How to manage impairment

by Norm Kramer

Raise the issue of Covid-19 and impairment, and our minds may go in multiple directions. Increased substance use from isolation and stress, for one, extreme fatigue from overwork for another. But these are just two forms of impairment.

Norm Kramer is a Canadian Registered Safety Professional
with over 25 years’ experience. Norm
provides health &
safety consulting
services for WSPS as
a Warehouse Specialist
in the GTA region.

CSA Standard Z1008:21, Management of Impairment in the Workplace, defines impairment as “a temporary physical, psychological, or physiological state of the worker that has a negative impact on performance or creates a hazard in the workplace.” In other words, it’s a state that distracts a worker from fully concentrating on the task at hand.

At any time, there could be many possible causes of impairment: unpredictable schedules, employee turnover, working excessive hours or multiple jobs, operating in extreme temperatures, a temporary disability, conflict in the workplace or at home, and more.

All of these causes may exist in warehouses and distribution centres, especially given the explosive demand for logistics services in this fast-paced, high-demand environment. These causes could compromise workers’ ability to do their job safely, making them a hazard to themselves and others.

As workplaces shift from a short-term to long-term approach to Covid-19, this may be an ideal time to review and update your impairment policy. That’s if you have one. Most employers already have a substance abuse policy, but that’s just one form of impairment.

Here are six possible steps for addressing workplace impairment.

1 Recognize as an organization that we all manage our way through this pandemic differently. It’s important to acknowledge we’re going through a hard time, and it’s okay not to be okay.

2 Conduct an impairment hazard assessment. Consider all possibilities (e.g. shiftwork). Any of them could contribute to impairment.

3 Create an impairment policy that sets out the workplace’s approach. Establish expectations and responsibilities of all workplace parties, and procedures to follow. The Canadian Centre for Occupational Health and Safety offers useful information for developing a policy at

4 Build anti-impairment measures into practices and procedures. For example, to minimize shift-related fatigue, whenever practical enable employees to choose shifts conducive to a healthy sleep pattern. Ensure new hires are fully qualified and trained, and have practical experience before you consider them fully competent. In one workplace I visited, a newly hired young worker was qualified to operate a powered piece of mobile equipment, yet was too young to operate a motor vehicle on the highway.

5 Provide information and instruction on impairment. Among other things, this could include educating everyone on the impairment policy, informing them of their responsibilities under occupational health and safety (OHS) legislation, and training them on the dangers of using equipment or machinery while impaired, and how to recognize signs of impairment.

6 Create a culture where people are encouraged to disclose possible impairment. Start by demonstrating through policy and actions that you will accommodate people who disclose, and offer support and access to resources. Talking about it, encouraging self-reporting, and demonstrating that you support your employees will help them feel safe in coming forward.

7 Provide ready access to supports. Employee and family assistance programs and community-based crisis, distress, or addiction support are just some of the resources that can help workers with impairment issues.

How OHS law applies to impairment

Under the legislation, employers, supervisors and workers each have responsibilities for maintaining a healthy and safe environment.

Employers and supervisors are required to take every precaution reasonable in the circumstances to protect a worker. This includes ensuring workers are not impaired, and not exposed to hazards caused by impairment. Employers and supervisors who become aware of a worker operating heavy mobile equipment near other workers and who may be impaired must take every precaution reasonable to ensure this worker and others are protected.

Workers have an obligation to perform their job safely, which includes not performing work when impairment may affect health and safety. Workers are also responsible for reporting hazards, such as a co-worker who may be impaired.

A possible next step

CSA Z1008:21, Management of Impairment in the Workplace, is a new standard that offers a structured approach to assessing and controlling impairment, including impairment from substance abuse. An implementation guide with expert guidance and practical tools is also available online. Log onto the CSA Group website and use “View/Access” to explore them.