How an Internal Responsibility System (IRS) can help your business thrive, and what it looks like in action
Ontario's Internal Responsibility System (IRS) is the one of the best tools a small business can use to reduce injuries and related costs. The IRS is the foundation of health and safety in Ontario. It requires owners, managers and frontline staff to work together to eliminate hazards in the workplace.
But some small businesses aren’t taking advantage of it. A Ministry of Labour, Immigration, Training and Skills Development (MLITSD) inspection revealed a lack of awareness of the IRS and legal health and safety responsibilities among small businesses.
The goals of the MLITSD initiative were to check that small businesses in sectors ranging from retail to restaurants and metal fabrication, were complying with the Occupational Health and Safety Act (OHSA) and its regulations. Inspectors looked at these areas:
- violence and harassment policy and program
- health and safety representative or joint health and safety committee (JHSC)
- posting requirements
- mandatory health and safety awareness training for employees
- identifying and controlling hazards.
The most frequently issued orders were for an employer’s failure to meet
- general requirements of the OHSA (e.g. posting, health and safety policy and program, health and safety rep, monthly inspections, etc.).
- workplace violence and harassment requirements (e.g. harassment and violence policies and programs).
- Regulation 851: Industrial Establishments requirements (e.g. ensuring a lifting device was examined by a competent person, etc.).
- requirements around providing basic health and safety awareness training for workers and supervisors.
Many of these orders are due to a poor Internal Responsibility System. The employers may not have developed, supported or implemented an effective IRS.
What is internal responsibility and how does it work?
Under the IRS, every workplace party has a role to play in keeping the workplace safe.
- Employers must ensure equipment is maintained in good condition and is safe to use, a safety policy and programs are established, competent supervision is provided, workers are trained, and every reasonable precaution is taken to protect workers.
- Supervisors must ensure safety equipment and clothing are used, safety procedures are followed, workers are advised of hazards, and every precaution reasonable is taken to protect workers.
- Workers must report hazards to the employer or supervisor, use or wear protective equipment, follow safety procedures and practices, and refrain from removing safety devices.
With everyone’s duties clearly laid out and understood, the IRS can be used to tackle workplace hazards and prevent accidents and injuries. Here’s how it might work in a retail store, for example.
- Chen works in a small retail store. He notices there’s a lot of water dripping from the ceiling tiles onto the floor. He knows this can lead to slip, trip and fall injuries. Chen puts a wet floor sign out and then reports the matter to his manager, Saleema.
- Saleema looks at the ceiling and notices the drips are coming from the air conditioning unit. She puts a bucket under the drips, ensures the water is mopped up, and notifies the owner.
- The owner calls a service company immediately and authorizes the repair.
Chen’s work area is now safe again. Everyone participated. Everyone communicated. Everyone worked together to make safety happen.
Protecting the bottom line
Businesses that have never had a significant lost-time injury may not realize the devastating impact it can have, not just for the injured worker but for the business itself. Neglecting health and safety can lead to:
- a greater risk of injury, illness, business disruption and property damage.
- MLITSD orders, tickets, fines or prosecution.
- lost time and incurred costs of WSIB claims submission.
- higher costs (e.g. overtime, training) to make up for lost production.
Additional Resources
- Internal Responsibility System (IRS) Primer
- OHSA Laws and Regulations: Roles and Responsibilities
- Pocket Ontario Green Book 2024 (Consolidated Edition)
- Safety information in your workplace: what needs to be posted? Your top 6 questions answered
- WSPS’ Small Business Centre – Enhance your health and safety program with training, checklists and tools; targeted help for businesses with 1 - 49 employees.
- Health & Safety Orientation Handbook Generator – Create a free customized handbook that covers health and safety legislation in Ontario, outlines the responsibilities of the employer, supervisor and worker, and the essential safety policies and procedures your workplace needs to stay in compliance.
- Small Biz Safety Podcast - Let our safety experts walk you through simple steps to make your workplace safer and your business better in this monthly podcast.
The information in this article is accurate as of its publication date.
Have health and safety questions? Please contact Denise Lam, WSPS Account Manager, Small Business at [email protected].
