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Managing for Wellness - Disability Management Handbook for Managers in the Federal Public Service


4.0  Prevention

The purpose of the prevention component is to promote health and wellness in the workplace, prevent injury and illness arising from risks and hazards in the workplace and its social environment, and protect employee health at work.

4.1  Background

Common Causes of Stress at Work

  • An excessive workload;
  • Lack of control over or knowledge of the tasks to be performed;
  • Lack of recognition;
  • Lack of consistency between the values of the organization and their daily application in the workplace;
  • Interpersonal or organizational conflict, including harassment; and
  • Not having enough to do and feeling undervalued.

—From Mental Health: First Aid in the Workplace, Canada Revenue Agency

The majority of cases of non-occupational illness or injury in the federal public service are attributable to two main causes: psychological and musculoskeletal. There is abundant evidence that these causes of illness or injury can be prevented. In the workplace, encouraging individuals with early symptoms to take remedial action is one of the most effective and least costly ways to support health and well-being. Table 3 at the end of this section provides an overview of these causes of disability, their prevalence in the public service, and some of the workplace interventions that can help prevent them. (Other significant but less prevalent causes of disability are cancer, accidents and cardiovascular illness.)

As a manager, it is important to be aware of “presenteeism,” when employees come to work, but for a range of reasons (including poor health) are not working to capacity, if at all. According to experts on health and productivity, presenteeism may be a greater threat to workplace productivity than absenteeism. Some associated conditions include headaches, allergies, arthritis, asthma, diabetes, mental health issues and other pressures causing sleep deprivation, exhaustion and difficulty concentrating.

Encouraging employees to take care of themselves creates a climate that reinforces individual responsibility for maintaining health and well-being. In the core public administration, under the Directive on Leave and Special Working Arrangements, managers are responsible for ensuring that different types of leave are used appropriately. This means that you can, for example, encourage employees to use sick leave for a day or two when they are feeling unwell or to take appropriate leave with or without pay for the care of family.

Studies show that employees who adopt a healthy, balanced lifestyle and whose employers support their efforts to maintain their health are more likely to be healthy, resilient and productive. Employee assistance programs (EAPs), for example, are instrumental in assisting employees with personal or work-related issues related to stress. The key is early problem identification and referral to support.

4.2  Your Prevention Responsibilities Under the CanadaLabour Code, Part II

GECA/Workers Compensation – refer to Appendix A for definitionThe purpose of Part II of the Canada Labour Code is to prevent accidents and injury to health arising out of these, linked with or occurring in the course of employment, in any workplace under federal jurisdiction. Under “Duties of Employers,” it spells out what is to be done in the workplace to ensure the health and safety of employees. In tandem with the Canada Occupational Health and Safety Regulations, employers are required to adhere to regulated requirements and standards concerning, for example, building and equipment safety, exposure limits for hazardous substances, lighting and sound levels, and elimination or control of hazards in the workplace.

GECA/Workers Compensation – refer to Appendix A for definitionUnder provisions outlined in Part II of the Code, managers are required to be adequately trained in health and safety and informed of their responsibilities under Part II of the Code while acting on behalf of the employer. Broadly speaking, managers’ responsibilities are to ensure that:

  • Appropriate hazard prevention programs are in place;
  • Employees under their supervision are made aware of every known or foreseeable health and safety hazard, and each employee is provided with the information, instruction and training necessary to ensure his or her health and safety at work; and
  • When incidents affecting health and safety in the workplace occur, they are investigated and reported, and corrective action is implemented and followed up on. (Consult your OHS advisor for information on your organization’s accident reporting procedures.)

Key Facts About the Canada Labour Code

  • Applies to employees who work under federal jurisdiction—about 10 per cent of Canada’s labour force.
  • Key sectors of the economy to which the Code applies include air, rail and highway transport; pipelines; banks; broadcasting and telecommunications; uranium mines; marine transport and related services.
  • Some 40 Crown corporations and agencies, Indian reserves and the entire federal public service are also subject to Part II of the Code.
  • Enforcement and administration is the responsibility of Human Resources and Skills Development Canada’s Labour Program, in partnership with Transport Canada and the National Energy Board.

Employees are expected to, among other things:

  • Use any safety materials, equipment, devices and clothing intended for their protection;
  • Follow established health and safety procedures;
  • Cooperate with those charged with carrying out health and safety responsibilities; and
  • Report as soon as possible to their immediate supervisor accidents or any other incidents in the course of their work that have caused them injury or have injured others.

Under Part II of the Code, a workplace that has fewer than 20 employees must have a workplace health and safety representative. Those that have 20 or more employees must have a workplace health and safety committee, and those that have 300 or more employees must also have a health and safety policy committee. The representative and the committees have various powers and duties under the Code aimed at preventing workplace hazards and implementing changes to improve occupational health and safety. For more information, visit www.rhdcc-hrsdc.gc.ca/eng/labour/health_safety/overview.shtml.

The Occupational Health and Safety Directive supplements Part II of the Canada Labour Code for the core public administration. Developed by employer representatives and the bargaining agents at the National Joint Council, the directive specifies further employer responsibilities in addition to the ones outlined in Part II of the Canada Labour Code and the Canada Occupational Health and Safety Regulations. Some of these include:

  • Consulting with the workplace health and safety committee or the health and safety representative on workplace changes that may effect health and safety;
  • Implementing and monitoring the hazard prevention program;
  • Providing first-aid services to employees and ensuring the availability of first-aid kits;
  • Making prompt referrals for medical treatment;
  • Maintaining records of illness or injury in the workplace;
  • Making qualified first-aid attendants available to employees during regular working hours (at least 1 per 50 employees); and
  • Posting emergency contact information (e.g., hospital, fire, police and poison control).

Your departmental OHS advisor will be able to tell you what your specific responsibilities are under this directive, such as in first aid, and how to ensure that your unit meets and maintains them.

The directive also supplements provisions in the Code that require workplace health and safety representatives or committees. In the core public administration, these entities must handle complaints relating to the health and safety of employees; participate in the implementation and monitoring of the hazard prevention program in the workplace; participate in all inquiries, investigations, studies and inspections pertaining to the health and safety of employees; participate in the implementation of changes in the workplace that may affect health and safety; and inspect the workplace on a monthly basis.

Departments and agencies that have more than 300 employees must also have an occupational health and safety policy committee. Its purpose is to help develop and monitor the department or agency’s overall health and safety program and to serve as a forum where management and employee representatives can meet to exchange information and address and resolve health and safety issues. 

As a manager, you can use these mechanisms to engage employees in promoting a healthy workplace. You can turn to the workplace health and safety representative or committee for advice and assistance in educating your employees on health and safety matters and to implement programs for the prevention of hazards in the workplace. The policy committee can assist in planning changes in the workplace that may affect the health and safety of employees and in improving or developing new health and safety programs.

Consult your OHS advisor to find out how these mechanisms are used in your organization to promote employee health and well-being.

4.3  Your Role in Prevention

Good Management Practices for Good Health

  1. Ensure your expectations are realistic for employees and yourself.
    • For example, eliminate roles and activities that are not essential and that help people say no without feeling guilty.
  2. Increase employee control over their work.
    • For example, delegate decision making where possible and differentiate between work that is essential and work that can wait.
  3. Reduce effort and tension.
    • For example, facilitate work–life balance with flexible work schedules, involve employees and clients in designing new work procedures, encourage open communication and make use of informal disputeresolution services.
  4. Increase rewards and recognition.
    • For example, support employees who receive promotion offers, regularly give positive feedback when work is done well, and learn what each of your employees considers to be rewarding in his or her work.

—From Mental Health: First Aid in the Workplace, Canada Revenue Agency

Good management practices promote good health and well-being. Clarifying work priorities and employees’ roles and responsibilities for each task to be performed is one of the best ways to prevent excessive stress in the workplace and create a climate that promotes good health. Encouraging supportive working relationships among team members and helping employees feel that their work is useful are also important ways to support well-being.

Becoming aware of safe work practices and informing your employees is critical to reducing the risk of illness or injury. Ensuring that employees have the accommodations they need, such as ergonomic chairs and keyboards, large monitors, air filters, supplementary lighting and so on, also reduces the risk of illness or injury.

One of the most important roles you have as a manager is to be attentive—look and listen for signs of emotional stress or physical discomfort in the people who report to you and respond in a timely manner. These signs are an early warning that more serious problems could be developing.

Your role is not to get personally involved or become your employees’ confidante, nor is it to diagnose a problem. As a manager, your role is to create a work environment that supports employees’ well-being and performance. This involves enabling employees to get help if you see signs of a possible health problem.

Communicating that you are concerned and supportive will demonstrate to employees that you care. Maintaining an “open door” policy—encouraging your employees to come to you at any time to ask about getting help—reinforces your commitment to their health and well-being. The more engaged you are in supporting your employees to take action to maintain their health, the more likely you will gain the trust and confidence of employees who require support to recover from illness or injury and return to work as soon as it is safe to do so.

Be aware of the early signs of possible mental health issues. These could include changes in personality and mood; sadness or crying, tiredness and emotional fragility; impatient, negative and disruptive behaviours; unpredictable outbursts and verbal threats; and changes in absenteeism patterns.

When you see these signs:

  • Mention what behaviours you have observed and their impact in the workplace and indicate your concern. Remind the employee about your organization’s EAP and what it can offer and provide the contact information.
  • Monitor the situation. If you see no improvement, set a time to discuss your concerns with the employee by reviewing specific incidents, changes in behaviour, attendance or performance issues, and what assistance the employee may require.
  • At the meeting, stick to the facts, but make sure you convey your concern. When you ask about what assistance the employee needs, do not ask for medical information. That is private. If the employee spontaneously provides it, treat that information as confidential. Provide the contact information for EAP again and review how they may be able to help. If applicable, suggest that the employee speak with his or her union representative, who may also be able to help with referrals to other services.
  • Depending on what the employee says, review his or her workload and explore changes to his or her schedule or duties. Listen for clues about ways you could support the employee’s job satisfaction.

The Canada Revenue Agency developed Mental Health: First Aid in the Workplace to help managers take appropriate action in cases of possible mental illness. Its suggestions on what to say to employees to encourage them to use the EAP are summarized in Table 4 at the end of this section.

Be aware of the early signs of possible musculoskeletal disorders. These include unnatural or unhealthy postures while using a computer and infrequent “mobility” breaks—in other words, you rarely observe the employee away from his or her desk moving around. Listen for complaints of numbness and burning sensation in the hand; pain in the wrists, forearms, elbows, neck or back; and frequent tension headaches.

When you see these signs:

  • Take the time to ask whether the employee is in pain or needs a rest break.
  • Encourage the employee to get away from his or her desk and take breaks more frequently.
  • If you see no improvement, set a time to discuss options for modifying work duties or workload, altering the workstation, or changing the employee’s work schedule, and to review the merits of an ergonomic assessment of the job, tasks or workstation.
  • Encourage the employee to conduct a self-assessment using the Labour Program’s ergonomics-related hazard identification tool developed by HRSDC’s Labour Program. Depending on the results, order an ergonomic assessment. Consult your OHS advisor about the procedures to follow in your organization for obtaining an ergonomic assessment.

GECA/Workers Compensation – refer to Appendix A for definitionHRSDC’s Labour Program provides a number of helpful resources to assist you in working with your employees to reduce the risk of musculoskeletal injury. These include:

GECA/Workers Compensation – refer to Appendix A for definitionIf an ergonomic assessment recommends modifications to tasks or workstation and/or the use of assistive technologies, you can consult Environment Canada’s Accessibility, Accommodations and Adaptive Computer Technology (AAACT) Program. It provides advice and assistance, on a cost-recovery basis, to Government of Canada organizations to help integrate employees with disabilities, injuries and ergonomic requirements. (More information about this program is provided in section 6.4 of this handbook.)

GECA/Workers Compensation – refer to Appendix A for definition4.4  Prevention Checklist for Managers

4.4.1  Prevention Practices That Support Health in the Workplace

Learn about effective prevention practices for the workplace. Health Canada offers a wide range of workplace health information online, which is useful to managers in all types of workplace settings. You will find detailed information on workplace health strategies you can use to formulate approaches with your employees in order to maintain and promote good health. You can also find information on how to convince senior management about the benefits of investing in workplace health programs.

On the Canadian Centre for Occupational Health and Safety’s website you will find information and tips on simple, low-cost ways to mitigate the health impacts of everything from rotational shift work and substance abuse, to coping with critical incident stress. In particular, you may wish to use this resource to understand the value of flexible work arrangements, workplace fitness, what to do to reduce occupational stress and the risk of musculoskeletal injuries in the workplace to bridge the gap between mental illness and workplace functioning.

4.4.2  Your Organization’s Employee Assistance Program

GECA/Workers Compensation – refer to Appendix A for definitionBeing informed about your organization’s EAP and encouraging employees to use it is one of the best ways that you can take early action when you notice that mental stress is affecting performance. Have EAP materials with contact information visible and available in the workplace to enable employees to access the service for confidential assistance. Ongoing promotion of the EAP helps alleviate concerns about using the service and hesitancy in reaching out for help. Always have contact information ready to provide to employees. Learn about the basics of your EAP, i.e., what it covers, how referrals are made and how privacy is respected. (See Table 4 in this section for tips on what to say to encourage employees to use this service.)

The EAP can also provide you with immediate guidance if you are confronted with an urgent and troubling employee situation in the workplace. You can also use it when you feel that stress may be affecting your performance or you are feeling overwhelmed by work or personal pressures.

For specific organizational needs such as counselling following a critical incident, additional EAP services, including guidance and coaching, are available on a cost-recovery basis from Health Canada’s Employee Assistance Services’ Specialized Organizational Services. For more information, call 1-888-366-8213 or email Contact Specialized Organizational Services by email: info-sos@hc-sc.gc.ca.

4.4.3  Instruments to Help You Assist Employees

Familiarize yourself with the Treasury Board’s Directive on Leave and Special Working Arrangements and its Telework Policy. You can take advantage of these to assist an employee who is struggling with a mental or physical health problem. In cases of stress, particularly related to work–life balance, you can devise a plan using one or more of these policies to help your employee cope. Flexibility in the workplace to accommodate personal or family needs yields significant benefits, including reduced levels of employee stress and conflict, higher levels of productivity and output, reduced absenteeism, and higher levels of employee satisfaction and motivation.

Special working arrangements such as leave with income averaging can be of enormous benefit to an employee who needs time off to provide care for an ill child or aging parent. Under this policy, the employee can take between 5 weeks and 3 months of leave without pay in a 12-month period. The employee’s pay will be reduced accordingly but will continue to be paid while he or she is away. This time away from work may also be split into two periods over the 12 months but cannot be less than 5 weeks for each period. (Note: The employee will be required to fill out the “Application for Leave with Income Averaging” form [TBS 325-10E].)

Subject to your operational requirements, you can also consider pre-retirement leave to help an employee transition successfully to retirement. This is available to employees who are within two years of retirement, to reduce their work week by up to 40 per cent (i.e., up to 2 out of 5 days). To be eligible, at the end of their transition leave period, employees must also be eligible for an unreduced pension, i.e., they must be 60 years old or have reached age 55 with a minimum of 30 years of service. Pay is adjusted to reflect the reduced hours, but existing pension and benefit coverage continues unchanged. This type of leave can be a particularly useful tool to support experienced employees who are nearing retirement, helping to ensure that they transfer their knowledge to other employees before their departure. (Note: The employee will be required to fill out the “Application for Pre-Retirement Transition Leave” form [TBS 325-9E].)

The Telework Policy can also be used to help employees who may require a better balance between their work and personal lives, and as a form of accommodation. It allows employees to carry out some or all of their work duties from a location other than their designated workplace. However, when you make a telework arrangement, be sure to follow up with the employee involved to discuss how well it is working (to reduce his or her stress levels) and consult with the employee’s colleagues to assess the impact on your unit’s overall workload. This will help you decide whether to renew an arrangement or to use telework with other employees on your team. Special working arrangements should be reviewed on a regular basis, at minimum once a year, to determine whether they should continue.

4.4.4  Occupational Health and Safety

Familiarize yourself with the Treasury Board’s Occupational Health Evaluation Standard and its policy on occupational safety and health. The objective of the standard is to prevent illness, injury and disability arising out of, or aggravated by, conditions of work. It specifies the actions to be taken to safeguard the health of employees, including when to use services mandated under the Occupational Safety and Health policy. The policy is aimed at promoting a safe and healthy workplace for public service employees and reducing the incidence of occupational injuries and illnesses. It mandates Health Canada to offer services to departments in the core public administration through the Public Service Health Program (PSHP). The services include occupational health evaluations. They are conducted on a routine basis for specific occupational groups exposed to hazards (e.g., firefighters, divers, dangerous goods inspectors, etc.), and on a non-routine basis in cases of employee illness or injury. When the latter type of occupational health evaluation is conducted by Health Canada, it is referred to as a Fitness to Work Evaluation (FTWE).

Non-routine occupational health evaluations or FTWEs are conducted to determine if employees have been affected by workplace hazards and/or are medically fit to safely and efficiently perform the tasks of a specific job. The standard states that these evaluations should be conducted with the employee’s consent and in specific situations when an employee:

  • Has been exposed to an unexpected occupational health hazard, such as a chemical spill;
  • As a result of job changes will be exposed to a different hazard or more strenuous work;
  • Appears to be having difficulty in performing the duties of the position (i.e., decreased function) or the employee’s actions appear to be affected by health-related factors; or,
  • Is absent for a lengthy period and a return date has not been established, or is returning to work after a period of medical leave and there is serious concern about his or her fitness for duty.

If the last two situations apply, an occupational health evaluation can be conducted by the employee's treating physician or by a supplier of occupational health evaluation services that the physician recommends or, in the case of organizations in the core public administration, as an FTWE by Health Canada. (Ensure that the professional conducting the evaluation receives a description of the employee’s day-to-day work and job duties that outlines the physical and psychological requirements of the job.) The purpose is to confirm the employee’s ability to carry out or continue to carry out the duties of the position and, where warranted, what functional limitations should be accommodated. In most cases, once you know what these functional limitations are, you can work with the employee to address them and enable him or her to continue working (or to return to work) without compromising his or her health. Examples of possible accommodations include adjusting the employee’s work schedule, modifying his or her workstation, and enhancing the work space such as with additional lighting or air filtration.

In certain situations, Heath Canada will not conduct an FTWE. It will not perform an FTWE if an employee is receiving benefits pursuant to an approved disability insurance claim (either disability insurance or the Public Service Management Insurance Plan) or is on injury-on-duty leave or Workers' Compensation. In these cases, the insurer or the provincial Workers’ Compensation Board provides case managers and/or adjudicators who can assist with arranging an occupational health evaluation as part of the planning process for return to work. (See section 6 of this handbook for more information.) Before requesting an occupational health evaluation, consult your accommodation and/or labour relations advisor. An FTWE from Health Canada can be requested by contacting the regional office of the Public Service Health Program or by sending an email to epohd-dmust@hc-sc.gc.ca.

4.4.5  Emergency and Traumatic Events

GECA/Workers Compensation – refer to Appendix A for definitionConsult Health Canada’s handbook for managers entitled Preparing for and Responding to Workplace Trauma : A Manager’s Handbook. It provides helpful step-by-step leadership guidance on what to do and what to say to employees to help them cope after events that can severely affect their emotional health as well as what you should do to be prepared. Traumatic events include witnessing a person die, violent physical attacks, physical threats, bomb threats, explosions, fire, body recovery and site investigation following a major accident or disaster, and attempted or completed suicide.

Make the workplace as safe as possible for employees at risk of a health emergency. Employees have a responsibility to inform you if they have a condition that could cause an emergency health event at work. Examples are a severe allergy, epilepsy or a chronic illness such as ischemic heart disease (a major cause of heart attacks). There are privacy restrictions on the medical information you are entitled to (see section 3.2), but you should encourage your employees to disclose any potentially life-threatening condition and the specific accommodations that it requires so that you can make the workplace as safe as possible for them. Once you are informed, you can develop an emergency plan with the employee, spelling out how you and work colleagues are to respond if the emergency occurs. Remember that witnessing an employee struggling with a life-threatening health emergency is much more likely to be traumatic for everyone on your team if they do not know what to do to help.

Prevention Leadership

Never underestimate your influence. One of the most effective ways you can promote health and wellness in the workplace is by setting an example. The easiest way to do this is to make a point of integrating physical activity into your personal workday. Taking the stairs instead of the elevator, conducting a bilateral meeting during a walk outside, walking to an off-site meeting rather than taking a taxi, stepping out of your office to speak to an employee rather than sending an email, and using public transit or riding a bike to work instead of driving—all are examples of ways that you, as a leader, can model physical activity at work, thus helping build a culture of health and wellness in the workplace.

Table 3. Common Causes of Disability in the Public Service and Potential Interventions
Descriptors Mental Health Issues Musculoskeletal Disorders
Definition Characterized by alterations in thinking, mood or behaviour—or some combination thereof —associated with significant distress and impaired functioning. Examples include mood disorders, anxiety disorders and personality disorders. A group of painful disorders affecting the muscles, tendons and nerves. Examples include carpal tunnel syndrome, tendonitis, thoracic outlet syndrome and tension neck syndrome.
Prevalence (represented employees) 44.5% of DI claims (2008) 14.2% of DI claims (2008)
Risk Indicators
  • Chronic pain
  • Physical injuries
  • Job insecurity
  • Low level of co-worker support
  • Work stress
  • Role conflicts and ambiguity
  • Insufficient work
  • Lack of control over work methods and workload
  • Lack of recognition
  • Overexertion and falls
  • Chronic pain and physical injuries
  • Excessive computer use
  • Job strain (high demand and little control)
  • Mental health issues (e.g., stress, depression)
  • Health habits (e.g., alcohol consumption, smoking, obesity)
Interventions That Work
  • Promoting Mental Health
    • Changing features of the work environment, e.g., workload, schedule, work processes and procedures
    • Addressing job demand and control, e.g., stabilizing work teams, clarifying roles and responsibilities, delegating work, supporting employee discretion and choice
    • Training, e.g., conflict management, stress management, communication skills, relaxation techniques
  • Identifying and Addressing Mental Health Issues
    • Training, e.g., psycho-education, stress management, self-awareness, benefits and disclosure training, workplace hardening
    • Stress management, combining skill development, social support and job redesign
    • Work-facilitated treatment, enabling access to psychological care (e.g., cognitive behavioural therapy)
  • Primary Engineering Controls
    • Workstation redesign and other ergonomic adjustments (e.g., larger monitor, chair with lumbar support, etc.)
    • Using assisted handling devices (e.g., mechanical lifting machines)
  • Secondary Interventions
    • Administrative controls (e.g., job rotation)
    • Exercise
    • Work schedules (e.g., rest breaks)
    • Participatory ergonomics (e.g., alternative mouse, new chair, etc.)

Adapted from the presentation “Environmental Scan on Workplace Health in Canada,” prepared by Health Canada for the Disability Management Initiative, November 17, 2009.

Table 4. Answers to Employees’ Concerns About Using the Employee Assistance Program
If the employee says... Your answer could be...
I don’t have time. It’s too far.
  • You can have access to Employee Assistance Program (EAP) during and after work hours.
  • You can talk with someone by telephone.
  • Arrangements can be made to suit you in terms of time and place.
It’s none of your business.
  • That’s true, but I’m worried about you. I only want to remind you that the EAP is available to you if you need it.
  • You’re right, but your work performance is (or your attitude at work is)…
Why don’t you worry about your own problems?
  • We’re not here to talk about me. I’m worried about you. I only want to remind you that the EAP is available to you.

Note: Do not get caught up in a discussion about yourself and try not to become defensive. Show empathy, but suggest that the meeting be postponed if emotions are too intense.

The employee wants to tell you all about his or her problems and does so.
  • I think you have a lot on your shoulders. Let’s focus right now on how I can help you with your work-related pressures. I think the EAP would be more helpful with your personal issues.
You can’t force me to use the EAP.
  • That’s true, but why not try? It can’t hurt.
  • It’s up to you. I only want you to know that the EAP is available.
  • I don’t need to know if you’ve used the EAP service. I just want to make sure you know about it. The decision to use it is yours and is a private one.
Are you saying that I have a problem?
  • I don’t know if you have a problem or not, but I’ve noticed that... (describe the attitude or work performance) and only want to remind you that the EAP is available if you want to talk to someone.
I don’t think the EAP is confidential.
  • The professionals at the EAP are bound by professional privilege. They strictly respect the confidentiality of clients.
I have the situation under control. I don’t need any help.
  • I don’t doubt that you’re able to get through this alone. But, sometimes, getting a little help and support can make things a lot easier.
The employee becomes emotional (crying or anger).
  • I can see how much this is affecting you. Maybe you could take the time to speak with someone at the EAP.
  • I can see that this is a sensitive topic for you. Maybe you could take the time to go through it with the EAP.

Adapted from Mental Health: First Aid in the Workplace, published by the Canada Revenue Agency.