Two Months Until July 1 Safety Awareness Training Deadline: Will You Be Compliant?

by Dentons

The July 1, 2014 deadline is quickly approaching.  Employers in Ontario have two months to ensure that their workers and supervisors complete “basic occupational health and safety awareness training” before the deadline.

Our February 25, 2014 article set out “what you need to do” to comply with this new requirement.  Our April 3, 2014 article set out various strategies for employers as to how to provide this training.

In this article, we will provide updates and address a number of questions that have recently arisen, including who has to take this training and how employers can continue to ensure that they are compliant with the requirements of this Regulation even after their current workforce is trained.

Ministry of Labour Guide to Requirements for Basic Awareness Training

The Ministry of Labour has now released “A Guide to OHSA Requirements for Basic Awareness Training”.  It is fairly brief and worth reading.

Are directors and officers of a company or charity required to take the supervisor training?

The issue of whether directors and officers of a company or charity are considered supervisors is dependent on the particular facts of the situation.  If a director or officer has the responsibilities of a supervisor under the Occupational Health and Safety Act in an Ontario workplace (i.e. the person has charge of a workplace or authority over a worker in Ontario), the Ministry of Labour will likely expect the director or officer to complete the supervisor safety awareness training.  “Authority over a worker” includes, among other things, the ability to promote and discipline workers, schedule work and grant leaves of absence.  If the director or officer is not a “supervisor” under the OHSA, he or she is not required to take the training.

Are volunteers with a charity or not-for-profit organization required to take the training?

Under the OHSA, a worker is defined in part as “a person who performs work or supplies services for monetary compensation”.  As a result, a volunteer is not considered a worker and does not have to take the safety awareness training.  We recommend, however, that if a volunteer is doing work that involves any safety risks, you require him or her to take the safety awareness training.

Must employers verify that temporary employees sent to them by temporary employment agencies have completed safety awareness training?

Yes.  Where a worker is employed by a temporary employment agency and sent to another company to perform temporary work assignments, the temporary employment agency and the company both have safety duties under the OHSA.  While the temporary employment agency is required to provide the training, the company at which the temporary employee is working is required to confirm that the employee has received the training.

Update your checklists and agreements now

Hiring checklists and offer letters:
Ontario employers should update their hiring checklists and offer letters now.  Hiring checklists should include a requirement that a new worker or supervisor provide to the employer proof of having received the safety awareness training.  Going forward, employment offer letters / employment contracts should include a condition that a worker or supervisor has completed or will complete the appropriate safety awareness training.

Contractor and temporary employment agency agreements:
Employers should also include, in their standard-form contractor or temporary employment agency agreements, a requirement that the contractor or temporary employment agency not send to the employer any workers who have not completed the training, and that the contractor or temporary employment agency provide proof that its workers have received the training.  Employers must ensure they have an up-to-date record of safety awareness training for all workers and supervisors who perform work for the employer (which includes workers and supervisors from contractors and temporary employment agencies) in order to demonstrate compliance in the event the Ministry of Labour inspects the workplace.

Keep in mind employees who may require accommodation

Some employees with disabilities, language or literacy issues may require accommodation in order to complete their safety awareness training.  These employees may need additional time, or for the material to be read aloud or clarified.  Some may benefit from the opportunity to ask questions in a one-on-one environment.

The Ministry of Labour currently offers the worker and supervisor workbooks, and accompanying employer guides, in English, French, Traditional Chinese, Simplified Chinese, Hindi, Punjabi, Portuguese, Spanish, and Urdu.  The Ministry of Labour’s e-learning modules are currently available in English and French; however, its website indicates that the e-learning modules will be available in the seven additional languages in Spring 2014.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Dentons | Attorney Advertising

Written by:


Dentons on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
Privacy Policy (Updated: October 8, 2015):

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.


JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at:

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.