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General questions and answers
Do employers have to hire training providers to deliver this training?
There is no requirement in the regulation for employers to hire external training providers to deliver awareness training programs. However, an employer may choose to do so.
Do employers have to develop their own awareness training programs?
No. Employers can choose to use the Ministry of Labour, Training and Skills Development’s workbooks or e-learning modules, which are available free of charge and in multiple languages. Employers can also use training from other sources, such as their existing occupational health and safety training and/or other programs, as long as the training meets the minimum content requirements set out in the regulation.
Can workplaces continue to use existing training programs? What if an employer’s existing program is not called an “awareness training program”?
Employers have the flexibility to use existing occupational health and safety training and/or other programs, as long as those programs meet the minimum content requirements set out in the regulation. This is valid even if the existing program is called something other than an awareness training program (for example, an “orientation program”).
What resources are available to ensure existing programs cover the topics required by the regulation?
The Ministry of Labour, Training and Skills Development has developed the Training Program Assessment for Supervisors and the Training Program Assessment for Workers guidance tools that can be used by workplaces to evaluate and compare their existing training programs with the minimum content required by the regulation. These guidance tools are neither mandatory nor enforceable. Ministry of Labour, Training and Skills Development Inspectors do not enforce the use of these guidance tools.
Do employers have to provide other occupational health and safety training to workers and supervisors?
Basic awareness training for workers and supervisors raises general awareness about rights, responsibilities and where to get more information and help about occupational health and safety.
However, basic awareness training does not replace or diminish other Occupational Health and Safety Act (OHSA) training obligations. For example, employers have OHSA duties to provide information and instruction to workers about workplace-specific hazards, including duties to:
- provide information, instruction and supervision to a worker to protect the worker’s health and safety [OHSA Section 25(2)(a)] and
- acquaint a worker or a person in authority over a worker with any hazard in the workplace and on the handling, storage, use, disposal and transport of any article, device, equipment or a biological, chemical or physical agent [OHSA Section 25(2)(d)]
Employers must also appoint a competent person as a supervisor [OHSA Section 25(2)(c)]. As explained above, a “competent” person is “qualified because of knowledge, training and experience to organize the work and its performance”. Thus, a supervisor must have received training relevant to the position in order to be appointed.
As such, there are additional workplace- and hazard-specific training requirements set out in the OHSA and regulations that would need to be provided to supervisors in addition to the basic occupational health and safety awareness training.
Do workers or supervisors have to retake the awareness training program if they change employers?
No, the regulation does not require workers or supervisors to retake awareness training programs if they change employers. However, the worker or supervisor must provide a new employer with proof that training was previously completed, and the new employer must verify that the training covered the minimum content requirements set out in the regulation.
Although not required by the regulation, an employer may choose to have every new worker or supervisor complete an awareness program, even if the worker or supervisor has already completed this training with a previous employer.
How can employers verify previous training taken by a worker or supervisor covered the minimum content set out in the regulation?
Employers are required to verify that previous training received by workers and supervisors covers the program information set out in the regulation [O. Reg. 297/13, subsections 1(2) and 2(2)]. This verification could occur in a number of ways:
- the worker or supervisor may have proof that he or she completed one of the Ministry of Labour, Training and Skills Development’s awareness training programs as these programs are designed to provide training that complies with the regulation
- the worker or supervisor may provide information or documentation from a previous employer that would allow the new employer to assess the previous training (such as training materials) and/or
- an employer could ask a worker about the details of the training received (date, method of training, source of training) and to explain what he or she learned in the previously completed training program and question a new worker or supervisor to satisfy himself/herself that the previous training covered the required topics. The Ministry of Labour, Training and Skills Development has developed the Knowledge Check for Supervisors and the Knowledge Check for Workers guidance tools that can be used by workplace parties to verify whether a supervisor or worker has previously completed occupational health and safety awareness training and that the training meets the requirements of the regulation. These guidance tools are neither mandatory nor enforceable. Ministry of Labour, Training and Skills Development Inspectors do not enforce the use of these guidance tools.
Does the training have to be completed on “work time”?
For existing workers and supervisors who are employees, the employer will need to consider their obligations under the Employment Standards Act, 2000 (ESA) and any collective agreement or other contract that may apply. Generally speaking, under the ESA, time spent by an existing employee in training that is required by the employer, or by law to continue in his or her employment, is counted as work time. For more information see What counts as work time?
When hiring new employees, employers could require prior completion of the awareness training. Time spent in this kind of training before an employment relationship begins is not considered work time. A person (e.g., a student, applicant, etc.) could also choose to complete a training program such as by using the Ministry of Labour, Training and Skills Development workbooks or e-learning modules prior to obtaining a job with an employer.