In Ontario, the responsibility for workplace safety does not rest solely on the shoulders of the worker. The Occupational Health and Safety Act (OHSA) establishes a clear framework of duties for employers, supervisors, and workers, often referred to as the Internal Responsibility System (IRS). When it comes to working at heights, the stakes are incredibly high, and the employer's obligations are stringent and non-negotiable.
The most fundamental responsibility of an employer regarding fall protection is ensuring that every worker exposed to a fall hazard has valid, Chief Prevention Officer (CPO) approved Working at Heights training [1]. This requirement applies to any worker on a construction project who uses a travel restraint system, fall restricting system, fall arrest system, safety net, work belt, or safety belt [1].
It is not enough to simply ask a worker if they have been trained. Employers must actively verify the validity of the training. This involves checking the worker's proof of completion document or accessing their training records through the Ministry of Labour, Immigration, Training and Skills Development's certification management system [1]. Furthermore, employers must confirm that the training provider was CPO-approved at the time the training was completed [1].
While CPO-approved Working at Heights training provides a crucial foundation of knowledge, it is generic by design. It covers the principles of fall protection and the general use of equipment. However, every construction site is unique, with its own specific hazards, anchor points, and rescue procedures.
Therefore, employers have an additional, critical duty: providing site-specific and equipment-specific training. Before a worker uses any fall protection equipment on a new project, the employer must ensure they are trained on the specific gear they will be using and the specific hazards of that site [1]. This includes instruction on the manufacturer's instructions for the equipment, the location of suitable anchor points, and the site's emergency rescue plan.
Compliance is only effective if it can be proven. Employers are legally required to maintain accurate records of Working at Heights training for every worker [1]. These records must be readily available to a Ministry of Labour inspector upon request.
The records must include either a copy of the worker's proof of completion document or a detailed log containing the worker's name, the approved training provider's name, the name of the approved training program, and the date of successful completion [1]. Failing to produce these records during an inspection can result in immediate stop-work orders and significant fines.
The consequences of failing to meet these responsibilities are severe. Beyond the devastating human cost of a fall-related injury or fatality, employers face substantial legal and financial repercussions. The Ministry of Labour actively enforces these regulations, and penalties for non-compliance can include hefty fines for both the corporation and individual directors or officers, as well as potential criminal charges in cases of gross negligence.
Navigating the complexities of OHSA regulations can be daunting, but you don't have to do it alone. Total Group of Companies is your trusted partner in safety compliance. We offer comprehensive, CPO-approved Working at Heights training and refresher courses, ensuring your workforce meets all regulatory requirements.
Our expert team can also assist with site-specific hazard assessments, equipment inspections, and the development of robust fall protection and rescue plans. By partnering with Total Group, you can focus on your project with the peace of mind that comes from knowing your team is safe, trained, and fully compliant.
[1] Training for working at heights | ontario.ca
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Prepared by: Shared Services Manager
Approved by: VP of Strategy & Development
Document Owner: Director of Operations