Occupational Health, Injury Prevention and Return-to-Work Program

Glooscap First Nation, Glooscap Ventures, and our related business entities are committed to providing a safe, healthy, respectful, and supportive workplace.

We are committed to preventing workplace injuries and illnesses, responding quickly when safety concerns are reported, and supporting employees who are injured or medically restricted in their return to work.

Safety is everyone’s responsibility. Managers, supervisors, employees, Human Resources, health and safety representatives, and workplace committees all play an important role in keeping our workplace safe.

About the program

This program applies to employees, managers, supervisors, contractors, students, temporary workers, volunteers, visitors, and all applicable workplaces within Glooscap First Nation, Glooscap Ventures, and related entities.

The organization includes both federally and provincially regulated operations. This program is designed to ensure that each workplace meets the health and safety requirements that apply to it. Provincially regulated business entities, such as Glooscap Ventures, Glooscap Landing, The Market at Glooscap Landing, and related commercial or operational workplaces, must comply with Nova Scotia occupational health and safety requirements and WCB Nova Scotia requirements, where applicable.

Glooscap First Nation operations are federally regulated under Part II of the Canada Labour Code. These workplaces are responsible for providing employees with the information, training, supervision, and protection needed to work safely. Employees have the right to know about hazards, to participate in health and safety matters, and to refuse dangerous work where the law allows.

If there is a difference between standards, the organization will follow the legal requirement that applies to the workplace. Where possible, the organization will apply the higher safety standard to protect workers and support a safe work environment.

Program Objectives

The objectives of this program are to:

Prevent workplace injuries, occupational illness, and near misses.
Promote a strong safety culture across all departments and entities.
Ensure employees understand their health and safety rights and responsibilities.
Identify, assess, and control workplace hazards.
Provide employees with appropriate training, equipment, supervision, and safe work procedures.
Ensure timely reporting of injuries, hazards, and unsafe conditions.
Investigate incidents and near misses to prevent recurrence.
Support employees who are injured or medically restricted.
Provide safe and meaningful modified duties where possible.
Cooperate with WCB Nova Scotia and other applicable authorities.
Maintain accurate records and review safety performance regularly.

Safety Culture

A strong safety culture means safety is part of daily decision-making, not only a written policy.

The organization will promote a safety culture by:

Encouraging employees to report hazards, injuries, and near misses.
Responding to safety concerns promptly and respectfully.
Training employees before assigning new or higher-risk work.
Holding managers and supervisors accountable for workplace safety.
Reviewing injury trends and corrective actions.
Discussing safety during onboarding, staff meetings, and operational planning.
Ensuring employees are not penalized for raising legitimate safety concerns.
Recognizing that psychological safety, harassment prevention, and respectful workplace practices are part of overall workplace health and safety.

Roles and Responsibilities

Senior Leadership

Senior Leadership is responsible for:

Demonstrating visible commitment to health and safety.
Ensuring appropriate resources are available for the program.
Approving safety policies, procedures, and program updates.
Supporting managers in addressing hazards and implementing corrective actions.
Reviewing safety performance, injury trends, WCB claims, and return-to-work outcomes.
Ensuring the organization complies with applicable legislation.

HR / Health & Safety Program Administrator

Human Resources is responsible for:

Maintaining this program and related procedures.
Coordinating WCB reporting where applicable.
Supporting managers with injury response and return-to-work planning.
Maintaining confidential injury, medical, WCB, and accommodation records.
Tracking training, incidents, modified duties, and program performance.
Advising managers on accommodation and return-to-work obligations.
Supporting respectful and consistent communication with injured employees.
Ensuring program reviews are completed.

Managers and Supervisors

Managers and supervisors are responsible for:

Ensuring employees are trained and supervised.
Identifying and correcting workplace hazards.
Completing inspections and following up on corrective actions.
Ensuring employees use the required PPE and safe work procedures.
Responding immediately to injuries and near misses.
Reporting incidents to HR the same day.
Participating in incident investigations.
Identifying safe and meaningful modified duties.
Monitoring employees working modified or transitional duties.

Employees

Employees are responsible for:

Following safe work procedures.
Using required PPE and safety equipment.
Reporting hazards, injuries, illness, pain, discomfort, unsafe conditions, and near misses as soon as possible.
Participating in required training.
Cooperating with investigations, inspections, and return-to-work planning.
Working within medical restrictions.
Advising their supervisor or HR if modified duties are causing difficulty or may not be safe.

Under the Canada Labour Code, employees in federally regulated workplaces have duties that include using safety equipment provided, following safety procedures and instructions, cooperating with persons carrying out Code duties, and reporting hazards, accidents, occupational diseases, and other hazardous occurrences.

Joint Occupational Health and Safety Committee (JOHC)

The Joint Occupational Health and Safety Committee at Glooscap First Nation/Glooscap Ventures is led by Lauren Coady, the Health & Safety Manager, and is responsible for supporting workplace safety by:

Participating in inspections.
Reviewing health and safety concerns.
Reviewing incidents and trends.
Making recommendations to management.
Supporting hazard identification and control.
Promoting employee participation in workplace safety.

Employee Health and Safety Rights

Employees have the right to:

Know about workplace hazards and receive appropriate training.
Participate in health and safety processes.
Refuse work that they reasonably believe is dangerous, in accordance with the applicable legal process.
Report hazards, injuries, illness, harassment, violence, or unsafe conditions without retaliation.
Be treated with dignity and respect during injury reporting, accommodation, and return-to-work planning.

Hazard Identification, Assessment, and Control

The organization will identify workplace hazards through:

Regular workplace inspections.
Employee hazard reports.
Incident and near-miss reports.
Job hazard assessments.
Safe work procedure reviews.
New equipment or process reviews.
Maintenance reports.
JOHSC or Safety Representative recommendations.
WCB and injury trend analysis.
Employee feedback.

Hazards may include, but are not limited to:

Slips, trips, and falls.
Manual lifting and material handling.
Repetitive work.
Ergonomic strain.
Working alone.
Workplace violence or harassment.
Fatigue.
Chemicals and cleaning products.
WHMIS-controlled products.
Driving and travel.
Weather-related risks.
Tools, equipment, ladders, and maintenance work.
Cold storage, cooler, freezer, and seafood-handling risks.
Retail, market, customer-service, and cash-handling risks.
Office workstation risks.
Psychological health and safety risks.

Hazard Control

Hazards will be controlled using the hierarchy of controls:

Eliminate the hazard where possible.
Substitute the hazard with a safer option.
Use engineering controls.
Use administrative controls, such as procedures, scheduling, signage, training, and supervision.
Use PPE as the final layer of protection.

Workplace Inspections

Workplace inspections will be completed regularly to identify and correct hazards.

Inspection frequency will depend on the workplace risk level, but the following minimum standards apply:

Office and administrative workplaces: at least quarterly, or more often where required.
Retail, market, seafood, maintenance, or operational workplaces: at least monthly.
Vehicles, tools, ladders, freezers, coolers, and equipment: pre-use or scheduled inspections where applicable.
Federally regulated workplaces: monthly inspections must be carried out by the health and safety committee or a representative, in whole or in part, to ensure the entire workplace is inspected at least once each year.

Inspection records will include:

Date of inspection.
Area inspected.
Hazards identified.
Risk level.
Corrective action required.
Person responsible.
Completion date.
Follow-up confirmation.

Safe Work Procedures

Safe work procedures will be developed for work activities that present a risk of injury, illness, or harm.

Safe work procedures may include:

Manual lifting and material handling.
Slips, trips, and falls prevention.
Ladder safety.
Cleaning and chemical handling.
WHMIS-controlled products.
Working alone.
Violence and harassment prevention.
Ergonomics and workstation setup.
Maintenance tasks.
Retail and customer-facing work.
Cooler, freezer, seafood, and market operations where applicable.
Emergency response and first aid.
Incident reporting.
Return-to-work and modified duties.

Safe work procedures will be reviewed when:

Work processes change.
New equipment is introduced.
An incident or near miss occurs.
A hazard assessment identifies a new or increased risk.
Legislation or WCB guidance changes.

Training and Orientation

Employees will receive health and safety training:

During onboarding by either their manager or the H&S team.
Before starting new or higher-risk duties.
When equipment, processes, procedures, or legislation change.
After an incident, near miss, or identified training gap.
On a refresher basis as required.

Training may include:

OHS rights and responsibilities.
Hazard reporting.
Incident and injury reporting.
Emergency procedures.
First aid process.
WHMIS.
PPE.
Safe lifting.
Ergonomics.
Slips, trips, and falls prevention.
Workplace violence and harassment prevention.
Working alone.
Return-to-work expectations.
Department-specific safe work procedures.

Training records will be maintained by HR or the designated program administrator.

Incident, Injury, Illness, and Near-Miss Reporting

All employees must report workplace injuries, illnesses, pain, discomfort, hazards, unsafe conditions, and near misses as soon as possible. https://forms.office.com/r/bG7kFbC3wL

Employees should report workplace injuries as soon as possible after they occur, preferably the same day.

Immediate Response

When an injury or incident occurs, the supervisor must:

Ensure the employee receives first aid or emergency medical attention.
Secure the area if there is an ongoing hazard.
Notify HR as soon as possible.
Complete an internal incident report.
Identify immediate corrective action.
Determine whether the employee can safely remain at work with temporary changes in place.
Begin the WCB reporting process where applicable.

For Nova Scotia WCB matters, WCB must receive the injury report within 2 business days after the injury was reported to the employer where the injury meets reporting criteria, such as medical treatment or lost time.

For federally regulated workplaces, serious injuries must be reported to the federal Labour Program within 24 hours, and written investigation reports are required for temporary and permanent disabling injuries within 14 days.

Incident Investigation

The organization will investigate incidents and near misses to prevent recurrence.

The purpose of an investigation is not to assign blame, but to understand what happened and correct underlying causes.

An investigation may review:

What happened.
Date, time, and location.
Work is being performed.
Employees or witnesses involved.
Environmental conditions.
Equipment or tools involved.
Training and supervision.
Safe work procedures.
Immediate causes.
Root causes.
Corrective actions required.
Person responsible.
Completion date.

Workplace Incident Investigation Report Template pdf

Corrective actions will be tracked until completed.

The JOHSC, Health and Safety Committee, may participate in investigations where required or appropriate.

WCB Reporting and Claims Management

For WCB-covered workplaces and employees, the organization will meet all applicable WCB Nova Scotia reporting and claims management requirements.

The organization will:

Report injuries to WCB within the required timelines.
Provide accurate information to WCB.
Maintain communication with the injured employee.
Cooperate with WCB during claim management.
Identify suitable and meaningful modified duties where possible.
Document return-to-work offers and plans.
Maintain confidential claim records.

Employees are expected to:

Report the injury as soon as possible.
Seek appropriate medical care where required.
Provide functional abilities information.
Cooperate with WCB and the employer.
Participate in return-to-work planning.
Work within restrictions.

Return-to-Work Philosophy

WCB Nova Scotia’s Duty to Co-operate rules took effect on July 15, 2025, and require employers and injured workers to actively work together with WCB to support a safe and timely return to work.

Return-to-Work Process

Step 1: Injury or Restriction Identified

The employee reports the injury, illness, or restriction to their supervisor and HR as soon as possible.

The supervisor ensures first aid or medical attention is provided where required.

Step 2: Early Contact

HR or the supervisor will contact the employee as soon as reasonably possible.

The purpose of early contact is to:

Check on the employee’s well-being.
Explain the reporting and return-to-work process.
Confirm whether the employee has medical restrictions.
Discuss safe work options.
Keep the employee connected to the workplace.
Identify any immediate barriers to return-to-work.

Step 3: Functional Abilities Information

The organization may request information about functional abilities from the employee or a healthcare provider.

Functional information may include:

Lifting limits.
Standing or walking tolerance.
Sitting tolerance.
Repetitive movement restrictions.
Use of hands, arms, shoulders, back, or legs.
Driving restrictions.
Hours of work tolerated.
Need for breaks.
Gradual return-to-work recommendations.
Expected review date.

The organization will focus on what the employee can safely do. Diagnosis or unnecessary personal medical details will not be requested unless legally required or directly necessary for accommodation.

Step 4: Identify Suitable Work

HR and the manager will review available work and determine whether modified or alternate duties can be offered.

Suitable work may include:

Modified regular duties.
Reduced hours.
Gradual return-to-work.
Temporary alternate duties.
Administrative work.
Training.
Documentation.
Filing or scanning.
Inventory records.
Safety checklists.
Remote work where appropriate.
Other productive work within restrictions.

Step 5: Written Return-to-Work Plan

Where modified duties or restrictions apply, a written return-to-work plan will be prepared.

The plan will include:

Employee name and position.
Department or entity.
Date of injury or restriction.
WCB claim number, if applicable.
Functional restrictions.
Approved duties.
Duties to avoid.
Work schedule.
Work location.
Start date.
Review date.
Supervisor responsible.
HR contact.
Employee responsibilities.
Signatures where appropriate.

Step 6: Monitor and Adjust

The supervisor and HR will monitor the return-to-work plan.

Reviews may occur:

On the first day of modified work.
At the end of the first week.
Weekly or biweekly, depending on the case.
When medical information changes.
Before duties or hours are increased.
When the employee raises a concern.

If modified duties are not working safely, the plan will be reviewed and adjusted.

Step 7: Full Return or Further Accommodation

When medically able, the employee will return to regular duties.

If restrictions continue, HR will review whether further accommodation is required. Accommodation will be assessed individually and may include modified duties, scheduling changes, equipment, workplace adjustments, reassignment, or other reasonable measures, up to the point of undue hardship.

Duty to Co-operate

For WCB-covered injuries, the organization, employee, WCB, and healthcare providers share responsibility for supporting safe and timely return-to-work.

Employer Responsibilities

The organization will:

Maintain respectful contact with the employee.
Offer safe and meaningful modified duties where available.
Provide WCB with the requested return-to-work information.
Participate in return-to-work planning.
Document offers of suitable work.
Adjust duties as medical restrictions change.
Address barriers to return-to-work.

Employee Responsibilities

The employee will:

Report injuries promptly.
Stay in reasonable communication.
Provide functional abilities information.
Participate in return-to-work planning.
Follow medical restrictions.
Raise concerns if the duties are unsafe or unsuitable.
Accept safe and suitable work where available.

WCB Nova Scotia has stated that employers and workers are required to work together, stay in touch during the process, and offer or participate in suitable duties; non-compliance can result in penalties for employers and/or workers.

Modified Duties

Modified duties are temporary or transitional duties provided to support an employee’s safe return to work.

Modified duties must:

Be safe.
Be meaningful.
Respect the employee’s dignity.
Be within medical restrictions.
Be productive where possible.
Be reviewed regularly.
Do not create new hazards.
Not to be used as discipline or punishment.

Examples of modified duties may include:

Administration and Office

Filing.
Scanning.
Data entry.
Policy review.
Training modules.
Reception support where appropriate.
Meeting notes.
Document organization.
Safety bulletin preparation.

Market, Retail, or Customer Service

Light customer service.
Price label updates.
Vendor file updates.
Online order support.
Product information review.
Inventory documentation.
Safety checklist completion.
Administrative support.

Maintenance or Operations

Work order documentation.
Tool inventory.
Preventive maintenance logs.
Supply ordering.
Safety inspection forms.
Light coordination work.
Procedure review.

Fisheries, Seafood, or Related Workplaces

Inventory records.
Quality checklist review.
Scheduling support.
Logistics documentation.
Safety procedure review.
Training or compliance documentation.

Modified duties will be matched to the employee’s functional abilities and operational needs.

Accommodation and Human Rights

The organization recognizes its duty to accommodate employees with disabilities, injuries, illnesses, or medical restrictions to the point of undue hardship.

Accommodation is a shared process. Employees must participate in the process and provide reasonable information related to their functional abilities. Managers and HR must consider reasonable options and avoid assumptions.

Accommodation may include:

Modified duties.
Modified schedule.
Gradual return-to-work.
Temporary reassignment.
Equipment or ergonomic changes.
Remote work where appropriate.
Additional breaks.
Adjusted work methods.
Permanent accommodation where required and reasonable.

All accommodation decisions will be made individually, based on the facts of the situation.

Psychological Health, Harassment, and Violence Prevention

Workplace health and safety includes both physical and psychological safety.

Return-to-Work for Psychological Injury

This page focuses on returning to work after a physical injury. Get information on return-to-work planning for psychological injury. https://www.wcb.ns.ca/employers/psychological-injury/return-to-work

The organization will take reasonable steps to prevent and respond to:

Harassment.
Violence.
Bullying.
Threatening behaviour.
Discrimination.
Psychological harm related to work.
Unsafe workplace conflict.

Employees are encouraged to report concerns early. Reports will be reviewed respectfully, confidentially where possible, and without retaliation.

Federally regulated workplaces are subject to federal workplace harassment and violence prevention requirements, while provincially regulated workplaces must follow applicable Nova Scotia OHS and workplace safety obligations.

Confidentiality and Privacy

The organization will protect the confidentiality of medical, WCB, injury, and accommodation information.

Medical information will only be shared with those who need the information to support safety, accommodation, claims management, or return-to-work.

Supervisors will generally only receive information about:

Functional restrictions.
Duties the employee can perform.
Duties the employee must avoid.
Schedule or workplace adjustments.
Emergency or safety considerations, where required.

Medical diagnosis will not be shared unless legally required or directly necessary.

Records and Documentation

The organization will maintain records related to:

OHS policy and program.
Training.
Inspections.
Hazard reports.
Incident and near-miss reports.
Investigations.
Corrective actions.
First aid.
WCB reports and correspondence.
Functional abilities forms.
Return-to-work plans.
Modified duty offers.
Accommodation records.
JOHSC, Health and Safety Committee, or Safety Representative activities.
Program reviews and safety performance indicators.

Nova Scotia’s OHS program guidance requires employers to maintain records related to health and safety, inspections, orders, tests, and program activities, and to make the required documentation available upon request.

Program Monitoring and Review

This program will be reviewed at least annually and whenever there is:

A serious injury or hazardous occurrence.
A pattern of incidents or near misses.
A change in legislation.
A WCB requirement or recommendation.
A new workplace, department, or business entity.
New equipment or work process.
A recommendation from the JOHSC, Health and Safety Committee, Safety Representative, WCB, or regulator.

The organization will monitor:

Number of incidents.
Number of near misses.
Number of hazards reported.
Corrective action completion rate.
WCB claims.
Lost-time claims.
Days lost.
Time from injury to report.
Time from injury to first return-to-work contact.
Time from injury to modified duty offer.
Repeat injury trends.
Training completion.
Inspection completion.
Return-to-work outcomes.

Non-Retaliation

Employees have the right to report hazards, injuries, unsafe work, illness, harassment, violence, discrimination, or accommodation needs in good faith.

The organization will not tolerate retaliation against any employee who: