Staff Report #2 – Occupational Health & Safety Work Programs – 2023 (status) and 2024

Staff Report #2

January 31, 2024

To All Commissioners

Re: Occupational Health & Safety Work Programs – 2023 (status) and 2024


The report be NOTED and FILED.


Each year, the Joint Occupational Health & Safety Committees (JHSC) hold a workshop to review the progress made against the annual Health & Safety Work Program and to recommend to the General Manager the proposed Health & Safety Work Program for the following year. Throughout the year, items may be added to the list and prioritized accordingly due to emergent issues.

2023 Work Program Status

A summary of the 2023, Work Program status is set out in Enclosure I. The following provides a high-level summary of the key initiatives included in the 2023 Program.

Job Hazards Analysis

In 2023 a Working Group was formed to update the job hazards analysis for two primary positions within the Fleet and Facilities department. The Working Group was comprised of JHSC members with significant knowledge of the positions and external expertise from Taylor’d Ergonomics. The two positions assessed were Hoist Mechanic and General Service (Wonderland), neither of which had any identified findings of significant hazard when measured against current policies and programs in place. The General Service position assessment included a recommendation for the parties to review the body posture when performing specific duties, and this will be addressed in the coming months.

Human Rights and Diversity (Anti-Harassment, Anti-Sexual Harassment and Anti-discrimination) and Mutual Respect in the Workplace

London Transit has a long-standing Human Rights and Diversity Policy (Anti-Harassment, Anti-Sexual and Anti-Discrimination) and a Mutual Respect in the Workplace Policy and Complaint Procedure. These Policies and related Complaint Procedure are reviewed as necessary and at least annually as part of the Occupational Health and Safety Work Program. The Policies and Complaint Procedure are developed in consultation with London Transit’s JHSC and legal counsel. The Policies and Complaint Procedures form part of London Transit’s anti-harassment, anti-sexual harassment, and anti-discrimination program in concert with the Commission’s Workplace Violence Prevention Policy and Procedure.

In the fall of 2023, Human Resources began a review and update of the corresponding training modules, which were initially developed and rolled out in 2015/16, in an effort to ensure the training continues to meet legislative requirements, effectively educates employees on provisions of the policies, addresses workplace issues to reduce policy-related violations and improve the workplace. All employees receive the requisite training as part of LTC’s Onboarding Program. In addition, all employees participate in refresher training at least once every eight years. Further, where warranted, employees may undergo refresher training when an investigation and recommendation dictates same. The eight-year cycle will resume in 2024, with the delivery of the training beginning in the second quarter of 2024.

Mental Health Strategy

London Transit’s Mental Health Strategy continues to build upon its existing foundation for psychological health and safety through the Wellness Committee, focusing on the following strategic goals: Changing the Culture, Building Capacity and Measuring, Reporting, and Continuous Improvement. In mid-2023, a call for new members for the Wellness Committee was initiated, and the response was positive. The new membership brings valuable lessons learned, experiences and applicable knowledge to contribute positively to Committee goals and initiatives going forward. In December 2023, the Committee re-developed/updated the mental health support Employee Pocket Guide and hosted educational sessions for the Operator group to provide a refresher to employees on the various programs and supports available, as well as the enhanced employee benefits coverage to support mental health. In the first quarter of 2024, the Committee will provide a refresher to all Fleet and Facilities, Administrative and remaining Operations employees.

Impact of Buses Not Communicating

A JHSC Working Group was tasked with reviewing and investigating potential issues relating to “buses on detour” reports that may not show an accurate location on CAD/AVL and the potential for associated health and safety risk. In 2022, there were reports that buses on detour were not accurately reporting their position back to Dispatch due to their non-adherence No Adherence (N/A) status in Transit Master Bus Operations (TM). The potential hazard would be the risk of Dispatch not knowing the accurate bus location in the event of an emergency, hampering the ability to send Inspectors or First Responders to the bus. Given the potential health and safety risks associated with this issue, a study was undertaken to assess the validity of the claims. An in-depth review of the data found no evidence of a hazard regarding the location information of the bus when shown as N/A status.

Use of Open-Door Switch When Bus is In Motion

Through the JHSC, Fleet and Facilities reviewed the mechanics relating to the operation of the “bus open door switch” on all bus models in the fleet as there appeared to be a lack of consistency, which raised safety concerns. In 2018, a modification to the bus specification was made (for safety reasons) to ensure that all new/future buses were equipped with an override system so that the external open door switch cannot be activated when a bus is in motion or in gear. Buses purchased prior to this date were not equipped with this same override system. Presently, fleet management is working with the bus manufacturer to re-program the older buses to ensure consistency in the operation of the switch. Once complete, a communication reminding all Operators of this new feature will be distributed.

Driving Buses with Broken Mirrors

Through the JHSC, Fleet and Facilities undertook a review of the procedures and related training associated with driving a bus with a broken mirror back to the facility. The approach enforced that when dealing with a change-off relating to a broken mirror (if it cannot be repaired on-road by a qualified staff member), the bus must be towed back to the property, not driven by an LTC employee. The review found that Fleet and Facilities had completed shift safety talks on this issue; however, not all employees were in attendance. To ensure the communications and employer expectations are clearly outlined, Fleet management developed a Standard Operating Procedure on this work rule and reviewed it with all Fleet employees in late fall, 2023.

Workplace Banning Policy and Procedure Review

Through JHSC a Working Group was formed to undertake a review of London Transit’s Banning Policy and related procedures to streamline the process, ensure employees are fully aware of expectations when dealing with a banned person and overall how to improve communications in this critical area for all employees. The Working Group recommended several enhancements, which have been approved and are currently being rolled out:

  • Update/refresh the training and development for all Operations (Operators, Dispatchers, and Inspectors), with increased emphasis on the following:
    • Operators adequately de-escalate situations involving banned passengers, understand how their response can negatively and/or positively impact the situation, avoid escalation when a banned passenger boards, and allow Inspectors to manage the incident when they attend, etc.
    • Ensure Dispatchers and Inspectors obtain sufficient information from Operators regarding the incident.
  • Additional training and continual reinforcement by management needed to ensure all key groups fully understand the banning process.
  • Modify the banning process as follows:
    • Ensure buses remain in service if a banned passenger is not causing an immediate safety hazard.
    • Dispatch is to send an Inspector to all banned passenger incidents. The Inspector(s) will attend and assess the need for LPS.
    • Where warranted, buses taken out of service for a banned passenger, with the intent of removal of the person, will be done near or in the core or at a terminal if possible. (This change is recommended for a one-year trial to review effectiveness, as Inspectors have indicated that removing a banned passenger near the end of a route generally escalates the passenger further as they are likely nowhere near where they want to be or where supports are more likely available).
    • If the Operator reports any escalation, Dispatch will send Inspector(s) and call LPS immediately.
  • Update the respective SOPs for all of the Operations groups (Inspector, Dispatch and Operator) to reflect the changes.
  • Implement enhanced communications tools for Inspectors, an Inspector Checklist to assist when dealing with banned passengers and the use of a pocket guide, both for quick and easy reference on the steps required to be taken.

Review and Update – Risk Assessment for the Inspector Position

In 2021, a JHSC Working Group began undertaking the Inspector Position Risk Assessment. This review was a multi-year project with key initiatives approved and implemented over the period to ensure the Inspector Position Risk Assessment aligned with the current work environment. Several key initiatives resulted from the review, as set out below.

Managing Passenger Mental Health Challenges as an Inspector

As noted in Staff Report #2 dated January 25, 2023, there has been a steady and notable increase (40% increase since 2019) in calls of a volatile nature that Inspectors attend. The calls range from assisting someone under the influence, dealing with banned passengers, being placed in dangerous situations, passenger disturbances, sleepers, workplace violence incidents, etc. To address this significant increase, and through the JHSC, Human Resources, with the assistance of Nancy Gowan from Gowan and Associates in late 2022/2023, developed a new one-day training module that focuses on ensuring Inspectors have the skills to manage challenges faced when they come upon passengers who are in distress, aggressive or dangerous. The module provides approaches for Inspectors to ensure they have the tools to keep themselves, the Operator and the passengers safe. All Inspectors received the training in the second quarter of 2023. This training program has been shared with other Ontario Transit systems as a best practice.

Trial for Additional On-Road Support

A one-year trial that provided for enhanced Inspector coverage was completed in 2023. This entailed adding one full-time Inspector and modifying shifts to provide for two Inspectors on duty for a majority of the on-road service period, better-defined optimal spots for stationary work, and maximum periods for Inspectors to be stationary. The objective of adding the additional Inspector and re-configuring the shifts and stationary locations was to allow two Inspectors to attend escalated calls and improve response times. The review/assessment was completed in the second quarter of 2023, and the findings demonstrated a significant improvement with respect to two Inspectors attending escalated calls. 63% of all escalated calls had two Inspectors attend, compared to the historical average of 39% before the change in protocol. This has allowed one Inspector to focus on the Operator and provide any support required while the other Inspector deals directly with the event (person), LPS, other passengers. The change also provides backup for the Inspector when dealing with highly volatile situations. The feedback from Inspectors for this process has been very favourable. Since the trial, the assessment demonstrated that the number one reason why two Inspectors did not attend an escalated call was that the first Inspector on-site cancelled the requirement for the second Inspector as the matter had been dealt with. The assessment also looked at the response time of Inspectors attending escalated calls. The evaluation found that a response time of “15 minutes” remained consistent before and during the trial period. The response time was anticipated to decline during the trial as Inspectors were stationary at locations more central to the core and/or main terminal locations. However, construction within the London area, specifically downtown, negatively impacted the response time during the trial.

The JHSC Working Group recommended maintaining the additional Inspector in the current 10-hour shift configuration to maximize coverage, maintain the current designated optimal spots for stationary work, and maintain a maximum period of 30 minutes for Inspectors to be stationary. All recommendations have been approved.

Radio Communications

A JHSC Working Group was tasked to assess the effectiveness and best practice of internal communications between two vital operational areas: Dispatch and Inspectors. Part of the approved recommendation was to conduct a study that tracks all issues relating to “dead zones” for Inspector radios and conduct an overall hazard analysis. Considerations of the study included whether the parties could communicate via alternate means, the level of risk to parties involved, and any other factors present. The study’s overall results demonstrated that no hazards were identified, as in all cases, the affected individuals could communicate through the radio or other means; however, as recommended and approved, the Supervisor will continue to track all issues and take action as warranted.

Review and Update – Risk Assessment for the Customer Service Representatives & Planning Staff

The Customer Service Representatives and Planning Staff’s risk assessment was recently updated through London Transit’s Workplace Violence Prevention Program. Both risk assessments detailed potential controls to be evaluated and implemented that could improve the overall work environment and reduce exposure to workplace violence incidents. One key initiative noted was the requirement for enhanced training and support to staff when dealing with the public who are disrespectful, irate and/or verbally threatening.

In addition to the risk assessments, it has been noted that over the last few years, there has been a demonstratable increase in complex interactions experienced by staff in both of these areas, both in terms of email, phone, attendance at public information sessions and in-person communications in general.

As the result of the risk assessments, coupled with an increase in more difficult communications, a training program was developed and delivered to all Customer Service Representatives and Planning staff in the third quarter of 2023. The program focused on managing difficult conversations, defusing escalated situations, knowing when to draw the line and terminate the discussion and when to involve the Supervisor for support. Additionally, on a go-forward basis, moderators hosting LTC events are advised of the requirement to ensure respectful interactions, and communications will be posted advising that there will be no tolerance for such behaviour.

2024 Health & Safety Work Program

The 2024 Work Program, as set out in Enclosure II, has been reviewed and approved by the General Manager. In addition to multi-year programs and those carried forward from 2023, new initiatives on the 2024 Program include:

Workplace Violence Prevention Program Training Program for Operators

A carryover from the JHSC Workplan from 2023 was delayed and is targeted for completion in the third quarter of 2024. In 2014/15, the Workplace Violence Prevention Program was reviewed and fully revamped to meet the needs of the employees and the overall organization. This included the re-development of a two-day Operator Training Program on Workplace Violence and the development of an Advanced Customer Service Program for Operators. Since the rollout, all Operators have received this training at least twice. As begun in 2023, the two-day Operator Training and Advanced Customer Service Program is under review to ensure they continue to meet the needs of Operators and the organization while ensuring Operator safety, and where necessary, London Transit will enlist external expertise in the re-development of the Program.

Develop a Campaign on Healthy Habits in the Workplace

Continued focus on creating and maintaining a healthy workplace begins with developing and educating employees on overall healthy habits. A new campaign will be developed and rolled out in 2024 through internal communication mediums, including internal screens, bulletin boards, LTC Communicator and shift talks.

Review of Mobility Securement on board Buses

This initiative will see a review of best practices and ergonomic enhancements to mitigate injuries relating to the securement of mobility devices on conventional transit buses. Any recommendations resulting from the review will be implemented as they are approved.

Updates with respect to progress on the 2024 Work Program items will be provided as part of the departmental quarterly updates to the Commission.


I – 2023 Occupational Health & Safety Work Program – Status

II – 2024 Occupational Health & Safety Work Program

Recommended by:

Joanne Galloway, Director of Human Resources

Concurred in by:

Kelly S. Paleczny, General Manager