Workers working alone at a work place under the control of the employer - 905-1-IPG-059
Effective date: June 2016
1. Subject
The health and safety of workers working alone at a work place.
2. Issue
To provide guidance on the provisions of the Canada Labour Code (Code), Part II, and the Canada Occupational Health and Safety Regulations (COHSR) that can be considered to protect the health and safety of employees working alone.
3. Questions
(a) Do any provisions of Part II in the Code or the pursuant COHSR prohibit employees from working alone?
(b) What must employers do to ensure the health and safety of those employees who are working alone?
(c) What criteria should be considered when determining whether or not working alone constitutes, in itself, a situation of danger; or unacceptable risk?
4. Conclusions
(a) Do any provisions of Part II of the Code or pursuant COHSR prohibit employees from working alone?
There are no specific provisions under the Code that prohibit employees from working alone. However, employers are bound by section 124 of the Code which states, “every employer shall ensure that the health and safety at work of every person employed by the employer is protected”.
There are several situations identified in the COHSR which prohibit employees from working alone, including:
- certain types of electrical work require a safety watcher or a first aider [section 8.8 and subsection 16.3(3) respectively]
- entry into confined spaces under specified hazardous conditions [paragraph 11.5(1)(c)]
- where there is a hazard of drowning [paragraph 12.11(2)(b)]
- repairs or maintenance work on a machine which cannot reasonably be locked out [subparagraph 13.16(2)(b)(ii)]
- operation of materials handling equipment with an obstructed view [subsection 14.25(b)]
Similar requirements exist within other Regulations pursuant to the Code, and should be consulted accordingly. These include the Maritime Occupational Health and Safety Regulations, Aviation Occupational Health and Safety Regulations, On Board Trains Occupational Health and Safety Regulations or Oil and Gas Occupational Safety and Health Regulations.
Therefore employers continue to be responsible for the health and safety of all employees, regardless of whether or not they work alone.
(b) What must employers do to ensure the health and safety of those employees who are working alone?
Hazard Assessment
As required by COHSR Part XIX, Hazard Prevention Program, the employer, in consultation and with the participation of the Policy Committee, or if there is no Policy Committee, the Work Place Health and Safety Committee or Health and Safety Representative shall assess the health and safety hazards associated with each particular job. The tools to be used are the hazard identification and assessment methodology developed in section 19.3 of the COHSR and the assessment shall take into account the following factors:
- the nature of the hazard
- the employees’ level of exposure to the hazard
- the frequency and duration of employees’ exposure to the hazard
- the effects, real or apprehended, of the exposure on the health and safety of employees
- the preventative measures in place to address the hazard
- any employee reports made under paragraph 126(1)(g) or (h) of the Code or under section 15.3 of the COHSR; and
- any other relevant information
In addition, if there is a potential for violence in the work place when an employee works alone, the employer shall conduct an assessment as required under section 20.5 of the COHSR.
An important factor to consider in respect to working alone is the remoteness of location and/or restricted access. For example, is the employee working alone outside at the corner of a busy street versus a remote rural area miles from the nearest occupied area?
After conducting the hazard assessment, the employer shall implement preventative measures to address the assessed hazards. Preventative measures include eliminating the hazard, reducing the hazard, providing the proper tools, equipment and protective equipment and administrative procedures up to, and including, safe work procedures.
For example, to help improve emergency notification and response time in the event of an accident involving an employee working alone, the employer may implement the use of a personal alarm (tools) or established check-in times for the employee working in a high risk job (procedures). But, no additional provisions may be required for an employee working in a low risk job.
Any assessment or change in the work place that is intended to improve the health and safety of employees shall be done in consultation with and participation of the Policy Committee, or if there is no Policy Committee, the Work Place Health and Safety Committee or Health and Safety Representative.The employer shall provide employees with education and training on the preventative measures implemented and any other training that will ensure their health and safety, including the requirements set out in sections 19.6 and 20.10 of the COHSR.
In any case, it remains the responsibility of the employer to ensure the health and safety of every employee at work.
(c) What criteria should be considered in determining whether or not working alone constitutes, in itself, a situation of danger or unacceptable risk?
Each case will have to be assessed on its own merits. All relevant facts should be reviewed, including the activities the employee performs and the anticipated emergency response time, in order to determine whether the employee working alone is exposed to either a danger or a situation which contravenes a provision of the Code or Regulations.
The following IPGs shall be referenced when assessing hazards to determine if they meet the definition of danger set out in subsection 122(1) of the Code:
- 905-1-IPG-062, Definition of Danger
- 905-1-IPG-070, Danger as a Normal Condition of Employment
In conclusion, the factors to be assessed in determining whether or not working alone constitutes a situation of danger or unacceptable risk include:
- the nature, potential frequency of occurrence and potential consequence of the hazards associated with a task, in an effort to determine the potential severity of the hazard
- to what degree the hazard is a normal condition of employment for the job
- the remoteness of the work site, or restricted access which will duly delay the notification and response of emergency personnel; and
- the procedures implemented by the employer to reduce the risk of the above hazards
Brenda Baxter
Director General
Workplace Directorate
Employment and Social Development Canada – Labour Program
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