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Ask The Expert: First Aid Requirements in Ontario

QUESTION

We have 250 employees working at our Ontario head office. Most work a standard 9 to 5, Monday to Friday shift, but some can stay late or work weekends without formal rescheduling or approval. In other words, I have no way of knowing how many employees are in the office working late or on a given Saturday or Sunday. We comply with WSIB First Aid Regulation 1101 during the regular work day but do we also have to provide first aid coverage for workers that stay late or work the weekend?

ANSWER

Yes, you would have to provide coverage after hours and on weekends, including the Section 11(2) requirement that the first aid room be in the charge of:

(a) a registered nurse; or

(b) a worker who,

(i) holds a valid St. John Ambulance Standard First Aid Certificate or equivalent;

(ii) works in the immediate vicinity of the first aid room; and

(iii) Performs no other work likely to adversely affect his/her ability to administer first aid.

EXPLANATION

Reg. 1101 first aid requirements are based on the number of workers employed at a place of employment “IN ANY ONE SHIFT.” So, to the extent there are over 200 workers employed at the head office during A SHIFT, the Section 11 First Aid Room requirements that you currently comply with during the week would also apply after hours and over the weekend.

According to Ontario MOL guidelines, the first aid resources required by Reg. 1101 must be available “during working hours” https://www.labour.gov.on.ca/english/hs/pubs/filmguide/gl_1.php. Although the guidelines address production companies, the same general principles presumably apply to other types of sites. Thus, if weekends are “working hours”, the RN/attendant worker required by Sec. 11(2) must be on duty. At least that’s my read. Unfortunately, WSIB doesn’t have any guidelines addressing this issue, even indirectly.