When you perform Health & Safety Induction, the question often arises, “what must be covered?” Rudy Maritz takes a look at what the Occupational Health & Safety Act says about “induction” and what must be covered.
The term “induction” is not defined in the Occupational Health & Safety Act, 1993 of South Africa. In fact, the first time it ever appeared in the safety law books, was in the 2014 amendment to the Construction Regulations. But H&S induction has been around for many years as an element of H&S Awareness training. Induction is generally defined as the action or process of inducting someone to a post or organization. In other words, it is a form of information transfer to a new employee.
In the context of South African safety law, the first encounter with induction can be found in the Duty to Inform clauses in Section 13 of the OHS Act. This requires the following to be disclosed to an employee:
- The hazards associated with the work to be performed, an article or substance to be produced, processed, handled, used, transported or stored and the use of plant and machinery to which the employee is to be exposed to.
- The precautions to be taken by the employee, to prevent these hazards materialising into injury or illness.
- The Act then goes a bit further in Section 8(2)(j) by including the duty to inform all employees regarding their scope of authority in terms of Section 37(1)(b).
The Act is not specific in terms of the content of a H&S Induction program but specific regulations include more specific requirements. And when combining these specific requirements, the overall view of the intention of the lawmaker is that an induction program should at least contain these elements:
- The contents and scope of the applicable regulations,
- Potential sources of exposure to hazards
- The health risks to exposed employees, their families and others due to taking home of contaminated materials and clothing,
- Measures to be taken by the employer to protect employees against these risks,
- The importance of good housekeeping and personal hygiene,
- The precautions to be taken by the employees including the use and wearing of personal protective clothing and respiratory protection equipment,
- The necessity of PPE and engineering controls provided as well as the potential of these measures to provide protection,
- The need for risk assessments, air & biological sampling and the necessity of medical surveillance,
- The safe work procedures that applies to the workplace,
- The procedures to be followed by employees in the event of exposure, spillage, dust release, injury or any similar emergency situation,
- The occupational exposure limit of any substance or stress factor
- Procedures for reporting and correcting defects
- Procedures for safe disposal of waste
- Procedures for record keeping, and
- The duties of employees in respect of safe handling of specific hazardous items
Frequency of Induction
Induction should not be seen as “ongoing awareness training”, but as an entry level process for new employees, or where an employee transfer from one section or deparment to another. It is therefor sufficient to do it once off as an “Induction program”
Format of Presentation
I have sat in a few so-called induction sessions, some presented by an appointed “induction officer” and pitched at labourers, and others merely a regurgitation of the “important” parts of the Act and some regulations. None of which have made me any wiser as to what will fall on me when I leave the training centre or site container.
And one form of “induction” that made me almost quit health & safety, was the “forced” induction syllabis. I recall me standing on a busy street corner in Cape Town, doing an onsite induction required by the Construction Regulations to a group of 20 odd workers about to start a trench (1 meter deep) for fibre optic cables. The client insisted we include their Absolute Rules in the induction program, which included for one, the prohibition of transporting people at the back of a truck or bakkie. I knew they arrived on site on the back of an 8 ton truck, as there is was no feasible alternative, but I told them, they need to walk home, or take a bus. That is not negotiable.I still remember their smiling faces.
But the real insult to my intelligence came when I told the excavation team that it is forbidden to work at heights without a harness. As I said it, I could not help but wonder what an ignorant passer-by would think upon hearing my instructions. And suddenly I wondered what the employees must be thinking. “Is he a moron or what?” True as it (the rule) may be, I could just as well have quoted the exchange-rate; both are totally irrelevant to the task at hand.
Stick to facts, not conjured fantasy
When presenting an induction program, it must be a formal training program, with, if you want, a little test afterwards to see if your message actually came across. But the Golden Rule, (Not the Absolute one) is to make sure you address “just” what they need to work in their environment. Stop wasting time Inducting people for the sake of “meeting a system requirement”. Change your system, but do not make a mockery of induction, unless you want to make a mockery of your LTIFR.
Keep the the three over-arching principles
- What is my hazards,
- What is my precautions against injury or illness, and
- What is my authority to decide what to adhere to and what not?
SAVE TIME; SAVE LIVES!
Your Induction program should, like anything else in your OHS program, be Risk Based. Why talk about risks that does not exist?
Have fun, and remember to check the air-vents on your submarine doors before you dive:-)