Strengthening Language around Monitoring
Part 8.1(3) of the Regulation says that an employer must monitor the effectiveness of any controls measure implemented.
Rationale: I would like to see an 8.1 (4) with some wording around the employer being responsible for monitoring the performance of their workers to ensure compliance to Safe Work Procedures, especially related to reducing exposure to MSI risk. I believe that this is the missing piece in the overall MSI prevention efforts in the workplace.
Health Care Facilities
Part 39 either 39.5 or 39.10 - Could there be included some similar language to Part 8 related to employers/supervisors monitoring on a regular basis to ensure workers are following SWPs as close to what is practicable under the circumstances (because there are going to be exceptional circumstances when the SWP cannot be followed.)
Rationale: Once again, I believe that having supervisors responsible for ensuring safe work procedures are being followed will ensure a safe environment for both worker and patient/resident. This is the missing piece in the overall MSI prevention efforts in the workplace, and would support training program roll-out efforts.