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Internal Responsibility System

Table of Contents

  1. Statement of Meaning
  2. Statement of Authority, Accountability & Responsibility
  3. Definitions
  4. Posters
  5. References

 Statement of Meaning

The Internal Responsibility System (IRS) is a joint partnership among all members of the McGill University community. Within the IRS everyone has direct responsibility for health and safety as an essential part of her or his job. Everyone at McGill University, no matter their title, is expected to take initiatives on health and safety issues and to work to solve problems and make continuous improvements in the workplace. Each person does this both as an individual and in co-operation with others because they share joint responsibility for identifying and resolving health and safety issues.

The principle underlying the Quebec Act Respecting Occupational Health and Safety (Quebec OHS Act) is that all individuals assume certain responsibilities for the protection of every employee's health and safety. Formal university policy outlines specific responsibilities for every position within the university, as well as establishing performance standards, organizational arrangements, and supporting programs designed to effect due diligence. This joint partnership is referred to as the Internal Responsibility System.

This document outlines the framework for an IRS where the employer, supervisors and workers share joint responsibility for identifying and correcting health and safety issues.

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Statement of Authority, Accountability & Responsibility

  1. Individuals

    1. Students

      In the context of the IRS, students are full members of the University community. Consistent with the intent of the Charter of Students’ Rights (e.g., article 7 regarding the University’s “obligation to maintain safe and suitable conditions of learning and study”), each student must take all reasonable care to preserve a healthy and safe learning environment, and refrain from actions that might adversely affect that environment (including, for example, actions prohibited in Section II, Non-Academic Offenses, articles 5 through 14, of the Code of Student Conduct and Disciplinary Procedures). Where students are paid to perform work they become workers under the Quebec Act Respecting Occupational Health and Safety (R.S.Q. c. S-2.1) and therefore have the same rights and responsibilities outlined in this document and the Act. In addition, any individual performing work on university premises, not for pay, but for educational and other authorized purposes is considered by the University to have rights and responsibilities under the University’s Environmental Health & Safety (EHS) System and supporting programs.
    2. Employees and Individuals Receiving Remuneration

      Every McGill employee is a "worker" within the meaning of the Quebec Act Respecting Occupational Health and Safety (R.S.Q. c. S-2.1) and therefore has the rights and responsibilities as outlined in the Act and is responsible for:
      1. complying with the rules and procedures developed within the EHS System for performing the work in a safe and healthy manner;
      2. taking an active role in protecting and promoting his or her health and safety;
      3. refraining from activities which may jeopardize the health and safety of others;
      4. taking an active role in fulfilling the requirements of applicable EHS Programs under McGill's EHS System with a view to fulfilling the intent of the EHS Mission Statement; and
      5. correcting or reporting forthwith to his or her supervisor, any observed EHS hazards or lapses in the functioning of an EHS System.
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  2. Supervisors, Professors, Principal Investigators, Laboratory Directors

    1. Supervising Faculty and Staff, including Principal Investigators and Laboratory Directors

      Any faculty or staff member having charge over an area or activity or with any degree of authority over an individual is responsible to their respective Chair or Unit Head (e.g., Executive Director, Academic Director) for ensuring that:

      1. any observed hazards or lapses in the functioning of an EHS program, and other EHS concerns are dealt with promptly;
      2. all individuals under their supervision have been informed of the hazards and instructed on the necessary risk control and emergency response measures;
      3. the applicable University and departmental EHS policies, programs, procedures and practices associated with the area and activity under their supervision are communicated and implemented;
      4. the hazards associated with the area or activity have been identified and the necessary risk control and emergency response measures identified, documented, communicated and implemented; and
      5. risk assessments are performed on all research projects which have actual or potential hazards;
      6. all individuals engaged in activity associated with the research project are informed and instructed on the hazards and related risk control and emergency measures;
      7. any individual assigned to a supervisory role is competent; and
      8. workplace inspections, monitoring, and accident reporting and investigations are routinely conducted to ensure the integrity of risk control and emergency response measures.
    2. Faculty Members and Instructors  

      Insofar as the Faculty Member/Instructor is a "worker", the member shall exercise the rights and duties of a worker as stated Section 1.b.

      Insofar as the Faculty Member/Instructor is a "supervisor", the member shall exercise the rights and duties of a supervisor as stated Section 2.a.

      Consistent with these obligations and a duty of care for their students, each Faculty Member and Instructor is responsible to their respective Chair or Academic Director for ensuring that:

      1. the curriculum is designed and conducted to ensure that the management of risk to students reflects the policies, procedures and practices established by the University, EHS, the faculty and the academic department, school or centre;
      2. risk assessments are performed for any activity with inherent EHS risk; and
      3. students are informed of their rights and responsibilities, the hazards associated with the course activity or environment and that they are instructed on risk and emergency control measures.
    3. Supervisors of Independent Contractors

      Any McGill employee who is responsible for overseeing a contract for goods or services between McGill and an independent contractor shall ensure that:
      1. the contract documents makes reference to applicable requirements under McGill 's EHS System;
      2. relevant EHS information is communicated between McGill and the independent contractor; and
      3. contract requirements for complying with McGill 's EHS System are monitored and, wherever possible, enforced throughout the duration of the work being conducted.
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  3. Chairs and Unit Heads (e.g., Director)

    A chair or head of a department, school, office, unit or institute shall ensure that: A chair or head of a department, school, office, unit or institute shall ensure that:

    1. any unresolved observed hazards or lapses in the functioning of an EHS program, and other EHS concerns are dealt with promptly;
    2. the programs set out in the EHS System are developed, implemented and maintained within the sector where applicable;
    3. a Departmental/Unit Safety Officer is appointed to assist the department/unit in fulfilling its obligations and requirements as specified in the EHS System; and
    4. where necessary, a Departmental/Unit Safety Committee is formed to assist the Chair or Unit Head in fulfilling the obligations and requirements as specified in the EHS System.
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  4. Deans, Executive Directors and equivalent level administrators

    The Deans and Executive Directors are responsible to the Provost, Deputy Provost and Vice-Principal for ensuring that

    1. any reported hazards or lapses in the functioning of an EHS System and other EHS concerns reported by the Chairs and Unit Heads are dealt with promptly;
    2. the EHS Programs applicable to their faculties, division, units or work areas are developed, implemented and maintained current;
    3. the annual performance review of those persons reporting to the Deans and Executive Directors includes evidence that the EHS functions well and measurement of the performance of applicable responsibilities under the EHS System; and
    4. the subject of the development, implementation, maintenance and effectiveness of the applicable EHS Programs appears quarterly on the agenda of the Deans' and Executive Directors’ review of operations.
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  5. Provost, Deputy Provost and Vice-Principal

    The Provost, Deputy Provost and Vice-Principal are responsible to the Principal for directing the health and safety activities of the University and for ensuring that:

    1. an EHS System is developed, implemented and maintained for the University;
    2. the annual performance review of those persons reporting to the Provost, Deputy Provost and Vice-Principal includes evidence that the EHS functions well and measurement of the performance of applicable responsibilities under the EHS System; and
    3. the subject of the development, implementation, maintenance and effectiveness of the EHS System appears semi-annually on the agenda of the Provost, Deputy Provost and Vice-Principal’s review of the University's operations.
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  6. Principal and Vice-Chancellor

    The Principal is responsible to the Board of Governors for directing the health and safety activities of the University and for ensuring that:

    1. an EHS System is developed, implemented and maintained current for the University;
    2. the annual performance review of those persons reporting to the Principal includes measurement of the performance of applicable responsibilities under the EHS System; and
    3. the subject of the development, implementation, maintenance and effectiveness of the EHS System appears annually on the agenda of the Principal's review of the University's operations.
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  7. Board of Governors

    The Board of Governors is responsible for directing the health and safety activities of the University and for ensuring that:

    1. sufficient resources are allocated to EHS;
    2. the annual performance review of the Officers of the University includes measurement of the performance of applicable responsibilities under the EHS System; and
    3. the subject of the development, implementation, maintenance and effectiveness of the EHS System appears annually on the agenda of the Board's review of the University's operations.
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Definitions

Environmental Health & Safety System

McGill’s Environmental Health & Safety System is a comprehensive system, covering all functions, positions and activities. It consists of:

  1. The Health & Safety Mission Statement that provides the overarching norm that the EHS System is designed to promote;
  2. A set of prescriptive principles that further develop the meaning and intent of the EHS Mission Statement;
  3. Organizational statements that outline the distribution of authority, responsibility, and accountability for EHS throughout the organization (i.e., Internal Responsibility System);
  4. An interlocking set of EHS programs, where each program is associated with a set of EHS concerns and details the responsibilities, procedures, standards and so forth that address those EHS concerns.

The EHS system at McGill University is incorporated within the University’s EHS risk management strategy, and is designed to facilitate due diligence within the intent of the Quebec Act Respecting Occupational Health and Safety and McGill’s commitment to a duty of care for the learning environment. The system establishes the means by which each member of the McGill community can achieve their personal legal obligations within the statutory duties of the internal responsibility system and obligations inherent in their relationship with McGill.

Environmental Health & Safety Program

An integrated set of responsibilities, procedures, standards and major activities (e.g., training) required to accomplish the objectives and fulfill the principles of the Environmental Health & Safety System

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Posters

Internal Responsibility Triangle

Internal Responsibility System Chart [.pdf]

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 References