Health & Safety

Below you will find the Health and Safety (H&S) chapter of the Disney International Labor Standards

(ILS) Guidebook. The Guidebook is intended to increase transparency into the requirements of the ILS

Program. Each chapter begins with a Guiding Principle, meant to set the stage for benchmarks,

violation examples and corresponding ratings. The Guidebook will be released one chapter at a time.

This H&S chapter highlights:

 Benchmark requirements and their associated ratings

 Definitions of key terms and phrases

 Information regarding required training and documentation, including permits and licenses

 Required safety procedures and equipment

 Recommended preventative measures

This chapter also introduces color-coded ratings for each of the benchmarks. The definitions for the

three rating levels are below.

Minimum Compliance Standard (“MCS”) is applied to violations which fall below the required

level of compliance with Disney’s Supply Chain Code of Conduct (“Code”).

Serious is applied to Code violations that may significantly impact worker safety if not

addressed promptly. When three (3) or more Serious violations are identified in a single audit,

they each will be rated as an MCS violation.

Non-MCS is applied to violations which are less egregious than the ratings above, but remain

issues that should be addressed in order for the Facility to be in full compliance with the Code.

Where Code requirements deviate from local legal requirements, the stricter standard will apply.

Violation ratings are periodically reviewed and updated. Please note that the violation examples

contained in the Guidebook are meant to be illustrative and not exhaustive. Disney reserves the right

to make changes to violations and corresponding ratings, at its discretion, taking into account that

some issues must be considered on a case-by-case basis.

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HEALTH AND SAFETY

GUIDING PRINCIPLE

Workers shall be provided with a safe and healthy working environment. Facilities must

implement measures to prevent hazards and minimize workers’ exposure to unsafe and

unhealthy conditions in the workplace and in employer-provided housing.

DISNEY CODE

KEY COMPLIANCE BENCHMARKS

The Key Compliance Benchmarks apply with respect to the Code of Conduct for

Manufacturers as well as the Supply Chain Code of Conduct announced in March 2022.

The following sections apply to all areas of a facility, including both on-site and off-site

employer-provided housing.

Suppliers must provide workers with a safe and healthy workplace, taking all

necessary steps required to ensure prevention or mitigation of injury or accidents

that may arise from the course of their work, as well as provide guidance on

proper chemical management and disposal. At a minimum, Suppliers must

provide workers with adequate and accessible restrooms, potable water, sanitary

food preparation, storage and eating facilities, personal protective equipment,

safe machinery and tools, training to prevent and mitigate accidents, adequate

temperature control and ventilation, and sufficient lighting.

Suppliers must ensure that all living and dormitory spaces are clean, safe, and fit

for the purpose. Spaces must be secure and allow reasonable freedom of

movement to enter and exit.

Suppliers should create, maintain, and execute emergency preparedness plans

and procedures that are understandable to workers and clearly communicate the

response procedures for various emergencies that may occur including fires,

natural disasters, security, and health-related events. Suppliers should regularly

assess whether buildings are structurally sound.

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Benchmark ratings are indicated with the following symbols:

MCS

Serious

Non-MCS

GENERAL HEALTH & SAFETY

Hazard Assessments

Training & Communication

Documentation

 Workers regularly exposed to occupational hazards must be

provided with health examinations and tested at the frequency

determined by applicable laws and regulations, or at least in the

following situations:

 Before being assigned hazardous work;

 Periodically while assigned to perform hazardous work;

 Upon reassignment back to non-hazardous work;

 At resignation or termination of employment; and

 Upon request by workers.

 Assessments to identify occupational health and safety (OHS)

hazards must be conducted regularly to ensure ongoing compliance

with applicable legal requirements. (Examples of common OHS

assessments can be found in the Preventive Measures section of this

chapter.)

 Health and safety trainings must be provided for all workers and

supervisors when hired, upon assignment to a new job, and on an

annual basis thereafter.

 Records of health and safety hazard assessments and work area

inspections must be maintained.

 Records of internal and third party audits and compliance

inspections by regulatory agencies must be maintained.

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Work Environment

 Health and safety corrective and preventive action plans, including

documented evidence of hazard control improvements, must be

maintained.

 Records of health and safety training attendance and assessment of

knowledge and/or skills (quizzes, tests, skills demonstrations) must

be maintained.

 Records of self-assessments and other evaluations of compliance

with the company’s health and safety policies and procedures and

compliance with applicable legal requirements must be maintained.

 A log of work-related accidents, injuries and illnesses, and copies of

accident investigation reports and the actions taken to eliminate

their root causes must be maintained.

 All areas of the facility, including employer-provided housing, must

be in compliance with the health and safety requirements outlined

in this chapter and meet all applicable laws and regulations for

occupant safety.

 Ventilation in the workplace must be maintained to control the

levels (or concentrations) of airborne contaminants, temperature,

noise, and other environmental factors within allowable limits as

prescribed by applicable laws and regulations.

 Lighting must be provided at the level necessary to prevent eye

strain and workplace accidents as required by applicable laws and

regulations, and necessary for workers to perform their tasks

effectively.

 Where proper controls cannot be feasibly maintained, appropriate

procedures must be implemented to minimize adverse health

impact to workers. For example, frequent rest breaks in a cooler

shaded location and ample drinking water should be provided to

those working in high temperature and/or humid environments.

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Helpful Definitions

Confined Space: The interior

of a place such as a tank or a

utility vault that is large

enough for a worker to enter

and perform work but is not

designed for occupancy and

has restricted means of entry

or exit.

FIRE & EMERGENCY SAFETY

Emergency Procedures

Evacuation Drills

 Elevated work areas, including scaffolds, mezzanines, and aerial

platforms must have guardrails to prevent falls. Where guardrails are

not feasible, workers working in such areas must be provided with

appropriate fall protection devices.

 Confined space work must be evaluated for risks and appropriate

control measures must be clearly communicated to workers and

implemented (e.g., confined space entry procedures, permitting

process, personal protective equipment) as required by applicable

laws and regulations.

 A written evacuation procedure based on potential emergency

scenarios must be established.

 All workers, including new hires, must be trained on emergency

evacuation procedures in a language they understand on an

ongoing basis.

 Evacuation procedures and maps must be prominently posted in all

occupied areas and be in a language understood by workers.

 Evacuation maps must indicate both primary and secondary exit

routes, the locations of fire extinguishers and alarm points, and the

designated assembly locations outside the building.

 Evacuation drills must be conducted for the entire facility once every

six months.

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Helpful Definitions

Means of Egress: A

continuous and unobstructed

path of travel from any point

in a building to the outside.

This includes the way of exit

access, such as a corridor, the

exit, and the exit discharge to

outside the building.

Exit: A portion of the means

of egress that is physically

separated from all other

spaces of the building. It

provides a protected way of

travel to the outside. This

includes but is not limited to

exit doors, exit passageways,

and exit stairways.

Occupant Load: Occupant

load is defined as the number

of occupants per story that

the means of egress is

expected to accommodate.

For example, for a space with

400 occupants and two

means of egress, the

occupant load for each is 200.

The minimum sizing of exit

doorways, exit pathways and

exit stairways is based on

occupant load.

Means of Egress

International Fire Code (2021), Section 1005 “Means of Egress Sizing”

 Evacuation drills must include:

 All workers;

 All work shifts; and

 All areas of the facility, including on-site and off-site

employer-provided housing.

Note: Large facilities and those with multiple shifts may need to

conduct drills at different times to ensure all workers are included.

 Workers with disabilities or special needs must be pre-assigned a

partner to assist them in evacuating during a drill and in case of an

actual emergency.

 Means of egress and stairways must be fully accessible at all times

and free from debris, clutter, equipment, and storage that may

impede egress or present a fire hazard.

 Emergency lighting for all means of egress pathways (e.g., aisles,

corridors, exit stairways, and ramps) must be installed, functioning,

inspected monthly, and powered by either battery or backup

generator.

 The minimum width of exit doorways and exit pathways must meet

the stricter of local fire safety regulations or the widths in the

following table

Minimum Width of Exit Doorways and Pathways

Occupant Load per Exit

Doorway or Pathway

Minimum Width

1 – 160 people

0.8 meters (32 inches)

161 to 200

1.0 meters (40 inches)

201 to 300

1.5 meters (60 inches)

301 to 400

2.0 meters (80 inches)

more than 400

Occupant Load times 5.1

mm (0.2 inches)

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Emergency Exits & Exit Signs

International Fire Code (2021), Section 1005 “Means of Egress Sizing”

International Fire Code (2021), Section 1006 “Numbers of Exits and Exit Access Doorways”

 The minimum width of all exit stairways must meet the stricter of

local fire safety regulations or the widths in the following table

Minimum Width of Exit Stairways

Occupant Load per Exit

Stairway

Minimum Width

1 – 50 people

0.9 meters (36 inches)

51 – 150

1.1 meters (44 inches)

151 to 200

1.5 meters (60 inches)

201 to 300

2.3 meters (90 inches)

301 to 400

3 meters (120 inches)

more than 400

Occupant Load times

7.6 mm (0.3 inches)

 All means of egress pathways must be delineated and marked with

arrows and signage to indicate the direction of travel to the nearest

exit.

 Exit doors must:

 Be unobstructed and unlocked during working hours,

including overtime hours, or whenever any workers are

present in the facility;

 Open with one single motion (e.g., push on a panic

bar, or turn a doorknob, or push down on a door

handle); the use of keys, slide bolts and/or security

codes to open the door are not permitted; and

 Open directly to an exit stairway or to the exterior of

the building (i.e., they cannot open into another room

or area, or into another building).

 Facilities must have a minimum number of exits based on

occupancy as detailed below

Minimum Number of Exits

Number of Occupants per

Story

Exits per Story

1 - 500 people

Two (2)

501 to 1,000

Three (3)

Over 1,000

Four (4)

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Emergency Equipment

International Fire Code (2021), Section 1017 “Exit Access Travel Distance”

International Fire Code (2021), Section 906.3 “Portable Fire Extinguishers: Size and Distribution”

 Exit doors must open in the direction of evacuation (i.e., outward)

and be side hinged (e.g., exit doors cannot be rolling or sliding).

 Visible and illuminated signage must be posted at each exit.

 The exits must be as far apart as possible (e.g., for a space with two

exits, the exits should be on opposite sides of the space).

 For facilities without an automatic sprinkler system, sufficient exits

must be available to ensure that the maximum travel distance for a

person to reach the nearest exit does not exceed 61 meters (200

feet)

 Fire alarms must be clearly heard and visible from all areas of the

facility and employer-provided housing, as required by applicable

laws and regulations.

 A fire alarm control panel, automatic fire sprinklers, smoke detectors

and fire extinguishers must be installed as required by applicable

laws and regulations.

 Maximum travel distance to a fire extinguisher cannot exceed 23

meters (75 feet)

or the distance required by applicable laws and

regulations, whichever is shorter.

 Inspections of all means of egress, exit components, alarms, and fire

detection and suppression systems must be performed on a monthly

basis. The inspection program should include, but is not limited to:

 An inventory of all exit components and emergency

equipment

 A checklist of the inspection and maintenance tasks to

be performed for each item

 Maintenance scheduling based on inspection outcomes

 Maintenance of any legally required fire inspection

certifications

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Helpful Definitions

Hazardous Materials:

Hazardous materials are

liquids, solids and gases that

present health and safety

hazards to workers,

property, or the

environment. They include

substances that are toxic,

corrosive, combustible,

flammable, reactive or

explosive.

These substances must be

used safely to minimize the

risk to workers and the

environment during their

handling, use, storage,

transport, and disposal.

HAZARDOUS MATERIALS

Permits & Licenses

Training & Communication

Hazards Management

 Inspection and maintenance records, including the date,

work performed (e.g., visual inspection, functional test,

or type of maintenance or repair performed) and the

name of the individual who performed the work

 Testing and maintenance of sprinkler system components must be

performed at a frequency recommended by the manufacturer or in

accordance with applicable laws and regulations, whichever is

stricter.

 Permits, licenses, registrations and certifications for the storage,

handling, treatment, and disposal of hazardous materials must be

obtained and maintained as required by applicable laws and

regulations.

 Workers working with hazardous materials must be trained on how

to safely store, handle, transport and use such materials, including

initial and refresher trainings and applicable certifications as

required.

 Emergency response procedures must be established to manage

spills, leaks and worker exposure to hazardous materials per

applicable laws and regulations.

 Hazardous materials must be properly stored. This includes the

following:

 Combustible and flammable materials such as paints,

solvents, sawdust, and compressed gases must be

stored in approved containers in rooms and storage

areas away from open flames or other sources of

ignition;

 Chemicals are stored only in containers approved for

use with the specific type of chemical;

 Materials are separated by hazard class (e.g., organic

acids must be segregated from flammables to prevent

the release of toxic or flammable vapors in the event of

a leak or spill); and

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Helpful Definitions

GHS: The UN Globally

Harmonized System of

Classification and Labeling

of Chemicals (GHS) is an

international system

created by the UN to

address the classification of

chemicals by types of

hazard and harmonize

hazard communication

elements, including labels

and safety data sheets.

Safety Data Sheet (SDS):

An SDS provides detailed

information about a

chemical to help ensure

that all workers who handle

chemicals have the hazard

information they need to

safely use, handle and

store them. Some of the

information they provide

includes, physical data (e.g.

flash point and vapor

pressure), physical and

health hazards, first aid

measures, required

personal protective

equipment, and how to

handle spills or leaks.

United Nations Globally Harmonized System (GHS) of Classification and Labelling of Chemicals:

http://www.unece.org/trans/danger/publi/ghs/ghs_rev02/02files_e.html

 Storage areas, rooms and cabinets are provided with

secondary containment to prevent releases to the

environment or mixing of incompatible materials in the

event of a leak or spill.

 A current inventory of hazardous materials that includes a list of

materials in the workplace, where and how they are stored, and the

volume of each material present must be maintained.

 The inventory of hazardous materials must be shared with local

emergency response authorities where required by applicable laws

and regulations.

 A GHS

-compliant Safety Data Sheet (SDS) must be available for

every hazardous material in the facility.

 SDS must be in the local language, in languages understood by the

workers, and be immediately accessible to workers in all areas

where chemicals are stored or used.

 All containers of hazardous materials must be labeled with a GHS-

compliant hazard label in the local language and in languages

understood by the workers. Labels must include the following:

 Signal word indicating the hazard level (e.g., Danger,

Warning, etc.);

 Hazard pictograms that illustrate the material hazard

types;

 Manufacturer information;

 Precautionary statement and first aid instructions;

 Hazard statements (for example, “Extremely flammable

gas,” or “Toxic if ingested”); and

 Product or chemical name

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Helpful Definitions

Hot Work: Any work using

open flame or heat sources

that could ignite

combustible materials.

Examples of hot work

include welding, cutting,

brazing, pipe soldering, and

metal grinding.

All hot work should be

approved by an authorized

individual at the workplace

who is trained on the

necessary precautions for

hot work management. This

individual is responsible for

granting permits when

combustibles are removed

from the work area where

hot work is performed, wall

and floor openings are

covered, combustible floors

are covered with fire-

resistant materials, a fire

extinguisher is readily

available, a fire watch is

provided, and any other

necessary precautions are

taken.

MACHINE AND ELECTRICAL SAFETY

Permits & Licenses

 Machinery and electrical system permits, licenses, registration and

certifications must be obtained and maintained as required by

applicable laws and regulations.

 Where licensing or certification is required to perform a specific

function (e.g., weld; operate any machinery, equipment or vehicle;

or install, maintain or repair electrical equipment and systems),

workers must be properly trained, licensed, and/or certified as

required by applicable laws and regulations.

Training & Communication

Machine Safety

 Machinery and electrical equipment must be provided with signs

and labels indicating the hazards and necessary precautions.

 All machinery and electrical equipment signs and labels must be in

the local language and in languages understood by the workers.

 Safe operating procedures for all machinery and electrical

equipment must be up to date and readily available for workers who

operate the machinery and electrical equipment.

 All safe operating procedures for machinery and electrical

equipment must be in the local language and in languages

understood by the workers.

 Required machine safeguards must be securely in place, in good

operating condition, effectively protect against identified hazards,

properly utilized and maintained according to manufacturers’

instructions or recommendations, and tested for proper operation at

the start of every work shift.

 Higher risk processes such as welding, torch cutting, brazing and

soldering must be conducted using proper safety measures, such as

a “hot work” permit system.

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Helpful Definitions

Control of Hazardous Energy

(Lockout/Tagout): Workers

who service or maintain

machines and equipment

may be exposed to serious

injury or death if hazardous

energy is not properly

controlled.

Lockout/tagout procedures

require affixing the

appropriate locks and/or

tags to energy-isolating

devices (for example,

switches and valves),

deenergizing machines and

equipment before beginning

work, and training all workers

performing lockout/tagout

procedures. Workers in the

area where lockout/tagout is

performed should be

provided with awareness

training.

Hazardous Energy: During

the servicing and

maintenance of machines

and equipment, the

unexpected startup or

release of stored energy

(e.g., electrical, mechanical,

hydraulic, pneumatic,

chemical, or thermal) can

result in serious injury or

death to workers.

Electrical Safety

Lockout/Tagout

PERSONAL PROTECTIVE EQUIPMENT (PPE)

Personal Protective Equipment

 All machinery must be reviewed for safety hazards, and safeguards

must be provided to protect workers against the identified hazards.

The types of hazards requiring safeguards include, but are not

limited to:

 Hot surfaces

 Rotating parts, including in-running nip points

 Reciprocating and transverse motions

 Cutting, punching, shearing, and bending actions

 Detailed preventive maintenance records for all machinery and

equipment safeguarding must be maintained, including, but not

limited to, inspections, functional testing, and scheduled

maintenance and repairs.

 Electrical wiring and equipment in damp or wet locations must be

approved for use in such locations in accordance with applicable

laws and regulations.

 All electrical wiring and equipment must be covered and insulated

to prevent contact with exposed live parts, per applicable laws and

regulations.

 Electrical equipment and installations must be maintained in a safe

condition through a program of routine inspections and preventive

maintenance at least annually or at a frequency recommended by

the designer or manufacturer, whichever is more frequent.

 Lockout/tagout procedures must be in place and followed to

protect workers from unexpected energization, release of

hazardous energy, or startup of machinery and equipment during

repair and maintenance activities.

 Personal protective equipment (PPE) must be provided,

maintained, and replaced at no cost to workers.

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Training & Communication

MEDICAL AND FIRST AID

Emergency Response

First Aid Equipment

 Workers must be provided with PPE that is appropriate for the

hazards involved.

 Workers must always wear PPE wherever its use is required by

applicable law to protect the health and safety of workers against

site-specific hazards.

 PPE must be stored properly when not in use, inspected prior to

each use, maintained to ensure ongoing effectiveness, and

replaced as required.

 PPE must fit workers properly to minimize exposure to hazards.

 Workers must be trained to properly use, store, and maintain PPE.

 In areas where PPE use is required, postings and signs about the

hazard(s) and type of PPE required must be available in the

language(s) understood by workers.

 A sufficient number of licensed medical staff members must be on

duty as required by applicable laws and regulations.

 Workers requiring emergency medical attention must receive

appropriate care by trained medical professionals in a timely

manner.

 Where professional medical attention is not immediately available

for an injured or ill worker, first aid must be administered by trained

facility first aid personnel in a timely manner.

 Where there is risk of hazardous materials exposure to eyes, face,

or body, emergency eyewash and shower equipment must be

available and maintained to function properly at all times.

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Helpful Definitions

First Aid Kit: A first aid kit

contains supplies essential

for providing first aid to

injured workers, such as

bandages, antiseptic,

scissors, gloves, and hand

sanitizer. The requirements

for kit contents are contained

in ANSI/ISEA standard

Z308.1.

Training & Communication

 First aid training must be provided at least every three years to

workers responsible for administering emergency first aid. Training

may need to be conducted more frequently to ensure a sufficient

number of trained facility first aid personnel on an ongoing basis.

 Workers handling hazardous materials must be trained on

emergency procedures including the location and proper use of the

eyewash and shower equipment.

 Emergency phone numbers must be communicated to all workers

and be visibly posted throughout the workplace and worker housing

in languages understood by the workers (e.g., labels containing the

number are affixed on all facility phones).

 Signage for emergency equipment must be in languages

understood by the workers.

SANITATION

Toilet Facilities

 An adequate number (at least 1 toilet for every 15 workers) of

separate male and female toilet facilities must be provided to

workers. Wherever possible, single stall bathrooms should also be

provided.

American National Standards Institute (ANSI) / International Safety Equipment Association (ISEA)

Z358.1 (2014) “Emergency Eyewash and Shower Equipment”

 The travel distance from any point in the work area to the eyewash

and shower equipment must not exceed 15 meters (55 feet) or 10

seconds of travel time in the event of an emergency

 First aid kits must be stocked with supplies appropriate for the

hazards in each area, and be readily accessible in all areas,

including worker housing.

 First aid kits must be inspected and refreshed at least monthly, or

more frequently if needed to ensure adequate amounts of

necessary supplies are available and not expired.

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 Toilet facilities in the workplace and employer-provided housing

must be well-ventilated, well-lit, and have running water (including

hot water where available), soap, toilet paper, and paper towels or

other hand-drying equipment.

 Toilet facilities must be maintained in a sanitary condition, be

cleaned twice daily (or more frequently as needed), and supplies

replenished as needed.

Drinking Water

 Safe and potable drinking water must be readily available and

accessible to workers at all times in the workplace and employer-

provided housing.

 Periodic testing of drinking water must be conducted at least once

per year to ensure that it meets local regulatory requirements for

safe drinking water.

Dining & Food Preparation

 All food storage areas, food preparation areas, and worker eating

areas must be inspected and cleaned frequently (for example, before

and after each meal) to maintain sanitary conditions.

 Food handlers, cooks and servers must receive required medical

examinations and be trained and certified in food safety as required

by applicable laws and regulations.

 All necessary certificates and licenses as required by applicable laws

and regulations must be obtained and maintained for

canteens/kitchens.

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WORKER HOUSING

 Employer-provided housing must be separated from buildings that

contain production processes, warehousing, or chemical storage

areas.

 Employer-provided housing must be safe and secure. This includes,

but is not limited to:

 A reasonable level of privacy

 A separate bed for each worker (sharing of beds by

workers on different shifts – also known as “hot

bedding” - is not permitted)

 Beds arranged no higher than two tiers

 Separate accommodations for men and women (both

sleeping rooms and toilets)

 Adequate supply of potable water available at all times

 Ventilation, both natural and mechanical, to ensure

sufficient air movement in all weather conditions

 Employer-provided housing must have a reasonable level of

hygiene and comfort. This includes, but is not limited to:

 Adequate natural and artificial lighting

 A reasonable amount of personal space and personal

storage for each worker

 Clean and sanitary toilet and washing facilities

Helpful Definitions

Housing (Dormitories):

Living accommodations

provided or arranged by the

employer for its workers.

Worker housing is typically a

shared accommodation,

also known as a dormitory,

with two or more workers

per sleeping room, and

common toilet and washing

facilities.

Hygienic: Free of biological

(bacteria and mold),

infestations of insects or

vermin, accumulations of

trash, and chemical

contaminants that can cause

illness by inhalation,

ingestion or skin contact.

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RECOMMENDED PREVENTIVE MEASURES

POLICIES & PROCEDURES

POLICIES

Develop formal and written policies that:

 Comply with applicable health and safety laws and regulations, including

obtaining all required building construction, occupancy and equipment

inspections, permits, certifications and licenses.

 Maintain a safe and healthy working environment and employer-provided

housing, transportation, and food services.

 Provide emergency first aid as well as ongoing medical treatment and

related services needed for a full recovery and return to work for workers

who suffer work-related injuries and illnesses.

 Ensure workers’ access to basic needs (e.g., toilet facilities and drinking

water) is unrestricted.

 Provide workers with information and training on an ongoing basis about the

health and safety hazards of their jobs and the precautions that are

necessary to prevent injury or illness.

PROCEDURES

In addition to the Compliance Benchmarks described above, develop and

implement formal written procedures to:

 Routinely identify, track and comply with applicable health and safety laws

and regulations.

 Regularly conduct assessments to identify occupational health and safety

(OHS) hazards to ensure ongoing compliance with applicable legal

requirements. The type of assessment should be appropriate to site

operations and can include:

 Job Hazard Analysis, which breaks jobs down into individual

tasks to identify the hazards each task presents and how to

eliminate or control the hazards

 Industrial hygiene (occupational hygiene) surveys to measure

exposures to health hazards such as dusts, vapors, gases,

noise, and ionizing and non-ionizing radiation

 Review new equipment and chemicals to identify safety and health hazards

in need of control before beginning to use them.

 Perform preventive maintenance for machine guarding, exhaust ventilation

and other hazard controls.

 Identify training needs and deliver appropriate health and safety training,

based on legal requirements, customer requirements, worker requests, and

job-specific assessments of health and safety hazards.

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 Provide, maintain, and replace as required, personal protective equipment

where hazards cannot be controlled by engineering means.

 Ensure reporting and investigation of all work-related injuries and illnesses,

including taking appropriate actions to prevent a recurrence.

 Encourage workers to report safety and health concerns or offer suggestions

for hazard controls without fear of intimidation or reprisal.

 Perform structural integrity inspections of all buildings using visual and non-

destructive testing methods (e.g., ultrasonic testing, electrical resistivity, and

radiographic testing).

ACCOUNTABILITY & RESPONSIBILITY

 Assign accountability to senior management staff for achieving policy

objectives and assign management and other staff for effective

implementation of procedures.

 Assign a senior manager with overall responsibility and accountability for

meeting policy objectives and overseeing how the system for managing

health and safety is working.

 Ensure that managers, supervisors, and workers have clearly defined roles

and responsibilities. For example, responsibility for ensuring workers are

given appropriate personal protective equipment where it is needed, that

they understand how to use the equipment and they use it consistently.

 Ensure that management takes into account suggestions from workers and

addresses concerns in a timely manner.

TRAINING & COMMUNICATION

 Provide initial and ongoing training to all managers, supervisors and workers

on the policy and the health and safety risks in the workplace that could

result in illness or injury.

 Provide in-depth training for the staff responsible for implementing specific

procedures. For example, workers that perform repairs and maintenance on

equipment that could accidentally become energized and cause injury or

death, must know how to follow lockout/tagout procedures to protect

themselves and others nearby.

 Post the company health and safety policy and local laws and regulations

where workers, on-site contractors and visitors can see them and in both the

local language and the languages workers understand. For workers with

difficulty reading, pictograms and photos can help. For example, pictures

and symbols can help communicate workplace hazards such as noise or

chemicals, and the types of protective equipment required.

 Encourage workers to report health and safety issues and to make

suggestions for improving workplace health and safety practices.

Effective: March 1, 2023 | 19

Worker-Management

Health and Safety Committee:

 An effective way to improve

company efforts to identify and

control workplace health and

safety hazards.

 Involve workers in accident

investigation teams, in

performing work area

inspections, and in developing

and implementing safe work

procedures and other hazard

controls.

 Helps the company track

achievement of its health and

safety objectives.

DOCUMENTATION

 Maintain a register of all applicable health and safety laws, regulations and

Disney requirements.

 Maintain health and safety committee meeting minutes, action items, and

attendance records.

MONITORING & CONTINUOUS IMPROVEMENT

 Conduct regular internal or third party audits and assessments using

qualified personnel.

 Set and measure progress on key performance indicators (KPIs). Examples of

KPIs include the percentage of workplace accidents and incidents

investigated for root cause, the number of corrective actions completed on

time, the number of accidents and injuries resulting from the same cause,

and the percentage of workers able to safely evacuate the workplace in the

target time.

 Perform regular worker surveys to measure how satisfied they are with

workplace conditions and practices and to understand what would help

them do their jobs more safely and efficiently.

 Conduct periodic senior management reviews to evaluate system

effectiveness and update policies and procedures.

 Take both corrective and preventive action to address each identified root

cause so that problems do not recur. For example, a facility may first re-train

night shift workers on proper health and safety practices (corrective action)

and then review night production quotas and work schedules to eliminate

tiredness or working too fast as causes of injuries (preventive actions).

 Assign task owners, milestones, and completion dates for any corrective and

preventive actions.

 Ensure that workers know how to follow any new or revised procedures that

have been developed to address risks through initial and refresher training

as needed.

 Measure whether the adjustments in procedures and supporting training are

producing desired results.

Effective: March 1, 2023 | 20

RESOURCES

DISNEY RESOURCES

 Disney International Labor Standards Program Manual

EUROPEAN UNION AGENCY FOR HEALTH AND SAFETY AT WORK

 http://osha.europa.eu/en

INTERNATIONAL LABOUR ORGANIZATION (ILO)

 Occupational Safety and Health: https://www.ilo.org/safework/lang--en/index.htm

 Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001):

http://www.ilo.org/safework/areasofwork/occupational-safety-and-health-management-

systems/lang--en/index.htm

INTERNATIONAL ORGANIZATION FOR STANDARDIZATION (ISO)

 ISO 45001 – Occupational Health & Safety: https://www.iso.org/iso-45001-occupational-health-

and-safety.html

SOCIAL ACCOUNTABILITY INTERNATIONAL (SAI)

 SA8000 Standard: https://sa-intl.org/

UNITED STATES OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA):

 Safety and Health Topics: https://www.osha.gov/SLTC/