Required Construction Documents Part 3: Health and Safety Policy by Steven Silva

As stated in my previous blog, Required Construction Documents Part 1 and Required Construction Documents Part 2, I require the 3 following documents to be provided IN ADVANCE by all contractors before I allow them to start work : 1- Registration of Constructors (MOL Form 1000), 2-Copy of a Workplace Safety and Insurance Board (WSIB) Clearance Certificate, 3-Copy of the contractors Health and Safety Policy.  When I ask for these documents, I know exactly who I am dealing with (thanks to the form 1000), I will hold them responsible for any accidents that may occur on my site (since they are insured by WSIB) and I expect them to be safe and follow their own Health and Safety Policy.

The Health and Safety Policy Statement is all that is required. It is a one page document (usually part of their whole Health and Safety Program which is usually many pages long). Take a look at my Health and Safety Policy Statement. This is my current policy for my Construction/Consulting company.

There are four things that I look for (as does the Ministry Of Labour) in order to make it valid.

1: It must say Health and Safety Policy on it.  Sometimes the policy is embedded in their Health and Safety Policy Program and Manual. If I have the whole thing then it is usually fine but if I have only one page and it doesn’t say what it is then how can I be sure.

2. The policy must be from the Owner, CEO, COO or whom ever has control over the WHOLE company  (it isn’t acceptable if a supervisor’s name is on it).

3. Is it Signed. There must be a signature of the person in charge. Without a signature it might as well be a printed draft.

4. Is the date on the Policy LESS than one year old. The policy MUST updated at least once a year. In theory, every company is supposed to review and update the health and safety program once a year. The signature with a recent date symbolizes that yearly renewed commitment to safety. If it is too old, it isn’t valid. The Inspectors won’t accept it so neither can I.

Be Careful though, you will be held accountable for any statements a company makes their policy. For example, in my policy I wrote “Accident prevention practices and safety training are some ways in which our company endorses and implements safety.” Well, if someone gets hurt and it is shown that I haven’t actually trained anyone recently I’m in deeper trouble. If I have, where is the written proof. I would expect the Inspector to ask me questions based on my own policy statements. Only make true statements in your policy.