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ESCALATION PROCEDURE
Section: 8 – Occupational Health & Safety Policy No: 8.02
Page: 1 of 4
Employees covered: All Employees Effective: April 1, 2009
Subject: Escalation Procedure
Authorized: Gordon MacInnis, Vice President, Finance & Operations
The Joint Occupational Health and Safety Committee (JOHSC) works to resolve occupational health and safety issues1 at Cape Breton University. Review of health and safety concerns, suggestions or issues may result in recommendations for improvement by JOHSC. Alternately, the Committee may identify non-compliance with the Nova Scotia Occupational Health and Safety Act (the Act) or University policy(ies). Normally, in such cases, a letter of request shall be sent by the Secretary to the manager or supervisor who is accountable with a copy to the appropriate Vice President. The letter shall request a response, in writing, within twenty-one (21) days, as outlined in the Act. Consistent with Section 34 and/or 35 of the Act, the response shall:
a) indicate acceptance of the recommendations or action and the implementation date; or b) give adequate reasons for the disagreement with any recommendations or request(s)
that the manager or supervisor does not accept. Dependent on the urgency or seriousness of the matter and as directed by the Committee, failure to provide an adequate response to the request within the twenty-one (21) day period may result in referral of the matter to the Nova Scotia Department of Labour (DOL) or the commencement of the Escalation Procedure outlined below2. The JOHS Committee shall determine what would constitute an adequate response by the manager or supervisor, prior to sending the letter. A decision can be made by a vote with a simple majority (50+1). If no response or an inadequate response is received, the Escalation Policy will be launched or the matter reported to DOL. Prior to sending the letter, the JOHS Committee shall instruct: The JOHSC secretary to commence the Escalation Policy if the manager or supervisor fails to provide adequate response to the request within the 21 day period; or The co-chair(s) to report inadequate response by the manager or supervisor to the DOL, if the manager or supervisor fails to provide an adequate response to the request within the 21 day period.
1 Some examples of Non-Compliance Issues
1.1) Fail to respond to JOHSC recommendations; 1.2) Fail to comply with CBU Occupational Health and Safety Policies or Procedures; 1.3) Fail to follow safe working procedures.
2 Note: Depending on the seriousness of the hazard, it may not be appropriate to wait for 21 days for a response to a recommendation. In such cases, DOL will be contacted immediately by co-chair(s).
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Escalation Procedure:
Step 1: The Secretary of JOHSC shall immediately send the appropriate form letter to the next level of management (Dean, Director, Manager or Vice President) informing them of the situation and requesting a written response to the request within seven (7) days. Within twenty-four (24) hours, the Secretary will verify receipt of the letter by the supervisor (or manager).
If there is no response:
Step 2: An appropriate form letter will be sent by the Secretary of JOHSC to the next level of management (Dean, Director, Manager, Vice President or President) informing them of the situation and requesting a written response to the recommendations within three (3) days. Within twenty-four (24) hours, the Secretary will verify receipt of the letter by the Dean, Director, Manager, Vice President, or President.
If there is no response:
Step 3: The Secretary will inform JOHSC by e-mail or phone call. The co-chair (s) will then notify the DOL in writing and/or by phone.
Implementation date: April 2009
Revewed: May 2015
Next Review: 2018
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APPPENDIX A
Form Letter 1
MEMORANDUM
d/m/y
TO: CC: Director, Human Resources FROM: Joint Occupational Health & Safety Committee RE: Occupational Health and Safety Non-Compliance
It has come to our attention that you are out of compliance with 1_________________________ regarding 2__________________________________. Under Section 34(1) of the NS OHS Act, please consider this written notice that you have 21 days to provide a written response to the committee secretary with either: a. Acceptance of the recommendations or action below, and its implementation date; or b. Rejection of the recommendations or action below, with adequate reasons for your rejection. Due to the severity of the non-compliance, if you fail to respond, the JOHSC will initiate the Escalation Policy. A copy of the policy is attached for your information. The recommendations to remediate your non-compliance are as follows: Regards, JOHSC Secretary 1
State section of OHS Policy, OHS procedure; NS Occupational Health and Safety Act, etc. 2 Briefly describe non-compliance.
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APPENDIX B
Form Letter 2
MEMORANDUM
d/m/y
TO: CC: Director, Human Resources FROM: Joint Occupational Health & Safety Committee RE: Occupational Health and Safety Non-Compliance
It has come to our attention that you are out of compliance with 1_________________________ regarding 2__________________________________. Under Section 34(1) of the NS OHS Act, please consider this written notice that you have 21 days to provide a written response to the committee secretary with either: a. Acceptance of the recommendations or action below, and its implementation date; or b. Rejection of the recommendations or action below, with adequate reasons for your rejection. Due to the severity of the non-compliance, if you fail to respond, the JOHSC will contact the Nova Scotia Department of Labour to initiate an investigation into the non-compliance. The recommendations to remediate your non-compliance are as follows: Regards, JOHSC Secretary 1
State section of OHS Policy, OHS procedure; NS Occupational Health and Safety Act, etc. 2 Briefly describe non-compliance.