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This Code of Practice provides practical guidance on the requirements of Manitoba Regulation 217/2006 Part 9 -- Workers Working Alone or in Isolation -- adopted under The Workplace Safety and Health Act. This code does not replace either the regulation or The Act.
Employees can safely work alone or in isolation if they make proper hazard/risk assessments and implement safe work practices and procedures.
1. assist in the recognition of working alone or in isolation situations
2. assist in the development of safe work procedures for performing such tasks
3. supplement an employer’s regular training program for workers required to work alone or in isolation
4. assist members of workplace safety and health committees in identifying and making recommendations for hazard evaluation and control
This Code of Practice does not cover all circumstances under which a worker may be required to work alone or in isolation. It does not specify monitoring methods required for specific situations.
Employers must ensure they have considered and addressed the hazards and risks in jobs where workers work alone or in isolation, and that appropriate safe work procedures have been developed and implemented.
The key concepts contained in the regulation for workers working alone or in isolation are:
Selected extracts from The Workplace Safety and Health Act, on duties of employers, supervisors and employees in the workplace follow.
4(1)Every employer shall in accordance with this Act:
(b) comply with this Act and regulations.
4(2) Without limiting the generality of an employer's duty under subsection (1), every employer shall:
4(3) For the purposes of clause (2)(h), an employer may supervise his or her workers if he or she satisfies the criteria set out in that clause.
4(4) Without limiting the generality of clause (2)(b), every employer shall provide information, instruction and training to a worker to ensure, so far as is reasonably practicable, the safety, and health of the worker, before the worker:
4(5) Notwithstanding subsection (4), a worker may perform a work activity while being trained if the worker is under the direction of a supervisor or another person who is fully trained and has sufficient experience in performing that work activity to ensure that the safety or health of the worker and any other person is not at risk
4(6) A worker is entitled to the same wages and benefits for any time spent in training that he or she would be entitled to had the worker been performing his or her regular work duties during that time.
4.1 Every supervisor shall
5 Every worker while at work shall, in accordance with the objects and purposes of this Act,l
The entire Act and relevant parts of the regulation should be studied in detail in order to gain working knowledge of their requirements.
Working alone means the performance of any work function by a worker who:
"Working in isolation" means working in circumstances where assistance is not readily available in the event of injury, ill health or emergency.
The definition of working alone indicates that the regulation will apply to virtually all workers who are performing a job function when they are not in the presence of their employer, another person in a supervisory capacity (designated by the same employer), or another worker directly associated with the same employer, at the particular workplace location and during the same time period the working alone job function is being performed.
The definition of working in isolation refers to those persons whose work sometimes or regularly requires them to be at a worksite that is remote from other workers, depending on the physical set up of the facility in question, and in circumstances where assistance is not readily available in the event of injury, ill health or emergency
Many workers may fall into either category. However, in the case of working alone, they may be in contact with workers associated with a different employer or the general public. Such contact does not rule out the concept that the worker is working alone, and therefore this situation will require the same particular attention as outlined in the Regulation.
9.1 This part applies to every workplace where employees work alone or in isolation.
9.2(1) When a worker works alone or in isolation, an employer must identify the risks arising from the conditions and circumstances of the worker's work in consultation with:
9.2(2)An employer must, so far as is reasonably practicable, take steps to eliminate or reduce the identified risks to workers working alone or working in isolation.
9.3(2) Safe work procedures must include:
9.3(3) An employer must post a copy of the safe work procedures in a conspicuous place at the workplace.
9.3(4) An employer must review and revise the procedures not less than every three years or sooner if circumstances at a workplace change in a way that poses a risk to the safety or health of a worker working alone or in isolation.
Personal first aid kit for worker working alone
Part 5.13 of M.R. 217/2006 statesthat an employer must ensure a personal first aid kit, that meets the requirements of Schedule B of this part, is provided to a worker who works alone and who does not have ready access to a first aid kit required to be provided under subsection 5.12(1).
As previously mentioned, subsection 4 (2), clause (b) of The Workplace Safety and Health Act states that every employer shall "provide to all his workers such information, instruction, training, supervision and facilities to ensure, so far as is reasonably practicable, the safety, health and welfare at work of all his workers."
When workers are involved in working alone or in isolation situations, special consideration should be given to the fact that the worker may not be able to secure assistance, in the event of an incident, as readily as when working with a group of co-workers.
Within the context of ‘reasonably practicable’, both employers and workers have responsibilities and duties to undertake any job function in the safest manner, taking all reasonable care in each circumstance in order to minimize the possibility of an incident
Risk identification is normally referred to as a Job Hazard Analysis (JHA) or Job Safety Analysis (JSA). Resource Material regarding job hazard analysis as developed by the Canadian Centre for Occupational Safety and Health (CCOHS) is appended.
When assessing the conditions or circumstances under which the worker is required to work alone or in isolation, particular job functions will have inherent hazards associated with them that may be deemed as high risk, low risk or combinations of both. The degree of risk involved will not eliminate the requirement for developing safe work procedures to minimize these risks.
Examples of work functions that present high risk hazards may include:
Examples of work functions that present low risk may include:
The circumstances or conditions under which employees are required to work alone or in isolation must be assessed. Control methods / safe work procedures must be developed (in writing) and implemented to minimize the identified risks.
For the purpose of this regulation, the consultation process, with the safety and health committee or representative, is integral to the development and implementation of safe work procedures and training for employees…
The Workplace Safety and Health Act requires workplaces in the province of Manitoba to establish workplace safety and health committees where there are 20 or more employees. Workplaces with 10-19 employees must have a worker safety and health representative. For further information, refer to The Act, Manitoba Regulation 217/2006 Part 3, and the Workplace Safety and Health Division’s Guideline for Safety and Health Committees.
Under The Workplace Safety and Health Act, employers must consult and co-operate with the workplace safety and health committee or the worker safety and health representative. In workplaces where a committee or representative is not required (less than 10 employees), the Act requires employers to consult with workers at the workplace.
Written, safe-work procedures must include an effective communication system and a way for employees working alone or in isolation to get help if there’s an injury or other misfortune.
The following suggestions may be incorporated as part of the safe work procedures. Depending on the situation, the examples could represent control methods to minimize risks, ways to get help in an emergency or a combination of both.
Using a buddy system may be part of a safe work procedure. Employees who are required to enter a confined space where the risk assessment has identified the space to be (or may become) hazardous must have a standby person (buddy) present at the entrance at all times while the employee is in the space. (Please see the Workplace Safety and Health Division’s Code of Practice for Confined Space Entry Work for detailed information on the requirements for confined space entry work.)
In all buddy system situations, consideration must be given to the buddy's qualifications. The buddy must be knowledgeable about the activities of the employee he/she is observing, be properly equipped with emergency equipment, and be capable of putting preplanned rescue or emergency operations into effect.
With the buddy system, a second person's presence is required at all times. However, where the probability of serious consequence is high, the two employees must not be exposed to the hazard at the same time. The second person should be within sight, but safely removed from the immediate area.
The buddy system may not be practical in some situations. The consultation must address all factors to decide the best approach in developing safe work procedures
In many instances, checking the worker's well-being can be done through periodic visits at regular intervals by an individual, such as the employer, another employee or someone designated by the employer.
The length of time between checks will depend on the identified risks of the job function.
As indicated with the buddy system, the person designated to check the employee working alone must be knowledgeable about that employee’s activities and must be capable of putting preplanned emergency operations into effect. Contact with the general public (Ex: passers by) is not considered an adequate control method. However depending on the activity, this control method may become part of a safe work procedure for working in isolation.
Use of the telephone for communication at regular intervals may be adequate in low risk situations. Telephone numbers for routine calling and emergency situations must be posted prominently.
An example could include a night security person’s function at a location which has been determined to have low risk. Security personnel could call in to their dispatch offices at regular intervals, (Ex: every hour before starting their rounds). The intervals between these contacts would have to be determined by the estimated hazards at the workplace. Regulating phone calls to specific times during that work activity may reduce the number of false alarms.
Protection of employees who do routine jobs will change when that job is performed in non-routine conditions. This includes such things as the absence of other employees in the workplace or when the job is performed outside of normal working hours for that employee. Even for low hazard activities, such as office work, the employee should be instructed in safe work procedures for working alone.
Mechanical or electrical surveillance equipment may be used in a working alone or in solation situation. The security systems in use at the workplace may be modified to monitor a particular employee who is working alone or in isolation as well as the status of the workplace itself.
Many workplaces use personal pagers, two-way radios, emergency sounding devices, visual monitoring systems and similar equipment. This equipment is used as part of everyday operations. Many workplaces use wireless or hard-wired systems as well.
The most important point to consider is the suitability of safety measures and systems to workers’ needs. For example, if an employee is deaf, visible alarms should be provided in the workplace.
Government of Canada, Canadian Centre for Occupational Health and Safety. Working Alone - General. 10 May 2024.
Loneworker.com is an aggregate resource and is not directly affiliated with government policies, legislation, or guidelines. Our site is intended to gather and display information for your use, but you are encouraged to conduct your own research.
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