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Records
Employers must keep a record of the awareness training for workers and supervisors who work for that employer. A record of any worker or supervisor who is exempt from the training must also be maintained. [O. Reg. 297/13, Subsections 4(1) and (2)]
If a worker or supervisor completes an awareness training program, the employer must, on request, provide the worker or supervisor with written proof of completion of the training. [O. Reg. 297/13, Subsection 4(3)]
If a supervisor is exempt from taking an awareness training program for workers, the employer must, on request, provide that supervisor with written proof of the exemption. [O. Reg. 297/13, Subsection 4(4)]
If a worker or supervisor no longer performs work for an employer, but makes a request for written proof of completion or exemption within six months, the employer must provide the written proof. Of course, employers may voluntarily provide the information after the six-month period. [O. Reg. 297/13, Subsection 4(5)]
What information should be included in a record of training?
The record should include information such as the name of the individual who completed the program, the date of completion and the name or a brief description of the training course or program. The Ministry of Labour, Immigration, Training and Skills Development has developed a Record Keeping Template that can be used by workplace parties to keep a record of employees who have completed occupational health and safety awareness training as required under the regulation. This guidance tool is neither mandatory nor enforceable. Ministry of Labour, Immigration, Training and Skills Development Inspectors do not enforce the use of this guidance tool.
Do employers need to submit records to the Ministry of Labour, Immigration, Training and Skills Development?
No, employers are not required to submit records of completion of training to the ministry, only to retain those records.
The ministry will not keep any records for awareness training programs. However, ministry inspectors may ask to review employers’ records of awareness training during an inspection or investigation.
How long must a record of training be kept?
No period of time is specified in the regulation. However, an employer must provide a worker or supervisor with written proof of completion or exemption, if a request is made within six months of the worker or supervisor no longer performing work for the employer. Therefore, an employer must keep the record of training for at least six months after a worker or supervisor stops working for him or her to be in a position to comply with this requirement.
Can I keep the records electronically or does it have to be a paper copy?
The regulation does not specifically prescribe the format in which the records need to be kept. The records may be kept in either paper or electronic form, as long as:
- the records can be shown to an inspector during a workplace inspection or investigation and
- provided to a worker or supervisor on request, as required in the regulation