The Internal Responsibility System (or “IRS”) is widely recognized as being a foundational component of workplace health and safety. A key finding that came out of a formal review of occupational health and safety in underground mining in Ontario that was led by the Ontario Ministry of Labour in 2014 and 2015, is that “the IRS is being applied inconsistently in the Ontario Mining Sector, likely because there is a lack of common understanding of how the IRS should function.” This paper has been written primarily in response to this finding. It attempts to trace the origins of the IRS and to shed light on its original intent. Moreover, it provides some thoughts on how the IRS could be executed according to a more formal structure and framework, while preserving its original intent.