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Worker awareness training program
Employers must ensure workers complete an awareness training program for workers as soon as practicable. [O. Reg. 297/13, Subsection 1(1)]. This includes all workers covered under the Occupational Health and Safety Act (OHSA), regardless of what sector they work in or their employment status (full-time, part-time, seasonal, etc.).
The basic awareness training program for workers must include instruction on the:
- duties and rights of workers under OHSA
- duties of employers and supervisors under OHSA
- roles of health and safety representatives and Joint Health and Safety Committees (JHSCs) under OHSA
- roles of the Ministry of Labour, Training and Skills Development, Workplace Safety and Insurance Board and entities under OHSA Section 22.5
- common workplace hazards
- requirements in Regulation 860 [Workplace Hazardous Materials Information System (WHMIS)] regarding information and instruction on controlled products and
- occupational illness, including latency. [O. Reg. 297/13, Subsection 1(3)]
The requirement does not apply if:
- the worker has already completed a basic occupational health and safety awareness training program that covers the required content
- the worker provides the employer with proof of completion of that training and
- the employer verifies the previous training covered the required content set out in the regulation. [O. Reg. 297/13, Subsection 1(2)]
This exemption may continue to apply to future employers of the worker (if he or she changes jobs, for example). However, the worker would need to provide the future employer(s) with proof of the exemption and the future employer would need to verify the previous training met the regulatory requirements [O. Reg. 297/13, Subsection 3(2)]. For more information on how employers can verify the content of previous training, see General Questions and Answers of this guide.
When does this training need to be completed?
The regulation requires employers to ensure workers complete a basic awareness training program as soon as practicable. While this provides employers with some flexibility, these programs must be completed as soon as reasonably possible after a worker starts performing work for an employer. It is recommended the program be completed before a worker is exposed to workplace hazards.
What are “common workplace hazards”? Are they general hazards or workplace specific?
An awareness training program should provide workers with general information about workplace hazards. This includes what the hazards are and what protective action needs to take place if hazards are found in the workplace. This can include information about common workplace hazards such as:
- slipping, tripping or falling
- working near motorized vehicles
- using or working near machinery
- workplace violence
- repeating the same movements over and over, especially if you are in an awkward position or use a lot of force
In addition to general information about workplace hazards, an awareness training program could also include information about other workplace hazards, such as those common in a particular workplace or sector.
The awareness training program is meant to provide workers with basic, foundational information about hazards. There are other training requirements under the OHSA and regulations that require more detailed training about specific hazards (WHMIS, confined spaces, etc.) or hazards in specific sectors (modular training for mining or logging, for example). Employers also have a general duty under the OHSA to provide information, instruction and supervision to a worker to protect his or her health and safety (OHSA Section 25(2)(a)].
What are “entities” under OHSA Section 22.5?
Entities under OHSA Section 22.5 include the Workers Health & Safety Centre, Occupational Health Clinics for Ontario Workers and four sector focussed health and safety associations (Workplace Safety North, Public Services Health and Safety Association, Workplace Safety and Prevention Services and Infrastructure Health and Safety Association). These entities are health and safety system partners of the Ministry. They provide a range of services to employers and workers and are funded by the Ministry.
Does the OHSA define “occupational illness”?
Yes. OHSA Section 1 defines “occupational illness” to mean “a condition that results from exposure in a workplace to a physical, chemical or biological agent to the extent that the normal physiological mechanisms are affected and the health of the worker is impaired thereby and includes an occupational disease for which a worker is entitled to benefits under the Workplace Safety and Insurance Act, 1997”.
What is latency?
Latency refers to the concept that some occupational illnesses may not be immediately apparent or known. Rather, there may be a period of time between the initial exposure to a physical, chemical or biological agent and the appearance of the illness or disease. This latency period can be brief or lengthy. In some cases, an occupational illness may appear years or decades after an exposure.