BC Forestry Employers Need To Get Ready For New First Aid Requirements

Sep 4, 2024 - one year ago

The date is quickly approaching — on November 1st, 2024, changes to WorkSafeBC First Aid requirements will come into effect.

The amendments were approved by WorkSafeBC’s Board of Directors in April 2023 and the 18-month time-lag in implementation was designed to allow employers and training providers to prepare for the changes. These amendments will apply to all workplaces and industries, but some of the key changes are especially relevant in the forestry sector because of the focus on remote and less-accessible work locations. The requirements for first aid are outlined in Part 3 of the Occupational Health and Safety Regulation. They have seen very few updates over the last 20 years, which has prompted the current overhaul.

Of particular concern was the provision of appropriate emergency transport for injured workers in remote areas. In addition to strengthening the current obligations, the changes will harmonize first aid training and first aid kit requirements with the national standards under CSA (Canadian Standards Association). Harmonizing with the CSA standards is intended to help with labour mobility, allowing qualified workers coming to BC from other provinces to use their first aid certifications obtained elsewhere.

Under the amended regulation, a workplace that is further than 30 minutes travel time by an ambulance under normal travel conditions, will be classified as a “remote workplace”. A workplace that cannot be reached by an ambulance travelling by land, or a workplace where EHS ambulance attendants cannot safely access, will be classified as a “less-accessible” workplace. There are many factors that will make a workplace less-accessible and include things like rough or steep terrain, or places where an injured worker would be carried for a significant distance. Clearly, a cutblock where a stretcher would need to be carried through logging slash would be less-accessible. Along these lines, many forestry operations will be deemed both “remote” and “less-accessible.” In the language of the new regulation, those would be Class 4 workplaces. This is significant because workplace classification will determine how many first aid attendants are required at a particular operation; and what level of certification they must have. The minimum requirements, based on industry hazard rating and workplace class, are outlined in Schedule 3-A of the Regulation.

Another key piece for identifying the appropriate minimum levels of first aid is the hazard rating assigned to industry and its classification units (CUs). Most forestry CUs, such as Logging Road Construction, Manual Tree Falling, or Cable Yarding, etc. fall under the High Hazard Rating, based on the nature and extent of the risks and hazards involved. The assigned Hazard Rating can be found in the Assessment Rate Notification that WorkSafeBC sends to all employers every year in November. All three factors: the hazard rating, the class of workplace (reflecting whether it is remote and how accessible), and the number of workers present will determine the minimum first aid services that can be looked up in Schedule 3-A.

It is important to note that Schedule 3-A lists only the “minimum levels” of First Aid and it is only meant to be a starting point for employers assessing what they will actually need to have in place depending on the hazards and conditions specific to their operation. In some cases, based on the risk assessment, these minimum levels from the Schedule may be adequate, but in other situations, additional first aid attendants and higher levels of certification may be required to properly respond to a first aid emergency. A requirement to conduct a formal risk assessment has existed before, but starting in November, this assessment will need to be written down and available for inspection. The written assessment must document both the minimum first aid services as per Schedule 3-A and any additional equipment, supplies, first aid attendants, and other services that are necessary to ensure that injured workers can have prompt access to first aid and prompt transport to medical treatment. To assist and guide employers through the assessment process, a First Aid Assessment Tool will be available in a pdf format in June and a digital version will be posted on WorkSafeBC’s website in September.

Another point worth noting is that under the new requirements, the written first aid assessment must be prepared, reviewed, and updated in consultation with the joint committee, where one is required, or the worker health and safety representative. But even in small workplaces that do not have a joint committee or a designated worker representative, workers should still be involved in the assessment process and their input can be obtained at the monthly safety meetings, tailgate crew talks, or pre-job meetings.

The assessment will need to consider the number of workers present, their location, the types of risks and hazards that they may be exposed to, and the types of injuries likely to occur. Additionally, any potential barriers to first aid being provided will need to be identified, along with solutions.

The assessment must be reviewed and updated every year and whenever there’s a significant change in the operations affecting the validity of the assessment.

Also under the new provisions, the employer will be required to conduct practical drills for first aid emergencies at least once each year and whenever the procedures change, such as when entering a different logging phase, moving to a significantly different operating area, and requiring a different type of response. Further, the employer will need to ensure that these drills validate the effectiveness of first aid procedures and that the first aid attendants and other workers, who might be called upon to assist, are capable of fulfilling their roles. A first aid drill should include realistic mock scenarios that can identify any gaps in skills, capability, response times, and any shortcomings in equipment. Gaps or deficiencies identified through a drill will need to result in changes and improvements to procedures. Above all, these drills will help the participants better understand their responsibilities in an emergency and better prepare them for the real thing.

As mentioned before, the amended regulation will harmonize first aid training and first aid kit requirements with the CSA standards, which raises questions about how a transition to the new system will happen. Currently, first aid attendants are trained and certified as OFA Level 1, 2, or 3. This will be replaced by training in Basic, Intermediate, and Advanced level certification. Of note is that the existing five-day Level 2 training course will be replaced by a two-day Intermediate course under the CSA system. This change in course duration and content was taken into consideration in the design of the revised Schedule 3-A. There will be corresponding changes to the first aid kit requirements.

To alleviate pressure and uncertainty, WorkSafeBC is implementing a number of transition measures:

The certification of first aid attendants who hold valid OFA Level 1, 2, and 3 certificates will continue to be recognized until the date of their expiry (up to November 1, 2027) and those certificates will be accepted as equivalent to Basic, Intermediate, and Advanced certification under the new system.
Valid OFA Level 1, 2, and 3 certificates that expire between July 2 and October 31, 2024, will be accepted as valid until November 1, 2024.
Employers wishing to utilize first aid attendants holding the new Basic, Intermediate, or Advanced certificates prior to November 1, 2024 will be able do so, if all other requirements of the amended first aid regulation are also implemented, including all required elements of the newly revised Schedule 3-A, a written first aid risk assessment, and written first aid procedures;
Employers may continue to use existing first aid kit contents, recognizing that they are mostly the same as the new CSA-aligned kit contents – they will only have to supplement existing kits with any items that are “net new” under the amended guidelines; there is no expectation for employers to dispose of existing first aid supplies that are essentially the same (other than, let’s say small changes in dimensions of bandages, etc.). Employers will be expected to replace first aid supplies and kits with CSA-aligned supplies as supplies are replenished or when purchasing new kits.

While the changes coming into effect on November 1st are extensive, they are expected to result in better outcomes for injured workers and more certainty for employers knowing that their first aid provisions and emergency protocols are suitable for the business operations.

While this article captures key elements of the changing regulation, a very comprehensive guideline to the new requirements will be posted on WorkSafeBC’s website towards the end of May. Employers, first aid attendants, and all workers who will be affected by these amendments, are encouraged to review the guideline to help prepare for the upcoming changes.

Source: BC Forest Safe