"Assistance" in section 3.18(1)(b) may include assistance from other workers, the B.C. Ambulance Service, or another ambulance service acceptable to the Board.

G3.18(2) Availability of first aid attendant

Issued March 30, 2004

Section 3.18(2) of the Occupational Health and Safety Regulation states:

The employer must not assign, and the first aid attendant must not undertake, employment activities that will interfere with the attendant's ability to receive and respond to a request for first aid.

This guideline discusses how to ensure that the first aid attendant is available to render first aid promptly, as required by section 3.16(1).

In order to provide effective treatment, the equipment, facilities, and attendant must be accessible and first aid must be administered to the worker as soon as practicable after the injury or disease, in accordance with the practices and standards found in the attendant's training program.

The following principles apply in determining whether the first aid service has been properly provided:

An attendant should actually be present in the area served, during all working hours. This includes periods such as lunch or coffee breaks when workers are on shift and at the workplace but not actually working.
The attendant, equipment, and facilities must be ready to receive the injured worker or to depart to where the worker is situated without delay, usually within 3 to 5 minutes of being summoned. (This allows the attendant time to clean up as needed, either take off coveralls or put on clean coveralls, and obtain the first aid kit.)
The location of the central first aid service should be readily accessible. A service will be readily accessible where it is within 10 minutes' walking time (or driving time, where vehicles are normally used for general movement within the workplace) for all workers in a workplace. Alternatively, the service is readily accessible where the attendant can reach injured workers within 10 minutes' walking time (or driving time) to render first aid.

Backup for absent first aid attendant
Absences from the workplace by first aid attendants may be planned (such as vacations or medical appointments) or unplanned (such as travelling with an injured worker to hospital or being absent because of sickness). Since it is foreseeable that planned and unplanned absences will occur, the employer will be expected to have a procedure for dealing with them.

Where planned absences may leave on duty fewer than the required number of attendants, the employer should have a substitute first aid attendant available as soon as the absence commences. With regard to unplanned absences, an absence of up to approximately half a shift is permissible until a replacement attendant is in place.

G3.19 First aid records

Issued March 30, 2004

Section 3.19 of the Occupational Health and Safety Regulation states:

(1) The employer must maintain at the workplace, in a form acceptable to the board, a record of all injuries and exposures to contaminants covered by this Regulation that are reported or treated.

(2) First aid records must be kept for at least 3 years.

(3) First aid records are to be kept confidential and may not be disclosed except as permitted by this Regulation or otherwise permitted by law.

(4) First aid records must be available for inspection by an officer of the board.

(5) Workers may request or authorize access to their first aid records for any treatment or report about themselves.

This guideline outlines what form of record-keeping is acceptable to the Board and what access to records is needed.

Acceptable record-keeping
Records containing the following information are acceptable to the Board:

The full name and occupation of the worker
The date and time of injury or report of exposure or illness
The date and time the injury, exposure, disease, or illness was reported to the employer or employer's representative
The name of witnesses
A description of how the injury, exposure, disease, or illness occurred
A description of the nature of the injury, exposure, disease, or illness
A description of the treatment given and any arrangements made relating to the worker
A description of any subsequent treatment given for the same injury, exposure, disease, or illness
The signature of the attendant or person giving first aid, and if possible, the signature of the worker receiving treatment

Access to records
Policy Item R3.19-1 states:

Where a person is entitled to have access under section 3.19, the access need not extend to all of the records. It should be limited to the minimum necessary to satisfy the purpose for which the access is required. If, for instance, access is required to investigate a claim for compensation, it would be limited to the records of the individual making the claim.

G3.20 Multiple employer workplaces

Issued March 30, 2004; Editorial Revision February 1, 2008

Regulatory excerpt
Section 3.20 of the OHS Regulation ("Regulation") states:

If workers of 2 or more employers are working at a workplace at the same time, the prime contractor must

(a) conduct an assessment of the circumstances of the workplace under section 3.16(2) in relation to all the workers in the workplace, and

(b) do everything that is reasonably practicable to establish and maintain the first aid equipment, supplies, facilities, first aid attendants and services required under section 3.16.

Purpose of guideline
The purpose of this guideline is to discuss the role of the prime contractor in providing first aid services. It also considers situations where a group of employers with adjacent workplaces provide a common first aid service.

Role of the prime contractor
The prime contractor will normally set up a central first aid service for the whole workplace or arrange for a subcontractor to do this. The prime contractor is the person defined under the Workers Compensation Act ("Act") as the owner of the workplace unless the owner enters into a written agreement with another party to assume the responsibilities of the prime contractor.

Where the first aid service is provided by agreement with another person or persons, the following guidelines are recommended:

The service should meet the requirements as to hazard classification, distance from hospital, and number of workers per shift of each workplace using it.
In considering the accessibility of the service, the demands on it by all workplaces using it must be considered. The number of workers per shift used to determine the level of service is the total number of workers in all these workplaces. In addition, consider any use of the service by members of the public visiting these workplaces.
In determining the location of the service, consider the need to provide first aid promptly. Also consider whether any workplaces are likely to create greater hazards and therefore make more use of the service.
The level and location of the service must allow for any restrictions on access that may occur at peak work periods.
Each employer participating in the service must separately comply with the obligation in section 3.19(1) to maintain records of all injuries and manifestations of disease at their own workplace. The service may also keep central records.
The service and each employer must restrict access to any first aid records to the persons authorized by section 3.19(3). Any person who has access to the records must under section 3.19(5) keep them confidential except as required for the legitimate purpose of their access.

The employer retains full legal responsibility for providing all first aid services for the workplace as required by Part 3 of the Regulation. If the service does not meet an obligation imposed on the employer, WorkSafeBC will hold the employer responsible, not the person agreeing to supply the service.

G3.21 Suspension and cancellation of first aid certificates

Issued August 31, 2007

Regulatory excerpt
Section 3.21 of the OHS Regulation ("Regulation") states:

(1) The first aid attendant must

(a) promptly provide injured workers with a level of care within the scope of the attendant's training and this Part,

(b) objectively record observed or reported signs and symptoms of injuries and exposures to contaminants covered by the Regulation, and

(c) refer for medical treatment workers with injuries considered by the first aid attendant as being serious or beyond the scope of the attendant's training.

(2) A first aid attendant must be physically and mentally capable of safely and effectively performing the required duties, and the Board may at any time require the attendant to provide a medical certificate.

(3) The first aid attendant is responsible, and has full authority, for all first aid treatment of an injured worker until responsibility for treatment is accepted

(a) at a place of medical treatment,

(b) by an ambulance service acceptable to the Board, or

(c) by a person with higher or equivalent first aid certification.

Section 195 of the Workers Compensation Act ("Act") provides:

195

(1) If the Board has reasonable grounds for believing that a person who holds a certificate issued under this Part or the regulations has breached a term or condition of the certificate or has otherwise contravened a provision of this Part or the regulations, the Board may, by order,

(a) cancel or suspend the certificate, or

(b) place a condition on the use of that certificate that the Board considers is necessary in the circumstances.

(2) An order under this section suspending a certificate must specify the length of time that the suspension is in effect or the condition that must be met before the suspension is no longer in effect.

Purpose of guideline
This guideline sets out the circumstances in which WorkSafeBC will consider suspending or cancelling a first aid certificate, and discusses the process by which first aid certificates are suspended or cancelled.

Background
Occupational first aid certificates are issued to first aid attendants by first aid agencies on behalf of WorkSafeBC. These agencies enter into an agreement with WorkSafeBC that permits them to issue first aid certificates to individuals.

WorkSafeBC has the authority to suspend or cancel these first aid certificates under s.195 of the Act.

Where a WorkSafeBC certification or prevention officer (officer) learns of circumstances that may indicate a lack of competence or misconduct on the part of a first aid attendant, the officer may consider suspending the attendant's certificate. The Manager of Certification Services may then consider further action, which could involve cancellation of the certificate.

When may a first aid certificate be suspended or cancelled?
Under section 195 of the Act, WorkSafeBC may cancel or suspend a first aid certificate where it has "reasonable grounds for believing" that the holder has

Breached a term or condition of the certificate
Contravened a provision of Part 3 of the Act or the Regulation

Section 3.21 of the Regulation sets out the requirements for the first aid attendant. The failure of an attendant to meet these obligations would be a contravention of the Regulation for the purposes of s.195 and may provide grounds for the suspension or cancellation of the certificate. Such circumstances would include failing to

Promptly provide injured workers with a level of care within the scope of the attendant's training and in accordance with sections 3.14 through 3.21 of the Regulation
Objectively record observed or reported signs and symptoms of injuries and exposures to contaminants
Refer for medical treatment workers with injuries considered by the first aid attendant as being serious or beyond the scope of the attendant's training
Be physically and mentally capable of safely and effectively performing the required duties

Policy D12-195-1 sets out an additional list of inappropriate conduct for first aid attendants, which may be considered to be failing to provide workers with an appropriate level of care under s.3.21, including

Smoking while assessing or treating an injured worker and/or while handling oxygen therapy equipment, or permitting others to do so
Failing to use the assessment and injury treatment techniques outlined in first aid training courses unless conditions precluded them
Conduct that poses an unreasonable threat to the safety and well-being of other workers or the public
Removing themselves from being able to see or hear any summons for first aid at a workplace
Abandoning an injured worker after beginning assessment or treatment
Refusing to treat an injured worker when acting as a designated first aid attendant
Treating or transporting an injured worker while impaired or under the influence of drugs or alcohol

Failing to provide competent care, failing to ensure first aid records are kept, and using intoxicants while on duty are common grounds for suspending and/or cancelling of certificates.

Process for suspending or cancelling a first aid certificate
There are two stages to suspending and/or cancelling of an occupational first aid certificate. The first stage, a temporary suspension, involves an officer seizing the certificate from the attendant and forwarding it to the Manager of Certification Services. The second stage involves the Manager of Certification Services reviewing the circumstances leading to the suspension and making a determination on what further action should be taken. The Manager may cancel the certificate, return it to the attendant, or place conditions based on the review.

Stage 1: Officer's Interim Suspension
Before a first aid certificate may be suspended or cancelled, WorkSafeBC must have "reasonable grounds for believing" that a contravention of the Act or Regulation or a breach of the terms of the attendant's certificate has occurred. While a finding of "reasonable grounds" does not require absolute proof that circumstances amounting to non-compliance have occurred, it does require that the officer undertake an investigation of the circumstances in question to ensure the suspension or cancellation is reasonable.

The officer's investigation should include the following:

Review the employer's incident investigation document
Review the worksite written procedures to ensure there is clear direction for attendant response
Inspect attendant training and orientation records
Provide the attendant an opportunity to offer his/her account of the circumstances
Interview all persons who may have relevant information before making the decision to suspend the certificate

Once the investigation is complete, and the officer thinks there are reasonable grounds for concluding that the attendant has failed to comply with the Act, Regulation, or the terms of the certificate, the officer will

Issue an Order to Worker suspending the first aid certificate

This order must specify the length of time that the suspension is in effect (as required by s.195(2) of the Act). The duration of the suspension may be up to seven days pending review by the manager of Certification Services.

Note: The officer may also consider issuing orders to the employer or other workplace parties in connection with the circumstances, as appropriate.
Notify the employer of the suspension of the certificate
Forward evidence supporting the suspension, any evidence offered by the attendant in his/her defense, and the outcome of the employer's investigation to Certification Services

Stage 2: Cancellation or Other Action
Once the officer's evidence is forwarded to Certification Services, the Manager of Certification Services will undertake a review of the circumstances and make a final determination with respect to the first aid certificate. This may include issuing a warning, placing a condition on the certificate, further suspension, or cancellation of the certificate.

The type of action the Manager takes will depend on the circumstances of each case. Factors that will be considered include

The risk of harm to workers caused by the breach, the potential severity of that harm, and the number of workers put at risk
The potential for future risk to workers should the attendant be allowed to continue to provide services
Whether the breach was caused by carelessness, recklessness, willful blindness, or intentionally
The need to maintain public or stakeholder confidence in first aid services in general

Once the Manager has made a determination, a letter is forwarded to the attendant notifying him/her of the Manager's decision and specifying the conditions under which reinstatement may occur. The letter also advises of the right to appeal. A "Request for Review" form is included with the letter.

The employer is notified if the attendant's certificate is cancelled. The training agency that issued the certificate is also notified of the cancellation.

Review and Appeal
Section 96.2(1)(c) of the Act provides that a person may request a review officer to review "a Board order, a refusal to make a Board order, a variation of a Board order or a cancellation of a Board order respecting an occupational health or safety matter under Part 3." Please refer to the "Reviews and Appeals" section of the OFA1 Standard.

Guidelines Part 3 - First aid supplementary materials

The following supplementary materials support OHS guidelines G3.14 to G3.20:

Assigned Hazard Rating List

"L" represents low;
"M" represents moderate;
"H" represents high

N.E.S. means not elsewhere specified

Abrasives-Mfg.	M
Acetylene Gas-Mfg.	H
Acetylene Welding	M
Acids-Mfg.	M
Acoustical Contractors	M
Adding Machines-Mfg. or repairs	L
Aerials-Erection	H
Air Conditioning Contractors	M
Air Transportation-Air Personnel	M
Air Transportation-Ground Personnel	M
Airport Construction	H
Alcoholic Beverages-Mfg.	M
Alkalis-Mfg.	M
Aluminum-Smelter	H
Ambulance Service	M
Amusement Parks	L
Animal Breeding	M
Animal Foods-Canning	M
Apartment Buildings-Operation	L
Apiary	L
Appliance Rental	L
Appliances-Household Electrical-Mfg. or Repairs	M
Appliances-Transmission Line-installation	H
Architecture	L
Argent Recovery Process	L
Armaments-Mfg.	H
Armature Rewinding-Small Motors-No Installation Work	M
Arsenical Products-Mfg.	M
Artificial Ice-Mfg.	M
Artificial Insemination Station	M
Artificial Limbs-Mfg.	M
Asbestos Mining	H
Asphalt Paving Material-Mfg.	H
Asphalt Roofing-Application	M
Asphalt Roofing, Shingles, Siding or Tile-Mfg.	M
Assaying	M
Auctioneering Establishment	L
Auto Courts or Trailer Courts	L
Automobile Driving Schools	L
Automobile Painting, Repairs or Sales	M
Automobile Rental	L
Automobile Springs-Mfg.	M
Awnings-Mfg.	M
Babbitt-Mfg.	M
Baggage Transfer Service	M
Bags-Plastic or Paper-Mfg.	M
Bags or Trunks-Mfg.	M
Bakeries or Distribution of Bakery Products	M
Barber Shops	L
Barber Supply Houses	L
Barrels-Wooden-Mfg.	H
Bath Service-Steam	L
Batteries-Mfg.	M
Beauticians' Supply Houses	L
Beauty Salons	L
Beds-Iron or Bedsprings-Mfg.	M
Beekeeping	L
Belting-Rubber-Mfg.	M
Berry Farms	M
Beverages-Alcoholic-Mfg.	M
Beverage-Non Alcoholic-Mfg.	M

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Guidelines Part 3

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OCCUPATIONAL HEALTH AND SAFETY PROGRAMS

CORRECTION OF UNSAFE CONDITIONS

REFUSAL OF UNSAFE WORK

OCCUPATIONAL FIRST AID - Added March 30, 2004

FIRST AID SUPPLEMENTARY MATERIALS - Added March 30, 2004

YOUNG OR NEW WORKERS

Guidelines Part 3 - Occupational health and safety programs

G3.1 Occupational health and safety program

G3.1-2 Farm labour contractors and growers - Responsibilities and OHS programs

G3.2 "Less formal" occupational health and safety (OHS) programs

Guidelines Part 3 - Correction of unsafe conditions

G3.11 Emergency circumstances

Guidelines Part 3 - Refusal of unsafe work

G3.12 Refusal of unsafe work

Guidelines Part 3 - Occupational first aid

G3.14 to G3.20 First aid guidelines for employers

G3.14 First aid attendant certification, qualifications and general responsibilities

G3.16 First aid assessment

G3.17 Developing and implementing first aid procedures

G3.17(1)-1 Implementing an early defibrillation program in the workplace

G3.18(1) Communications

G3.18(2) Availability of first aid attendant

G3.19 First aid records

G3.20 Multiple employer workplaces

G3.21 Suspension and cancellation of first aid certificates

Guidelines Part 3 - First aid supplementary materials

Assigned Hazard Rating List