Fall Protection Training Requirements – Know the Laws of Your Province
Vertical falls remain a leading cause of workplace injuries and OHS penalties. Among other things, employers are required to provide safety training to all workers exposed to fall hazards. Such training must cover:
- The fall hazards to which workers are exposed;
- The fall protection measures and systems used;
- Assessment and selection of anchors;
- Proper use of connecting hardware;
- How to inspect and care for the equipment;
- The impact of falls and fall arrest on the human body; and
- The safe work and rescue procedures to follow.
In addition, 3 provinces—Ontario, Newfoundland and Nova Scotia—require employers to ensure that workers exposed to fall hazards at construction sites successfully complete a special certification working at heights certification training course approved by the government. Here’s a look at the fall protection training rules in each part of Canada.
- Employer must ensure that every person granted access to a workplace and who uses fall protection equipment gets instruction by a qualified person in the use, operation and maintenance of that equipment, as well as the fall-protection plan for the workplace, if any (COHS Regs., Secs. 12.2(1) to (3))
- If there’s a risk of drowning in a work place, employer must ensure that every person granted access gets instruction by a qualified person on the written emergency procedures (COHS Regs., Sec. 12.2(4))
- Employer must ensure that the above required instruction is summarized in writing and must keep a copy of that summary readily available for consultation by every person granted access to the work place (COHS Regs., Sec. 12.2(5))
- If an employee is required to work on a vehicle and it’s not feasible to provide or put in place a fall-protection system, employer must, in consultation with the policy committee or, if there’s no policy committee, the work place JHSC or health and safety representative, perform a job safety analysis to eliminate or minimize the need for the employee to climb onto the vehicle or its load, and provide every employee who could be required to climb onto the vehicle or its load with instruction and training by a qualified person on the safe method of climbing onto it and working there, report that training in writing to the Head of Compliance and Enforcement and review the job safety analysis, instruction and training every 2 years in consultation with the policy committee or, if there’s no policy committee, the work place JHSC or health and safety representative (COHS Regs., Sec. 12.07)
- Employer must ensure that a worker is trained in the safe use of the fall protection system before allowing the worker to work in an area where a fall protection system must be used (OHS Code, 141(1))
- Above training must include: (a) a review of current Alberta fall protection legislation; (b) an understanding of what a fall protection plan is; (c) fall protection methods a worker is required to use at a work site; (d) identification of fall hazards; (e) assessment and selection of specific anchors that the worker may use; (f) instructions for correct use of connecting hardware; (g) information about the effect of a fall on the human body, including: (i) maximum arresting force, (ii) the purpose of shock and energy absorbers, (iii) swing fall, and (iv) free fall; (h) pre use inspection; (i) emergency response procedures to be used at the work site, if necessary; and (j) practice in inspecting, fitting, adjusting and connecting fall protection systems and components, and emergency response procedures (OHS Code, 141(1))
- In addition to the above training, employer must ensure that a worker is made aware of the fall hazards particular to that work site and the steps taken to eliminate or control those hazards (OHS Code, 141(3))
- Employer must ensure that a worker who wears fall protection equipment and PPE is adequately instructed in the correct use, limitations and assigned maintenance duties for the equipment to be used (OHS Regs., Sec. 8.7)
- A worker required to use fall protection and PPE must use the equipment in accordance with training and instruction (OHS Regs., Sec. 8.9(1)(a))
- Employer must train workers in safe work procedures to prevent falls at the workplace (WSH Regs., 14.2(1)(b))
- Employer must ensure that a worker using a fall protection system is trained in its use, care and inspection by a competent person (WSH Regs., Sec. 14.11)
- When a worker may have to climb on a vehicle or its load at any location other than a garage, warehouse or other permanent facility and it’s not reasonably practicable to provide a fall protection system for the worker, employer must provide information, instruction and training to a worker on safe work procedures for climbing or working on the vehicle or its load (WSH Regs., 14.17(b))
- Before an employee is allowed into an area where a risk of falling exists, an employer and a contractor must each ensure the employee is instructed in the fall-protection system for the area and in the post-fall rescue procedure, if applicable, and that the employee is competent in the procedures to be followed (OHS Gen. Regs., Sec. 50.1)
- Employer must ensure that a competent person trains an employee in the use, maintenance and inspection of a fall-protection system for the task being performed unless the fall-protection system is a guardrail (OHS Gen. Regs., Sec. 50.3(1))
- Employer must ensure that the above competent person referred to in subsection (1), who provides the training, prepares a written training record that lists: (a) the name of the employee who received the training; (b) the date the training took place; and (c) the name of the competent person and the name of the agency if any (OHS Gen. Regs., Sec. 50.3(2))
- The above training record for each employee must be made available to a govt. OHS officer upon request (OHS Gen. Regs., Sec. 50.3(3))
- Employer must, in consultation with the JHSC or health and safety representative, if any, review annually or more frequently, if required by a change in work conditions or in the fall protection field, the training provided to employees concerning fall protection to determine if retraining is necessary (OHS Gen. Regs., Sec. 50.3(4))
- Since 2012, all workers must successfully complete fall protection certification training program delivered by a vendor and course approved by WorkplaceNL before using fall protection equipment (OHS Regs., Sec. 139)
- Training must be a minimum of 16 hours and consist of 2 components: 8 hours of theory and 8 hours of individualized practical training (WorkplaceNL guidelines)
- Length of training may need to be increased based on the work requirements, workplace complexities and industry risks (WorkplaceNL guidelines)
- Fall protection certification training expires after 3 years and must be renewed for worker to use fall protection equipment (WorkplaceNL guidelines)
- Employer must ensure that a person takes and successfully completes certification training on fall protection before they use fall protection, before they work in, supervise or plan the work for a work area where fall protection is required, and at least once every 3 years (WHS Regs., Sec. 21.19(1))
- A person must not use fall protection or work in, supervise or plan the work for a work area where fall protection is required before successfully completing the required training (WHS Regs., Sec. 21.19(2))
- To successfully complete required training, a person must be deemed competent to inspect and use fall protection by 1 of the following persons who conducted the training: (a) their employer; (b) a training organization (WHS Regs., Sec. 21.19(3))
- Training must be instructed by a competent person (WHS Regs., Sec. 21.19(4))
- The person conducting the training must identify a method of evaluating the person taking the training and determining whether a person successfully completes the training (WHS Regs., Sec. 21.19(5))
- Fall protection training must include all of the following, as applicable to the nature of the work: (a) a review of all applicable health and safety legislation, regulations and standards; (b) identification of fall hazards; (c) a review of the hierarchy of controls that may be used to eliminate or minimize risk of injury from a fall; (d) the different methods of fall protection and the most suitable application of the methods; (e) fall-protection and safe-work procedures; (f) instruction on assessing and selecting specific anchors that may be used for various applications; (g) instruction on selecting and correctly using fall-protection components, including connecting hardware; (h) information about the effect of a fall on the human body, including all of the following: (i) free fall, (ii) swing fall, (iii) maximum arresting force, and (iv) the purpose of energy absorbers, (i) pre-use inspections of equipment and systems; (j) emergency response procedures to be used if a fall occurs; (k) practice in all of the following: (i) inspecting, fitting, adjusting and connecting fall-protection systems and components, and (ii) the emergency response procedures required by clause (j) (WHS Regs., Sec. 21.20)
- The employer and training organization that completes the training, if any, must keep a record of the required fall-protection training for each participant who successfully completes the training which lists: (a) the name of the participant; (b) the training date(s); (c) the name of the instructor; (d) the name of the employer; (e) the name of the training organization, if training is not conducted by the employer; (f) a description of the training; and (g) the expiry date before which training must be renewed (WHS Regs., Secs. 21.21(1) and (2))
- Each person who takes required fall-protection training must be given a copy of their record that the regs. require be maintained
- Person who conducts required training must give each person who successfully completes it a training certificate or card, signed by the instructor, which lists: (a) the name of the participant; (b) the training date(s); (c) the name of the employer and training organization, if training is not conducted by the employer; (d) the type of training; (e) the expiry date for the training certificate or card before which training must be renewed (WHS Regs., Sec. 21.22(1))
- Person must have their fall-protection training certificate or card available at the workplace at all times (WHS Regs., Sec. 21.22(2))
Employer at a construction project at which fall protection is used must:
- Ensure that a worker who may use a fall protection system: (a) is adequately trained in its use and given adequate oral and written instructions by a competent person; and (b) meets the working at heights training requirements of the OHS Awareness & Training Reg. ( Proj. Regs., Secs. 26.2(1) and (1.1))
- Ensure that the person who provides the training and instruction referred to in subsection (a) above prepares and signs a written training and instruction record for each worker that lists the worker’s name and dates on which training and instruction took place ( Proj. Regs., Secs. 26.2(2) and (3))
- Make the training and instruction record for each worker available to an MOL inspector on request ( Proj. Regs., Sec. 26.2(4))
Requirements for fall protection certification at construction projects under the OHS Awareness & Training Reg.:
- Employer must ensure that any worker who’s required to use a travel restraint system, fall restricting system, fall arrest system, safety net, work belt or body belt at a construction project successfully completes either: (a) a working at heights training program that meets the requirements set out in the next bullet and which hasn’t expired; or b: a fall protection program that meets certification requirements in Newfoundland and which hasn’t expired (Awareness Training Reg., Sec. 7(1))
- For purposes of subsection (a) in the bullet immediately above, a working at heights training program: Must be approved by the Ontario Chief Prevention Officer (CPO); 2. Must be provided by a training provider approved by the CPO (Awareness Training Reg., Sec. 7(2))
- Exceptions: Working at heights training not required if the worker using fall protection at a construction project: (a) is performing work on a project at a workplace where, (i) automobiles are manufactured or assembled, (ii) automobile marshalling is conducted, (iii) automobile parts manufacturing is conducted, (iv) automobile parts warehousing occurs, or (v) automobile research and development is conducted; and (b) is directly employed by an employer that manufactures or assembles automobiles and that owns and operates the workplace (Awareness Training Reg., Sec. 7(3))
- Working at heights training is valid for 3 years (Awareness Training Reg., Sec. 8)
- Employer must maintain a record of the required fall protection training that lists: (a) the worker’s name; (b) the approved training provider’s name; (c) the date on which the approved training was successfully completed; and (d) the name of the approved training program that was successfully completed (Awareness Training Reg., Sec. 10)
- Employer must make a training record available to an MOL inspector upon request (Awareness Training Reg., Sec. 10(4))
- Employers who are required to provide fall protection must ensure workers are trained by a competent person in the use of the means of fall protection and that training includes: (a) training in the use, care and inspection of the means of fall protection; and (b) a review of the provisions of these regulations that apply to the means of fall protection (Fall Prot. Regs., Sec. 2.1(1))
- Employer must maintain a training record for each worker during, and for 2 years after, the worker’s employment with the employer and make the record available to an OHS officer upon request (Fall Prot. Regs., Sec. 2.1(2))
- The above required training record must include: (a) the name of the worker who received the training; (b) the date on which the training took place; (c) the name of the competent person providing the training; and (d) any training material provided to the worker (Fall Prot. Regs., Sec. 2.1(3))
General OHS training requirements apply
- Employer or contractor must ensure that the worker is trained in the safe use of any full-body harness used (OHS Regs., Sec. 7-17(c))
- Employer or contractor must ensure that a worker is trained in the fall protection plan and the safe use of the fall protection system before allowing the worker to work in an area where a fall protection system must be used (OHS Regs., Sec. 9-3(4))
- Employer must ensure that the worker is trained in the safe use of any full-body harness used (OHS Regs., Sec. 105(c))
- Employer shall ensure that a worker is trained in the fall protection plan and safe use of the fall protection system before requiring or permitting the worker to work at a work site where a fall protection system is used (OHS Regs., Sec. 121(4))
- Employer must ensure that all workers are trained on: (a) the identification of existing and potential hazards in the workplace; (b) the policy statements and procedures that the employer has developed and implemented for the prevention of injury in the workplace; (c) the appropriate response to incidents and injuries, including procedures for obtaining assistance; and (d) the procedures for reporting, investigating, and documenting incidents and injuries (WSC Regs., Sec. 1.06.01(1))
- Employer must maintain records of training provided to their workers (WSC Regs., Sec. 1.06.01(2))