Which roles should be on the Management Structure?

A role should be included in the management structure whenever it carries supervisory responsibilities or influences the implementation of the Safety and Health Management System (SHMS). Under CMSHA s.55, the Site Senior Executive (SSE) must document the responsibilities and required competencies for every supervisory position, and identify the people authorised to carry out those responsibilities.

Recognised Standard 22 further requires the SSE to include in the management structure all roles that have delegated responsibilities contributing to the development, implementation, or maintenance of the SHMS, with competency requirements aligned to the risks associated with those responsibilities. 

Therefore, any role should be incorporated into the management structure if it:

• Supervises workers or contractors

• Directly influences, controls, or coordinates work activities

• Has responsibilities that affect safety-critical tasks or risk controls

• Contributes to or interacts with SHMS elements (e.g., permits, isolation, hazard management, emergency readiness)

• Makes operational decisions that impact safety or health outcomes

If a role meets any of these criteria, excluding it from the management structure would likely fall short of the requirements under s.55 and RS22. If the role has no supervisory authority, does not oversee work, and carries no SHMS-related responsibilities, then it may not need to be included.

A role should be formally part of the management structure if they:

·       Supervise workers or contractors

·       Control project work that introduces new risks

·       Approve or coordinate project tasks

·       Have responsibilities that interact with SHMS elements (e.g., isolation, permits, construction activities, commissioning)

·       Lead or influence safety-critical decisions

·       Hold defined responsibilities that impact risk controls

In these cases, leaving them off the management structure would be non‑compliant with s.55 and RS22.

A role might not need to be included if the role:

·       Is purely administrative

·       Has no supervisory authority

·       Does not coordinate work or people

·       Has no delegated SHMS responsibilities

·       Does not influence safety‑critical decisions

…then the SSE may choose to exclude it.