Transportation Safety Board of Canada - Management Response and Action  Plan - Internal Audit of OSH
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English

Transportation Safety Board of Canada - Management Response and Action Plan - Internal Audit of OSH

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Description

TSB Management Response and Action Plan Internal Audit of OSH Training and PPE TSB management accepts the findings of this audit and generally agrees with the recommendations made by auditors. The detailed management responses and actions planned are described in the following tables. Recommendation 1 The National OSH Policy Committee should review the personal protection equipment policy and standards and attached guidelines and provide clarity in regards to maintenance, record keeping, and obligation for persons granted access to the sites. Management Management agrees that the PPE policy and standards Response need to be clarified. Actions Planned Review PPE policy and standards. Update and clarify PPE maintenance, record keeping and obligations for persons granted access to occurrence sites, where necessary. OPI PPE Sub-Committee Timeline End of Fiscal Year 2010 / 2011. Recommendation 2 The Manager of Human Resources in conjunction with Responsibility Centre managers should develop an orientation program for all new employees that includes a review of policies, overall responsibility for the implementation of the policies and information on the corporate reference centre and how to access policies on the intranet. As a best practice, the TSB should distribute their OSH policies annually to all employees as a part of National Occupational Health and safety week. Management Management agrees that new employees ...

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TSB Management Response and Action Plan
Internal Audit of OSH Training and PPE


TSB management accepts the findings of this audit and generally agrees with the
recommendations made by auditors. The detailed management responses and actions
planned are described in the following tables.


Recommendation 1 The National OSH Policy Committee should review the
personal protection equipment policy and standards and
attached guidelines and provide clarity in regards to
maintenance, record keeping, and obligation for persons
granted access to the sites.

Management Management agrees that the PPE policy and standards
Response need to be clarified.

Actions Planned Review PPE policy and standards.

Update and clarify PPE maintenance, record keeping and
obligations for persons granted access to occurrence sites,
where necessary.

OPI PPE Sub-Committee

Timeline End of Fiscal Year 2010 / 2011.


Recommendation 2 The Manager of Human Resources in conjunction with
Responsibility Centre managers should develop an
orientation program for all new employees that includes a
review of policies, overall responsibility for the
implementation of the policies and information on the
corporate reference centre and how to access policies on
the intranet. As a best practice, the TSB should distribute
their OSH policies annually to all employees as a part of
National Occupational Health and safety week.

Management Management agrees that new employees must be informed
Response on TSB’s OSH policies and that all employees be reminded
on a regular basis of these policies.

Actions Planned The new employee orientation session will be modified to
remind employees of Management’s responsibility to brief
employees on OSH policies and requirements.

The new employee orientation session, which includes
instructions on how to access TSB’s Reference Centre
where all policies are filed, will be delivered on an on-going
basis.

The orientation checklist provided to new employees will be
modified to include an item for briefing employees on OSH
policies.

Annual reminders on OSH policies, as part of the OSH
Safety Week, will be sent out to employees.

OPI Manager of Human Resources / OSH National Policy
Committee

Timeline End of Fiscal Year 2010 / 2011.


Recommendation 3 A comprehensive tool or system should be implemented to
monitor:
 types of OSH training required,
 mandatory completion or renewal dates, and
 actual training completed for each employee.
The system should contain a notification or reminder function
for mandatory dates and managers should be accountable
for ensuring that notifications are acted upon and that
training is received in a timely fashion.

Management Management agrees that a better monitoring and tracking
Response tool for OSH training is required.

Actions Planned Once the Training and Standards Division is created, this
Division will work with Human Resources to identify and
implement suitable systems to track and report on all
training, including OSH.

The Training and Standards Division, in conjunction with the
OSH National Policy Committee, will ensure that clear
training standards for the required OSH training are
established.
In the interim, a communiqué will be issued to managers and
employees reminding them of their obligation to remain
current on OSH training.

OPI Manager of Training and Standards

Timeline Fall 2011.


Recommendation 4 Responsibility Centre Managers should be responsible for
entering information and maintaining accurate records within
the provided system. Further, they should institute a point of
control to ensure that courses approved are completed by
the employee, that the information is entered into HRIS, and
that certifications or proof of attendance is included in
individual training files.

Management Management agrees that accurate information and training
Response records must be captured and inputted into selected system.

The option selected for maintaining the OSH Training
Records (see Recommendation 3) will influence how the
records are entered and what documentation is maintained.

Actions Planned When conducting the review of options for the OSH Training
Monitoring System, the requirements identified in this
Recommendation will be considered.

Where required and feasible, the appropriate functionality
will be implemented into the selected system (see
Recommendation 3).

Until a new system is implemented, HR will work with the RC
Managers to ensure that OSH Training Forms are
completed, approved and entered into the HRIS system by
the Branch Administration Officer. A copy of the OSH
Training Form will be sent to HR for entry verification and
filing.

OPI Manager of Human Resources

Timeline End of Fiscal Year 2010 / 2011.

Recommendation 5 The Directors of Investigations should mandate a
documented site safety assessment. The site safety
assessment should identify hazards that would allow
Investigators to assess the minimum OSH training required
for persons on site.

Management Management agrees that a site safety assessment should be
Response documented for all occurrence sites.

Actions Planned A Site Safety Assessment Form will be developed and
implemented across all modes.

OPI DOI – Air

Timeline Fall 2010.


Recommendation 6 The Manager of Finance and Administration should review
practices for maintaining a PPE inventory to ensure that
requests for PPE can be filled in a timely fashion.
Additionally, expired equipment and equipment that no
longer meets the specifications identified in the TSB PPE
standards should be removed from inventory.

Management Management agrees that obsolete equipment must be
Response disposed and inventory management practices need to be
improved.

Actions Planned Review, update and implement changes (if necessary) to the
practices for maintaining a PPE inventory.

Remove and appropriately dispose of all expired PPE
equipment and PPE equipment that no longer meets TSB
requirements.

OPI Manager of Finance / Administration

Timeline Fall 2010.


Recommendation 7 Responsibility Centre Managers should enforce the policy
guidelines by ensuring administrative officers maintain complete and accurate information on PPE issued to
employees.

Management Management agrees that recordkeeping for PPE must be
Response improved.

Actions Planned Determine how this information is currently captured and
maintained.

Develop and update guidelines for capturing and maintaining
this information on a consistent basis across all TSB offices.

Notify RC Managers and Administrative Officers of the new
policy guidelines.

OPI PPE Sub-committee.

Timeline End of Fiscal Year 2010 / 2011.


Recommendation 8 The Directors of Investigations should mandate a
documented site safety assessment. The site safety
assessment should identify hazards that would allow
Investigators to assess minimum PPE requirements for
persons on site.

Management Management agrees that a site safety assessment should be
Response documented for all occurrence sites.

Actions Planned A Site Safety Assessment Form will be developed and
implemented across all modes (see Recommendation 5).

OPI DOI – Air

Timeline Fall 2010.


Recommendation 9 The Directors of Investigations should enforce the use of
appropriate PPE as per the policy.

Management Management agrees that the use of appropriate PPE (as per
Response the policy) must be enforced. Actions Planned Prepare and disseminate a communiqué to all personnel that
have been issued PPE regarding compliance to the use of
appropriate PPE.

Develop guidelines on how to monitor for compliance to the
use of appropriate PPE.

Develop guidelines on how to handle situations when
appropriate PPE is not used.

OPI PPE Sub-Committee

Timeline End of Fiscal Year 2010 / 2011.


Recommendation 10 The National OSH Policy Committee should update the
existing OSH PPE standards to include minimum PPE
requirements for accident investigation sites.

Management Management agrees in principle that existing OSH PPE
Response standards should include minimum PPE requirements for
accident sites.

However, individual minimum PPE requirements may be
developed for each mode if an overall consolidated minimum
list cannot be identified.

Actions Planned Refer to Actions Planned for Recommendation 1.

OPI PPE Sub-Committee

Timeline End of Fiscal Year 2010 / 2011.



Recommendation 11 Managers should institute an annual process requesting that
employees review the PPE that they ha

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