Why is health and safety orientation required?
- The Occupational Health and Safety Act (OHSA) requires the City as an employer, to provide information, instruction and supervision to workers to protect their health and safety. Orientation training is therefore a legal obligation. (See Appendix “A” regarding references to training in the OHSA and its regulations). In addition to this general requirement, the OHSA and its regulations make numerous references to the need for workers and supervisors to be competent, as defined in the OHSA. Training is a component of occupational health and safety competency. (See Appendix “B” for competency requirements under the OHSA and its regulations).
- Providing health and safety orientation and job-specific health and safety training, assists in preventing injuries and illnesses, reducing accident-related costs, improving labour-management relationships, improving quality, productivity and customer service.
- Each year, City workers (“Worker” as defined in the Orientation Training policy) incur thousands of injuries and illnesses. These injuries and illnesses result in years of lost time, millions of dollars of Workplace Safety and Insurance (WSI) costs and other negative impacts to the corporation, employees, their families and society.
- Providing health and safety orientation and job-specific health and safety training enhances the City’s Internal Responsibility System. The OHSA places legal duties on workplace parties including owners, constructors, employers, officers and directors of the corporation, supervisors, workers, members of joint health and safety committees and health and safety representatives. Making all workers, regardless of their position, aware of their legal obligations and rights under the OHSA and their role within the City’s health and safety program, is essential in supporting and promoting the internal responsibility system.
- Health and safety orientation and job-specific health and safety training are also key elements of many recognized health and safety management systems including:
- British Standard Institute’s “OHSAS 18001” (similar to the ISO 9001 Quality standard and the ISO 14001 Environmental standard)
- Ontario Workplace Safety and Insurance Board’s “Work-Well Audit”
- Ontario Municipal Health and Safety Association’s “Audit Program”
- Det Norske Veritas (DNV) “International Safety Rating System” (previously International Loss Control Institute)
- Canadian Council of Health Services Accreditation (CCHSA) Program
- Ministry of Health and Long-Term Care Facility Compliance Program
- National Quality Institute
- Certification of Recognition Program (CORTM) for construction contract management and construction tendering process
Health and Safety Orientation
Who requires health and safety orientation?
- All new workers including supervisory staff, regardless of position. The applicable content for management can be found in the Supervisory Competence Policy and Training Standards. As outlined in that policy, an individual is a supervisor based on job responsibilities, not on management/bargaining unit status.
- Employees reassigned, transferred or promoted to a new division or position, if their reassignment, transfer or promotion results in exposure or potential exposure to health and safety hazards not present in their previous position
- Employees assigned to “acting” positions, if the assignment results in exposure or potential exposure to health and safety hazards not present in their base positions
- Seasonal, temporary, casual and part-time workers
- Workers returning from long absences (E.g.: WSIB, LTD, maternity leave), if significant changes that may impact the health and safety of these workers have occurred during their absence. Training for these workers may be abbreviated to provide a review of the initial orientation and to cover those changes that may impact their health and safety.
- Workers for whom training records do not exist.
- New members of joint health and safety committees or new health and safety representatives to improve their awareness of any hazards in their areas of responsibility for which they have not previously received training
- Contract employees, with modifications, as outlined below
- Volunteers, to the extent required to ensure they are aware of hazards to which they may be exposed and the means of protecting themselves from such hazards
When must health and safety orientation be delivered?
- Part A (Ministry of Labour Worker Health & Safety Awareness in 4 Steps course) should be completed prior to a worker completing Part B
- For new workers, prior to them being assigned any work that places their health and safety at risk
- When the introduction of any new health and safety legislation, City health and safety policies and/or guidelines, or significant changes to the City’s health and safety program affects workers. (If workers have already completed health and safety orientation training, training or information-sharing may be limited to new information resulting from legislation or program changes)
- As a result of inadequate performance, remedial training may be limited to the specifics of the inadequate performance
Content of health and safety orientation – City workers
Note: Applicable content for management can be found in the Supervisory Competence Policy and Training Standards. As outlined in that policy, an individual is a supervisor based on job responsibilities, not on management/bargaining unit status.
For all City workers (including permanent, full-time, part-time, casuals, seasonal and temporary), the health and safety content of worker health and safety orientation must include all 3 parts outlined below:
Part A:The Ministry of Labour’s mandatory Worker Health & Safety Awareness in 4 Steps course.
Part A is available in the following learning formats:
- As an e-learning course by registering on the City’s learning management system Enterprise eLearning Initiative (ELI) training site, which is the preferred method and contains identical training content as the Ministry of Labour’s course.
- As an e-learning course on the Ministry of Labour’s Health and Safety internet site. Note: With this option, the worker must print the completion certificate and provide it to the City, as the certificate will be the only record of course completion.
- As a City Instructor-led classroom course using the Ministry of Labour’s approved Health & Safety Awareness in 4 Steps Workbook and Employer Guide
Part B: The City of Toronto’s City-Specific Health & Safety Orientation course, which includes the following learning objectives/content:
To be able to describe the City’s:
- Health and safety framework
- Health and safety program
- Health and safety hazards
- General emergency procedures
- Hazard and incident reporting
Part B is available in the following learning formats:
- As an online course for those with the ability to use a computerized learning format
- As an Instructor-led classroom course
Part C: Job and worksite-specific health and safety orientation training
Appendix “C” a checklist for use by City supervisory staff when generally orienting workers to their new position and work location).
Job Specific Health and Safety Training
When Part C job-specific health and safety training must be delivered?
- Prior to workers being assigned a specific job or task that places them at risk for which they have not previously successfully completed training.
- Following the introduction of new materials, equipment, vehicles, tools or processes that introduce a new hazard.
How should the need for Part C job-specific health and safety training be determined?
The Occupational Health and Safety Act and its regulations specifically reference a number of job tasks or work operations for which workers must be trained (see Appendix “A”). In addition, numerous references are made to the need for supervisors and/or workers to be competent (see Appendix “B”), which in the context of occupational health and safety means:
- Are qualified because of knowledge, training and experience.
- Are familiar with the OHSA, its associated regulations, other related safety legislation and applicable City policies, procedures, guidelines, codes and/or standards.
- Have knowledge of potential and/or actual dangers to health and safety in the workplace.
In circumstances where the OHSA specifies a requirement for training or competency, the hiring division must either confirm that the worker has completed training and is competent or provide the required training to ensure the employee is “competent” to perform the work to which s/he is assigned.
Additional need for job/task specific health and training programs should be determined by utilizing the following processes:
- Hazard assessments and risk analysis
- Job task analysis
- Conducting and reviewing health and safety inspections, audits or risk management audits
- Benchmarking with other organizations in the same business, as needed
- Reviewing applicable legislation, standards, codes, guidelines and policies
- Reviewing accident statistics
- Reviewing minutes and recommendations of joint health and safety committees
- Researching and where applicable adopting industry best practices
- Consulting with:
- Joint health and safety committees
- Health and safety representatives
- Health and safety consultants
- Training staff
- Operational staff
- Bargaining unit representatives
Content of Part C job-specific health and safety training
It is not possible to list the content of every health and safety program available to City staff. However, health and safety training programs should typically include the following components, as applicable to the subject of the training:
- The theoretical component of job-specific health and safety training programs should include, as applicable:
- A review of the learning objectives
- A description of the job or task
- A description of both actual and potential health and safety hazards
- What injuries or illnesses may result from uncontrolled exposure to health and safety hazards
- A review of applicable legislation, standards, codes, guidelines and/or policies
- A review of terms, acronyms and jargon associated with the specific job or task
- Requirements to ensure public safety, if any
- How the health and safety hazards are controlled including but not limited to:
- Guards or barriers
- Operating specifications of vehicles, machinery, equipment and tools including pre-start and shutdown checklists or procedures
- Maintenance and inspection requirements
- Personal protective equipment (PPE)
- Monitoring or testing equipment
- Personal hygiene
- Do’s and Don’ts of the job or task
- Emergency response/rescue procedures and equipment
- Problem reporting (operational problems, equipment problems, health and safety problems)
- Multi-worker operations (who does what when)
- Specific and detailed safe work procedures
- Disposal of waste and residual material
- An evaluation to confirm that the worker has absorbed the knowledge, concepts and skills relevant to the job. In those cases where the Occupational Health and Safety Act mandates that work be performed only by “competent” persons (see Appendix “B”), documentation of evaluation is particularly critical.
- Practical demonstrations (by the instructor/trainer) including but not limited to:
- Use and care of required personal protective equipment
- Use of testing or monitoring equipment (e.g.: air-sampling monitors)
- Emergency response/rescue procedures
- Proper use of equipment and/or tools
- Step-by-step procedures of the job/task
- Practical demonstrations (by the worker)
- Worker demonstration to the instructor that they can adequately perform the required components of the job or task, including the use of all equipment and personal protective equipment.
Vehicle and Equipment Training
- City workers required to use or operate vehicles or equipment covered by the Driver/Operator Fleet Safety Policy shall comply with the requirements of that policy and the City of Toronto Driver’s Manual.
- Where workers are required to use or operate equipment not covered by the Driver/Operator Fleet Safety Policy, the employee shall prior to using the equipment be provided training on the use and operation of the equipment including requirements set out in the manufacturer’s manual.
- Where workers are required to use or operate similar but different pieces of equipment they shall receive training on the differences between the pieces of equipment. (E.g.: riding lawnmowers but different makes, models or year of manufacture).
Content of health and safety orientation – volunteers
Volunteers are not workers as defined by the Occupational Health and Safety Act. However, as an organization (under the Criminal Code), we have a responsibility to protect the health and safety of those in our workplaces (even if they are not our workers. It is therefore expected that volunteers will not be exposed to significant hazards. For all volunteers, health and safety orientation should include the following:
- Information of general emergency procedures, as applicable, including:First aid/medical aid
- Fire and evacuation
- Security procedures
- Bomb threats
- Other division or workplace specific emergency procedures
- An overview of the hazards to which they may be exposed including:
- Safety hazards including:
- Energy hazards
- Equipment hazards (vehicles, machines and tools)
- Material handling hazards (manual and mechanical)
- Work practice hazards
- Health hazards including:
- Chemical hazards
- Biological hazards (including risks of exposure to infection disease and preventive measures)
- Physical hazards
- Ergonomic hazards (including the job’s musculoskeletal disorder risks and preventive measures)
- Workplace violence (including domestic violence)
- Psychosocial hazards (including bullying, harassment, stress)
- Protocols to be used by them in reporting and avoiding/addressing hazards
- An overview of the requirements for reporting accidents, illnesses and incidents as required by:
- The Occupational Health and Safety Act
- Workplace Safety and Insurance Act
- City of Toronto policies
- Divisional requirements
Content of contractor health and safety orientation training
- In accordance with the City’s policy for Managing Health and Safety Aspects of Contracts for Services, operating divisions, and Purchasing and Materials Management Division shall ensure the contract language requires the contractor and its’ workers to be competent and qualified for the nature of the work being tendered.
- Divisions shall acquaint the contractor with health and safety hazards to which they may be exposed in City work operations.
- Where a City workplace has a specific procedure for dealing with hazards or emergencies, the division shall ensure that the contractor is made aware of that procedure. (e.g.: chemical alarms and evacuation procedures).
Evaluation and Reinforcement
It is important to establish whether learning objectives have been met during training. In order to evaluate whether learning objectives have been met, evaluation of worker learning within training courses as well as within the workplace is needed. Within training courses, worker learning can be addressed through written or verbal evaluations and/or practical demonstrations, as appropriate.
- Ongoing reinforcement by supervisors of knowledge and skills acquired through training is also essential. Job/task assessments should therefore be made through direct observation at specific intervals of time following training. This is the responsibility of front-line supervisors. For this reason, those with supervisory responsibilities must attend and be competent in all health and safety training programs required by workers under their authority. This is consistent with the supervisory responsibility to ensure that the worker(s) work in the manner and with the protective devices, measures and procedures required by the OHSA and regulations.
- The content of worker health and safety orientation should also be reviewed on a regular basis and updated as needed, based on new/revised work processes or conditions or legislative changes.
Communication of City occupational health and safety training programs
- All workers should be able to readily access required occupational health and safety training, whether delivered by Human Resources or by divisions.
- Mechanisms to advise workers of available training programs should be developed and implemented. These mechanisms may include, but are not limited to:
- Posting on the City’s ELI site and in the “Courses for the Toronto Public Service” guide, or
- Posting on a divisional Intranet site and in divisional training calendars.
- Posting on bulletin boards within City workplaces.
- Employee News – e.g. Monday Morning News e-mails/postings
Retention of Training Records
- The Occupational Health and Safety Act provides Ministry of Labour inspectors the duty and power to:
- Require employers to produce materials concerning the content, frequency and manner of instruction of any training program
- Inspect, examine and copy the materials
- Attend any health and safety training program
- Make enquiries of any person who is or was in the workplace
- Other safety related legislation sets out similar requirements for their enforcement branches.
- For this and other reasons, it is essential that training records are maintained, accurate, current and readily accessible.
- Copies of all health and safety orientation and job-specific training activities should be documented and stored in accordance with the Corporate
- Records Management Program as established by Corporate Records and Archives.
Records analysts with Corporate Records Services are available to assist all divisions in establishing a Records Program to comply with the above.
- Training records must be made available, upon request, to those individuals who require and are entitled to receive this information (e.g. agencies such as the Ministry of Labour and Ministry of Transportation).
- Attendance lists must be maintained for all health and safety training programs including formal training and informal training such as tail-gate sessions, service packs and remedial training.
- If a training program is delivered over a period of time (E.g.: 2 days), attendance lists must be maintained for each day.
It is the responsibility of the instructor to confirm attendance at each course. Instructors shall forward attendance lists to designated staff for record keeping, immediately following completion of the training program.
- Attendance lists should include the following information:
- Worker’s full first and last name
- Instructor’s name
- Name of training program
- Date, location and duration of training program
- Space for employee signatures
“A” Legislative Health and Safety Training Obligations
“B” Legislated Competency Requirements
“C” Checklist for Supervisors
Executive Management Team (EMT), October 12, 2004
Occupational Health & Safety Coordinating Committee (OHSCC) approved and reviewed:
August 10, 2004
February 25, 2009
April 26, 2016
February 7, 2018
October 12, 2004
Reviewed by OHSCC
February 7, 2018
Health and Safety Orientation Training Policy