This submission is on behalf of the Provincial Workplace Safety and Health Specialist Working Group. We are Safety and Health Specialists representing healthcare facilities, sites, and programs across Manitoba whose mandate is to develop consistent safety and health programming across all healthcare sectors.
We respectfully propose the following changes for your consideration:
Act - Serious Incidents
Add a clarification for hospitals:
For incidents occurring at a hospital, the requirement for reporting a cut or laceration to the WSH Branch is as follows:
- A cut or laceration that requires medical treatment beyond the training of a level 3 first aider.
- A cut or laceration that requires medical supplies not found in the content of a standard first aid kit or on patient units. Minimum requirements of a standard first aid kit per CSA Z1220.17 First aid kits for the workplace.
Act - Right to Refuse
Other workers not to be assigned
Remove subsection (c) “the actions require by subsections (3) and (4) have been taken.
Rationale: In healthcare, it is not always reasonably practicable to investigate and resolve a work refusal prior to immediate, potentially lifesaving care needing to be provided to a vulnerable patient, and not providing immediate care may cause harm to a patient.
Part 5 - First Aid Kits and First Aid Rooms
Add an exception for medical facilities.
Part 12 - Hearing monitoring for casual workers
12.4(2)(c) add a clause exempting casual employees working less than a *set number of hours from employer responsible audiometric testing. *a Set number of hours would need to be established by audiology professionals.
Rationale – Some casual staff work minimal hours, making it unreasonable to assume hearing loss can be attributed to the workplace. Does WCB have a formula/threshold of when they would accept a hearing loss claim from a worker? If so, could this also be the same number of hours at which casual employees would be included in bi-annual audiometric testing.