Step-by-Step Process for Sharps Safety Initiative
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What must you do?
1. a. Place the issue of
Sharps Safety on the next Joint Health and Safety Committee (JHSC) agenda.
b. If your workplace
requires a Health and Safety (H & S) Representative (workplaces with 5-19
workers) the H & S Representative should complete the checklist and
implement this initiative by going directly to the employer with your
2. At this meeting,
designate members of the JHSC, from worker and employer, to complete the
attached checklist (time to complete it should be paid as part of the JHSC’s
3. Ensure that the
completed checklist is distributed to all committee members prior to the
JHSC meeting where it will be discussed and prior to worker caucus meeting.
4. Prearrange to caucus
with all worker members of the JHSC at least one hour before the meeting
[Section 9 (34) Occupational Health and Safety Act (OHSA)] to discuss the
completed checklist and the adequacy of the employer’s current sharps
exposure control plan/program. It is important to have consensus from the
other worker members to move this issue forward.
The OHSA states that all
members of the committee are entitled to one hour or longer, as the
committee determines is necessary, to prepare before each and every JHSC
meeting. The JHSC makes this determination, not the employer. If your
supervisor or employer refuses to allow workers time to caucus before a JHSC
meeting, immediately call the Ministry of Labour. Your union representative
can assist you if you are uncertain about how to do this.
5. If the Sharps Exposure Control Plan is non-existent or
deficient based on the checklist, draft written recommendations for
presentation at your next JHSC meeting by modifying the attached sample
recommendation. (An electronic Word version can be found on your union’s
6. It is not the JHSC’s or the H & S Representative’s job
to write the exposure control plan/program/training materials for the
employer. The JHSC (or H & S Representative), in a written recommendation,
a. Recommend that the employer develop or revise the
Sharps Exposure Control Plan/Program and training.
b. Recommend that the employer ensure all supervisors,
including nurses and physicians acting in the capacity of supervisor are
trained to meet the definition of a “competent person” under the OHSA
c. Refer the employer to the Ontario Safety Association for
Community and Healthcare (OSACH) Planning Guide (found at http://www.osach.ca/products/SEMS/introduction.html)
d. Refer the employer to the Vancouver Island Health
Authority (VIHA) Exposure Control Plan for Blood and Body Fluids (found at
e. Refer to the sample recommendation (found on your
union’s website). The JHSC (or H & S Representative) should also point out that
OSACH has representatives who can assist your employer.
7. Propose the recommendations at the JHSC meeting. If the
JHSC as a whole cannot agree to make the recommendations to the employer, call
the Ministry of Labour (MOL) with a formal union complaint (you must actually
say it’s a formal complaint). (MOL’s phone directory for regional offices can be
http://www.labour.gov.on.ca/english/about/reg_offices.html). Explain that
your committee cannot resolve this issue and, as a result, unsafe working
conditions persist. NB: The “employer” is usually the Chief Executive Officer (CEO)
or someone the CEO has appointed to handle all JHSC recommendations.
8. If the JHSC agrees to forward the written recommendations
as per the OHSA, your employer has 21 days to respond to the written
recommendations, including providing a time frame for implementation of the
recommendations [Section 9(20) & (21) of the OHSA or Section 8 (12) for
workplaces with a H & S Representative].
9. If the employer’s 21-day response will not resolve your
concerns as identified in the recommendations in whole or in part, call the MOL.
10. When you call the MOL, inform them that your JHSC (or H & S
Representative) has been unable to resolve the issue so workers continue to be
at risk. Explain that you have tried to get the employer to develop an exposure
control plan/program/training with adequate occupational health and safety
Also provide the MOL with
examples of any unsafe situations that you are aware of, such as:
a. Inadequate exposure
control plan/program (inadequate or no attention to worker health and safety).
b. A plan that was developed without consulting the JHSC
(or H & S Representative).
Let the MOL know that the employer is doing little or nothing to
resolve the problem. Being more specific at the time of the call will help the
MOL understand the urgent nature of the call.
11. If your call to the MOL does not resolve your concerns,
immediately advise your Union representative to determine options, which may
a. Filing grievances if your collective agreement permits.
b. Filing appeal of an unsatisfactory MOL decision (30-day
Post initiative activities
Once an appropriate exposure prevention plan is agreed upon, or
12. The JHSC (or H & S Representative) should ensure that an
implementation plan is in place and adhered to. If the employer unduly delays
implementation worker members should contact the MOL requesting an order for a
13. The JHSC (or H & S Representative) should assess that
appropriate training is being delivered.
14. The JHSC (or H & S Representative) should conduct ongoing
monitoring of program and review and/or revise the program at least yearly and
whenever there is a change of current knowledge and practice, such as when new
devices, technologies, or alternative methods become available.
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