Plan, Do, Check, Act: The need for independent audit of the internal responsibility system in occupational health and safety

This research explores the use of regulatory non-compliance as an additional measure of the health of the internal responsibility system. Using an analysis of orders issued pursuant to the Occupational Health and Safety Act in the Ontario mining sector over a 10 year period this paper argues that observed non-compliance shows that even with sophisticated sectors in developed jurisdictions third party audit with sanction powers is needed. Additionally, this analysis provides a leading indicator approach that can be used by regulators or those who are regulated to improve health and safety outcomes by complementing other techniques to gauge the strength or success of internal responsibility systems that are based on workplace questionnaires.