The Ontario Occupational Health and Safety Act (OHSA) imposes a strict duty on the City, as an employer, to appoint competent supervisors. Section 25(2)(c) states that “an employer shall, when appointing a supervisor, appoint a competent person” (see definition below). Competent supervisors are well positioned to protect the health and safety of City employees.  They do this by enforcing legislation and adherence to City policies within workplaces. Conviction for failure to ensure that City of Toronto supervisors are “competent” could result in significant fines against the Corporation and individual penalties for supervisory staff, City officers and directors, as outlined in Section 66(1)(2) of the OHSA.

This policy, developed at the direction of the Occupational Health and Safety Coordinating Committee (OHSCC), establishes requirements with respect to hiring, training, performance management and promotion to ensure that City supervisors are competent from a health and safety perspective. This policy, and its Training Standard, is further intended to promote a uniform standard of occupational health and safety knowledge amongst supervisory staff throughout the City.

In addition, Ontario Regulation 297/13, made under the OHSA, entitled Occupational Health and Safety Awareness and Training, also requires that all supervisors complete the Ministry of Labour, Immigration, Training and Skills Development’s (MLITSD) Supervisor Health and Safety Awareness in 5 Steps training module, (available on the City’s learning management system, ELI). The City requires that employees take this training prior to commencing their supervisory role.


This policy applies to all City of Toronto service areas. All City divisions and staff will implement the provisions of this policy and its accompanying training standards.


ARR – Alternate Rate as Required: Acts as a supervisor when needed, such as when someone is sick or on vacation; they step in occasionally or once in a while, on an as needed basis.

ARC – Alternate Rate Continuously: Temporarily hold the position of supervisor for a known period of time, i.e. Parental Leave, doing the work every day while the base holder is off, or is in place doing the work on a daily basis until a job is filled permanently.

Competent Person, as defined under the Occupational Health and Safety Act (OHSA):

A person who:

  1. is qualified because of knowledge, training and experience to organize the work and its performance;
  2. is familiar with the Act and regulations that apply to the work; and
  3. has knowledge of any potential or actual danger to health or safety in the workplace

Job Hazard Analysis/Job Safety Analysis (JHA/JSA): Job Hazard/Safety Analysis is a fundamental tool in health and safety management for protecting everyone’s safety.  A JHA, also known as a Job Safety Analysis (JSA), helps to logically examine a particular job or task so that all hazards associated with that job or task can be identified and assessed, and when necessary, suitable control measures can be determined.

Supervisor, as defined under the OHSA:

A person who has charge of a workplace or authority over a worker.

(Supervisory staff include, but are not necessarily limited to, senior managers, managers, front-line supervisors (ARRs, ARCs) forepersons, lead hands and RN’s-in-charge. The determination of whether an individual is a supervisor is based on job responsibilities, not on management/bargaining unit status). As case law has shown that a lead hand, depending on circumstances, may be found by the courts to be a supervisor, it is required that in-charge personnel such as lead hands and RNs-in-charge also complete the supervisory training requirements specified by this policy. Some City staff may play a leadership role with other employees that is not supervisory in nature. In these cases, training appropriate to the level of assigned health and safety responsibility will be provided.


Divisions are responsible for:

  • Ensuring that all appointed supervisory staff (e.g. ARRs, ARCs, team leads, etc.) demonstrate health and safety competency
  • When hiring supervisors, ensure health and safety qualifications are referenced in the job postings and health and safety questions are incorporated in the interview process
  • Making “Competent Person,” as defined by the OHSA, a condition of employment, for internal promotions and external hires
  • Incorporating occupational health and safety training courses, including this supervisor competency course into their overall supervisory training program
  • Ensuring new and current supervisory staff complete the MLITSD’s Supervisor Health and Safety Awareness in 5 Steps training module prior hire or promotion to their supervisory role
  • Verifying that individuals in supervisory roles have successfully completed the City’s health and safety competency for supervisors training
  • Orienting supervisory staff to health and safety hazards, issues and protective measures within their area of responsibility in advance of assigning them supervisory responsibilities
  • Identifying hazards for the work performed within the division
  • Conducting Job Hazard Analysis (JHA), as required, and share the identified hazards and controls measures with managers and supervisors
  • All supervisors in areas where workers perform high risk jobs should be given division specific information and instruction on how to implement the Hierarchy of Controls to address worker and JHSC hazard concerns
  • Implementing appropriate control measures in accordance with the Hierarchy of Controls
  • Documenting and tracking Health and Safety Competency for Supervisors training
  • Including occupational health and safety competency in performance evaluations
  • Ensuring that the health and safety knowledge of supervisors is updated on a regular basis (in addition to ongoing communication mechanisms, attendance of at a refresher program, conference, etc.)
  • Conducting an annual assessment of the occupational health and safety training needs of supervisory staff and providing training as required (i.e. to address identified health and safety issues, new legislation, injury trends, etc.)
  • Preparing workers to take on supervisory responsibilities prior to commencing a supervisory role (e.g. upskilling, coaching, mentoring, training, etc.)
  • Ensuring that all levels of management are educated on health and safety legislation, City policies and division specific program elements, on a continual basis
  • Monitoring this policy’s implementation through all levels of management (see checklists in Appendices A, B, C and D)

Supervisory staff are responsible for:

  • Completing the MLITSD’s Supervisor Health and Safety Awareness in 5 Steps training module prior to being hired/promoted to a supervisory position/role
  • Attending required Health and Safety Competency courses
  • Being knowledgeable of work-related hazards to which their employees are exposed
  • Conducting a Job Hazard Analysis (JHA), as required
  • Identifying workplace specific hazards and implementing controls to protect employees from work-related hazards
  • Continue to familiarize themselves with legislative and City health and safety requirements
  • Bringing forward to their divisions their occupational health and safety training needs, on an ongoing basis and during the annual needs assessment
  • Applying the occupational health and safety knowledge acquired through training and other methods of communication to protect worker health and safety, and ensure legislative compliance within their area of responsibility

The Occupational Health, Safety and Wellness Section of People & Equity is responsible for:

  • Developing Health and Safety Competency course materials
  • Maintaining a pool of questions and establishing standards for successful course completion
  • Coordinating and delivering Supervisory Health and Safety Competency courses
  • Ensuring course information is entered into ELI
  • Providing, when requested, a report to Divisions and/or the Occupational Health and Safety Coordinating Committee on the percentage of supervisory staff, by service area, who have successfully completed training
  • Following up with supervisors and their managers when a participant fails to meet the training requirements of a program

The Occupational Health and Safety Coordinating Committee is responsible for:

  • Monitoring the level of occupational health and safety supervisor competency achieved
  • Reporting any significant compliance concerns, with recommendations to address these concerns, to the divisional senior management team

Training Standard for Health and Safety Competency Course Content

 [Note: Content may be added/removed in response to significant new legislation and/or City policies and programs]

  • The City’s health and safety framework and internal responsibility system
  • The external responsibility system
  • City’s health and safety policies and programs
  • Responsibilities of the workplace parties (with an emphasis on the employer, supervisor and worker)
  • Rights of workers
  • Reprisals prohibited
  • Role of the MLITSD inspectors, including enforcement of the Act and regulations
  • Due diligence
  • Penalties
  • Recognizing, Assessing, Controlling and Evaluating Hazard Controls (RACE)
  • Injury/Incident Definitions, Investigations and Reporting
  • A review of City injury/incident statistics and WSIB costs

Successful completion of this course will be determined by participants passing a knowledge assessment.

Refresher Training

Prerequisite: participants must have successfully completed a full Health & Safety Competency course.

Content will be developed as deemed appropriate by People & Equity, Occupational, Health, Safety and Wellness.

Successful completion of this course will be determined by participants passing a knowledge assessment.


Occupational Health and Safety Act (R.S.O. 1990, c. 0.1)
Ontario Regulation 297/13, made under the Occupational Health and Safety Act, Occupational Health and Safety Awareness and Training

Endorsed by Occupational Health and Safety Coordinating Committee (OHSCC)

April 22, 2008

Approved by

City Manager

Date Approved

August 20, 2008

Most Recent Revision and re-endorsement by OHSCC

December 8, 2022

OHSCC Reviewed and Revised

OHSCC, February 28, 2012
November 25, 2014
April 26, 2016

December 8, 2022

Related links

Occupational Health and Safety Act
Occupational Health and Safety Awareness and Training