Carrier Occupational Health and Safety Systems: The Key Actors

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Introduction

Welcome back to article four of ten in this series on carrier safety management systems.  Previous articles have explained why systems allow individuals and organisations to meet objectives and we have dived into parts of a typical carrier safety system.  In this article, I will provide a high-level overview of the occupational health and safety (OHS) component of a carrier’s safety system.

In the trucking industry, companies frequently segregate compliance requirements with National Safety Code (NSC)-related legislation and OHS legislation.  Many companies ignore their OHS responsibilities and focus on NSC; for companies that strictly operate over-the-road fleets and don’t have their own facilities, OHS may not seem as important as the on-road safety elements for the company.

All trucking companies have to comply with the OHS legislation that applies to their organisation.  Carrier management needs to know if they are Provincially or Federally regulated in order to understand what legislation applies [1].  Once this is known, the safety system needs to manage OHS responsibilities alongside those that specifically relate to transportation and fleet management.

The following sections will address the different actors that play roles in an OHS system present in a carrier.  My main objective in including this article in this series is to temporarily draw attention away from safety topics that are specific to the transportation industry and remind carrier managers that even though all transportation-related safety matters are addressed adequately by their system, the world of OHS - which applies to all employers - needs to be addressed by the organisation, too.

Actors in the OHS System

An actor is a role that plays a part in a system - at least that is how I am using the term in this article.  It describes a set of responsibilities and an overarching purpose that may be held by one person, a group of people, or just be part of a single person’s job description.  In this way, “actor” refers more to a set of responsibilities than it does to a single person, and a single carrier may have multiple individuals who have tasks in their job description that can be found in several of the following subsections.

Occupational health and safety (OHS) requirements and transportation safety requirements are typically similar in spirit: they are concerned with taking precautions to protect the health and safety of workers and anyone else who may come into contact with the company’s operations.  I will now show how everyone has some part to play in the OHS management system, regardless of their status as a driver, worker, or manager.

Drivers

Drivers probably receive the most attention in a trucking company when it comes to safety.  However, a lot of the attention the industry pays to driver safety has to do with the actual task of driving vehicles.  There is nothing wrong with this since driving is likely the most hazardous task most drivers undertake at a company and insurance costs dictate that an emphasis be placed on on-road safety; but, drivers undertake many non-driving tasks that require attention from a health and safety perspective.  These non-driving tasks can also result in injuries that can increase the company’s Workers’ Compensation Board (WCB) premiums.

OHS regulations require organisations to ensure that hazards related to the driver’s job description be identified and appropriate controls implemented to ensure their health and safety are protected [2, 3].  This means tasks like using trailer dolly leg cranks and climbing in and out of trucks and trailers require attention from the carrier’s safety program.

Drivers have requirements to participate in the health and safety system the employer puts into use.  If they train other, newer drivers, then the senior driver may be considered to have taken a supervisory position which can come with additional OHS responsibilities.

Non-Driving Workers

All workers and contractors under the direction of the carrier require protection from work-related hazards.  While drivers may have the most dangerous job, all workers are exposed to occupational hazards and require attention from the OHS system.

If a carrier employs office workers, shop technicians, yard workers, and other support staff, the safety system should identify and document hazards present to all of these workers.  Once done, action needs to be taken to reduce the likelihood of these hazards harming the workers.

Depending on the size of the company, there may be a requirement for a health and safety committee to be established and this will require the participation of employer and employee representatives.  In this way, OHS systems require a certain amount of collaboration; the feedback generated from the diverse inputs when workers and management collaborate is valuable in that it can help guide the OHS system.

Management

Management, which in this sense includes senior managers and company owners, bears the ultimate responsibility for everything related to safety and compliance.  At a minimum, the OHS system at a company should report to management and influence operations; ideally, the safety management system is fully integrated into the company’s overall management system and management considers the safety and compliance consequences of all of their decisions.

Management’s role in the OHS system is to act on information presented to them and direct operations in a way that is consistent with health and safety best practices.  Management has the ability to override any safety-related recommendation.  As a result, management must understand that they may do considerable harm if they do not consider the wellbeing of their workers when making business decisions since no one else within the organisation can hold them accountable; instead, they answer to law enforcement and the court system.

Safety Manager

The safety manager is the person who manages and modifies the OHS system in a company; depending on the size of the company, this person may also administer most parts of the system and may have other non-OHS-related duties. 

Safety managers collaborate with the carrier’s senior management to set OHS goals for the organisation and report on system performance.  When problems are identified, the safety manager may modify the system as needed to better protect worker health and safety.

Safety Coordinators

In organisations that are large enough to have multiple safety people, safety coordinators work under the direction of the safety manager and help administer parts of the OHS system.  When multiple sites are involved, some may be stationed at different sites.

There is a lot of safety-related work at a carrier; some examples include worker/driver training, incident reporting and investigation, compliance monitoring, and internal auditing.  Depending on the demands of the carrier, some individuals may have titles like “driver trainer” or “internal auditor”.

OHS officers - Inspections and Investigations

The Federal and Provincial Governments in Canada employ individuals who normally hold peace officer status and are tasked with enforcing OHS legislation.  These officers are not company workers, but provide feedback for the OHS system through their inspection and investigation activity.  They are also excellent contacts for safety professionals as they can provide valuable interpretive guidance for OHS legislation.

Much of the work that OHS officers do - besides community outreach and education - can be categorised either as inspection- or investigation-related.  Inspection activities include performing random inspections of workplaces for compliance or in response to enforcement directives.  Investigation activities take the form of responding to a complaint or conducting an incident investigation when workers are injured or killed.

Auditors - Internal and External

An OHS auditor is someone who examines the health and safety system of an organisation to assess its performance.  Sometimes this is done to assess compliance with the law; other times, it is done to assess compliance with a voluntary standard that an organisation might be pursuing.  OHS officers conducting an inspection of a carrier’s OHS system may be considered external compliance auditors.

Internal Auditors

Carriers that hold a voluntary safety standard like an Alberta Certificate of Recognition (COR) may have someone on staff who is qualified to audit the carrier’s OHS system [4].  This person provides regular and valuable feedback for the OHS system management since they are able to assess the system’s performance on an ongoing basis.

External Auditors

Carriers often use external auditors to assess their safety system performance.  Sometimes, this is a requirement to obtain and maintain a voluntary safety standard like a COR.

Many safety consultants in OHS and in carrier compliance can act as an auditor in addition to consulting.  Through these activities, an external perspective can be brought into the organisation to troubleshoot weak areas of safety and compliance.

Summary

Trucking companies are often most concerned with the safety and compliance activities that relate to the task of driving commercial vehicles on public roadways.  However, occupational health and safety requires attention from the carrier’s safety system.  While the remaining articles in this series will focus on National Safety Code-related topics, safety professionals in the trucking industry should familiarise themselves with all safety regulations that apply to their operations.

References

1 - “List of federally regulated industries and workplaces”, Government of Canada, accessed September 12th, 2021, https://www.canada.ca/en/services/jobs/workplace/federally-regulated-industries.html

2 - “Part 2 Hazard Assessment, Elimination and Control”, Alberta Occupational Health and Safety Code, Alberta Regulation 87/2009, Government of Alberta, accessed September 12th, 2021, https://www.qp.alberta.ca/1266.cfm?page=2009_087.cfm&leg_type=Regs&isbncln=9780779818730

3 - “Specific duties of employer”, Canada Labour Code, R.S.C. 1985 c. L-2, Government of Canada, accessed September 12th, 2021, https://laws-lois.justice.gc.ca/eng/acts/L-2/FullText.html

4 - “Get a Certificate of Recognition (COR)”, Government of Alberta, accessed September 12th, 2021, https://www.alberta.ca/get-certificate-recognition.aspx

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Dave Elniski

Since graduating from the University of Lethbridge in 2013 with a Bachelor’s degree in biological sciences and women and gender studies, my professional life has included work in health care, the Canadian military, speech and presentation training, writing, and the trucking industry.

My Bachelor’s degree included research in both biology and women and gender studies. This combination of science and social science research has given me a unique skill set for solving problems for organisations.

I have received my Certified Transportation Safety Professional (CTSP) designation from the Alberta Motor Transport Association (AMTA) and am proud to be amongst the first graduates of the program. The CTSP stands out from other safety credentials as it is specifically designed for the transportation industry.

My Associate Diploma (ATCL) from the Trinity College London, England has given me specific skills and techniques for delivering speeches and presentations. These are skills that help me communicate ideas to stakeholders.

I have worked in the trucking industry as a driver and safety professional, and the majority of that has been with companies hauling flatbed freight in Canada and the USA. In that time, I have written on a variety of topics and regularly contribute to industry publications.