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Module 5-The Implications For OHS Governance
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The Implications For OHS Governance
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oLesson 1: SHE Rep in the
workplace
oLesson 2: COVID-19
Compliance
Module
5
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The Role of Shop Stewards in the OHS Structure
SHE Rep has intimate knowledge of
the work activities, and is
permanently employed
One of the key principals of the OHS
Act is that work-related hazards, risks
and dangers should be addressed
through good communication
between management and
employees.
According to Section 17 of the
Occupational Health and Safety Act
(Act 85 of 1993), employers who
employ 20 or more workers on
premises must appoint
representatives to monitor health and
safety conditions.
Appointed representatives represent
workers regarding safety and health
matters to management.
Representative's forms part of an
important link between management
and the rest of the organisations
employees.
SHE Reps need to be nominated by
their piers and ideally the workforce-
team should choose their leader (SHE
Rep)
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• Identify hazards and potential incidents
• Inspect the workplace and report unsafe conditions
• Participate in internal health and safety audits
• Visit the site of an incident & participate in investigations
• Make health & safety recommendations to the employer
• Review the effectiveness of health (and safety) measures in the workplace
• Investigate employees’ health and safety concerns & complaints
SHE Representative - Functions
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• Review the findings of incident investigations
• Accompany a Dept. of Labour Inspector during an inspection
• Report to the Dept. of Labour if the employer fails to respond to recommendations
• Attend investigations & formal inquiries conducted by the Dept. of Labour
• Receive information from an inspector from the Dept. of Labour
SHE Representative - Functions
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• Meet as often as needed - At least once every three months
• Discuss incidents at work in which a person was injured, became ill or died
• Make recommendations to the employer regarding H&S at work
• Participate in incident investigations & Review the findings of investigations
• Keep records of recommendations made to employer & reports made to DoL.
• Employer responsible to ensure records of H&S committee are kept for at
least three years
H&S Committees- Functions
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Structures- COVID-19 Compliance Officer
COVID-19 Compliance Officer is
responsible to:
Manage the phases of return of
employees from other provinces,
metropolitans and district areas
Develop measures to ensure that
the workplace meets the standards
of health protocols, adequate space
for employees and social distancing
measures for the public and service
providers
Ensure adherence to the standards
of hygiene and health protocols
relating to COVID-19 at the
workplace
The development and
implementation of a COVID –ready
plan for the phased-in return, of
employees to the workplace, prior
to reopening for business
The COVID-ready plan must
correspond with Annexure E and
should be retained for inspection
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Structures: COVID-19 Manager
• Ensure continued compliance the COVID-
19 PLAN set forth by the COVID-19
Compliance Officer
• Ensure that all employees are well versed
in all the identified risks that COVID-19
poses within the working environment
• Enforce COVID-19 related preventative
measures in all areas of the workplace with
all employees
• Ensure that, as far as is reasonably
practicable, the workplace remains current
with updated legislation measures and
developments related to COVID-19.
• Ensure that a distancing of minimum 1.5
meters is maintained throughout the
workplace by all employees and visitors or
alternatively ensure adequate screening or
barriers are in place to prevent the spread of
the COVID-19 virus
• Communicate as frequently as is necessary
with SHE-Committees and Representatives on
all COVID-19 -related health safety matters,
facilitating feedback and ensure that clear
records are kept thereof
• Encourage employees to work from home as
much as possible
• Ensure continuous cleaning and de-sanitizing
of all relevant areas of the workplace
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Structures: COVID-19 Manager
• Avoid any grouping of employees,
visitors and contractors workplace by
ensuring implementation of strict
Workplace Distancing Protocols &
Standard Operating Procedures (SOP)
• Facilitate the implementation and
management of the Screening
Process for all staff, contractors &
visitors
• Manage the process to follow if an
employee is confirmed or suspected
to have COVID-19 in the workplace
• Ensure that Medical Surveillance of
recovered employees are recorded.
• Determine the area of floor space in
square meters and calculate how
many employees, visitors, contractors
and customers will be allowed to be
on the premises
• Take steps to ensure that persons
queuing inside or outside the
premises are able to maintain
adequate distancing measures
• Provide hand sanitisers for use by the
public and employees at the entrance
to the premises
• Assign an employee or any other
suitable person, as the compliance
employee/s, who must assist in the
day to day requirements of COVID-19
Compliance
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Structures: Response Team Member/Suitable Person/Employee
COVID-19 Response Team Member has the duty to:
Assist and support the
COVID-19 Compliance
Officer and/or COVID-19
Manager/s
Participate in educating all
employees on the
company’s COVID-19
preventative measures
Assist with on-going
communication to all
employees regarding
COVID-19 preventative
measures as required
Contribute to the
implementation and
evaluation of COVID-19
processes and protocols
Assist with Operating
Procedure & Medical
Screening Procedure of all
staff, visitors and
contractors
Contribute toward the
restriction of grouping in
the workplace, and
applying strict physical
distancing rules
Assist in managing the
protocols of confirmed or
suspected COVID-19 cases
in the workplace
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SHE Reps Knowledge
•COVID-19 Company Policy
COVID-19 Standard Operating Procedures
(SOP)
VISITOR & EMPLOYEE screening
COVID-19 Toolbox Talks
COVID-19 - PPE
Workplace Checklists – Monthly / Weekly /
Daily
COVID-19 Incident reporting and Investigation
COVID-19 Posters
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Scope of SHE Reps in the COVID-19 Sphere
Other than assisting DoL when coming to the workplace, SHE Reps also liaise
between management and employees
SHE Reps in the workplace may be involved in:
• Assisting the employer with COIVID-19 measures
• Be proactive in identifying potential COVID-19 risks in the workplace
• Attend to and investigating COVID-19 -related complaints from employees
• Assisting in the investigation of COVID-19 incidents in the workplace
• Make COVID-19 -related health suggestions to management
• Assist in the COVID-19 implementation and communication of the back-to-work
plan
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Having said all that, it is interesting to note that all the duties of the SHE Rep is prepositioned by the word
“may” Many expectations from SHE Reps was never intended to be added to the list of responsibilities they
already have and be held accountable for. Expectations from SHE Reps must ultimately be based on their
ability to handle their normal work activities as well as keeping an eye on everyone and everything else. This
is not always easy and SHE Reps feel the additional pressure bestowed upon them
If you really want to understand what the safety culture of a company is, speak to the safety representatives.
They are at the coal face of your safety management plan.
SHE Reps spend their time doing the work as part of a team and are given the additional responsibility of
documenting issues and completing check lists, attend safety meetings and discuss safety concerns with
employees during the day. The SHE Reps frequently share the additional burden of production expectations
Challenges and Concerns
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Challenges & Concerns
16.5 “It must appoint a manager to address employee or workplace representative concerns and to keep them
informed and, in any workplace in which an health and safety committee has been elected, consult with that
committee on the nature of the hazard in that workplace and the measures that need to be taken
The regulations speak about a COVID-19 Manager whom carries the responsibility to train, monitor and advise
on site. The COVID-19 Manager must communicate with the Safety Committee as well as the SHE Reps to
ensure that the latest facts on the ground are communicated throughout the workforce. (Avoiding groupings of
employees should be kept in mind)
Ideally not.
Should additional COVID-19 -responsibilities be given to SHE Reps?
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Challenges and Concerns
This is distinctly different from the above, specifically speaking about an employee,
not rep or committee member, but an employee selected to perform certain duties
seemingly temporarily and only with relation to the COVID – 19 crises. It also seems
that the chosen person does not have to be permanently employed either, but
suitable to expedite COVID-19 related duties. These assigned employees will assist
the COVID-19 Manager in the day to day operations pertaining to the virus.
Assign, in writing, an employee or any other suitable person, as the compliance
employee, who must ensure-
compliance with the measures provided
for in paragraphs (a) to (d); and
that all directions in respect of hygienic
conditions and limitation of exposure to
persons with COVID-19 are adhered to.
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The role and responsibilities of the COVID-19 selected persons is likely to mount as more employees return to work.
Training the returning employees will require time, which should not be harvested from the SHE Rep or the Committee
Members.
Selected employees or other suitable persons have to be tasked with only COVID-19 related issues as they will not be as
easily distracted with their daily activities.
Manufacturing, production and the other essential services remain as dangerous now, perhaps more so now with less
hands, and should not be overlooked. The SHE Reps and Committee Members must continue with their routines as
before and COVID-19 responsibilities should preferably not be added to their portfolio if possible.
The Regulations clearly state that the Occupational Health and Safety Act and subsequent Regulations are still valid and
100% applicable. Therefore, we must be careful not to discard our current systems and safety procedures and only focus
on COVID-19.
Challenges and Concerns
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The COVID-19 landscape seems to change continuously. At the
drop of a hat, changes might need to implemented as the
regulations change. This will add an unnecessary burden to the
SHE Reps and the Committee Members who should only be
tasked with the communication of certain facts and procedures
to the work force.
The execution of emergency protocols should be part of
the COVID Managers’ duties and his assigned suitable
persons. If screening, isolating or quarantine protocols
are implemented because a positive or potential positive
person is identified, immediate action may be required.
Workstations may have to be isolated and cleaned and
departments may have to be shut down. Hands will be
required for these protocols and withdrawing SHE Reps or
other employees off machines and production scenarios
could cause problems.
Challenges and Concerns
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Challenges & Concerns
We do, however, see the Safety Committee
members and SHE Reps being the ‘voice of reason’
among the workforce.
SHE Reps armed with the facts communicated to
them by the COVID-19 MANAGER/s will potentially
stay the go-to person for employees.
It would be preferred that SHE Reps stay available
at all times to address COVID-19 issues (when they
are responsible for this) and not be tied up in their
daily activities.
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Final Thoughts –
Safety Representative Appointment
Check your attitude!
Look at your entire
company and all its
sections and divide the
areas up in a logical way
Keep them informed Field trips!
Know your staff.
Respond / Re-act to
issues immediately.
Seek external advice
Train, train, train
Appreciate them!