Ontario COVID-19 Construction Protocols

Disclaimer: This Ontario COVID-19 Construction Protocols article is not meant to replace any safety legislation or be intended as legal advice.


First of all, you want to reduce transmission of COVID in the workplace. This means keeping asymptomatic workers away from the workplace. Actively or passively screening will be the best way to do this, where you ask your employees questions about how they are feeling and where they have been, or you ask them to self screen themselves. Self screening options are passive but still work, and requires workers to be observed daily on the job site for symptoms by their colleagues and supervisors.


Doing that makes sure that construction workplaces are free of COVID, and don't need to be shut down.


Being safe goes beyond the screening process. Observations and conversations are key to working with your joint health and safety committee and colleagues. Encourage everyone to self monitor, to use the COVID assessment tool, the COVID alert App, and place posters around the workplace for them to educate themselves.


Supervisors should have a record of each employee, marking their attendance to keep track of who was there incase anyone does come down with COVID symptoms.


Workers may become comfortable with the same group of guys and let their guard down when it comes to being cautious about COVID. For this reason, the supervisors need to plan the work in intervals with assign groups per task. For example, bring one group in at 6:45am, and the next at 7:45 am, and restrict the number of people on site. Assigning certain group waves or cohorts of workers to come in with given staggering breaks between the all work groups effectively decreases exposure risk.


Simple communication works, as do visual cues such as physical distancing stickers on the floor or posters. But beyond that, planning for the overall flow of the job site needs to take place, ie. Where are workers entering and leaving? Are there signs in stairwells to remind them to not cross paths? Can meetings be held outside with more space? Can unnecessary contact between workers be eliminated?


"The coffee truck for example may have to be taken away if social distancing becomes a problem around there to ensure that 2 meters of distancing is respected."

- Scott Lane, IHSA COVID-19 Construction Awareness: FAQ Webinar


The work and tasks that happen on the site sometimes make it next to impossible to physically distance workers from each other. So, conducting a hazard assessment would be essential and the hierarchy of controls should be implemented:


Ask yourself the following important questions when considering COVID protocols:

  • Can that task be eliminated if social distancing isn't possible?

  • Can it be substituted?

  • Can it be done differently?

  • Can we be creative and change the method of how it's carried out?

  • Can we change the amount of workers in close proximity?

  • Who are the workers, and are they at higher risk than others?

  • Do the workers have health complications or people at home who may be high-risk?


If the answers to those questions don't satisfy the elements of your COVID protocols, then workers may need to be excluded from the task.


If the hierarchy of controls cannot be done with elimination and substitution, then administrative procedures comes into play. Policies and procedures must be frequently used, and the health and safety rep must be involved. Frequent hand washing and sanitization must be implemented, and crews should be kept small and in consistent cohorts/groups.


Workers most importantly need to be asked, "how is this working for you?", because we want to avoid work complaints and work refusals. All things must be effectively communicated, like through a tool box talk as a constant reminder that disinfecting procedures, protocols and other safety measures must be respected.


Beyond that, further personal protective equipment needs to be introduced depending on the worksite conditions, such as more face shields based on the job hazard analysis that's been conducted. PPE are a last resort and do not prevent the spread, but they certainly help in combination with controlled protocols. Because PPE isn't a standalone control, engineering and administrative procedures need to be applied alongside the use of PPE.


What PPE should be used?


The tasks being performed matters, as does the ability to use it and the effectiveness of it. Is the PPE that you need available? Does anyone need training on it? Because at the end of the day, the effectiveness of the protective equipment is up to the user. Whether or not they are using it correctly is ultimately up to the user. It must be used consistently, and diligently.


Pieces of PPE include:

Gloves when sanitizing

Surgical or medical grade face masks

Goggles

Shields


But, again, what is being used as PPE depends on your job site requirements and tasks being performed. Whatever it is, it has to be consistent, and worn correctly along all other PPE used not just for COVID safety protocols. Proper training use care and maintenance of the PPE must also be provided.


Toilets and Washing Facilities on the Construction Site


Section 29 of the construction regulation 213-91 says the constructor has to provide and arrange for all workers to have reasonable access to washrooms. There are a number of meters they cannot be close to one another (180m from the work area). If it's in a tunnel, it should be 150m from the entrance of the tunnel, and not more than 3 km away from work if transportation is provided and required. If a building is being constructed, the washroom must be 9 meters vertically from the level that the work is being performed!


This means sewer toilets and non-sewer toilets provided by a supplier must comply with section 29. This means there must be a water or chemical flush toilet provided with a trap or positive seal separating the waste from the seal. The waste can be deposited and chemically treated safety. There must be an adequate supply of toilet paper, and a disposal waste bin. It must lock from the inside, be lit, heated if possible, ventilated, and kept in good repair and state of cleanliness at all times. Also, there must be a ratio of 2:1 for every washroom to wash basin.


Wash up facilities under O. Reg. 213/91: CONSTRUCTION PROJECTS, S. 29.2 (1) helps eliminates the risk of the spread of COVID-19. A wash basin must be equipped with hot and cold water where reasonable, with paper towels or a hand dryer. If water is not possible to be provided, then hand sanitizer must be provided. However, sanitizer is not wholly effective to get off grime and viruses, so this is important that the workers and employers recognize that a wash facility is the best practice for eliminating COVID in the workplace.


It is the position of the Ministry that it is reasonable for all wash-up facilities be set up with both hot and cold water.


Best Practices When Cleaning Shared Tools and Equipment


Review the work before starting. Ask yourself, "What tools are there and where are they being used?" After that, develop procedures to be followed. Consider that workers must work independently and practically. The welder who may need to set up all the gear and have help setting up, may need more time to set up on their own. That's so other workers are not touching the tools, and there is less time spent sanitizing.


It's important to identify and label commonly shared tools and to provide regular cleaning tools such as spray sanitizer and paper towel. Make it so the tools must be cleaned before during and after, and even the tools that are not being shared should be wiped down too.


Just be mindful of anything you are bringing on the job site. Clean it first and pay attention to sanitization product safety labels. Hazardous material labels should be respected always, and should correspond with the WHMIS GHS data sheets for complete details of use. This means always using gloves with the chemical used to clean the tools, plus whatever precautions the label states.


Cleaning thoroughly reduces the numbers of germs, reducing the majority of germs that can be transmitted. A clean and sanitized jobsite is best kept with continuous cleaning and disinfecting of workplace surfaces and provides adequately cleaned facilities. After washing, sanitizing reduces germs on surfaces through a chemical process further decreasing the risk of germs spreading.


TIP: A simple disinfectant agent is made by adding 1 cup (240 ml) of bleach to 5 gallons (18.9 l) of water. Spray and leave on the surface for 10 minutes, then rinse with water and let it air dry. Remove gloves and place them in the trash, followed by of course - washing your hands.


To clean hard surfaces like your swing stage, any stainless steel, floors, railings, light-switch plates, or doorknobs should be done by following the instructions on the label of the container and the corresponding safety data sheet (SDS).


Please, use chemicals in a well-ventilated area and NEVER mix cleaning chemicals.


As you increase your frequency of cleaning and disinfecting, monitor your supply of disinfectant wipes, cleaning products, and cleaning gloves to ensure that you have enough. Monitor the frequency and location of cleaning too, this will ensure that all areas get cleaned and sanitized on a regular basis. Look for any overlooked areas, and keep an open conversation with your team about it.


Transporting the Crew from point A to point B



Beginning with the self assessment processes, workers should sit as far apart as possible and have the window open. They should also use seat covers and be provided lots of hand sanitizer. All parties have to practice washing and sanitizing their hands frequently, especially while exiting and entering the vehicle. Procedural masks, goggles, and face shields/masks are also going to make a huge impact on the spread of germs while sharing a work vehicle.

Going beyond those recommendations, workers can come up with their own safety precautions such as maybe reducing the amount of speaking while within the vehicle to avoid 'speaking moistly'.


Positive COVID-19 in the Workplace and WSIB claims


So, what happens if a worker tests positive?


The nature of peoples work puts them at greater risk of contracting it - so everything is a case by case basis with the facts and circumstances all laid out within a filed report.

But, the diagnosis or signs and symptoms of COVID-19 should be first communicated to the employer. Then, treatment would be implemented and documented. After that - a WSIB claim would be made to determine eligibility.


The claim would need the following:


  1. Employer name type and business

  2. Nature of the illness

  3. Worker name and address

  4. Address of legal practitioner they were attended by

  5. Name and address of medical facility

  6. Steps to eliminate further spread of the illness


If you believe you have been exposed, but you have no symptoms - you would not do a WSIB claim. A PEER construction exposure incident report would be made and processed. An incident number would be assigned, and if you have a positive test - this form would be provided to WSIB for information.


With a positive COVID diagnosis or signs and symptoms of COVID, the Ministry of Labour, Training and Skills Development reporting Act S. 52.2 is triggered.


Occupational Health and Safety Act, R.S.O. 1990, c. O.1 S. 52(2) states:


Notice of occupational illness

(2) If an employer is advised by or on behalf of a worker that the worker has an occupational illness or that a claim in respect of an occupational illness has been filed with the Workplace Safety and Insurance Board by or on behalf of the worker, the employer shall give notice in writing, within four days of being so advised, to a Director, to the committee or a health and safety representative and to the trade union, if any, containing such information and particulars as are prescribed.  R.S.O. 1990, c. O.1, s. 52 (2); 1997, c. 16, s. 2 (12).


Then, going to section 9 of O. Reg. 213/91: CONSTRUCTION PROJECTS from the Occupational Health and Safety Act, where it states further details to include:


9. (1) A notice under subsection 52 (1) of the Act respecting an occurrence involving a worker shall set out,

(a) the name, address and type of business of the employer;

(b) the nature and the circumstances of the occurrence and the bodily injury or illness sustained by the worker;

(c) a description of the machinery or equipment involved;

(d) the time and place of the occurrence;

(e) the name and address of the worker involved;

(f) the names and addresses of all witnesses to the occurrence;

(g) the name and address of any legally qualified medical practitioner by whom the worker was or is being attended for the injury or illness;

(g.1) the name and address of each medical facility, if any, where the worker was or is being attended for the injury or illness; and

(h) the steps taken to prevent a recurrence


Together everyone on the site can keep one another safe, especially with the help of supervisors and joint health and safety committees. Strict cleaning and sanitization schedules are recommended, and you may have to consider shutting down the site until all the workers are healthy again. Tracking each employee with the above mentioned questions are a step in the right direction for eliminated workplace exposure to COVID.


What will a surprise visit from the Ministry of the Labour look like?


They are looking for cleaning and sanitization of the site - the tools, toilets, clean-up facilities, what PPE are being used, and more. They have the ability under the civil protection act to issue time compliance orders, shut down your site, or issue a part III summons to provincial court.


Under the emergency act, inspectors can observe public health guidelines and give part I tickers when social distancing isn't being respected and followed. Even imprisonment is possible for up to one year for not following all the COVID-19 safety protocols on each construction site in Ontario.


Just ensure that best practices are being followed, and really communicate with everyone on the job site. Keep an eye out for COVID symptoms, and speak up if you have any questions or concerns about the health and safety of yourself and everyone present on the work site.


Ontario COVID-19 Construction Certificate Extensions


To keep up with the latest news and how worker training is impacted: Joint health and safety certification and first aid have been lengthened.


March 27th, 2020 - Validity period for working at heights training set to expire between February 28th - August 31 2017 has been extended another year. This is just to help with Toronto and other city shut downs of trainers in the area due to coved outbreaks. This is so that workers can return to the job site while they wait for training to be available. This doesn't change the necessity to train all workers in fall arrest procedures.


Changes have also been made to joint health and safety committee training, and First Aid. Click here to read more.


Staying Up To Date With COVID-19 Construction Support Links


IHSA COVID-19 Resources

Canadian Construction Association

Center for Disease Control






























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