Report on the audit of Occupational Health and Security

Sharon Moren

Informations

• Publié par: Assa
• Nombre de lectures: 21
• Langue: English

Extrait

   

        TABLE OF CONTENTS

STATEMENT OF ASSURANCE ................................................................................................ i 

ABBREVIATIONS ...................................................................................................................... iii 

EXECUTIVE SUMMARY ...........................................................................................................1 

OVERALL MANAGEMENT RESPONSE ................................................................................5 

1. INTRODUCTION ..................................................................................................................7  1.1 Background........................................................................................................................7 1.2 OHS Organization .............................................................................................................7  1.3 Audit Objectives and Scope...............................................................................................9

2. OBSERVATIONS – MANAGEMENT FRAMEWORK..................................................11  2.1 Vacant Positions in NAOHS Division.............................................................................11 2.2 OHS Policy and Operations.............................................................................................12 2.3 Integrated Management System and Due Diligence .......................................................21 2.4 Tracking of OHS Activities and File Management .........................................................22 2.5 Training............................................................................................................................24 2.6 Risk Management ............................................................................................................26 2.7 Management Information System and Performance Reporting ......................................27

3. OBSERVATIONS, RECOMMENDATIONS AND MANAGEMENT RESPONSE.....31 

APPENDIX A – CONTEXTUAL INFORMATION ................................................................39 

APPENDIX B – AUDIT METHODOLOGY ............................................................................41     

 

STATEMENT OF ASSURANCE

    We have completed the internal audit of Occupational Health and Safety (OHS) Program at the Department of Justice. The overall objective of the audit was to review and assess the management control framework and the degree of compliance with the relevant provisions of the Canada Labour Code, Part II   and Regulations   as well   as   with Treasury Board and departmental OHS policies.     The internal audit was conducted in accordance with the requirements of the Treasury Board Secretariat Policy on Internal Audit and the Institute of Internal Auditor Standards of the Professional Practice of Internal Auditing.   The audit team assessed the management control framework against criteria derived from the Canadian Centre for Occupational Health and Safety (CCOHS) (a crown corporation), other recognized occupational health and safety organizations, and the Treasury Board Secretariat’s Management Accountability Framework.   In our professional judgment, sufficient and appropriate audit procedures have been conducted and evidence gathered to support the accuracy of the conclusions reached and contained in this report. The conclusions were based on the comparison of the situations as they existed at the time of the audit against the audit criteria. It should be noted that the conclusions are only applicable for the areas examined.      

 

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    Acronym   DGAD   DM DLSU DPP HRSDC HQ IRS JUSnet   KPI MAF MIS NAOH S NPHSC OHS PWGSC TB TBS WHSC      

 

Explanation

ABBREVIATIONS

Director General, Administration Directorate Deputy Minister Departmental Legal Services Unit Director of Public Prosecutions Human Resources and Social Development Services Canada Headquarters Internal Responsibility System Justice Technology Information Network Key Performance Indicator Management Accountability Framework Management Information System National Accommodations & Occupational Health & Safety National Policy Health and Safety Committee Occupational Health & Safety Public Works and Government Services Canada Treasury Board Treasury Board Secretariat Workplace Health and Safety Committee

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EXECUTIVE SUMMARY

    Background   We have completed the internal audit of occupational health and safety (OHS) at the Department of Justice. Our objectives were to   the management control framework within which thereview OHS programs operate, to assess the degree of compliance with theCanada Labour Code,Part II   and the Canada Occupational Health and Safety Regulations, as well as to assess compliance with the relevant Treasury Board Secretariat (TBS) and departmental policies. We also reviewed OHS interfaces with other federal departments and agencies. Our ultimate goal was to recommend improvements to OHS in the Department.   The audit took place from November 2007 to February 15, 2008. The scope included OHS activities at HQ and a review of the functional direction from NAOHS Division to the regions.   For fiscal year 2007-08, occupational health and safety programs in the Department of Justice had a staff of five full-time equivalents (FTEs) and an O&M budget of $110,929.   In accordance with TBS standards, the deputy minister (DM), as the senior officer of the Department, is responsible for OHS and has duly appointed the Director General, Administration Directorate (DGAD) to oversee these responsibilities. At the time of the audit, the National Accommodations & Occupational Health & Safety (NAOHS) Division had both operational and functional responsibility for OHS. The day-to-day operations of OHS programs were the responsibility of the Manager, OHS.   Management Framework   Vacant Positions in NAOHS Division   The NAOHS Division has had significant staff vacancies since it was created in late 2001. The key positions of Manager, OHS and Regional Liaison Officer were vacant for most of fiscal years 2002-06. These vacancies have had a negative impact on OHS activities and operations as well as on the achievement of intended results. The Manager, OHS position was staffed in early  1

Internal Audit Branch     2007, but near the end of the audit period the position again became vacant. This position needs to be staffed as soon as possible.   OHS Policy and Operations   The departmental OHS Policy, effective April 2003, details the policy principles as well as the roles and responsibilities of all parties including the Deputy Minister, OHS managers, the National Policy Health and Safety Committee (NPHSC), workplace health and safety committees (WHSC), employees, contractors, and visitors. The audit revealed that the current departmental OHS Policy is not clear and needs to be broadened. Duties and responsibilities are incomplete with regard to third party maintenance contracts and adequate and timely follow-up on identified hazards reported to committees. The OHS Policy does not refer to or mention important considerations such as a vision statement, references to the internal complaint resolution process, the prioritization of monthly inspections, or employee rights.   The responsibilities of the National Policy Health and Safety Committee include research, development, and implementation of certain health and safety program activities. We found that the NPHSC has accomplished worthwhile projects and established appropriate health and safety committees. Where senior management commitment is strong and fully functioning, these workplace health and safety committees are making a difference in the workplace. However, we noted a need to improve senior management’s commitment and support.   There is also a need for OHS management to develop the ways and means for ensuring sufficient financial and human resources for the NPHSC. One of the important responsibilities of the NPHSC is to monitor OHS activities on an ongoing basis. However, due to limited resources, staff turn-over, and/or absence of key OHS personnel, information or data about OHS activities or programs in the Department is either unstructured or not readily available. We found limited information on performance of any kind available for either 2006 or 2007. An appropriate database is required that will include information on the results of monitoring OHS activities. This will enable the Department to report on these results.   The Department of Justice interacts with and/or is required to report on its health and safety activities with other federal departments and agencies. We found these interfaces to be appropriate.    Workplace health and safety committees are adhering to inspection schedules and conducting inspections on a monthly basis. However, we have identified some recurring hazards that need immediate attention.   There is need for a monthly checklist of identified items that require

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Occupational Health and Safety Executive Summary   corrective action and for an assigned individual who is responsible for action and periodic follow-up.   An appropriate organizational status and operational framework will permit OHS programs to succeed and the intended results to be achieved. Our audit work revealed that roles, responsibilities, and interaction with, for example, human resources and other sectors need to be clarified and that an operational framework needs to be established.   Integrated Management System and Due Diligence   An internal responsibility system (IRS) is the underlying philosophy of occupational health and safety legislation in all Canadian jurisdictions. Closely associated is the due diligence concept that identifies the employer’s responsibility to undertake all reasonable precautions, under the particular circumstances, to prevent injuries or accidents in the workplace. Although due diligence has been shown by the Department of Justice, we noted a lack of an integrated management system that would identify its management functions or record its activities. Moreover, the audit revealed that OHS management has not developed an action plan. All of these matters are important aspects of due diligence. It is also important to document OHS development and progress over time. The Department needs to be able to readily demonstrate that all elements of an OHS integrated management system are in place over a period of time.   Tracking of OHS Activities and File Management   The tracking of activities and file management needs to be improved. OHS operations involve many actions, procedures, and processes. However, we found the associated information to be incomplete, in draft form, or out-of-date. Furthermore, there is no management control or registry of OHS documents and records. All OHS documents and records need to be identifiable, locatable, and readily available. There is a need for a document and record registry to be established and maintained. In addition, an administrator should be appointed who would be responsible for the management and control of all OHS documentation.   Training   Training is a critical component of the OHS Program. TheCanada Labour Code, Part II identifies specific training requirements. NAOHS Division offered several training sessions in the fall of 2007. However, due to a lack of documentation and recording, we were unable to establish the extent of training efforts since 2004. Since NAOHS Division is not monitoring training information, it is not known whether all new workplace health and safety committee

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Internal Audit Branch     members are receiving OHS training. We also found that NAOHS Division has not established a national OHS training framework or plan.   Risk Management   Risk management is an important tool in the decision-making process, more specifically in the management of OHS. Our assessment revealed that there is a need to integrate and document OHS activities, as it identifies, evaluates, and prioritizes hazards or risks and the ways and means for reducing those risks. Our audit revealed that risk management has mainly concentrated on security of individuals and not on risks relating to health and safety in the workplace.   Management Information System and Performance Reporting   Management information system and performance indicators are basic and key elements of accountability and departmental reporting. There is a need to develop an OHS management information system and performance indicators.   The management response to the recommendations contained in this report was submitted by the Director General, Administration.  

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OVERALL MANAGEMENT RESPONSE

    After the completion of Internal Audit’s fieldwork in February 2008, the new Safety, Security and Emergency Management Division (SSEMD) was created and the Departmental Occupational Health and Safety function, which formally rested with the National Accommodations and Occupational Health and Safety Division (NAOHS), was transferred to this new division. This step significantly transformed the approach to the national management and oversight of the Occupational Health and Safety Program at DoJ. With the department’s safety program now organizationally situated within the Departmental Security Program, the DoJ has a much more comprehensive and integrated Departmental program framework to address the core gaps for employee and occupant safety and security in the workplace. This new approach to Departmental Occupational Health and Safety includes a more resourced SSEM division, the creation of a framework for the new integrated functions within SSEMD, and the completion of a strategic business plan that is supported by a multi-year work plan of activities.   Significant attention is now being given to the Departmental Occupational Health and Safety, Building Emergency Response, Emergency Management (new program for DoJ) and Security Programs. SSEMD has received increased financial and human resources and has much improved its center of expertise.   SSEMD’s new mandate is to establish and maintain a level of safety and security that will protect employees, information and assets and to ensure the delivery of DoJ critical services during business disruptions and national emergencies. SSEMD is now better positioned to fulfil this mandate as a result of adopting an integrated safety and security program approach which focuses on prevention, awareness, risk management, emergency management response and business continuity planning. This new mandate directly supports the Deputy Minister and DoJ in meeting accountabilities and legal obligations under theCanada Labour Code   and its related safety   Regulations, the Government Security Policy and related standard for the Protection of Employees, theEmergency Management Act,the National Security Policy   and other key GOC policies, standards and initiatives for safety, security and emergency management.   While program challenges are being addressed and improved upon, ongoing and long term commitment and attention to this program is required from all Portfolio Sector and Regional

 

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